Policies and Statements

QDB HOLDINGS UC - GROUP TAX POLICY

Commitment to compliance

The Group is committed to conduct its global tax affairs consistent with the following objectives:

• Comply with all relevant laws, rules, regulations and disclosure requirements wherever we operate 

• Ensure the tax policy is at all times consistent with the Group’s overall strategy, its approach to risk and the Group’s values

• Apply professional diligence and care in the management of all risks associated with tax matters and ensure governance and assurance procedures are appropriate

• Foster constructive, professional and transparent relationships with tax authorities

Effective risk management

The Board is responsible for the Group’s tax policy and tax risks. Day to day responsibility is delegated to the Finance Director who works with the Financial Controllers of the Group finance department and the shared services centre to manage the tax risk through the Group finance function and through operational accounting functions of the business.

The Board reviews and approves the Group’s tax policy annually. The Group finance function identifies and manages tax risks using its knowledge of the Group’s operations and tax legislation. This is done by:

• regular communication with finance staff within the business to keep informed of any significant business changes

• monitoring proposed changes in tax legislation to identify its potential impact for the Group; and

• involvement in all acquisitions including review of financial and tax due diligence reports into the target’s business. 

Eliminating tax risks entirely is impossible, therefore the Group’s attitude towards the level of control required over the processes designed to reduce these tax risks is driven by the likelihood of occurrence and scale of impact of each risk. 

The identified tax risks are then assessed on a case by case basis, allowing the Group to arrive at well-reasoned conclusions on how each individual risk should be managed so that potential tax exposures may fall within the Group’s acceptable tolerance levels for risk. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the Group’s decision making process.

When reviewing the tax risks associated with a specific decision or action, always bearing in mind the Group Tax Policy, the following is to be considered:

• The legal and fiduciary duties of directors and employees.

• The requirements of any related internal policies or procedures.

• The maintenance of the Group’s corporate reputation, having particular regard to the way we interact with the communities around us in accordance with the Group’s CSR policy.

Responsible attitude to arranging our tax affairs

The commercial needs of the Group are paramount and all transactions must therefore have a business purpose or commercial rationale. The Group considers different tax outcomes when structuring material transactions to ensure they are carried out in an efficient manner and compliant with all relevant laws.

In cases where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought to support the Group’s decision making process.

Due consideration will be given to the Group’s reputation, brand, corporate and social responsibilities when considering tax initiatives, as well as the legal and fiduciary duties of directors and employees of the Group and will form part of the overall decision making and risk assessment process.

Constructive approach towards dealings with tax authorities

The Group values having good relations with tax authorities. We are therefore committed to the principles of openness and transparency in our approach to dealing with tax authorities and engage with them in a spirit of co-operative compliance. 

The Group strives to make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion. The aim would be to seek to resolve any issues in a timely manner and where disagreements arise work with tax authorities to resolve issues by agreement where possible.

In accordance with UK rules, the Group nominates a Senior Accounting Officer (SAO) for each of the UK subsidiaries. The SAO ensures that processes of tax compliance are carried out correctly and encourages regular communication with the Customer Relationship Manager (CRM) assigned by HMRC to develop a constructive and mutually beneficial relationship. 

Board ownership and oversight

This document, approved by the Board of QDB Holdings UC, sets out the Group’s approach to conducting its tax affairs and dealing with tax risks for the year ending 31 December 2017.  

 

Signed on behalf of QDB Holdings UC (The Group)

Daniel Browne

Director

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ENVIRONMENTAL POLICY

Dawn Meats Group operates meat processing facilities producing fresh and frozen meat products. The Company is aware of the effect of its operations on the environment and recognises that environmental management and sustainability practices are an integral part of our business culture.
We are committed to conducting our activities with due care and regard for the environment and to continual improvement to achieve a high standard of sustainable environmental performance.
To minimise environmental impacts concerning our activities, products and services, we shall:

• Comply with applicable legal requirements and other requirements to which the Company subscribes which relate to its environmental aspects.

• To include the consideration of environmental issues in all business strategies and initiatives.

• Dawn Meats Group senior management are committed to ensure that protection of the environment is firmly embedded in both the company’s and all employees’ culture and will endeavour to influence its suppliers and customers in a similar strategic environmental manner.

• Prevent pollution, reduce waste and minimise the consumption of resources.

• Consider the wider global impact of all our activities including those of our suppliers, customers and other stakeholders.

• Educate, train and motivate employees to carry out tasks in an environmentally responsible manner and ensure that a continuous professional development strategy remains core to our business goals.

• Encourage environmental protection among suppliers and subcontractors.

• To investigate the feasibility of influencing its suppliers, customers and third parties with consideration to life cycle impacts of their aspects and activities.

• Encourage and enhance biodiversity and ecology.

The Company is committed to continual improvement of environmental performance This policy will be communicated to all staff, contractor and suppliers, and be available to the public through selected media.

Niall Browne 

Chief Executive 

September 2016

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction
This statement is made by Dawn Meats (UK) [“Dawn Meats”] and sets out the steps the Company has implemented to ensure that slavery and human trafficking is not taking place in its supply chain or any part of its business.  It is a Statement made in accordance with Section 54 of the Modern Slavery Act 2015 (the MSA), and covers the financial year from January 1st 2016 to 31st December 2016. 

Dawn Meats is fully committed to the objectives of the MSA and recognises its responsibility to be aware of potential risks of modern slavery within the organisation and its supply chain.  Modern slavery is a global problem.  It is complex and is characterised by exploitation and abuse. Working in collaboration with our business partners we are committed to monitoring, reviewing, improving, aligning and developing our management systems to ensure the integrity and transparency of our supply chain both at home and overseas.

The CEO and Senior Management Team have ongoing responsibility for ensuring that the statement is published annually and accurately reflects the company’s measures and initiatives to tackle slavery and human trafficking.  The Group Human Resources department and site HR Managers are responsible for implementing policies and reviewing the process by which they are developed.  The HR teams are also responsible for the cascade of information throughout the sites and the conveying of similar messages to the wider business. 

In addition, we have appointed a Modern Slavery Champion, whose role it is to ensure that we are doing all that we can to avoid the possibility of modern slavery occurring within our operations and supply chain. Furthermore, a key objective of the company’s Corporate Social Responsibility forum is to devise and implement ethical initiatives to endorse the company’s commitment to acting ethically and with integrity in all its business practices.

About Us
Dawn Meats is a premium meat processor and supplier of choice to a range of leading supermarkets, food service and restaurant businesses.  Established in 1980, Dawn Meats is now an industry leader.  We employ more than 3,300 staff in ten countries, exporting to over 48 countries. At Dawn Meats we are committed to our staff and our customers.  People are our strength and dedication to excellence is at the heart of Dawn Meats success. 

We welcome and encourage fresh thinking and actively build on an innovative culture across the company.  We are a family owned business, which remains true to its farming heritage through the close relationships it has forged with 20,000 farmers in the UK and Ireland.  Dawn Meats works closely with some of the world’s leading food companies who are attracted by our commitment to business integrity, sustainability and quality.

Our Supply Chain
Our supply chain includes the sourcing of livestock and raw materials principally related to the provision of food.  The manufacturing supply chain is one of the most complicated of any industry with several tiers of suppliers. 

Supply chain transparency, security and integrity are crucial components of our business model.  We have implemented robust technical and traceability systems to ensure that our products are responsibly sourced from suppliers whose values are aligned with our own.  We have clearly established internal processes which set out to verify that our key suppliers comply with our own very high standards which includes a long term established and detailed farm auditing programme. 

We are an AB member of SEDEX (Supplier Ethical Data Exchange) and we encourage our suppliers to register and complete a SEDEX SAQ as part of their relationship with Dawn Meats.   Those suppliers who are not members of SEDEX need to demonstrate their compliance and commitment to ethical trading and supply chain integrity in order to qualify for a relationship with our company.  All sites within Dawn Meats extensively undertake Ethical Trade Audits. 

Our Standards
Dawn Meats has a fundamental commitment to acting ethically and with integrity in all business relationships. We are committed to working collaboratively with our business partners to ensure that our supply chain is transparent and is free from labour exploitation and abuse.  Our commitment is extended to social and environmental responsibility and we have a zero tolerance of slavery and human trafficking.

Our Social Accountability Policy embraces the principles of the Ethical Trading Initiative base code.  It specifically addresses the key subjects contained in the Modern Slavery Act as the following exert taken from section 1 demonstrates: -

‘Employment is freely chosen.  There is no forced, bonded or involuntary prison labour. The Group operates a policy of providing equal opportunities to all workers.  Workers are not required to lodge deposits or identity papers and are free to leave after notice.’

Ethical Best Practice has been identified as a bedrock of the Dawn Meats business model.  The risks posed by Slavery and Human Trafficking are continually monitored by our Modern Slavery Champion and HR Leaders. 

Risk Assessment
One of the largest risks in our supply chain lies with our labour providers as the numbers of temporary workers may rise significantly at peak times of the year.  We have stringent Service Level Agreements in place with our labour providers to ensure that they are fully committed to the principles of the Modern Slavery Act, and we remain acutely alert to any hidden labour exploitation which may include practices such as bonded labour, payment for work finding services, payment for access to specific shifts and forced use of accommodation. 

Dawn Meats use labour provider partners to supply a percentage of our workforce.  These are long established business relationships with providers who are fully aware of the Company’s compliance requirements.  All labour providers to Dawn Meats are registered with and in possession of a valid GLA licence and are required to attend Stronger Together Workshops as part of our terms of business.

Active Check immediately highlights to us any changes in license status.  The diagram below maps out the planned monitoring and audit process for labour providers.  Each labour provider will be audited on an annual basis.

Diagram Outlining Labour Provider Audit and Monitoring Process for 2017

Training and Awareness
We have an ongoing training programme for HR Leaders to ensure that they are fully trained on the risks posed by labour exploitation. HR practitioners have and will be attending Stronger Together Workshops which are aimed at tackling modern slavery in the supply chain. 

The learnings and knowledge from these workshops will be communicated at induction and refresher induction to Dawn employees and agency colleagues alike.
In 2016 to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business we embarked on an education awareness campaign with our senior managers via two methods – the Executive Team briefing and the Company’s Corporate Social Responsibility forums.  The company has reinforced its responsibility under the Modern Slavery Act via its commitment in the published 2016 CSR report which appears on the Company’s website.

Whistleblowing Policy / Whistleblowing line
We have a robust and established Group Whistleblowing Policy that is bought to the attention of all employees and agency workers who join Dawn Meats.  The policy which is translated into a number of languages is published on staff notice boards. Additionally, there is an anonymous confidential hotline in place.  Information posters are published in both English and Polish.  The line is available 24 / 7 and is manned by a team of independent professionals who have translation facilities available in multiple languages to all callers. 

This confidential helpline is available to all employees, contractors and agency workers.  It is managed entirely independently by a 3rd party who will investigate any complaints made. 

Dawn Meats encourages and supports any individuals who raise genuine concerns to ensure that no one suffers as a consequence.

Measuring Effectiveness – Performance Indicators
In order to monitor the effectiveness of the steps taken by the business to prevent slavery and trafficking  the company will use the following indicators on an ongoing basis: -

- Detailed monitoring /recording of all complaints received via our Confidential Hotline.
- Ongoing training of existing and new people to ensure full understanding of the commitments of the Modern Slavery Act and ethical trading initiatives.
- Ongoing annual audit of all Labour providers 
- Increased usage of SEDEX platform in close conjunction with our suppliers.
- Delivery of in house and external ethical training awareness to key people.
- Commitment to continuous improvement and thus a review of our recruitment and induction practices.
- Full review and audit of transportation practices to and from work.
- Translation of relevant policies into most commonly spoken languages other than English.

Niall Browne
Chief Executive

This Statement has been approved by the CEO and Senior Management Team who will review and update annually.