Tax Strategy

Apta is part of The AMES Companies UK Ltd, (Comprising of The AMES Companies UK Ltd, La Hacienda Ltd, Kelkay Ltd, Altia Holdings Ltd, Vatre Group Ltd, Vatre Terracotta Ltd).

Scope

We are committed to high standards of corporate governance, transparency, and responsibility in supporting the execution of our global business strategy – which is to drive profitable growth in our businesses and deliver sustainable returns for our shareholders. Our approach to tax supports this strategy.

Application of the strategy

Our UK tax strategy has been approved by the Board of Directors of The AMES Companies UK Ltd. and applies to all entities within the UK that are part of the Griffon Corporation group, including La Hacienda Ltd, Altia Holdings Ltd, Kelkay Ltd, Vatre Group Ltd and Vatre Terracotta Ltd (collectively “AMES UK”, “the Group”) in accordance with paragraph 19(2) of Schedule 19 to the Finance Act 2016. This strategy describes AMES UK’s approach to managing the company’s tax affairs and aligns with Griffon Corporation’s Codes of Business Conduct and Ethics.

This strategy is applicable from the date of publication and remains in place until superseded; it will be reviewed annually and/or as organizational changes occur within the UK. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.

This tax strategy was published on 12 February 2021 and The AMES Companies UK Ltd regards this publication as complying with its duty under paragraph 19(2) Schedule 19 FA 2016 in its financial year ending 30th September 2021.

Governance and Management of Risk in relation to UK taxation

The Board of The AMES Companies UK Ltd. oversees and approves the UK tax strategy, which is aligned with Griffon Corporation’s global approach. Responsibility for setting and implementing the tax strategy and the management of our tax risks ultimately sits with the Managing Director (MD). Day-to-day responsibility for the application of the tax strategy and the management of our tax affairs is delegated by the MD to the local Finance Director, Controllers and other personnel. The delivery of this strategy is also supported by the tax, finance, and accounting teams of AMES Australasia Pty Ltd., The AMES Companies, Inc. and Griffon Corporation.

We operate a tax control framework which focuses on having the right control environment, risk identification, effective channels of communication and monitoring of our compliance with both the relevant legislation and our strategy.

To this end we ensure that we:
• Adhere to our Codes of Business Conduct and Ethics which set out the behaviours expected of our employees so as to align with our overall strategy in its approach to risk and respect for our core values,
• Comply with all applicable laws, rules, regulations, and disclosure requirements; and
• Seek advice from external advisers where appropriate.

Attitude towards tax planning and level of risk

We aim to ensure that all tax positions are built on sound commercial business activity. Where eligible, we claim the benefit from various credits, incentives, and various elective provisions. AMES UK manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

Where appropriate, we seek certainty on inherently uncertain tax positions by obtaining external advice or seeking advance clearances with the relevant tax authorities.

AMES UK does not undertake tax planning unrelated to commercial transactions; we do not engage in aggressive tax planning schemes and our appetite for risk is low in this regard.

Relationship with HMRC and working with Tax Authorities

We work in a collaborative, transparent and proactive manner with revenue authorities and policy makers. We strive to inform the HMRC of significant UK transactions and changes to the business at the earliest appropriate stage and are open about our decision-making, governance processes and tax planning policy. We interact with these bodies in a professional, courteous, and timely manner, and seek to maintain a collaborative relationship through regular meetings, discussion, and written communications. Pursuant to our Codes of Business Conduct and Ethics, we cooperate fully in any inquiries.

When submitting tax computations and returns to HMRC, AMES UK discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

Paul North
Managing Director AMES UK