The Steinhoff UK Group (“Steinhoff’) is a major retailer and manufacturer within the UK.
Steinhoff recognises the responsibility it has, along with its suppliers, to operate in an ethical manner. As part of this responsibility, we acknowledge the requirements of the Modern Slavery Act 2015. Therefore, Steinhoff is working to ensure that there is sufficient transparency both within the organisation itself, and within its supplier base.
In relation to its suppliers, Steinhoff has updated the Service Level Agreements (“SLA”) that it has with its major suppliers in order to include a reference requiring compliance with the Modern Slavery Act 2015. The update to the SLA also includes a request that our suppliers comply with Steinhoffs Code of Conduct and that they also complete a self-assessment questionnaire in relation to this area. Our supplier appraisal process has also been updated to take into account what commitment and actions our suppliers are taking to comply with the Modern Slavery Act 2015.
Steinhoff wants its customers to be confident that both Steinhoff and its business partners treat their employees fairly, with respect for their human rights.
Steinhoff will not work with any organisation that either has or is found to be knowingly involved with either human trafficking or modern slavery.
The Steinhoff UK Group (the “UK Group”) is the group of companies owned directly or indirectly by Steinhoff UK Holdings Limited (including this company), which itself is a subsidiary of Steinhoff International Holdings N.V.. The Steinhoff International group has a Tax Risk Management Framework to align the worldwide group’s approach to tax management and tax risk. The UK Group ensures its compliance with this framework by paying the right amount of tax, in the right place, at the right time.
The UK Group considers this publication meets the requirement of the Finance Act 2016 to publish its UK tax strategy.
Tax considerations impact on all the UK Group’s commercial operations whether these are corporate business taxes based on trade results, VAT and customs duties on the products we buy and sell, employment tax responsibilities when paying staff we employ, or property taxes on the premises from where we make our offering. The UK Group’s in-house tax function plays a role in all aspects commencing with planning and reviewing change proposals to implementation and recording to HMRC through the tax returns and reports.
Within the UK, the UK Board is ultimately responsible for the management of tax risk. The Finance Directors of each subsidiary company or division in turn hold responsibility for tax accounting arrangements within their own businesses, whilst day to day responsibility for the management of the UK group’s tax risk rests with the UK Group Tax Manager. The UK Group Tax Manager has clear reporting channels to all Finance Directors and the divisional and UK Group audit committees, and a tax compliance status report is presented at each quarterly UK Group audit committee meeting, with significant or material matters being reported to the UK Board.
Minimising the tax risk also relies heavily on the accounting systems and controls in the underlying businesses. The UK Board is responsible for implementing and monitoring these systems and controls, with delegation to the Finance Directors of the subsidiary companies and divisions for the day to day management. The internal audit team regularly assesses and tests these controls, and reports to divisional audit committee meetings on a quarterly basis. The businesses in the UK Group are also required to complete and maintain risk registers which are discussed at the quarterly audit committee meetings, and in order to comply with the Criminal Finances Act 2017, businesses are required to have in place controls to specifically guard against tax evasion. External auditors provide an opinion on the UK Group companies’ results on an annual basis, which includes tax amounts and disclosures.
Overall, the UK Group’s appetite for tax risk is low and it structures its affairs based on sound commercial principles.
As stated above, tax considerations can have a significant impact on the UK Group’s commercial operations. The UK Group recognises its duty to stakeholders to control unnecessary costs, including taxation, so utilises tax reliefs and allowances that are available. We do not condone either personal or corporate tax evasion under any circumstances.
Efficient tax planning is engaged to support our business and reflect commercial and economic activity. Adherence to relevant tax law is fundamental and the UK Group seeks to minimise the risk of uncertainty or disputes.
For the purposes of UK corporation tax, forecasts are prepared for the UK Group on a quarterly basis in order that an estimate can be made of the annual corporation tax due, and payments on account can be made accordingly. These forecasts inherently contain numerous estimates, particularly surrounding future trading prospects, but are put together with the support of results from all relevant underlying businesses to ensure that the estimate is as accurate as it can be in the circumstances.
Professional opinions are sought from reputable external advisers on matters where the amount of tax involved is significant and the tax treatment uncertain.
A full and active dialogue with tax authorities such as HMRC is maintained, disclosing all relevant facts and circumstances in a timely manner. Where relevant, we will use tax clearances to obtain agreement in advance from tax authorities prior to undertaking transactions.
We support the protection and elevation of human rights in the countries within which we operate and are guided by the fundamental principles as set out in the UN Universal Declaration of Human Rights, the UN Global Compact and the ILO’s Declaration on Fundamental Principals and Rights to work. We support the UN Guiding principles and accept our corporate responsibility to respect human rights. Our support for these fundamental principles is reflected in our policies and actions towards our employees, suppliers, customers and the communities that we affect, within the countries that we conduct our business.
We believe that our employees should be treated with respect and dignity and work in an environment that is free from harassment and unlawful discrimination. Our commitment to respect human rights is manifested in our Employee Handbook and HR Policies and procedures. These state that all employees should be able to work in an environment that is free from discrimination, victimisation, harassment, bullying and that all employees should be treated fairly and with dignity regardless of their background or categorisation, or any views they may hold. The Fair Treatment Policy is periodically reviewed and amended where appropriate to ensure that it continues to reflect best practice and legal requirements. Our position on human rights is communicated to our employees and our employees are expected to uphold these standards. Our employees have access to an ethics hotline through which, concerns can be raised and resolved effectively. Employees are encouraged to raise relevant issues and report suspected violations of applicable laws, regulations and policies.
We strive to promote adherence to the human rights principles throughout our supply chains by encouraging actions that are consistent with our Supplier Code of Ethics and by using suppliers whose corporate values are consistent with ours. Specifically, suppliers are encouraged to follow best practice in areas such as Business Ethics, Employment Standards and the Environment and to understand the impact of their products and services in order to mitigate any negative effects they might have on their stakeholders. We see our relationships with our suppliers as an opportunity to share best practice and through open communication, to promote continual learning and improvement with respect to human rights.
In order to further drive best practice for improving human rights within our zone of influence, it is important to us to develop partnerships with other organisations that share our values. In doing so we openly welcome inspection and auditing processes that aim to develop more robust and transparent human rights systems within our business.