UK tax strategy

Tax policy: Financial year ending 30 September 2017

This policy applies to Nampak Holdings (UK) Limited and all the UK entities in its group. The policy covers our approach to UK Taxation, as defined within the UK tax strategy legislation.

About Nampak

The Nampak Group is Africa’s largest diversified packaging manufacturer, with operations in 11 African countries as well as the United Kingdom and Ireland.

We mainly operate in South Africa where there are 28 operations, contributing 45% of trading profit, whilst the rest of Africa and Europe operations contribute 59% and -4% of trading profit from 15 and 18 operations respectively.

We have been listed on the JSE Limited (Johannesburg Stock Exchange) under the symbol NPK since 1969.

Our tax policy comprises four key components:

1. Commitment to compliance with tax law and practice in the UK and tax risk appetite

Compliance for us means paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to tax authorities as appropriate and claiming reliefs and incentives in the spirit in which they were intended.

Given the scale of our business and volume of tax obligations, risk will inevitably arise from time to time in relation to the interpretation of complex tax law and nature of our compliance arrangements. Whilst there are no rigid levels of acceptable tax risk, we will actively seek to identify, evaluate, monitor and manage these risks to ensure they remain in line with our objectives.

Where tax risk may occur we work closely with the Group Tax Department to ensure risks are fully appraised and where there is significant uncertainty or complexity in relation to a risk, external advice will be sought as appropriate.

2. Responsible attitude to arranging our tax affairs

In structuring our commercial activities we will consider, amongst other factors, the tax laws of the countries in which we operate, with a view to maximising value on a sustainable basis for shareholders and employees.

Any structuring that is undertaken will have commercial and economic substance and will have full regard to the potential impact on our reputation and broader goals and those of our major customers and suppliers. We will not put in place any arrangements that are contrived or artificial and ensure that we act within the spirit of the law.

The Group seeks to price transactions between Group companies in compliance with the OECD Transfer Pricing Guidelines and the laws of relevant jurisdictions.

3. Constructive approach to engaging with HMRC

We engage with HMRC with honesty, integrity, respect and fairness and in a spirit of co-operative compliance.

Whilst we will not take positions on tax matters that may create reputational risk or jeopardise our good standing with HMRC, we are however prepared to litigate where we disagree with a ruling or decision of HMRC, having always first sought to resolve any disputed matters through active and transparent discussion.

In the event or likelihood of an event which would give rise to material transactions arising then we would take a pro-active approach in engaging with HMRC.

4. Board ownership and oversight

This tax policy is aligned with our Group Tax Risk Management Policy whereby all material tax risks are reported to the Tax Risk Committee at Head Office in South Africa on a quarterly basis or ad hoc basis where significant risks are identified. This in turn is communicated to the Audit Committee which reports to the Board of Directors.

Nampak Holdings (UK) Limited regards this publication as complying with the duty under para 16(2), Sch 19 FA16.