Graph Comm Holdings International, Inc.

Our UK Tax Strategy[1]

Introduction

Veritiv Corporation is a leading North American business-to-business distributor of print, publishing, packaging, and facility solutions. Additionally, Veritiv provides logistics and supply chain management solutions to its customers.

Graph Comm Holdings International, Inc. (GCHI), a U.S. corporation, is part of the Veritiv group and operates in the United Kingdom via a UK branch. GCHI has no operations outside the UK.

GCHI is committed to complying with UK tax law. Compliance for GCHI means paying the right amount of tax at the right time. It involves disclosing all relevant facts and circumstances to the UK tax authorities.

Our approach to tax
risk management and governance

Identification, mitigation and management of risks are central to our strategy, and our enterprise-wide risk management processes are designed to effectively manage risk.

The Board sets and oversees the risk management strategy and the effectiveness of the Group’s internal control framework. The VP of Tax for Veritiv Corporation and Subsidiaries is responsible for the management of tax risk and reports up the chain to the Chief Financial Officer, CEO, the Audit Committee, and the Board. We continuously identify and manage those risks and opportunities that could affect the achievement of our business plans and strategic objectives, our shareholder value and our reputation, through our risk management process.

Systems, processes and controls are central to ensuring compliance and as part of our statutorily required procedures. We conduct regular system and control checks to ensure robust and appropriate tax accounting arrangements. The VP of Internal Audit, who reports up the chain to the Chief Financial Officer, CEO, the Audit Committee, and the Board, monitors business risk and ensures systems and controls are in place to minimize risk.

We have established policies and processes in place to ensure the integrity of our tax filings and other tax compliance obligations in the UK and worldwide, and our tax processes are subject to the same level of internal controls, review and external audit as the rest of the business.

Our attitude towards
tax planning

When considering the structure of our commercial activities, we take account of a number of factors including consideration of the tax laws of the countries in which we operate.  We do not take an unreasonable stance on our interpretation of tax legislation and we strive to work within both the letter and spirit of local laws. We do not use artificial arrangements. We do not undertake aggressive tax planning, the sole purpose for which would be obtaining a tax advantage. Intercompany transactions are conducted on arm’s length principles.

Where there is significant uncertainty or complexity in the law or the application of the law to our particular facts is uncertain, external advice may be sought in accordance with our internal framework.

The level of tax risk we
are prepared to accept

As with our broader business risk appetite we have a low tolerance towards tax risk (across all taxes) and do not make use of tax planning which does not support genuine commercial activity. We seek to minimize the risk of a dispute with HMRC by being open and transparent about our tax affairs.

The Board sees compliance with tax legislation as key to managing our tax risk. We understand the importance of tax in the wider context of business decisions and have processes in place to ensure tax is considered as part of our decision making process.

We have relationships with professional advisers that allow us to seek expert advice on specialist areas of tax. Our approach is to ensure we are compliant and understand our responsibilities with regards to tax, rather than looking for ways to aggressively avoid payment of tax.

Our approach to dealings
with HMRC

We seek to ensure that our engagement with HMRC is professional, open and honest, and undertaken in a spirit of cooperation. We aim to respond to information requests in a timely manner and ensure that access is given to all relevant information. We are proactive in resolving areas of disagreement. If there is uncertainty in the law or application of the law, we would reach out HMRC to obtain clarity.

We take care to ensure that our tax affairs are reported accurately. If we were to identify an error in a submitted tax return, we would seek to voluntarily disclose it, quantifying the effect of the error and paying any additional tax and interest that becomes due as a result.

[1] The purpose of this statement is to satisfy the UK legislative requirements of paragraph 16(2) Schedule 19 Finance Act 2016 in relation to the publication of tax strategy insofar as it affects our UK group.

Version date: 31 December 2018