Stanley Group in UK Tax Strategy
ScopeThis strategy applies to Stanley Electric Holding Europe Co., Limited and Stanley Electric(U.K.) Company Limited (“Stanley Group in UK”) in accordance with Schedule 19 to theFinance Act 2016. In this strategy, references to ‘Stanley Group in UK’, ‘the firm’ or ‘thegroup’ are to all these entities. The strategy has been published in accordance withparagraph 19(4) of the Schedule.
This strategy is in relation to the year ended 31/3/2023 and applies from the date ofpublication until it is superseded. 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 inrespect of which the Group has legal responsibilities.
Aim
Stanley Group in UK is committed to full compliance with all statutory obligations and full
disclosure to relevant tax authorities. The group’s tax affairs are managed in a way whichtakes into account the group’s wider corporate reputation in line with Stanley Group in UK’soverall high standards of governance.
Governance in relation to UK taxation•••••

Ultimate responsibility for Stanley Group in UK’s tax strategy and compliance rests withthe each Board of Stanley Group in UK;
The each Managing Director (‘MD’) is the Board member with executive responsibility fortax matters;
Day-to-day management of Stanley Group in UK’s tax affairs is delegated to the FinanceTeam, which reports to the MD;
The Finance Team is staffed with appropriately trained individuals;
The Board ensures that Stanley Group in UK’s tax strategy is one of the factors
considered in all investments and significant business decisions taken;

Risk Management•••••

Stanley Group in UK operates a system of tax risk assessment and controls as acomponent of the overall internal control framework applicable to the group’s financial
reporting system;
Stanley Group in UK seeks to reduce the level of tax risk arising from its operations as
far as is reasonably practicable by ensuring that reasonable care is applied in relation toall processes which could materially affect its compliance with its tax obligations;Processes relating to different taxes are allocated to appropriate process owners, whocarry out a review of activities and processes to identify key risks and mitigating controls
in place. These key risks are monitored for business and legislative changes which may
impact them and changes to processes or controls are made when required;
Appropriate training is carried out for the members of the Finance Team who manage orprocess matters which have tax implications;Tax compliance support and advice is sought from external advisers where appropriate.

Attitude towards tax planning and level of risk
Stanley Group in UK manages risks to ensure compliance with legal requirements in amanner which ensures payment of the right amount of tax.
When entering into commercial transactions, Stanley Group in UK seeks to take advantageof available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax
legislation. Stanley Group in UK does not undertake tax planning unrelated to suchcommercial transactions.
The level of risk which Stanley Group in UK accepts in relation to UK taxation is consistent
with its overall objective of achieving certainty in the group’s tax affairs. At all times StanleyGroup in UK seeks to comply fully with its regulatory and other obligations and to act in away which upholds its reputation as a responsible corporate citizen. In relation to any
specific issue or transaction, the Board is ultimately responsible for identifying the risks,
including tax risks, which need to be addressed and for determining what actions should betaken to manage those risks, having regard to the materiality of the amounts and obligationsin question.
Relationship with HMRC
Stanley Group in UK ensures that HMRC is kept aware of significant transactions andchanges in the business and seeks to discuss any tax issues arising at an early stage. Whensubmitting tax computations and returns to HMRC, Stanley Group in UK discloses all
relevant facts and identifies any transactions or issues where it considers that there ispotential for the tax treatment to be uncertain.
Any inadvertent errors in submissions made to HMRC are fully disclosed as soon asreasonably practicable after they are identified.

Date Published: March 2024