Oppenheimer Europe - UK Tax Strategy

Introduction

Oppenheimer is a leading investment bank and full-service investment firm that provides financial services to businesses and financial institutions. Oppenheimer Europe Ltd is a UK affiliate of Oppenheimer & Co. Inc. which offers institutional and corporate clients a superior and high quality customized service. As a business we are committed to complying with tax law and practice in all the territories that we operate, including the UK. Ensuring that we pay the correct amount of tax in a timely manner is one of our core responsibilities, meaning that all relevant facts and circumstances are disclosed to the tax authorities in an open and constructive manner.

Our strategy applies to Oppenheimer Europe Ltd with the following principles and key components:

1. Commitment to Compliance
We take compliance seriously and are committed to comply with the law and practices in the UK, the Isle of Jersey and Switzerland. Paying the correct amount of tax in a timely manner is paramount to ensuring we meet all our compliance requirements with full disclosure of all relevant facts and circumstances to the tax authorities, claiming reliefs where available. We utilize experts with country tax knowledge to assist in filing income tax returns.

2. Tax Planning
Relevant tax law is adhered to and we seek to minimize the risk of disputes and uncertainty. We are conservative in our tax planning and do not take aggressive tax positions. Entities and branches are established in jurisdictions suitable to drive our business activities taking into consideration the regulatory environment and requirements. We engage in efficient tax planning that supports the commercial and economic substance of our business and reflects the tax laws of the country within which we operate. We do not engage in planning of artificial tax arrangements.

3. Tax risk management
Given the nature of our business, from time to time interpretation of tax law may give rise to risks in relation to our compliance arrangements. We proactively identify, assess and manage tax risks and account for them appropriately. Risk management measures over compliance processes and appropriate internal controls are implemented to monitor the processes. Where there is uncertainly or complexity in relation to risk, we may seek external advice.

4. Relationships with tax authorities
Transparent discussions and negotiation is how we engage with the tax authorities, seeking to build and sustain relationships. We are prepared to litigate where we disagree but we will first work collaboratively with the tax authorities to resolve disputes to achieve agreement and certainty.

5. Governance
The Board is responsible for oversight of tax compliance, for risk management and for the systems and internal controls in place to manage risk. The Board conducts reviews into the effectiveness of controls. This UK Tax Strategy is approved by the Board. This tax policy is aligned with our Ethics Code and is approved and owned by the CEO and overseen by the Board.