The Compleat Food Group

Corporate Tax Strategy

The Compleat Food Group tax strategy for the year ending 31 March 2026

Introduction

This document sets out the tax strategy for The Compleat Food Group of companies and their approach to conducting their UK tax affairs and dealing with UK tax risk as required by paragraph 16(2) of Schedule 19 of the Finance Act 2016. The Compleat Food Group is headed by Quantum Topco Limited and includes its subsidiaries and investments (“the Group”).

Scope

The strategy applies to Corporation Tax, Customs and Excise Duties, Employment Tax, Indirect Taxes, Stamp Duty Land Taxes, and any other tax liabilities that the Group is liable pay and report to HM Revenue & Customs (HMRC) as set out in paragraph 15(1) of said Schedule.
Group’s tax strategy is to ensure that it complies with all tax laws wherever it does business and that it pays all taxes that it is legally required to pay when they fall due.

Approach to risk management and governance arrangements

Executive responsibility for the delivery of tax management is with the Chief Finance Officer (“CFO”) who also acts as the Senior Accounting Officer (“SAO”) for the Group and ensures that tax is properly considered during decision making. The day-to-day implementation and management of the strategy is managed by the Group’s Tax Manager who reports any significant tax matters arising to the CFO. The Board is appraised of these tax matters through regular reporting at the Audit and Risk Committee meetings.

The Board fully supports to apply professional diligence and care in the management of all risks associated with tax matters and to ensure that governance and assurance procedures are appropriate.

The Group is committed to the following objectives when managing their tax affairs:

  • Tax value: Efficiently manage the “tax burden” arising from its business activities, in compliance with all the relevant laws and obligations and with the principles and purposes of the tax system.
  • Risks and reputation: Control and manage tax risks and protect the reputation of the UK Companies through appropriate policies, procedures, organisational solutions and communication tools, including appropriate internal audit testing of such controls.
  • Tax compliance: Ensure that the Group acts with integrity and taxes due are correctly determined, respecting the timing and the requirements associated with them, to avoid disputes with the tax authorities.
  • Promotion of a virtuous corporate culture: Promote awareness to the values – transparency, honesty, correctness and compliance with the relevant laws and regulation; at all levels within the organisational structure.
  • Relations with the tax authorities: Establish relations with the tax authorities based on good faith and transparency with the aim of enhancing long-term relationships; ultimately leading to being recognised as a reliable counterpart to establish open and collaborative relationships.

Tax planning

Tax is an important consideration in strategic and operational decision-making processes. The objective of the Group’s tax planning activities aims to support the commercial needs of the business by ensuring that the Group’s tax affairs are performed in a tax efficient manner whilst remaining fully compliant with all relevant laws and regulation.

The Group maximise shareholder value by using incentives and reliefs where appropriate to reduce the tax costs of conducting the Group’s business activities, albeit in a manner consistent with the objectives set out in the risk management section in the Tax Strategy.

The Group does not utilise tax havens for the purpose of tax avoidance or financial secrecy.

The Group does not engage in tax planning arrangements which are without commercial substance, or if the arrangements will potentially impact the Group’s reputation, brands, corporate and social responsibilities, or its future working relationship with the tax authorities.

The Group does not undertake tax practices or strategies that could be perceived as intended to erode the tax base or artificially transfer profits.

The Group does not undertake transactions, establish business relationships or implement corporate structures with the prevailing purpose of tax savings, in the absence of economic substance or other valid nonmarginal reasons.

Approach to tax risk

Effective risk management is paramount for the Group and underpins its business strategy to strive to achieve “certainty” on the tax positions it adopts. The Group’s appetite for risk (including tax risk) is a carefully calibrated part of the business model aligned to the strategic and corporate objectives.

Diligent professional care and judgement will be employed to assess tax risks (in relation both to the UK and to all other jurisdictions) in order to arrive to rational conclusions on how those risks should be managed. Where there is uncertainty as to the application or interpretation of tax law, appropriate written advice evidencing the facts, risks and conclusions may be obtained from third party advisers to support the decision-making process.

The Group takes the view, that whilst managing tax is a complex process, involving many different areas of the business, reducing tax risk to an acceptably low level is entirely feasible by ensuring that the overall governance procedures, including the internal control framework is robust and operating effectively.

The Group adopts a low tax risk approach and is committed to paying the right amount of tax at the right time.

Approach toward dealing with HMRC

We are committed to maintaining an open, transparent and constructive relationship with HMRC, we follow these core principles when engaging with HMRC:

Openness and transparency


We provide clear, accurate and timely information to HMRC, ensuring full disclosure on relevant matters. Where uncertainties arise, we proactively explain our position and the underlying commercial rationale.

Constructive engagement


We seek to resolve issues collaboratively wherever possible, recognising HMRC as a key stakeholder. Our objective is to avoid disputes by addressing queries promptly and engaging in early dialogue when required.

Professionalism and courtesy


All interactions with HMRC are handled by appropriately qualified members of the tax team, reinforcing strong governance, with daytoday tax affairs are managed by the Group Tax Manager under Executive oversight from the CFO.


Compliance with the spirit and letter of the law


Our dealings with HMRC reflect our broader commitment to compliance, ensuring that the Group pays the correct amount of tax at the right time, consistent with our stated principles.


Escalation and governance


Material HMRC matters are escalated in line with internal governance processes and, where appropriate, are reported to the Audit & Risk Committee. This ensures oversight, accountability and alignment with the expectations embedded in our annual approval process for the Group Tax Strategy.

Contribution to the UK economy

An assessment of a Group’s contribution towards the UK economy typically focuses on Corporation Tax, however this only reflects a small proportion of the overall fiscal contribution of a Group operating in the UK.

The Group makes significant other tax and duty payments as part of its normal operations. This includes Employer’s National Insurance Contributions, the Apprenticeship Levy, Business Rates, Customs Duty, Fuel Duty and Value Added Tax. The Group is a significant employer and operate across the UK, providing significant employment opportunities which generate income taxes and helps to support the communities in which the Group operates.

Board’s Approval

This document is approved by the Board of Directors and annually reviewed and updated.

Publishing this document on the Group’s website is regarded as complying with the duty under Paragraph 16(2) of the Schedule.

Tom Riley
Chief Financial Officer
March 2026