This Tax and Customs Compliance Policy of Naten SAS (“nocnoc”) applies to its operations and those of its subsidiaries, in conjunction with nocnoc’s General Terms and Conditions for Sellers, nocnoc’s Know Your Clients Policy and nocnoc’s Anti-Money Laundering and Counter-Terrorism Financing Corporate Manual.
- POLICY OBJECTIVES
nocnoc recognizes the importance of tax and customs compliance in our operations. We are committed to managing our tax affairs by applying best practices, acting transparently and fulfilling our tax obligations responsibly and efficiently. In addition, we promote cooperative relations with governments and seek to avoid significant risks and unnecessary disputes.
nocnoc also recognizes the importance of correct tax collection for local society and the development of the countries where we do business. We manage all tax matters in accordance with applicable law and support measures that contribute to transparency, predictability and equal treatment regarding tax matters.
To this end, we have developed this Policy, which aims to provide clear guidelines and procedures for all employees, agents and business partners, with a view to ensuring tax and customs compliance, as well as combating smuggling, contraband and counterfeiting in all the company’s activities.
- TAX COMPLIANCE
3.1. REGISTRATION AND DECLARATION
nocnoc commits to maintaining accurate, reliable and complete tax and customs records and declarations, in accordance with the deadlines established by the competent authorities. All data provided must faithfully reflect the original commercial transactions and comply fully with applicable legislation.
To ensure compliance with applicable laws and regulations, it is essential that the use of special customs benefits and regimes is accompanied by adequate control and accurate documentation, guaranteeing the correct classification of goods and the accuracy of information regarding import and export procedures.
3.2. TAX PAYMENTS
The company is committed to correctly calculating and due payment of all taxes and duties levied on its operations within the stipulated deadlines.
We continuously monitor changes in tax and customs legislation to ensure the proper application of rates, accuracy of calculations and the use of tax incentives, where applicable.
Similarly, we require our business partners to comply with applicable tax and customs laws.
3.3 SPECIAL CUSTOMS REGIMES AND BENEFITS
nocnoc will use special customs benefits and regimes in accordance with applicable laws and regulations, maintaining strict control and proper documentation. Goods will be correctly classified, and information related to import and export procedures will be accurate.
- GOVERNANCE AND RESPONSIBILITY
The Senior Management of nocnoc is responsible for promoting a culture of compliance, providing resources and exercising leadership in complying with tax and customs laws, as well as designating those responsible for implementing, disseminating and monitoring policies.
The Compliance department is responsible for implementing and developing this Policy, as well as carrying out other functions such as prevention, regulation, education, monitoring, management, control, consultation and deliberation.
All nocnoc employees are responsible for understanding and applying the procedures established in this policy, as well as adhering to applicable tax and customs laws and reporting suspicious activities through appropriate channels.
- TRAINING AND AWARENESS
nocnoc is committed to providing regular training on tax, customs and anti-smuggling and counterfeiting laws to all employees, including understanding individual responsibilities, identifying risks and preventive measures. nocnoc is also committed to disseminating information on good tax and customs practices to its business partners, as well as requiring them to duly comply with tax regulations.
- MONITORING AND AUDITING
nocnoc will conduct periodic internal audits to assess compliance with established policies, identify gaps and propose improvements. Furthermore, nocnoc will constantly monitor changes in tax and customs legislation, updating procedures as necessary.
- PERIODIC REVIEW AND UPDATING
This policy will be periodically reviewed to ensure its effectiveness and compliance with constantly evolving laws and regulations. Any necessary updates or revisions will be made, and all employees, agents and business partners will be promptly informed of any changes.
In case of violation of this policy, appropriate disciplinary measures will be applied, taking into account the seriousness of the breach. Such measures may include formal warnings, suspensions, dismissals or contract terminations, without prejudice to other measures provided for in nocnoc’s General Terms and Conditions for Sellers, nocnoc’s Know Your Clients Policy and nocnoc’s Anti-Money Laundering and Counter Terrorism Financing Corporate Manual.
In addition to internal measures, nocnoc will fully cooperate with competent authorities in investigations related to illicit activities.
- FINAL PROVISIONS
Changes to established work processes must be approved by the Legal Department and duly documented.