|

TAX STRATEGY & PRODUCT COVER

TAX STRATEGY

SCOPE

This strategy applies to: Freemans plc, Grattan plc and, in general, to the group of companies headed by Freemans Grattan Holdings Ltd (“the FGH Group”).

The FGH Group is a part of the wider Otto Group of companies which operates on a global basis.

The strategy is considered to cover the following taxes paid and administered by the FGH Group (“UK taxes”): Income Tax; Corporation Tax; PAYE; NIC; VAT; Insurance Premium Tax; Customs Duty; Import VAT; Stamp Duty Land Tax.

COMMITMENT TO COMPLIANCE

Elements of the FGH Group have traded in the UK for over a century.  As a member of the Otto Group of companies, the FGH Group always applies the core principles of social responsibility and sustainability to its business and considers potential reputational impacts as part of decision making.

The aim of the group is to be a preferred choice for customers; building sustainable long-term relationships by acting fairly and, ethically with integrity, following necessary due process.

As licensed credit providers, Freemans and Grattan plc’s are also regulated by the Financial Conduct Authority.

Whilst the FGH Group has a responsibility to deliver returns and value for our shareholders, we also take seriously the requirement to comply with UK tax rules and regulations and to pay the right amount tax, in the right place, at the right time.

The Otto Group expects its member businesses to aim for strict adherence to local tax legislation and the FGH group also maintains this commitment.

TAX GOVERNANCE

The tax strategy is ultimately owned by the Chief Financial Officer (“CFO”) of the FGH Group companies.  The CFO is also appointed as Senior Accounting Officer’s (“SAO”) with responsibility for monitoring the integrity of the respective financial reporting systems, internal controls and risk management frameworks which includes those elements relating to taxation.

The CFO of Freemans plc, Grattan plc and Freemans Grattan Holdings Ltd assumes responsibility for tax matters affecting these entities and the associated trading brands, with day to day management delegated to the Head of Central Finance.

Processes relating to specific UK taxes are allocated to appropriate internal specialists who maintain monitoring of systems and activities to identify and mitigate risks.  Changes to business activity and in legislation are considered for impact on existing systems, processes and reporting, with required consequential changes made to address risks based on materiality and relevant obligations.

The FGH Group is also required to report to and consult with the Otto Group regarding material issues affecting the structure or operation of the UK businesses from a tax perspective, including identification of significant risk.

RESPONSIBLE ATTITUDE TOWARD RISK & ARRANGING OUR TAX AFFAIRS

The FGH Group seeks to actively identify, evaluate, monitor and manage tax risk associated with our business activities.

We aim for certainty on the tax positions adopted and, in order to adhere to our principles, any structuring undertaken will have commercial and economic substance.

We will take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, the tax legislation.

In line with its cultural values, the FGH Group will not enter into transactions which it considers are contrived, artificial or counter the spirit of the law, or whose main purpose is to create an abusive tax result.

UK tax law is, however, complex and constantly evolving; consequently the correct position can sometimes be unclear. The FGH Group may therefore challenge the interpretation and views of the UK tax authorities.

Where there is significant uncertainty, complexity or material amounts in question, in order to address identified risks, we may seek external advice from reputable tax advisors, legal firms or tax counsel as appropriate and will follow necessary due process.

RELATIONSHIP WITH HMRC

The FGH Group is committed to the principles of integrity, transparency and openness and seeks to apply these in its dealings with UK tax authorities. Wherever possible we seek constructive and early discussions on any new arising tax matter to obtain certainty.

The FGH Group seeks to pay its UK taxes at the appropriate times and provide any relevant information requested by the tax authorities.

The FGH Group and the companies within it regard publication of this Tax Strategy as complying with the duty under paragraphs 16(2) and 22(2) of Part 2 of Schedule 19 of the Finance Act 2016 in the current financial year.

Dated: January 2022

PRODUCT COVER

IMPORTANT NOTICE FOR CUSTOMERS WHO PURCHASED PRODUCT COVER
Customers who purchased optional Product Cover policies are entitled to a refund. Following a review of our insurance products, we have identified concerns with Product Cover policies previously purchased by some of our customers. We believe this protection was not appropriate and provided little or no value to customers. In addition, we have concerns about the way the policy was charged to accounts and the benefit our customers subsequently received from their payments. We would like to apologise to all affected customers for that.

We are committed to the fair treatment of all our customers and, to put things right, we will be making full refunds of all premiums paid under these policies, plus interest. This will put customers back to the position they would have been in had those premiums not been applied to their accounts.

AM I AFFECTED?
Product Cover was an insurance policy offered to customers between 2007 and 2012 which covered goods purchased against accidental damage and theft. In some cases, the items protected by this policy were low cost items which were unsuited to this type of insurance. If Product Cover was purchased, a monthly charge would have shown clearly on monthly account statements. All customers also received policy documentation when they initially purchased the insurance. Product Cover was offered to Freemans, Grattan, Look Again, Kaleidoscope and Montage customers. No other brands are affected.

WHAT SHOULD I DO?
You do not need to take any action unless your contact details have changed since you last communicated with us. We have identified all affected customers and we are in the process of calculating and processing refunds. We have already begun contacting customers and this activity will continue over the coming months.

Customers DO NOT need to contact a third party to arrange their refund. Doing so will not increase the refund customers are entitled to but may result in fees being charged by third parties which will decrease the refund amount ultimately received.

If your address is the same as it was when you last communicated with us, there is no action you need to take. If your contact details have changed, please email us at productcover@fgh-uk.com or write to us at:

Product Cover Review Team
Freemans Grattan Holdings
66-70 Vicar Lane
Bradford, BD99 2XG