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Greensill Capital statement on whistleblowing arrangements

October 2020

Introduction

Greensill is committed to protecting and supporting employees to speak up so that concerns or issues can be escalated and dealt with effectively.  Employees are encouraged to voice their concerns in an anonymous and confidential manner, without fear of personal repercussions, which they believe show malpractice or illegality.

Safeguards

  • Confidentiality: Greensill will treat all disclosures in a confidential and sensitive manner.
  • Untrue Allegations: If an individual makes an allegation in good faith, they will not be penalised, and will be protected.
  • Protection: Greensill wishes to provide a supportive environment protecting all employees that make disclosures. Greensill will not tolerate any employee being subjected to detriment as a result of making a disclosure in good faith.

Making a Disclosure

  • Greensill has engaged an independent organisation, Safecall, to take any employee whistleblowing concerns in an anonymous and confidential manner that an employee feels cannot be reported internally.
  • Safecall provide options to raise whistleblowing concerns by phone which will not be audio recorded, or via the it’s web address. Reports can also be made 24 hours a day, 7 days a week in over 170 different languages.

Investigations

Greensill has procedures in place for the investigation of cases reported through Safecall. Care is taken to ensure the investigation of all concerns are carried out thoroughly, independently, and in a timely manner, by appropriate subject matter experts.

Governance

The Audit and Risk Committee are responsible for reviewing the whistleblowing procedures and may receive regular updates on relevant matters of concern raised under these arrangements, together with management actions taken in response.


Greensill Tax Strategy

31st December 2020

Greensill’s business

“Greensill was formed on the simple belief that access to working capital should be easier, better priced and more readily available”

The Greensill group specialises in providing effective and comprehensive working capital solutions to corporates globally. We are focused on having the broadest and most robust sources of capital, on leveraging technology and data to develop innovative finance solutions, and on partnering with leading electronic platforms. This successful operating model has grown at a considerable pace over recent years and has now led to Greensill becoming a market leading provider of working capital finance across the globe.

As part of the group’s general policies on how it conducts this business, the group has developed its tax strategy.

Tax strategy

Wherever we carry on business or look to expand our operations, Greensill considers the tax implications. We seek and obtain appropriate tax advice in each relevant territory to ensure the group meets its tax compliance obligations. We are committed to properly managing our tax reporting requirements and to acting in accordance with the relevant tax laws and regulations in each territory. We aim to pay taxes on a timely basis, and to pay the amount of tax legally due in a territory arising from the activities and transactions undertaken by the group in that territory.

This tax strategy sets out how Greensill’s tax affairs are managed globally and is reviewed and approved by the Directors on a periodic basis as appropriate. It is published in accordance with the requirements under Section 161 and paragraph 16(2) Schedule 19 of the UK Finance Act 2016 for the year ended 31 December 2020.

“Changing finance to change the world”

In line with our strategy to help support business globally, Greensill seeks to operate in a fair, open and transparent manner in all the relevant jurisdictions in which it operates.

The group seeks to ensure that our engagement with HMRC (and other relevant tax authorities) is professional, open and honest, and is undertaken in a spirit of cooperation. The group aims to make fair, accurate and timely submission of all tax returns and correspondence for all the territories that we operate in.

Greensill is committed to making full disclosure to HMRC (and other relevant tax authorities) of any relevant issues that may impact on its tax filings in a timely manner.

Greensill’s wider operations facilitate transactions across the globe. When undertaking these transactions our approach is to be tax compliant and to operate in a tax efficient manner; Greensill does not engage in artificial tax arrangements lacking economic or commercial substance.

“Unlocking capital so that the world can put it to work”

Our Head of Tax has overall responsibility for the oversight and management of the tax affairs of Greensill on a group-wide basis and is responsible for reporting to the Chief Financial Officer and Board regarding tax compliance, tax risk and material tax uncertainties.

The group maintains robust controls and procedures in line with the following criteria:

  • Greensill’s policies regarding tax compliance and strategy are authorised by the Board;
  • Our Risk Committee has been appointed to identify monitor and manage key business risks, including those that are tax related.
  • Day-to-day management of Greensill’s tax affairs are delegated to Greensill’s Head of Tax and the tax team. Specialist tax advice is sought where appropriate.

Greensill is prepared to accept risk on tax matters in line with the levels which the Board and Audit Risk Committee determine to be appropriate. This is based on reports made to them as required on any significant tax matters and developments where these might arise.


Greensill Capital Modern Slavery Act 2015 Statement

for year ending 31 December 2019

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 on behalf of Greensill Capital (UK) Limited (“Greensill”), to whom the requirements apply.

Our Business

Greensill is the market-leading provider of working capital finance for companies globally.  Greensill uses the financial markets to unlock capital on terms that fit the requirements of our clients.

Our Statement

As a business we are committed to operating responsibly and to the highest standards of ethics and integrity.  Greensill does not tolerate any form of slavery, human trafficking or other similar work environments or practices and is committed to maintaining and improving the processes it has in place to help ensure that these abuses do not occur in its own operations.

We also expect the same high standards from our contractors, suppliers and other business partners – we will not work with anyone or organisation that has been or is found to be knowingly involved in modern slavery.

Governance

Globally, Greensill has continued its efforts on raising awareness around Environmental, Social and Governance concerns within the organisation. Under the Board’s oversight, we have started to implement a reputational risk framework to ensure appropriate concerns are highlighted and escalated to senior management. Any credible allegations regarding clients and third parties are investigated and will be reported under this framework.

Due Diligence

Greensill is strengthening its procurement approach to the engagement of suppliers and service providers through a consistent assessment process. Looking forward, Greensill will investigate introducing clauses relating to modern slavery and human trafficking in supplier contracts. As part of our client due diligence process, our Financial Crime teams undertake due diligence exercises on client relationships which incorporate negative media checks.

People

Greensill has committed to investment in its support areas across the three lines of defence to ensure that our policies and procedures are appropriately developed and communicated to all relevant staff. During 2019, the Whistleblowing policy was implemented to ensure employees have an independent escalation process to speak up.

Board Approval

This statement was approved on the behalf of the Greensill Board of Directors by: Al Eadie

Date: 2nd January 2020.

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