Version 1.2, 16 September 2024

1.1 Introduction

The TP ICAP Group plc Board is committed to maintaining the highest standards of honesty, openness, and accountability. We recognise that all those who work with or within the Group have an important role to play in achieving this goal. We take protecting our colleagues, customers, and business from issues such as discrimination and harassment very seriously. However, like any major organisation, there are occasions where we face the risk of things going wrong, or we are unaware of malpractice taking place. 

To ensure we are aware of any wrongdoing, we provide a confidential and secure service that enables our colleagues, suppliers, and their staff to raise concerns. We have global coverage through our whistleblowing policies, which apply to all entities within the TP ICAP Group. The TP ICAP Group Board treats all malpractice and/or misconduct with the utmost importance, whether it is committed by senior managers, staff, suppliers or contractors.

1.2. Values-led organisation

As TP ICAP is a values-led organisation, employees must also be aware that TP ICAP’s values form part of the wider context that this policy operates in. TP ICAP's values are Accountability, Authenticity and Adaptability (“Triple-A Values”). Above all else, we respect our clients and each other, without bias. 

Whistleblowing is the disclosure of information that relates to suspected wrongdoing in relation to TP ICAP's activities. This may include, but is not limited to:

• criminal activity; 
• failure to comply with any legal or professional obligation or regulatory requirement; 
• miscarriages of justice; 
• danger to health and safety; 
• damage to the environment; 
• unethical behaviour; 
• conflicts of interest; 
• bribery or corruption; 
• money laundering and tax evasion; 
• financial fraud or mismanagement; 
• insider trading or market abuse; 
• negligence; 
• breach of TP ICAP's internal policies and procedures; 
• behaviour that harms or is likely to harm TP ICAP's reputation or financial wellbeing; 
• unauthorised disclosure of confidential information; and 
• the deliberate concealment of any of the above. 

TP ICAP’s policy states that whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. 

1.3. Raising a concern 

TP ICAP encourages genuine concerns to be raised in good faith to ensure our businesses continue to act with honesty and integrity. If you suspect misconduct/wrongdoing, or a contravention of law/s on behalf of TP ICAP, TP ICAP encourages you to raise these via our whistleblowing hotline provider, Safecall, using the following link:

Report An Incident & Update (safecall.co.uk)

For more information on our commitment to equality, diversity, and discrimination, please visit our Harassment, Equality & Diversity page.

Publication date: 14 December 2023

1.1. Introduction

1.1.1. This document, approved by TP ICAP Group plc’s Board of Directors, sets out the global policy and approach to conducting the tax affairs and dealing with tax risk in the TP ICAP group of companies (‘the Group’).

1.1.2. This strategy applies from the date of publication until it is superseded. The document will be reviewed periodically by the Group Tax team, and any amendments will be approved by the Board.

1.1.3. This Group Tax Strategy meets the requirements set out in Schedule 19 of the Finance Act 2016 for Large Businesses in the UK to publish their tax strategy in respect of the current financial year. It supersedes the Group Tax Strategy published in the preceding financial year.

1.2. Strategy

1.2.1. The Group is headed by a UK tax resident company and is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities wherever we operate. 

This includes:

- Ensuring the tax strategy is consistent with the Group’s overall strategy, its approach to risk, and the Group’s core published values;
- Applying professional diligence and care in the management of all risks associated
with tax matters, and ensuring appropriate governance and assurance procedures are in place;
- Paying the right amount of tax required under the laws and regulations of the jurisdictions in which the Group operates; and
- Fostering constructive, professional and transparent relationships with tax authorities.

1.3. Tax Risk Management and Governance

1.3.1. The Group’s tax risk appetite is low, and is based on professional judgement obtained inhouse and through specialist guidance from advisers, where appropriate.

1.3.2. Responsibility for tax strategy, policies and management of tax risk ultimately rests with the Group’s Chief Financial Officer. Day-to-day management of the Group’s tax affairs is delegated to the Group Head of Tax. Regular reports are made to the Audit Committee in relation to tax matters, supplemented by reports to the Board as required. The Board ensures that the Group’s tax strategy is one of the factors considered in all significant business decisions taken.

1.3.3. The Group operates a system of tax risk assessment and controls as a component of the overall enterprise risk management framework. A broad range of risks are considered in reaching any decisions. Key tax risks are considered to be:
- Transactional risk
- Compliance and reporting risk
- Reputational risk

1.3.4. The Group seeks to reduce tax risk by ensuring that reasonable care is applied in relation to all processes which could materially affect compliance with its tax obligations. Local Finance teams are staffed with appropriately qualified individuals who account for tax under the financial reporting control framework. Where potential risks are identified Group Tax will review and advise on the appropriate steps to mitigate the risk.

1.3.5. The Group Tax team is staffed with qualified tax professionals who review relevant tax processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes, and processes or controls are updated when required.

1.4. Attitude Toward Tax Planning

1.4.1. The Group seeks to fully comply with its statutory obligations. The Group does not engage in artificial transactions which have the sole purpose of obtaining a tax benefit. In the course of the Group’s commercial activities there may be choices as to how business is undertaken, which may result in different tax outcomes. In such cases the Group may seek to carry out its business in a manner which produces a lower tax cost than the alternative approach(es), provided that results in an appropriate application of tax law consistent with the Group Tax Strategy set out in this document.

1.4.2. Tax incentives and exemptions are sometimes implemented by governments and fiscal authorities in order to support investment, employment and economic development. Where they exist the Group seeks to apply them in the manner intended.

1.4.3. The Group adheres to relevant tax law and seeks to minimise the risk of uncertainty or disputes. Where there is uncertainty as to the application or interpretation of tax law, appropriate written advice may be taken from external advisers or tax authority clearance obtained to support the decision-making process.
 

1.5. Working with Tax Authorities

1.5.1. The Group is committed to openness and transparency in dealing with tax authorities wherever we operate around the world. Dealings will be conducted in a collaborative, courteous and timely manner. The Group aims to strive for early agreement on disputed matters, and to achieve certainty wherever possible.

1. Procurement

Supplier Code of Conduct

2. Modern slavery

Modern slavery & human trafficking statement