LEGAL PAGES
Fiscal Policy
1.- OBJECTIVE
1.1.- CONTEXT
This Tax Policy is articulated based on the fundamental principle of tax compliance consisting of properly fulfilling the tax obligations to which the Global Exchange Group (hereinafter the Group or Global Exchange) is subject, while fostering a relationship with tax authorities based on transparency, good faith, loyalty and mutual trust.
This must be combined with the firm commitment of the Group's Management and, particularly, of the Board of Directors of the Group's parent company, Eurodivisas, S.A., to promote a solid culture of compliance, ethics and integrity in the performance of all activities of the Global Exchange Group, in line with the first of the Group's Corporate Principles that refers to strict compliance with Ethics, Legality and Transparency.
For the purposes of this Policy, GLOBAL EXCHANGE GROUP or the Group is understood as the one integrated by EURODIVISAS, S.A (hereinafter, the Company), as the parent entity, and its subsidiaries and dependent companies.
1.2.- OBJECTIVE
The objective of this Tax Policy is to establish the fundamental guidelines that will guide the decisions and actions of the Group and the entities that compose it in tax matters, globally and in accordance with the applicable regulations in the different territories and countries in which it operates.
2.- SCOPE
This Tax Policy applies to employees of Eurodivisas S.A. and all Global Exchange subsidiaries, regardless of their geographical location or hierarchical position, and is mandatory. This Policy is of special relevance for the following bodies of Eurodivisas S.A.: Board of Directors, Ethics and Compliance Committee, members of the Administration and Finance area and equivalent bodies of the investee entities.
It is equally applicable and mandatory as far as it applies to suppliers and other third parties that provide services to or in any way relate to the Global Exchange Group.
In the case of subsidiary companies whose management is controlled, directly or indirectly, by Eurodivisas, S.A, the Company is responsible for ensuring that this Tax Policy is known by them, transmitting to the country manager the requirement for its compliance.
In cases of those investee companies over which the Company does not have control, it tries through its voting rights to ensure that this Tax Policy is known or that at least an equivalent policy is available.
In cases where "joint ventures", temporary business unions and other equivalent associations are carried out, when the Company assumes their management, this Policy applies.
3.- DESCRIPTION
3.1.- OVERVIEW
Eurodivisas, S.A has a Tax Compliance Management System, integrated into the Compliance System, following the guidelines established in the UNE 19602 Standard. In accordance with the Group's centralized management model, the Company promotes the adoption of comparable systems in the different subsidiaries. This Policy must be interpreted in the context of the Policies and procedures that make up the Compliance System of Eurodivisas, S.A and which are published on the intranet.
3.2.- PRINCIPLES OF ACTION IN TAX MATTERS
The principles of action in tax matters of the Global Exchange Group are as follows:
- Global Exchange's Tax Policy is based on compliance with tax regulations by the Group and, consequently, by all persons involved not only in tax processes, but also in carrying out operations with tax impact. Such compliance implies satisfying in accordance with current legislation and in due time and form all taxes and tax obligations that are required by the tax regulations applicable in each country.
- The management of tax affairs will be based on a reasonable interpretation of tax regulations, taking into account both the literal meaning and the spirit and purpose thereof.
- Practices aimed at preventing and reducing significant tax risks will be encouraged, ensuring that the taxation of generated profits bears an adequate relationship with the structure and location of activities, human and material resources and the location of business risks.
- Any business decision that may have a tax impact must be adopted with full knowledge of it and brought to the attention of the Board of Directors of Eurodivisas, S.A when it comes to operations subject to their approval.
- The relevant tax implications of any corporate operation, including both reorganization and investment or divestment structuring, must be reported to the same bodies or management levels that have to decide on their adoption.
- Tax planning practices that involve reducing tax costs and that pursue a tax advantage and do not respond to business reasons should be avoided.
- Eurodivisas, S.A will not establish or acquire companies resident in non-cooperative jurisdictions unless this responds to business reasons and these companies are endowed with sufficient human and material resources so that it is considered that there is economic substance.
- Eurodivisas, S.A will not establish corporate structures with the purpose of opacity or that may undermine the transparency of the Group, that is, tending to avoid or hinder knowledge of the ownership of assets or liabilities or the execution of transactions.
- A cooperative relationship with tax administrations should be sought, based on mutual trust, transparency and good faith.
- A transfer pricing policy is applied to all operations between related parties and entities.
- When situations of special complexity occur, the opinion of one or more advisors of recognized prestige will be requested and, if necessary, it will be confirmed that the tax treatment is appropriate with the corresponding tax authorities.
The cooperative relationship with the different tax administrations will be promoted based on transparency and mutual trust.
4.- IMPLEMENTATION GUIDELINES
The Company will implement control mechanisms and provide the necessary resources for effective compliance with tax regulations and the Tax Policy approved by the Company's Board of Directors, ensuring that all persons involved in tax practice have sufficient technical training proportionate to their level of responsibility, as well as the necessary means to perform their role.
The Ethics and Compliance Committee (ECC), as an internal and permanent collegiate body with autonomous competence and powers of initiative and control, reporting to the Board of Directors, is assigned the functions of the tax Compliance body. In this regard, it will ensure proper compliance with this Tax Policy through the establishment of necessary internal control mechanisms and standards, continuously promoting and supervising the implementation and effectiveness of the Tax Compliance Management System, and reporting on it to Senior Management and the Board of Directors.
5.- REPORTING OF CONDUCT AND DISCIPLINARY SYSTEM
5.1.- ETHICS CHANNEL
In accordance with the provisions of the Ethics Channel Regulations of Eurodivisas, S.A, any director, Executive, Employee or Supplier can send confidential and anonymous reports to the ECC, related to irregular conduct that may involve any act contrary to the Global Exchange Group's Code of Ethics.
For these purposes, Eurodivisas, S.A has a confidential communication channel for receiving reports with the aim of adopting appropriate measures to protect the Group's interests and the effective compliance with the breached rule or provision.
The Ethics Channel is accessible to all members of the organization and to Eurodivisas, S.A's stakeholders, through which they can report non-compliance with this Tax Policy and other tax-related policies and processes, as well as those belonging to the Compliance System.
The aforementioned Ethics Channel can be accessed through the following URL: https://eurodivisas.globalsuitesolutions.com/ethicalchannel
5.2.- CONSEQUENCES OF NON-COMPLIANCE
All members of the organization are responsible for understanding, observing and applying the provisions of this Tax Policy and other associated documents that are part of the Tax Compliance Management System.
Therefore, any action contrary to the Group's Code of Ethics and the rest of the documents of the Tax Compliance Management System, including this Policy, that results in non-compliance in the tax area, may be sanctioned in accordance with the provisions of the Group's Disciplinary Code.
6.- DISSEMINATION AND COMMUNICATION
It is the responsibility of the Board of Directors and the ECC of the Company to ensure the effective dissemination of this Policy and to make it known to employees, shareholders or any interested party, as well as any modifications that may be agreed upon.
This Policy is available and accessible to all stakeholders.