This strategy meets the requirements of Part 2 of Schedule 19 to the Finance Act 2016.

This strategy was formalised during the year ended 31 October 2024 and updated on 18th December 2024.  It has been approved by the Boards of Directors of Nomad Investco Limited, as the UK parent company of the New Era Fuels Group of Companies.

Approach to Risk Management and Governance

New Era’s objective is to maintain a robust framework to ensure appropriate controls and processes are in place to mitigate tax risk to acceptable levels. The company takes a proactive approach to tax and is compliant with all applicable tax legislation and considers HMRC guidance. Key aspects of this framework include:

• Establishing and maintaining processes and controls to ensure tax compliance and effective risk mitigation.
• Assigning roles within the company to oversee tax responsibilities and decision-making.
• Seeking external third-party support and advice in situations where in-house tax knowledge or expertise is insufficient.
• Regular reviews of tax processes and controls to ensure alignment with compliance and legal changes.

This approach ensures New Era effectively manages its tax affairs while maintaining transparency and accountability.

Attitude to Tax Planning

New Era is committed to observing all applicable laws and regulations and acting fairly in all tax matters. The company’s tax planning strategy is guided by the following principles:

• Paying the right tax, in the right place, at the right time.
• Maintaining year-round processes and controls to ensure tax awareness is high among key employees.
• Ensuring tax planning activities align with both the letter and the spirit of the law.
• Managing and monitoring the company’s tax position proactively throughout the year.
• Leveraging third-party support to confirm adherence to tax law and HMRC guidance, always in a fair and non-aggressive manner.

By fostering an environment of transparency and fairness, New Era’s approach to tax planning reflects its commitment to ethical business practices.

Level of Risk New Era is Willing to Accept

New Era’s appetite for tax risk is low. The company’s policy is to minimise uncertainty and ensure compliance through the following measures:

• Paying the correct amount of tax at the correct time.
• Seeking external advice when uncertain about the appropriate tax treatments for specific transactions or scenarios.
• Implementing rigorous review processes to identify and mitigate potential risks.

This cautious approach ensures the company’s tax affairs remain compliant, minimising exposure to financial and reputational risks.

Approach of New Era Towards HMRC

New Era is committed to fostering a collaborative and transparent relationship with HMRC. The company’s approach includes:

• Responding promptly and effectively to any correspondence or queries from HMRC.
• Engaging in open and constructive communication with HMRC to resolve any issues or discrepancies.
• Ensuring compliance with HMRC’s guidance and requirements through proactive management and monitoring.

By prioritising collaboration and transparency, New Era aims to build and maintain a positive working relationship with HMRC, reflecting its commitment to responsible tax practices and maintaining a low risk rating.

Compliance

By publishing its tax strategy applicable with effect from the year ended 31 October 2023, New Era has complied with its duty under paragraph 16(2) of Schedule 19 to the Finance Act 2016.