Statutory & regulatory disclosures

At AtkinsRéalis, we strive to ensure that everything we do respects the highest standards to prevent modern slavery and human trafficking in order to meet our responsibilities to our people, our stakeholders and our society.

Our Principles

We are dedicated to protecting our employees, contractors, partners and clients from any form of modern slavery and human trafficking by promoting their wellness throughout all our activities in accordance with our core values: Safety, Integrity, Collaboration and Innovation.

Our Commitments

• Our Code of Ethics and Business Conduct lies at the heart of our Integrity program and sets the highest expectations for integrity in our business dealings across all our divisions, sectors, business units, regions and subsidiaries;
• Our Supplier Code of Conduct summarizes AtkinsRéalis' expectations and governing principles. These principles apply to all our suppliers, including our business partners;
• We strive to deal transparently and accurately with third parties. We want to work with third parties who share our values and culture of integrity and expect them to embrace and implement our best practices. As part of our initiative to identify and mitigate risk, we carry out due diligence on our third parties, including clients, suppliers and business partners;
• We undertake risk assessments when required to review our global supply chain practices in order to determine where our operations present a higher risk of modern slavery and human trafficking. Where we identify higher risks, we implement mitigation measures to manage them;
• To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training for employees in key positions. Our training actively explains human trafficking, how to recognize it and proposes compliance strategies to use internally and throughout the supply chains. This training is mandatory for the entire senior management team, as well as managers and professional staff in the Human Resources, Legal, and Integrity teams;
• Everyone at AtkinsRéalis has an important duty and a responsibility to report in good faith any known or suspected violation of our Code and its underlying policies, as well as any violation of applicable laws, rules or regulations. This includes any concerns about slavery and human trafficking. The reporting line is a secure reporting system operated by an independent third-party service provider;
• Lastly, we are committed to continuously improving our practices to combat slavery and human trafficking.

The President and Chief Executive Officer of AtkinsRéalis is responsible for implementing and monitoring this Policy and all employees and persons working on our behalf have the duty to share our commitments. Everyone is empowered to speak up and act to ensure that they are met.

Ian L.Edwards

Interim President and Chief Executive Officer

June 2019

The following companies are registered in England and Wales and have their registered office at Woodcote Grove, Ashley Road, Epsom, Surrey, England, KT18 5BW:

• ATK Energy EU Limited - 5613520
• ATK Energy EU Services Limited - 5462826
• Atkins ATK Limited 8850358
• Atkins ATK Investments Limited - 4404511
• Atkins Bennett (Holdings) Limited - 6546169
• Atkins Bennett Limited - 1797126
• Atkins Consultants Limited - 755613
• Atkins Consultancy Services Limited - 07470137
• Atkins International Holdings Limited - 6434611
• Atkins Investments UK Limited - 5313134
• Atkins Limited - 688424
• Atkins MSL Engineering Limited - 02581102
• Atkins Pension Trustee Limited - 7008492
• Atkins Rail Limited - 1026689
• Atkins ULC - 7465328
• Broomco (985) Limited - 3097696
• Confab Limited - 755561
• Faithful+Gould (Holdings) Limited - 2991351
• Faithful+Gould Limited - 2236832
• Kins Holdings Limited - 688415
• Parfab Limited - 755581
• AtkinsRéalis Co. Ltd. - 8772712
• AtkinsRéalis (GB) Limited - 9026118v
• AtkinsRéalis (GB) Holdings Limited - 10715197
• AtkinsRéalis Rail & Transit Limited - 3062722
• AtkinsRéalis Rail & Transit Verification Limited - 4847610
• AtkinsRéalis Transport Advisory Limited - 7577610
• AtkinsRéalis UK Limited - 2046233
• AtkinsRéalis UK Holding Limited - 7783146
• Ventron Technology Limited - 1036947
• WS Atkins (No. 3 Trustees) Limited - 2669866
• WS Atkins (Trustees) Limited - 2047084
• WS Atkins (UK Holdings) Limited - 3754382
• WS Atkins International Limited - 1091953
• WS Atkins Limited - 1885586
• WS Atkins Quest Trustee Limited - 3491253

The following companies are registered in Scotland and have their registered office at Kirkgate House, St Nicholas Centre, Upperkirkgate, Aberdeen, Scotland, AB10 1HW:

• Atkins Boreas Consultants Limited

AtkinsRéalis is a global, fully integrated, professional services and project management company with offices around the world including the UK.

This document is published in accordance with Schedule 19 to Finance Act 2016, applies to all of AtkinsRéalis' UK subsidiaries (“AtkinsRéalis UK”) and will remain in force from the date of publication until superseded.

Tax strategy for the financial periods ending 31 December 2018

This strategy is published on behalf of AtkinsRéalis UK in accordance with paragraphs 19(2) and 22(2) of Schedule 19 to Finance Act 2016.

Approach to Risk Management and Governance in Relation to UK Taxation

AtkinsRéalis UK is exposed to a variety of tax related risks including tax compliance and reporting, transactional and reputational. Its objective is to adhere to all relevant tax regulations and ensure tax compliance in each country in which it operates. In addition, AtkinsRéalis UK maintains internal policies and procedures to support its tax governance framework, which aligns with its wider risk and control framework.

Day-to-day responsibility for managing UK tax resides with AtkinsRéalis UK’s finance teams with support, as appropriate, from AtkinsRéalis' global tax team. The global tax team, led by the Senior Vice-President – Taxation, has the mission of supporting AtkinsRéalis' businesses, including the UK, to ensure compliance with and guidance on all tax matters and internal controls. The SVP – Taxation reports directly to the Chief Financial Officer who, by delegation of the Board of Directors, is responsible for AtkinsRéalis' overall tax strategy, supporting a governance framework and management of tax risks, with key tax issues being reviewed by AtkinsRéalis' Audit Committee.

Attitude Towards Tax Planning (So far as affecting UK taxation)

AtkinsRéalis UK has a responsibility to pay its appropriate share of tax in each of the jurisdictions, including the UK, in which it operates while, at the same time, balancing its responsibilities to its shareholders. AtkinsRéalis UK, in consultation with the global tax team, structures its businesses in a tax efficient manner while remaining compliant with all UK, and other country, applicable tax laws. Where there are alternative methods to achieve the same commercial results or business purpose, AtkinsRéalis UK will consider all relevant factors, including taxation, before deciding the best option. The UK Tax Strategy is in line with the wider AtkinsRéalis tax strategy.

On a case-by-case basis, where there is uncertainty as to how the relevant law should be applied, and depending on other factors such as materiality, uncertainty, application of recently enacted legislation or special technical challenges, AtkinsRéalis UK may seek external professional advice to support the decision making process.

Level of Risk in Relation to UK Taxation that AtkinsRéalis UK is Prepared to Accept

AtkinsRéalis UK assumes a conservative approach to tax risk and to the adoption of tax positions. Assessment of risk will take account of reputation, brand, governmental relationships, the benefit of certainty and tax authority relationships.

It is understood that there is always some level of tax risk associated with operating in multiple tax jurisdictions, frequent changes in tax laws and different tax authorities taking differing interpretations regarding the application of relevant tax legislation. It does however value certainty on future cashflows. It values and takes very seriously its reputation as a responsible tax payer not least as it recognises the potential impact of not complying on its ability to win work, particularly with Government bodies.

AtkinsRéalis UK is committed to the principles of openness, cooperation, communication and transparency in its approach to dealing with HMRC. All dealings with tax authorities, government officials and third parties should be undertaken in a professional, courteous and timely manner. In the event of an error arising, AtkinsRéalis UK will seek to remedy, disclose and proactively resolve, as soon as reasonably practical after identification as required by law.

AtkinsRéalis UK is committed to the framework for co-operative compliance as developed by the OECD and used by HMRC.