UK Tax Strategy Statement

Freepoint Commodities – UK Tax Strategy

Scope

This document is prepared in compliance with the requirements of Paragraph 19(2), Schedule 19 of the UK Finance Act 2016 and applies with respect to the year ended 31 December 2023, with reference to all businesses of Freepoint Commodities (‘Freepoint’) within charge to UK corporation tax.

This statement is approved by the senior management of Freepoint’s UK entities.

How our business manages UK tax risks

Freepoint employs a team of experienced tax professionals with expertise in the commodities sector.  This tax team works in daily collaboration with senior management and other operational functions, thereby learning of all significant business initiatives at an early stage. Such an approach is indispensable in identifying business tax risk, enabling implementation to be designed in such a way that any UK tax risk is suitably addressed. This process has further facilitated a strong degree of tax awareness in the senior management team with an undoubted benefit for tax risk management. Freepoint’s payroll and management of payroll taxes is outsourced to third party service providers.

Freepoint’s system of management of tax risk operates at the level of the in-house team, senior management in the UK and senior management at the US headquarters. Where tax risk is identified, it is escalated along these reporting lines.

Furthermore, the in-house tax team have access to a network of external advisors familiar with the business, whose input is typically sought in advance of business expansion into new jurisdictions as well for assistance with more complex aspects of UK and international tax law relevant to our business.

Freepoint has implemented rigorous procedures in its expectation of each employee’s adherence to our Ethical Standards and Business Conduct Standards at all times. Every Freepoint employee is required to become familiar with the directions laid out in the Global Compliance Manual and the Employee Handbook. Employees undertake regular training run by the Compliance team on topics including but not limited to bribery and corruption, financial crime, sanctions, and market conduct. Any non-compliance is taken very seriously, and the same high standards of conduct are expected in relation to the management of UK tax risk.

Freepoint’s tax risk management framework is considered commensurate with a UK entity headcount not exceeding 140 employees.

Our business’s attitude to tax planning

In compliance with its tax obligations, Freepoint seeks to act as a responsible corporate citizen. Our business therefore does not pursue arrangements that may be perceived to create an undue tax advantage, or to reduce a tax liability beyond that permitted under the framework of generally available tax reliefs enshrined in UK (or other) tax law. Decisions involving structural changes in business operations or reporting entities are driven only by commercial needs to facilitate business growth.

The level of risk our business is prepared to accept for UK taxation

Freepoint demonstrates a low appetite for UK tax risk. We are fully committed to adhering to the letter and spirit of the laws and regulations in all jurisdictions in which we operate and therefore seek apply tax laws and principles in manner consistent with their objectives. Where the manner in which these laws and regulations applies to our business might be unclear, we seek expert professional advice to find a pathway to resolve such uncertainty and minimise any associated tax risk.

How our business works with HMRC

Freepoint endeavours to be fully compliant with all its tax filing and payment obligations. We would seek to engage in an open and collaborative manner with HMRC to resolve any queries or material uncertainties proactively and without undue delay.

December 2023