GMR CAPITAL GROUP
Group Tax Strategy
30 September 2023

Introduction

This disclosure is made in compliance with the duty of GMR Capital Limited under paragraph 16(2), Schedule 19, Finance Act 2016 to publish its group tax strategy in respect of the year to 30 September 2023.   It has been approved by the Board of GMR Capital Limited and applies to all UK taxes applicable to the Group.  The policy will be reviewed annually.

Aim

The Group is committed to:

• Ensuring full compliance with all applicable laws and regulations relating to its tax activities, together with all reporting and disclosure requirements.
• Interacting with the tax authorities in an open and transparent manner based on principles of collaboration and integrity.
• Maintaining high levels of tax governance.
• Being diligent and careful in its management of tax risks.
• Operating its business in a manner which minimises its tax cost using incentives and reliefs whilst ensuring that these reliefs are used in accordance with the spirit of the legislation.

Approach to Risk Management and Governance Arrangements in Relation to UK Taxation

The aspiration of the Group is to maintain the highest standards in relation to compliance with regulations and reporting accuracy. This means paying the correct amount of tax at the correct time.

The Group’s exposure to UK taxes is a significant business risk and, as such, the Group seeks to minimise that risk by ensuring compliance with the relevant legislation.  The Group incurs a substantial amount and variety of business taxes including corporation tax, employment tax and other taxes, The Group also collects and pays over employee taxes and indirect taxes such as VAT.

Tax is managed by the business in a manner that is consistent with other areas of operational risk by introducing and maintaining appropriate monitoring and management procedures across the Group.

The Group actively monitors new tax legislation and any changes of interpretation of existing legislation throughout the year. Where appropriate, the Group seeks external assistance from professional advisors and clarification from HM Revenue & Customs where necessary.

Overall responsibility for minimising tax risk rests with the Board.  It is managed by the Group Finance Director and individuals in the finance function with the appropriate skills and experience.  There is also ongoing engagement with suitably qualified, reputable external firms who, as well as assisting with tax compliance, advise on the tax considerations arising in connection with changes in the business and tax legislation.

Where any risks are identified, the Group will implement appropriate controls and procedures to minimise those risks.

The Group fosters a risk-aware culture in relation to its tax position.  Tax risks are assessed on a case by case basis enabling each risk to be managed appropriately.

The Board exercises oversight of tax risk management and governance by:

• discussing the tax implications of its activities at Board meetings
• the involvement of directors with relevant skills in transactions with inherent tax risk.
• considering the legal and fiduciary duties of the directors and employees

The Attitude of the Group Towards Tax Planning

The Group manages risks to ensure compliance with legal requirements in a manner which ensures that the correct amount of tax is paid. The commercial needs of the business will never override compliance with all applicable laws and regulations.

The Group is a commercially driven organisation and tax planning is undertaken as part of the Group’s strategic planning. The Group has a low appetite towards tax risk.  Where alternative courses of action to achieve a strategic objective are available, those which reduce tax liabilities will only be adopted if they comply with the spirit, as well as the letter, of the law.  External advice is obtained to ensure that this is the case.

Any material tax planning is considered by the Board of Directors and must be supported by an appropriate level of tax analysis. In all cases, the Group ensures that all tax planning relates directly to commercially focused activities. The Group does not seek to structure transactions in ways that produce tax results that are inconsistent with their underlying economic consequences.

The UK tax legislation often incorporates tax incentives, credits or exemptions for commercial business activity. Where the Group qualifies for such incentives, the Group claims them where this is in line with the commercial objectives of the Group. In the event that there is any uncertainty about the availability of such incentives, the Group will take professional advice and/or engage with HM Revenue & Customs to confirm the correct tax treatment.

Approach to dealing with HM Revenue & Customs (“HMRC”)

The Group is committed to the principles of openness and transparency in its dealings with HMRC and the Group commits to:

• adopting an open and collaborative relationship with HMRC.
• engaging with HMRC to discuss tax planning, strategy, risks and significant transactions.
• making accurate and timely disclosure in correspondence and returns and responding promptly to questions and information requests from HMRC.
• be open about decision-making, governance and tax planning.
• interpret tax law in a reasonable way.

The Level of Risk that the Group is Prepared to Accept

GMR Capital Limited and its subsidiaries seek to manage their tax affairs so that tax risk is low.  They seek to minimise risk through:

• robust compliance processes, and
• obtaining advice on the tax impact of business changes.

The level of risk which the Group accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the Group’s tax affairs. The Group seeks to comply fully with its regulatory and other obligations and act in a way that maintains its reputation as a responsible corporate citizen.

MODERN SLAVERY STATEMENT

RONTEC ROADSIDE RETAIL LIMITED

 MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR 2022

INTRODUCTION 

This statement sets out Rontec Roadside Retail Ltd and its subsidiary Companies (the Group) actions to understand all potential modern slavery risks related to the companies and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st October 2021 to 30th September 2022.

As part of the forecourt retail industry the company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Group is absolutely committed to preventing slavery and human trafficking in its corporate activities, in its supply chains.

OUR BUSINESS 

The principal business of the Group is the ownership and operation of 263 forecourt service stations. This is carried out by the 110 employees of Rontec and supplemented by a business model of contracting with third parties (known as Commission Operators) acting as our agent and providing services in relation to the day-to-day operation of our forecourts.

The main business activities include:

• Fuel sales
• Cash wash and valet facilities
• Retail shop sales
• Fast food franchise operations

Countries of operation and supply

 The company currently operates in the following countries:

• England
• Wales

The Group regularly reviews its countries of operation to assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking.

RESPONSIBILITY

Responsibility for the company’s anti-slavery initiatives is as follows:

Policies:

The Group operates several internal policies and procedures to provide guidance to ensure we conduct our business in a legally compliant and ethical manner.  All policies are reviewed and approved by the company’s Managing Director.  All policies are reviewed regularly and amended in accordance with any new legislative requirements or changes within the business.

Risk assessments:

The Board is responsible for reviewing the risk of our commercial activities to understand if there are any potential risks where Modern Slavery could occur.

Having risk-assessed our business the Board has identified that as we are not involved in activities where occurrences of modern slavery have been identified, we and our supply chain are both at low risk of having modern slavery occur.

We operate with a preferred supplier list and operate with confidence that all our suppliers are aware of the Modern Slavery Act 2015. We conduct regular reviews of our supply partners to ensure they have published their own Modern Slavery statement.

We believe that the highest risk to our business is within the operation of our service stations, where direct labour is engaged via a third-party employer (known as the Commission Operator). In this respect we have little direct control over the employment practices and activities of the independent   retailer at the forecourt. We have implemented a Commission Operator Agreement that strongly encourages ethical employment activities and gives us the ability to terminate the commercial arrangement if breaches occur. We provide our Commission Operator with training to be able to understand and comply with their responsibilities as outline within this commercial arrangement to reduce the risk of non-compliance.

We have identified that there is a significant minority of Non-EU Nationals within the working population within the retail sector, this is not specifically limited to our business but an industry wide trend so there is a potential opportunity for human trafficking and forced labour activities.

Investigations/due diligence:

To minimise the risk imposed through our supplier chain, we regularly check our existing suppliers’ compliance with the publication of a modern slavery statement and if a supplier is not required to publish a statement, we request confirmation that they are not aware of any acts of modern slavery or human trafficking within their supplier chain. If a breach is discovered this is immediately raised to the Managing Director, and the contractual arrangement is immediately reviewed.

To ensure compliance with the numerous legislative requirements linked to employee’s right to work in the UK, we carry out regular screening of our employees both during the recruitment process and periodically thereafter. If there are any suspected instances of Slavery and Human Trafficking, this would be immediately investigated by the Head of HR and findings provided to the Managing Director so appropriate action can be taken.

Rontec carries out a detailed check for all new Commission Operators through a third-party reference checking agency that includes right to work status, residency status and criminal record information. Regular checks are carried out to ensure Commission Operators are complying with their contractual obligations as stated within the commercial agreement with Rontec. Any non-compliance with legislation e.g. minimum wage, immigration, discrimination, would be immediately investigated and reported to the Managing Director and authorities by the Head of HR. 

Training:

The Group provides on-line training to all its employees to provide an awareness of the Modern Slavery Act, and an awareness of the key risks to the company, their personal responsibilities and how to report any concerns including but not limited to the whistleblowing policy. The training forms part of the induction process and is refreshed annually.

As well as training staff, the company has raised awareness of modern slavery issues to its third-party Commission Operators and their workers through providing a mandatory modern slavery module again highlighting how to raise concerns. This is further supported through regular information bulletins highlighting important changes in ‘right to work’ obligations as well as other factors that would impact their ability to fulfil their contractual obligations such as national minimum wages rate changes.

RELEVANT POLICIES

The Group operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Anti-slavery Policy – The policy sets out the Group’s stance on modern slavery and explains how employees can identify and raise concerns.
• Whistleblowing policy – The Group encourages all its employees to report any concerns related to the direct activities, or the supply chains of, the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
• Employee code of conduct – The Group’s code makes clear to employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct.
• Recruitment Procedure -We operate a robust recruitment process that includes eligibility to work in the UK checks, proof of residency and references for all new employees. The Group uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Commission Operator – Eligibility to Work in the UK screening – We conduct pre-contract screening as part of the first stage in the application process for all interested parties wanting to take on the operation of one of our Forecourts. This includes eligibility to work in the UK documentation check, proof of address and completion of a third-party criminal and credit check. If any concerns are highlighted during this process, the application is terminated. Periodically checks are carried out to ensure all Commission Operators remain eligible to work in the UK. If there are any changes to their eligibility, their Commission Operator Agreement is at risk of termination.
• Audits – Specific authorised Rontec Employees conduct periodical checks to ensure that employment practices of our Commission Operators are in line with the requirements of the Immigration Act 2016.

 PERFORMANCE INDICATORS

The Group considers that there are two reasonable indicators that slavery and or human trafficking is not taking place within our business if:

• we receive no reports from either law enforcement agencies, employees, Commission Operators, their workers, or the public to indicate that slavery and or human trafficking practices have been identified in relation to our business, our trading partners, or suppliers.
• That none of our third-party Commission Operators appear on the Sanction List.

This statement is reviewed on a regular basis to ensure that a process of continued improvement is applied.

Board Approval of Statement

This statement was approved by the Board:

Giles Taylor

Managing Director

As part of any recruitment process, the company collects and processes personal data relating to job applicants. The company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the company collect?

The company collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the company needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

The company collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

The company will also collect personal data about you from third parties, such as references supplied by former employers, and if required, information from employment background check providers and information from criminal records checks. The company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the company process personal data?

The company needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.

In some cases, the company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

The company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The company may also need to process data from job applicants to respond to and defend against legal claims.

Where the company relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

The company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the company processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

For some roles, the company is obliged to seek information about criminal convictions and offences. Where the company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, in case there are future employment opportunities for which you may be suited. The company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks if this is deemed necessary for your role.

The company will not transfer your data outside the European Economic Area.

How does the company protect data?

The company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. The company has implemented internal policies and controls, e.g. systems restrictions to ensure data is protected.

For how long does the company keep data?

If your application for employment is unsuccessful, the company will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow the company to keep your personal data on file, the company will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file.The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require the company to change incorrect or incomplete data;
• require the company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the company is relying on its legitimate interests as the legal ground for processing; and
• ask the company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the company’s legitimate grounds for processing data.

If you believe that the company has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the company during the recruitment process. However, if you do not provide the information, the company may not be able to process your application properly or at all.

How to contact us
If you have any questions that haven’t been covered in this policy or wish to exercise any of your rights in respect of your personal data, please contact Rontec’s recruitment team either on:-

Send us an email hr-recruitment@rontec.uk.com

Contact us by telephone 01923 694000

Write to us at

Rontec Roadside Retail
1st Floor
40 Clarendon Road
Watford, Herts
WD17 1JJ