Statement under Modern Slavery Act of 2015
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets forth the steps that Castleton Commodities International LLC (together with its subsidiaries, “we,” “us” and “CCI”) has taken during the financial year ending 31 December 2018 to prevent slavery and human trafficking from taking place in its supply chains or in other areas of its business.
CCI is committed to the maintenance of the highest ethical and legal standards. We seek to comply with both the letter and the spirit of all applicable laws and regulations, to deal fairly and honestly with our counterparties, and to avoid even the appearance of impropriety.
CCI has adopted a Compliance Manual that contains a requirement for all employees to comply with the laws of all countries in which we do business, and disciplinary or legal action may be taken by us against an employee for any violation of that requirement.
CCI has adopted a Code of Ethical Business Conduct, pursuant to which we strive to do business with suppliers, customers and counterparties who honour our principles and values, and to ensure that our customers and counterparties observe applicable health, safety and environmental standards as well as all applicable laws. We also apply screening procedures to our trading counterparties, ship owners, vendors, brokers and agents using a risk-based approach.
We encourage employees to contact the Company’s Compliance, Legal or Human Resources Departments, its dedicated toll-free anonymous hotline, or other Company resources open to them, if they have any questions or concerns about the Code of Conduct or the legality or ethics of a particular course of action or activity, or if they are unclear about the application of the law or the Code of Conduct to their responsibilities or activities.
We require employees to report immediately if they become aware of or are concerned about an actual or potential violation of the Code of Conduct or applicable law, regulation or policy (whether the violation involves them or someone else, including any employee, customer, counterparty, supplier, contractor, business partner or agent of the Company). This includes situations where potential non-compliance has been reported previously but the employee believes it has not been adequately addressed.
All employees have access to practical guidance regarding our policies and procedures.
CCI UK tax strategy
This statement sets out the tax strategy of the UK sub‐group of Castleton Commodities International. The UK sub‐group currently consists of the following entities:
•Castleton Commodities UK Limited
•Navires Fuels Limited
•Navires Aviation Limited
•Rolympus UK Commodities Group Limited
•Norwegian Energy Limited
who are hereafter collectively known as the “UK Group”.
In making this strategy available, the UK Group is fulfilling its responsibilities under Schedule 19 of the Finance Act 2016.
Our Approach to risk management and governance arrangements in relation to UK taxation
Effective risk management is a core component of the way in which CCI carries out its business. It allows us to pursue commercial opportunities across the globe with the confidence that we can quantify and understand the risks we take. Our approach is therefore no different when dealing with taxation for the UK Group.
Day-to-day responsibility for maintaining and executing our tax strategy is delegated to the Global Tax Director who reports to the Chief Financial Officer (“CFO”). The Global Tax Director is supported by an in-house tax team staffed by experienced, qualified professionals. In addition, the tax team consults where required with Big Four and other tax advisors to ensure the integrity of tax filings and other tax compliance obligations in the UK (and worldwide.)
Our Attitude towards tax planning in respect of UK taxation
The UK Group manages tax affairs in a proactive manner that seeks to maximise shareholder value. However, it does not enter into artificial arrangements that lack commercial purpose in order to secure a tax advantage. If a position is uncertain, the Group may obtain third-party advice in order to gain clarity or support for a particular stance or approach.
The level of risk in relation to UK taxation that the group is prepared to accept
Our aim is to ensure full compliance with all statutory obligations and as a consequence, to attempt to minimise risk wherever possible. Where there is any doubt in relation to tax risk, the matter is escalated to the CFO and/or the Board for consideration.
Our Approach to dealing with HMRC
We have not yet been appointed with a Customer Relationship Manager. As such, although our contact with HMRC to date has been limited, we consider that we have an open and constructive relationship with the UK tax authorities.