SUMCO is a specialized silicon wafer manufacturing company and aims to be a good corporate citizen, contributing to the development of industry and the improvement of people’s quality of life by supplying silicon wafers.
It is the mission of the SUMCO Group to be the world’s No.1 silicon wafer supplier by exceeding the expectation of our customers and stockholders, by recognizing the value of our employees and by being good neighbors in communities.
It is the quality policy of the SUMCO Group to deliver world class quality and reliability through anticipation of future needs; continuously improving products, process, technology and service for total customer satisfaction.
Introduction
This document sets out SUMCO Europe Sales plc’s (“SES”) strategy for conducting its tax affairs and managing tax risk in the year ending 31 December 2023.
It is SUMCO Group’s (“SUMCO”) mission to be the world’s number one silicon wafer supplier by exceeding the expectations of our customers and stockholders, by recognising the value of our employees and by being good neighbours in communities.
We place a great value on supporting and contributing to the communities in which we are based, partly through the taxes we pay.
SES continues to review its key tax procedures on an ongoing basis and publish its tax strategy in accordance with measures contained in Section 161 and Schedule 19 of the Finance Act 2016.
This tax strategy has been approved by the directors of SES and will be reviewed annually.
As such, SES considers that its obligations under Paragraph 22(2) Sch 19 FA 2016 in the year ending 31 December 2023 have been met.
Commitment to compliance
We are committed to complying with tax law and practice in both the UK and overseas.
To us, this means paying the right amount of tax in the right jurisdiction at the right time.
We have a long history of being prudent in handling our tax compliance.
Tax risks and tax risk management
Tax risk management is fundamental to SES.
Tax matters are proactively managed by having clear business controls and processes.
SES operates in a risk-averse manner in relation to its tax affairs, and where appropriate, we seek professional advice from external advisors to minimise areas of risk.
The Head of Finance and Administration is responsible for the management of SES’s tax affairs and is supported by the managers in the department.
These individuals are responsible for identifying and monitoring the inherent tax risks within SES.
SES’ business is relatively straightforward and constant, with few significant changes year on year; the inherent tax risks relating to the business are accordingly relatively low.
The same individuals are responsible for ensuring that the business controls and processes in place continue to be sufficient to mitigate these risks.
Suitably qualified external advisors prepare our annual Corporation Tax Return, which is then reviewed for accuracy and completeness by the Head of Finance and Administration before submission to HMRC.
Professional advice from external advisors would be sought over any specific items where the tax treatment is uncertain. Other tax returns are prepared by the finance team.
While SUMCO’s larger operations are in Japan, the Head of Finance and Administration ensures that UK risks that may arise within the worldwide group are analysed and appropriately addressed.
Our procedures are designed to minimise the risk of significant errors in tax returns.
Where errors are uncovered, prompt disclosure is made to HMRC, and a review of processes is undertaken to ensure that similar errors do not arise in future.
Attitude to tax planning
SUMCO believes that sound corporate activities must be guided by an awareness of social values and morals as well as compliance with applicable laws and regulations.
To this end, SES has adopted and is implementing the SUMCO Charter of Corporate Conduct as a standard of behaviour to be observed by the company and its officers and employees.
In structuring our commercial activities, SES will consider – among other factors – the tax laws of the countries in which we operate, with a view to maximising shareholder value on a sustainable basis. Transactions between SUMCO Group companies are at an arm’s length basis in accordance with current OECD principles.
While we take advantage of any tax incentives or reliefs that are available to us through our commercial activities, we do not use them in a way that is knowingly contrary to the intentions of any country’s government.
We do not seek to create any structures that lack commercial and economic substance for which the main purpose is the avoidance of tax.
Working with HMRC
SES is committed to always acting with integrity and maintaining a transparent, open, and honest relationship with HMRC.
This includes being punctual with our submission of tax returns, complying with other statutory and legislative tax requirements and deadlines, and the payment of any tax that is due.
As a multinational business, we support measures to improve international transparency regarding taxation matters.
SES is not, however, considered to be a large or complex business under HMRC’s Framework for Cooperative Compliance, and accordingly, SES does not have an appointed Customer Compliance Manager (CCM) at HMRC.
This means there is no formal communication channel with HMRC, and dealings with them are ad hoc.
Where we have communications with HMRC, we are committed to working collaboratively to resolve any uncertainties and achieve early agreement.
We consider this collaborative approach to working with tax authorities to be fundamental to our tax strategy.
We endeavour to respond to any queries or information requests from tax authorities in a timely manner and to ensure that sufficient and appropriate disclosure is made in relevant tax returns where necessary.
Transparency and tax evasion
We support the UK Government’s adoption of the OECD’s Base Erosion and Profit Shifting recommendations. We do not tolerate tax evasion or the facilitation of tax evasion by any persons acting for or on behalf of SES.
Reviewed and updated December 2023
Modern slavery and human trafficking policy
The Company is committed to driving out acts of modern day slavery and human trafficking within its business and that from within its supply chains, including sub-contractors, and partners.
The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These as well as the suppliers of services make up the supply chain within the organisation.
As part of the Company’s due diligence processes into slavery and human trafficking the supplier approval process will incorporate a review of the controls undertaken by the supplier. Imported goods from sources from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.
The Company will not support or deal with any business knowingly involved in slavery or human trafficking.
The Directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chains.
A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the HR department upon request.
To All Customers:
SUMCO’s goal is to be an ethical and responsible supplier and we work to ensure that our whole supply chain is in accordance with our vision.
Following the implementation of the UFLP act, SUMCO has done a thorough review of our supply chain to ensure that none of the materials we use in the production of our wafers have any material that is sourced from locations that may use any human trafficked or involuntary labour such as forced, debt bonded, prison, indentured, or slave labour.
As well as our commitment to the UK Modern Slavery Act, we can confirm that no material we source arises from such human trafficking or involuntary labour.
Should you have any additional concerns or require further information please do not hesitate to contact us.
Yours Sincerely
P Dorman
President
SUMCO Europe Sales
Please contact London office +44(0)2032143800. Thank you
SUMCO CORPORTATION
1-2-1 Shibaura, Minato-ku, Tokyo 105-8634
http://www.sumcosi.com/english
SUMCO Europe Sales Plc
SES Tax Strategy Dec 2023
SES Modern Slavery Act policy
Modern Slavery Act
SES-UFLPA-SES Commitment
SUMCO EUROPE SALES PLC, 30 CHURCHILL PLACE, WEWORK 1ST-10TH FLOOR, LONDON, E14 5RE
Monday - Friday: 9am - 5pm
Saturday: Closed
Sunday: Closed
Copyright © 2023 SUMCO EUROPE SALES PLC - All Rights Reserved.
Powered by GoDaddy