TAX STRATEGY

Introduction

Ronly Group Limited (Ronly, We) is a privately owned commodity trading group, focussing its main commercial trading activities through Ronly Limited, with several investments held through subsidiary entities. Trading activities are mainly in ferrous products, but the Group is able to trade in any physical commodities that may be approved by its Risk Committee.

Our commercial activities relate to the international trading of physical commodities with clear audit trails. Every transaction involves multiple stakeholders, including regulated banks.

Our Tax Strategy

This Tax Strategy is applicable to our tax activities as they relate to UK taxation.

This document meets the requirement for Ronly to publish its Tax Strategy as required by section 161 and section 16(2) of Schedule 19 of Finance Act 2016.

It is effective for the year ended 31 December 2023 and covers Ronly Group Limited and all of its UK subsidiaries.

Governance and risk management

The Chief Financial Officer is responsible for setting and monitoring the strategy. They are accountable to the Board for the implementation of the tax strategy and management of tax and related risk.

Tax compliance and reporting

In meeting our UK taxation obligations, we are committed to meeting all our legal and regulatory requirements in paying the correct amount of tax. As part of this commitment, we comply with the Senior Accounting Officer (‘SAO’) requirements and we undertake a review of our tax processes (for Corporation Tax, VAT and Employment Taxes), working with external advisors to benchmark our SAO review processes to leading practice.

Our approach to tax planning

We have a low-risk appetite to tax planning as it affects UK taxation, and tax decisions are aligned to business and commercial strategy. We will not engage in artificial transactions for the sole purpose of reducing UK tax, however we will consider undertaking commercial activities and transactions that give rise to UK tax efficiencies provided these are compliant with the associated UK tax legislation.

We will not engage in tax efficiencies if the underlying commercial objectives do not support the position, or if the arrangements impact upon Ronly’s reputation, brand, corporate and social responsibilities, or future working relationships with HMRC.

Working with HMRC

Ronly is committed to working with HMRC in an open, honest and transparent manner. Wherever possible, we also seek to achieve early agreement on issues and certainty. We will be willing to host regular face-to-face or virtual meetings with HMRC to discuss any commercial developments and events in our business that may have a tax impact. We will make available to HMRC upon request our tax procedures and controls.

Approved by the Board on 26 April 2023

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