Statutory information

Modern Slavery Act 2015

Marston (Holdings) Limited (“Marston”) modern slavery statement for the financial year ended 31 May 2020

Marston is a provider of transportation and enforcement services to government and commercial clients which involves interfacing with the general public.

The supply chain is mainly UK based with very few goods and services being procured from overseas. There have been no incidents related to modern slavery during the financial year ended 31 May 2020.

Due to the nature of our business and our high standards of corporate governance we assess that that there is a low risk of modern slavery in our business and supply chains.

The Executive Board has apportioned responsibility for the prevention of modern slavery to the Chief Risk Officer.

Marston’s Prevention of Modern Slavery Policy sets out in writing how it achieves its policy objectives together with the steps that we have taken to prevent modern slavery from occurring in our business and supply chains:

Supply Chain Due Diligence

All major procurement is channelled through the group procurement team to ensure due diligence is carried out for modern slavery risk.

Recruitment Due Diligence

All permanent, temporary and contract staff are subject to the group vetting policy. The group vetting policy includes checks on

- the source of any candidates e.g. agencies / personal referrals
- candidates right to work in the UK
- Identity verification and other personal details.

Staff Training and Awareness

All staff are required to complete Safeguarding Awareness Training when they first join Marston and then periodically refresh their training. The Safeguarding Awareness Training includes a standalone module on modern slavery which was devised in consultation and with content from the Gangmasters and Labour Abuse Authority.

Reporting and Investigation of Modern Slavery concerns

Marston is committed to the highest possible standards of openness, honesty and accountability. Marston recognises that there may be times where staff and self-employed contractors have legitimate concerns which they may not feel comfortable to raise with their line managers or other members of staff and has put in place a whistleblowing policy. Marston uses Safecall a confidential whistleblowing hotline which is monitored 24 hours, 7 days a week.

Signed
Chief Risk Officer
September 2020

Free Flow Topco Limited and its subsidiaries

Tax Strategy

Period ended 31 May 2022

Tax strategy

Publication of this strategy is regarded as complying with the obligation under para. 16(2), sch. 19, FA 2016 in respect of the period ended 31 May 2022. Risk management is the responsibility of the Board and is integral to the ability of Free Flow Topco Limited and subsidiary undertakings (the Group) to deliver on its strategic priorities. The Board is responsible for setting the risk culture of the Group and establishing and maintaining appropriate systems and controls to manage risk. A robust risk management framework has been implemented to support this. The Group’s risk management framework is overseen by the Chief Risk Officer reporting into the Board via the CFO. The Board also considers the effectiveness of the internal control environment. The Group is committed to full compliance with all statutory obligations and full disclosure to tax authorities.

Governance in relation to UK tax

The Board is responsible for the Group’s tax strategy and management of tax risk
The Board member with executive responsibility for tax matters is the Chief Financial Officer (CFO)
The Director of Financial Planning and Analysis, who reports into the CFO, take day-to-day responsibility for the management of tax matters and consult regularly with our outsourced tax support ensuring compliance with emerging issues and review of all returns and computations
Audit Committee monitors the appropriateness and integrity of the tax strategy
All key tax processes and procedures are fully documented and updated regularly

Management of tax risk

The Group’s processes, policies and governance operate to ensure compliance with tax regulations
Where necessary the Group will engage with tax authorities to disclose and resolve uncertain tax positions
The Group will also look beyond financial risks to the wider impact tax risks may have on its relationships with stakeholders

Tax planning

The Group balances a responsibility to pay the right amount of tax with a responsibility to shareholders to maximise value by efficiently structuring the Group’s tax affairs
External advice is sought in relation to tax planning or areas of uncertainty

Relationship with HMRC

The Group has an open and constructive relationship with HMRC (UK tax authority)
Wherever possible the Group commits to working with HMRC on a real time basis to minimise tax risk and strives to resolve any disputed matters through active and transparent discussion
Any unintentional filing errors are fully disclosed to HMRC as soon as they are known.

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