This UK tax strategy is published on behalf of HRT UK Limited and its UK subsidiary entities (“Pandrol”, “the Group”) for the financial year ending 31 December 2024. This tax strategy applies to all UK entities within the Pandrol business group and satisfies the requirements of Paragraph 19(2), Schedule 19 of the UK Finance Act 2016.
Pandrol forms part of the wider Delachaux Group, an international industrial group. This tax strategy is aligned with the overarching principles set out in the Delachaux Group Tax Policy.
Pandrol considers the timely submission of tax filings and payments a key business priority. We are committed to acting with integrity, transparency and respect in all dealings with tax authorities. Employees are expected and encouraged to work in an open and collaborative manner with tax authorities in every jurisdiction in which Pandrol operates, including the UK.
1. Our approach to tax risk management and governance
Pandrol is committed to managing tax risks responsibly and ensuring compliance with all relevant UK tax obligations. The Group maintains appropriate policies and internal controls to identify, assess and manage tax risk.
Internal tax and finance professionals are actively involved in day-to-day business decisions to ensure tax is properly considered, and tax risk and potential exposure is minimised. Where appropriate, external advisers are engaged to support compliance and interpretation of complex or evolving legislation.
The Group regularly performs a mapping of the tax risks borne and the tax opportunities available in the countries it operates in, including the UK. On the basis of these mappings the Group puts in place systems of tax risk management and controls, which establish specific procedures for identifying and monitoring as well as mitigating and/or eliminating tax risks. Pandrol’s approach to tax governance is aligned with the principles set out in the Delachaux Group Tax Policy, providing consistency across the wider group. This strategy is reviewed annually and updated as needed to reflect any changes in regulation or business activity.
2. Our attitude to tax planning
Pandrol is committed to paying the correct amount of tax at the correct time in each jurisdiction in which we operate. Our business decisions are driven by commercial rationale, not by tax outcomes.
In accordance with our Ethics Code we do not engage in aggressive or artificial tax planning and do not adopt arrangements that could damage our reputation or undermine trust with tax authorities.
Pandrol will make use of available tax reliefs and incentives where they are consistent with the intent of the legislation and the commercial substance of our activities, and reflect the operational and economic reality of its business. Where needed, we seek professional advice to ensure that any planning undertaken is fully compliant with both the letter and the spirit of the applicable tax laws.
3. Our level of tax risk
Pandrol has a low appetite for tax risk. We aim to ensure that our tax positions are robust, well supported, aligned with our values of transparency and compliance and support our overall commercial and economic strategy.
Where interpretation of tax law presents uncertainty, we adopt a prudent approach, consult experts where necessary, and maintain appropriate documentation to support our positions.
4. Working with HMRC
Pandrol is committed to maintaining a professional and transparent relationship with HMRC based on mutual respect. We seek to engage constructively and cooperatively, disclosing relevant information clearly, accurately and on a timely basis.
Where appropriate, we may seek clearance or guidance from HMRC on areas of complexity or uncertainty to ensure the correct treatment is applied.
This UK tax strategy satisfies the requirements of Paragraph 19(2), Schedule 19 of the UK Finance Act 2016 in respect of the financial year ending 31 December 2024. This document was reviewed and approved by the Board of Directors of HRT UK Limited on the 6th of November 2025.