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Tax Policy

The objective of Gerald’s tax policy is to set forth and formalize procedures to prevent tax

evasion from being committed and is based on the following key principles:

1. Risk assessment

2. Implementation of procedures to carry out risk assessment

3. Secure buy in of top management to tax policy

4. Due diligence

5. Communication and training

6. Monitoring and review

Summary of Gerald’s Tax Policy

The Group's approach to overall business is based upon a code of conduct where there is an

expectation that its people will carry themselves in such a way that demonstrates personal and

professional integrity, ethically responsible behavior and professional excellence. Consistent

with this overall philosophy is the expectation of top management that the tax affairs of the

Group are managed consistent with this code of conduct. The Group is thus committed

conducting its business in accordance with all relevant laws, rules and regulations and the

highest ethical and legal standards. The Group's approach to tax compliance and planning is to

be consistent with these values.

Gerald believes it has an obligation to pay the amount of tax legally due in any jurisdiction in

accordance with relevant rules and regulations. Consistent with its code of conduct, Gerald will

continue its historic policy of managing its tax affairs responsibly, encompassing a zerotolerance

approach to illegal tax evasion and facilitation of such tax evasion.

Scope of Tax Policy

It is intended that this policy apply to all the Group entities and operations, whether operated by

Gerald, an affiliate, or a subsidiary. It shall apply to all employees of Gerald, affiliates and

subsidiaries. All relevant contractors or third-party service providers are expected to agree to the

terms of, and abide by, this Policy or to terms substantially the same and no less onerous.


As previously stated the aforementioned objectives will be accomplished by means of a 6 fold


1. Risk Assessment

To determine the scope and risk profile of each facet of the Group’s business including

external and internal relationships and implementation of relevant procedures.

Sector, transaction and geographic risks will be identified.

2. Implementation of procedures to carry out risk assessment

Subsequent to such determination the intention is to map existing financial crime

controls to inherent risks and identify whether their design and operation is sufficient to

mitigate the risks. If required, additional controls and/or procedures will be designed to

address the residual risk.

3. Secure buy in of top management to tax policy

This tax policy will be explained to the Board of Directors, and senior management and

they will commit, to a zero-tolerance approach to the facilitation of tax evasion and other

financial crimes. They will also sign off on the fact that tax planning and compliance will

be based on the principle that there is an obligation to pay the amount of tax legally due

in any jurisdiction in accordance with relevant rules and regulations and that that no

transaction is entered into, or implemented in a manner, which is considered high risk

or likely to be characterized as abusive for tax purposes.

Further, the Group’s tax director will continuously inform senior management and the

Board about forthcoming changes of legislation, policy or practice which will need to be

respected and/or implemented in accordance with this policy.

4. Due diligence

The tax function will be involved in this planning and implementation and focus review

on cross border financing arrangements, compensation arrangements and processes

affecting tax compliance including related transfer pricing analyses and country by

country reporting.

5. Communication and Training

Training on the terms of this Policy will be provided to relevant employees and

Gerald will conduct reasonable due diligence to determine the potential for any

associated persons to commit financial crime and seek to develop reasonable

measures to mitigate any such impacts; which will include the development of a

compliance manual (developed in consultation with outside UK counsel).

6. Monitoring and Review

The Group will institute procedures and controls that specify how financial crime

allegations, such as tax evasion and the facilitation of tax evasion, should be reported

by employees and stakeholders, and how such allegations are to be investigated. The

Group’s tax director and Anti-Money Laundering officer will be jointly responsible for

such monitoring and review

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