Moving Energy

Responsibly

Tax Governance Framework

Gunvor is committed to comply with all applicable tax laws, rules and regulations of the countries in which we operate in, both in terms of the letter but also the spirit of the law.

Tax plays an important role in corporate responsibility and is overseen by the Board of Directors of Gunvor Group.

Our Group Tax Policy set out our approach to tax strategy and approach in conducting its tax affairs and dealing with tax compliance risk.

Our Group Tax Policy set out our approach to tax strategy and approach in conducting its tax affairs and dealing with tax compliance risk.

Group Tax Governance

Gunvor is committed to comply with all applicable tax laws, rules and regulations of the countries in which we operate in, both in terms of the letter but also the spirit of the law.

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Singapore Tax Governance Framework

Some info needed here on what the Singapore Tax Governance Framework is.

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Compliance with Tax Laws

•  We endeavour to comply with all relevant tax laws and regulations.

•  Our business is driven by genuine commercial and economic activities. We are aware of the importance of ensuring   any tax planning opportunities are carried out within the ambit of tax laws.

Relationship with Tax Authorities

•  We maintain an open and cooperative relationship with IRAS.

•  We perform regular reviews and self-assessment programs of our tax filing positions and are committed to make   accurate and timely disclosure to IRAS.

•  Where appropriate, we will seek clarification or rulings from IRAS on material transactions or interpretation of tax   law relevant to us.

Governance for Managing Tax Risks

•  We have formalised a governance structure for tax risk management, where the roles and responsibilities are clearly   defined:

  – The Board is apprised of the company’s overall tax governance strategy and delegates responsibility of our tax   function to the Head of Tax;

  – The Head of Tax, supported by the tax function, is responsible for overseeing the company’s tax affairs, including   producing timely, accurate and reliable tax returns and paying all taxes due.

•  We maintain a sound system of risk management and internal controls to identify, assess and manage tax risks and   ensure accurate tax reporting.

•  Our internal tax team is competent in managing tax compliance, and where necessary, we would engage external   advisors to seek their advice or clarification on complex issues.

•  Any significant tax risks and issues will be escalated to the Board where appropriate.

More information on Gunvor Policies and Code of Conduct

Gunvor has established clear policies for ABC, AML, market conduct, market abuse, economic sanctions, and other risk areas. They have been communicated from the top-down. Importantly, we have also created a whistleblowing policy that has been clearly communicated by the CEO to all Gunvor employees.

Specifically regarding ABC, policies and procedures and systems and controls meet standards put forth by the US. Foreign Corrupt Practices Act, UK Bribery Act and those propagated by the OECD. With respect to breaches, Gunvor maintains a zero-tolerance approach.

In the context of Gunvor’s Payments to Governments Policy, the company has expressed support for the Extractive Industries Transparency Initiative (EITI) to establish a consistent means by which to reliably report on its payments to governments, with the aim to improve transparency and reduce the potential for corruption in cooperation with these governments.

Gunvor’s reporting includes purchases of crude oil and refined oil products acquired from state-owned enterprises in EITI implementing countries. More information

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