Tax policy statement

Introduction

This policy applies to the Covéa group of companies in the UK, which includes MMA Holdings UK plc (“MMAH”) and all its subsidiaries. The main trading subsidiaries of MMAH are Covea Insurance plc, Covea Life Limited, Sterling Client Services Limited, Swinton Group Limited and Hebble Law Limited. It covers both the internal governance of tax matters and approach to tax. The policy has been considered and approved by the relevant Committees/Boards.

The tax policy applies to all taxes applicable to the UK Group. The principal taxes are corporation tax, insurance premium tax, employment taxes, and VAT.

Minimising level of tax risks

In line with Covéa Group’s values and risk appetite, we seek, where possible, to minimise the risk of uncertainty or disputes.

We are committed to paying all taxes due to HMRC at the right time, and to ensuring we are compliant with all relevant tax regulations.

We obtain independent assurance as to the appropriate operation of tax processes and that these are managed within our risk management framework. The independent assurance principally comes from internal audit and external tax advisors and further assurance is sought by periodic reviews by management.

Tax risk management and governance

The tax policy operates within our group’s established risk management framework. Our finance functions have, and will maintain, sufficient skills and processes in place to identify and assess tax risks. Discussions will take place with external advisers where tax risks are identified, to ensure understanding and to obtain appropriate advice where necessary. We implement risk management measures and ensure compliance through robust controls and procedures. New and existing tax risks are reported to the operating companies’ Chief Finance Officers and, where appropriate, the Audit Committees and/or Boards, as and when the risks are identified.

The group is within scope of the Senior Accounting Officer (SAO) regime. Each company has an SAO who is personally responsible for ensuring appropriate controls are in place to manage the tax affairs.

Appetite towards tax planning

Where there are alternative ways of conducting our business or structuring a transaction, we may choose the alternative which achieves the commercial aims of the business with the lowest tax cost. However, we will not enter into any non-commercial arrangements where the only purpose is to reduce the tax burden of the business, nor will we seek to utilise any scheme that is artificial in nature and that seeks to provide benefit beyond the apparent intent of the legislation.

Where tax incentives and exemptions are implemented by the Government to support investment, employment and economic growth, we seek to apply them in the manner intended.

Approach to dealings with HMRC

As part of our commitment to being responsible businesses with high standards in the UK insurance market, we are committed to adhering to tax laws in a transparent manner. We take a constructive, cooperative and open approach to all aspects of engagements with HMRC, and regard this way of working as fundamental.  The group is currently rated ‘low risk’ by HMRC and we seek to maintain this rating.