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                                    67 About Strategy and Governance Our People Our Business Our Outcome AppendixContracts with business partners are thoroughly and diligently vetted by the legal department, including a review of potential issues related to antitrust and competition law. The legal department is in regular contact with business teams and, as needed, conducts training on antitrust and competition law-related aspects relevant to day-to-day business to ensure compliance with antitrust and competition laws. Between 2019 and 2021, for example, we conducted a total of four global online training courses and one regional training course for three Business Units. The target group for these sessions comprised managers of the three Business Units, who are regularly involved in contract negotiations. Further internal training sessions have been conducted in Hong Kong, Australia, and Malaysia. The legal team also recently received training from an external legal counsel.DKSH performs regular audits to verify compliance of its contracts with the standards set forth in the Contract Manual (including those which relate to competition/antitrust law).In 2023, no legal actions were filed against DKSH for breach of anti-competition law or violations of antitrust and monopoly legislation.%u2023 GRI 2-27, GRI 206-1Responsible Tax PracticesTaking a Responsible Approach to Taxes As a multinational company, we drive sustainable economic growth in markets around the world through the economic value we create. In turn, this has a positive impact on our stakeholders, such as providing returns and dividends for our shareholders, salaries for our employees, and tax payments to local governments.Our company is committed to complying with tax laws in all markets where we operate and to paying taxes in the markets where revenue is generated. Intra-Group transactions are carried out under market conditions and are supported by transfer pricing documentation. All inter-Group transactions are subject to the %u2018arm%u2019s length%u2019 principle described in the Organization for Economic Co-operation and Development%u2019s (OECD) Transfer Pricing Guidelines. We are cooperative and transparent in our interactions with local tax authorities and strive to achieve a swift resolution to tax matters. DKSH has a Group Tax Policy in place, which is reviewed annually by the Chief Financial Officer (CFO) and Head of Tax. The policy is approved by the Board of Directors. Any proposed amendments are subject to the Board%u2019s approval. The Group Tax Policy is aligned with the Group%u2019s Code of Conduct and applies to all tax and finance professionals who deal with tax matters within the Group.The policy is aligned with our business strategy and commercial activities. It ensures that we pay the right amount of taxes that are legally due in the jurisdictions where we do business. For example, when we consolidate acquired entities or reorganize the legal structure, our primary goal is to minimize compliance costs and optimize taxes where possible in accordance with local tax laws. Such restructuring plans are properly articulated in internal memos and submitted to relevant internal stakeholders for approval in accordance with the Limit of Authority policy. We rely on internal expertise of our regulatory, tax, finance, secretarial, and legal teams while also seeking external advice, where needed, to ensure we fully comply with local regulations. In particular, the Group Tax Policy sets out five core guidelines. It ensures compliance by stipulating our tax compliance process flow and the obligations of each entity within the Group. Our tax policy is available internally on our finance portal to ensure all employees have access.Tax RisksWe take tax risks very seriously, so we have established processes to manage and monitor these risks. The Group Tax Policy is aligned with the Group%u2019s broader risk and control framework. Apart from communicating regularly with Country Finance Managers, the Group Tax team prepares a monthly tax report for the CFO and senior management. This report updates the recording and tracking of reported tax risks and all forms of tax fluxes and losses, payments, etc. This monthly report is a management tool to oversee and control the Group%u2019s tax affairs. We have also created a tax dashboard, which highlights the most known material tax risks for DKSH and tracks the corporate tax return submission compliance rate and tax audit status. The dashboard also shares transfer pricing benchmarking data within the Group and is accessible 24/7.The Board of Directors oversees DKSH%u2019s tax risk management processes. The Board and the Audit Committee receive annual updates on tax opportunities and major tax risks. Our Group Tax Policy also sets out an appropriate escalation process. Tax matters requiring significant judgements or decisions are escalated to the Country Management Teams and/or the Senior Executive Team. Any major tax risk that materializes or reaches a significant level is communicated to the Audit Committee and the Executive Committee. Employees and external parties can report concerns about unethical or unlawful tax-related behavior using the Integrity Line, our online reporting platform. More information on this channel can be found in the Combatting Corruption chapter.%u2023 GRI 207-1, GRI 207-2, GRI 207-3
                                
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