Code of Ethics

Updated on 25th October 2023

This tax strategy applies to Benjamin Moore UK Limited and has been approved by the Board of Benjamin Moore UK Limited. Publication of this strategy is considered as satisfying Para 22 (2), Schedule 19 of the UK Finance Act 2016 in respect of Benjamin Moore UK Limited's financial year ending 31 December 2024.

Benjamin Moore's CFO and CEO is responsible for the implementation of the policy.

Governance

As stated in its Code of Ethics, Benjamin Moore is committed to doing the right things the right way with honesty and integrity as its guiding principles. By acting with honesty and integrity, Benjamin Moore builds the strong and enduring relationships that are critical to its long-term success.

We maintain compliance with tax laws and legislation via a strong system of internal governance using appropriately qualified and experienced staff. Where applicable, tax advice will be obtained from external advisors in respect of material transactions or when the tax department does not have the necessary expertise or skills required in that area. We strive to ensure that all decisions are made at an appropriate level, with diligent professional care and judgment.

Tax Planning and Risk

Benjamin Moore's intention is to comply with all tax rules and regulations on a worldwide basis and adhere to Double Tax Treaties. Where eligible, Benjamin Moore claims the benefit from appropriate credits and incentives that are intended to lower the cost of doing business or otherwise encourage investment.

Benjamin Moore's tax arrangements are based on its commercial business and economic activities. Benjamin Moore reviews its operations in the U.K. and around the world and adjusts its tax arrangements when necessary to be compliant with tax rules and regulations, including transfer pricing guidelines. Benjamin Moore's intercompany transfer pricing policies follow OECD guidelines, as well as the guidelines of the jurisdictions in which Benjamin Moore operates. Benjamin Moore applies the arm's length standard to intercompany transactions.

When appropriate, Benjamin Moore seeks guidance on inherently uncertain tax positions by obtaining external advice or by seeking advance clearance with the relevant tax authority.When appropriate, Benjamin Moore seeks guidance on inherently uncertain tax positions by obtaining external advice or by seeking advance clearance with the relevant tax authority.

Relationship with Her Majesty's Revenue and Customs (HMRC)

Benjamin Moore's intent is to ensure that all tax returns and tax payments are made within statutory deadlines and provide all relevant tax-related information that may be requested by HMRC on a timely basis.

Benjamin Moore engages with Her Majesty's Revenue & Customs (HMRC) in an open and honest manner and manages its tax affairs responsibly and transparently.