ALPRO UK – TAX STRATEGY

CONTEXT

The publication of this UK Tax Strategy statement is regarded as satisfying the statutory obligation under Para 19(2), Schedule 19, Finance Act 2016.

On April 12th, 2017 the acquisition of the WhiteWave Foods Company by Danone, which includes the Alpro group was finalized. Alpro’ s policies and procedures are in the process of being gradually aligned to Danone’s policies and procedures. This Tax Strategy is based on Danone UK’s tax Strategy. Where needed reference to Danone has been replaced by Alpro UK (Ltd) and procedures updated in line with Alpro’s way of working. Alpro UK’s tax compliance and strategy is managed from Alpro’s Headquarters in Ghent (Belgium), in close collaboration with the Corporate tax department of Danone in Paris.

We believe that our company’s responsibility does not stop at the factory gates, but extends to cover all of our stakeholders: employees, shareholders, suppliers, consumers, customers, collaboration partners and the communities in which we work.

At Alpro, everything we do must respect our ethical standards and the laws of all countries where we operate. Our Business Code of Conduct sets out our commitment to our stakeholders and the standards of behaviour to which all of us at Alpro must adhere. This is vital not only for the effectiveness and the sustainability of our business, but also for the continued reinforcement of our dual economic and social commitments.

Alpro UK’s tax affairs are managed in a way which takes into account Alpro’s wider reputation, brand and social and corporate responsibilities. In line with our “dual social and economic project”, we are committed to managing our tax policy in a responsible, transparent and sustainable way. This supports the way Alpro and Danone do business.

The Alpro UK Tax Strategy comprises of 4 key components:

ENSURING COMPLETE COMPLIANCE

We are committed to full compliance with all statutory obligations. We seek to comply with our tax filing, tax reporting and tax payment obligations in the UK; to ensure that the right amount of tax is paid at the right time.

In relation to cross-border transactions, we apply the OECD standard and ensure that the transfer pricing policies implemented respect the “arm’s length principle”.

Whilst we seek to get things right first time we work in an environment of continuous improvement. Any inadvertent errors in submissions made to HM Revenue & Customs are fully disclosed as soon as reasonably practical.

SUSTAINABLE APPROACH TOWARDS TAX PLANNING AND LEVEL OF RISK

The ambition of the UK Tax Strategy is to bring value to our stakeholders; to maximise the tax efficiency of business transactions including taking advantage of available tax incentives and exemptions. We seek to do this in a way that is aligned with the commercial objectives.

When proposing tax solutions, we will not implement aggressive tax planning schemes that would disconnect from the conduct of the business or enter into artificial tax planning arrangements.

We have a low risk appetite in respect of taxation and seek to minimise the risk of uncertainty or disputes. Any potential planning is assessed against the Business Code of Conduct.

CONSIDERED RISK MANAGEMENT

Alpro’s tax planning and procedures are discussed between the Alpro VP CFO and Global Tax Director for Danone on a regular basis. Both are responsible for ensuring that policies and procedures that support the approach are in place, maintained and used consistently and that the teams have the skills and experience to implement the approach appropriately.

The UK approach to tax is approved by the Board of Directors of Alpro (UK) Ltd and the Global Tax Director for Danone. Day-to-day responsibility sits with the Finance Shared Service Center of Alpro based in Belgium, in liaison with Alpro’s UK based personnel where appropriate.

We regularly seek professional opinions and advice from independent external advisors on tax matters; on areas of complexity or uncertainty to support the UK in complying with its tax strategy. We identify, assess and manage tax risks and account for them appropriately. We implement risk management measures including controls over compliance processes and implement and monitor their effectiveness.

OPEN AND TRANSPARENT RELATIONSHIP WITH HM REVENUE & CUSTOMS

We are convinced that increased transparency towards tax administrations will ultimately contribute to reduce unfair competition and hence benefit our business.

Alpro (UK) Ltd seeks to have a transparent and constructive relationship with HM Revenue & Customs. However, situations may arise where positions are challenged and from time to time, our views on the appropriate tax treatment in any given case may differ from those of the tax authorities. Where such circumstances arise, we will work constructively and proactively with HM Revenue & Customs with a view to achieving an early resolution to any matters arising.