Tax Policy
This document sets out the tax strategy for the Vela Software UK Group (defined below) which are UK subsidiaries of Constellation Software Inc. (“CSI” or the “Company”) (the UK subsidiaries are hereafter referred to as the “UK Group”) and in making this available, fulfils the responsibilities of Schedule 19 FA2016.
The tax strategy is guided by the Company’s priority to create and maintain shareholder value, whilst balancing its commitment to compliance with laws and regulations. The Company does not seek to take an aggressive approach to tax.
CSI acquires, manages and builds vertical market software businesses that provide mission-critical software solutions.
The Company has multiple operating groups, focusing on different sectors/markets and operates in a highly decentralised manner. In most cases, the different operating groups act autonomously with individual finance teams holding operational responsibility for tax management. As well as this operational management, wider tax governance and oversight of the tax strategy is provided by the CSI head office tax team (“CSI Tax Team”). To successfully combine these areas, the Company strongly encourages a culture of consultation.
The tax strategy of the Company is regularly reviewed and updated. Commitment is given to keeping abreast of new developments and changes in the law across the wide range of taxes to which the group is exposed; namely corporate income taxes, employment taxes, indirect taxes such as duties and VAT, and withholding taxes.
How the UK group manages its tax risk
The UK Group’s approach to UK tax risk management is based on the principles of reasonable care and a conservative risk.
The UK Group actively monitors the controls and processes in place. A tax audit register is populated and regularly reviewed by the CSI Tax Team. Quarterly updates on ongoing tax audits are presented to the CSI audit committee, alongside a review of current global tax issues and risks facing the Company. As the UK Group continues to grow, tax governance maintains a high priority on the CSI Audit Committee’s agenda.
The Company employs specific personnel with a responsibility for ensuring tax compliance across the group. The CSI Tax Team are responsible for keeping abreast of legislative changes and their potential impact on the group. As part of the culture of consultation, bi-weekly tax team calls are held to monitor any tax risks arising, and internal memos are prepared and used as a basis for educating the wider tax and finance teams across the global group.
This consultative approach ensures that the UK group operates with a consistent tax strategy, despite its decentralised operating structure. Significant decisions with a material tax consequence are approved by the CSI Tax Team, ensuring appropriate oversight is maintained.
The UK group’s attitude to tax planning
The UK Group adheres to relevant tax laws, whilst seeking to operate in the most efficient manner by making use of exemptions and incentives put in place by relevant tax authorities and OECD principles. Where applicable, clearances are sought prior to engaging in any planning activities to ensure the group is compliant. Regular communication is upheld with the UK Group’s tax advisors’ both on a local level and a global group level. This ensures the finance teams are kept up to date on developments and changes. Most significant tax sensitive matters are discussed with tax advisors and advice sought where required.
Senior employees’ joint ownership in the company via share purchase plans means that all senior employees are aligned in terms of the priority to maintain shareholder value via avoidance of fines and penalties.
The UK Group and its tax risks
Oversight is provided by the CSI Tax Team, ensuring the tax strategy is implemented consistently across the Company. Consultation and approval by the board of the UK Group (“UK Board”) for all acquisitions and significant tax planning offers a robust monitoring of its implementation.
The UK Group does not adopt any tax planning arrangements which result in tax avoidance. The UK Group always looks to submit all UK tax returns on a timely basis, pay the appropriate tax when it is due and ensure appropriate documentation underlying the tax transactions is in place.
The UK Group’s relationship with HMRC
The UK Group respects the position of the tax authorities in the collection of tax revenue and will seek to engage and collaborate with the HMRC to ensure it pays the correct amount of tax.
The UK Group operates a policy of full disclosure in its dealings with HMRC. As part of this, the UK Group operates in an open, honest and transparent manner. Whilst the UK Group does not have a dedicated customer relationship manager at HMRC with whom they can engage, as far as possible proactive dialogue is sought. In particular, where possible advanced clearances are obtained in order to avoid unnecessary dispute, minimise tax risk and drive commercial efficiency.
As the UK Group grows, consideration is given to new tax risks arising and appropriate controls to mitigate these risks, which are discussed frequently with the UK Board as well as the relevant operating group managers. The Vela Software UK Group is made up of the following UK entities: A + W Software UK Limited, Airport Information Systems Limited, Atex Media Limited, Aura Corporation (UK) Limited, Carina UK Holdco Limited, Datamine Corporate Limited, Datamine International Limited, Datamine Software Limited, Figtree Systems Europe Limited, Finglow Limited, FOG UK Holdco Ltd., InfoAsset Limited, Infomill (Holdco) Ltd., Infomill Limited, Intelligent Retail Limited, Interica Limited, Island Pacific (UK) Limited, ITS Computing Limited, M.D.F. Database Solutions Ltd., Maron Systems Limited, Ascertra UK Ltd., Realis Simulation Limited, Seaplanner Limited, Searoc Group Limited, Searoc Limited, Tanygraig Limited, Vela APAC UK Holdco Ltd, Vela Software Limited, Vela UK Holdco Ltd, Vital Software Limited, Hexcuity Ltd., Ikon Intermediate Limited, Ikon Parent Limited, Ikon Science Limited, Rezatec (UK Services) Ltd., Tambla International Limited, Traveltek Group Holdings Limited, Traveltek Group Limited, Traveltek Ltd., Crescent One Software Limited, Adept Energy solutions Limited, Perigon Solutions Holdings Ltd., Perigon Solutions Ltd.
Accessibility
Vela Software International Inc., and each of its operating groups, business units and other operations are committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows and supports them to maintain their dignity and independence. Our organization values inclusion and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (Ontario) (“AODA”) and Ontario’s accessibility laws.
Accessibility for Ontarians with Disabilities Act
We are committed to working towards full compliance with current standards under the AODA. The purpose of AODA is to move organizations in Ontario forward on accessibility with the long-term goal of a barrier-free Ontario.
Visit the Government of Ontario website for more information about Accessibility for Ontarians with Disabilities.
Our Plan
Our Multi-Year Accessibility Plan outlines our strategy and the actions that have been taken to prevent and remove barriers to accessibility and to meet the requirements under the AODA. The Plan focuses on our initiatives in respect of the Accessibility Standards outlined in the Accessibility Standards Regulation, Ontario Regulation 191/11 that deal with: Information and Communications, Employment, Customer Service, and the Design of Public Spaces. For more information, download our Multi-Year Accessibility Plan.
Feedback
If you’d like to submit an inquiry or provide feedback regarding accessibility, please contact us:
- Vela People Operations: people@velasw.com
- Head Office: 360 Adelaide St W UNIT 500, Toronto, ON M5V 1R7
Accessibility Customer Service Plan
Purpose
Vela Software International Inc[1.1]. and each of its operating groups, business units and other operations (“Vela”) is committed to fostering a positive customer service environment in serving all customers, including those with disabilities. Vela will strive to provide services in a manner consistent with the principles of ensuring respect, self-reliance, inclusivity, and equitable access.
SCOPE
Applicability to Representatives
This policy applies to all Vela employees, contractors, and agents who interact with the public or third parties on behalf of Vela.
Service Animals
Provisions regarding guide dogs, service animals, and service dogs apply exclusively to the delivery of goods and services at Vela-owned and operated premises.
Policy Development
The requirements outlined in this policy also extend to individuals involved in creating or influencing Vela’s policies, practices, and procedures related to providing goods and services to the public or third parties.
DEFINITIONS[2.1][2.2]
- Assistive Device – is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that customers bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.
- Disability – the term refers to:
- a. any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
- b. a condition of mental impairment or a developmental disability;
- c. a learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- d. a mental disorder;
- e. an injury or disability for which benefits were claimed or received under an insurance plan established pursuant to applicable law; or
- f. such other conditions or disabilities as may be defined in applicable laws or standards (for example, accessibility or similar legislation or human rights codes).
- Guide Dog – is a trained working dog that has been at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.
- Service Animal – an animal is a service animal for a person with a disability if:
- a. the animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
- b. the person provides documentation from one of the following regulated health professionals confirming that the person requires the animal for reasons relating to the disability:
- (i) A member of the College of Audiologists and Speech-Language Pathologists of Ontario.
- (ii) A member of the College of Chiropractors of Ontario.
- (iii) A member of the College of Nurses of Ontario.
- (iv) A member of the College of Occupational Therapists of Ontario.
- (v) A member of the College of Optometrists of Ontario.
- (vi) A member of the College of Physicians and Surgeons of Ontario.
- (vii) A member of the College of Physiotherapists of Ontario.
- (viii) A member of the College of Psychologists of Ontario.
- (ix) A member of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario. Service Dog – a dog, other than a guide dog for the blind, is a service dog if:
- a. it is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability; or
- b. the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.
- Support Person – means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs or with access to goods, services or facilities.
PRINCIPLES
A. The Provision of Goods and Services to Persons with Disabilities
Vela will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:
- a. ensuring that all customers receive the same value and quality;
- b. allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk;
- c. using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
- d. taking into account individual needs when providing goods and services; and
- e. communicating in a manner that takes into account the customer’s disability.
B. The Use of Assistive Devices
Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by Vela, unless such devices present a safety risk or where accessibility may be an issue.
In cases where the assistive device presents a safety risk or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services. For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank may involve ensuring the customer is in a location that would be considered safe for both the customer and Vela and its employees, agents and contractors. Or, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.
C. The Use of Service Animals, Guide Dogs and Service Dogs
People with disabilities and accompanied by their guide dog, service dog or other service animals will be welcomed onto Vela’s premises.
There may be rare circumstances where, for reasons of health and safety of another person, allowing a person with a disability to enter the premise accompanied by a guide dog, service dog or other service animal needs to be considered. An example of such a situation may include where a person is allergic to animals and adversely affected if they are in close proximity to such an animal. If necessary, a risk assessment will be conducted by Vela.
The person accompanied by a guide dog, service dog or other service animal is responsible for maintaining care and control of the guide dog, service dog or other service animal at all times, including ensuring the safety and clean-up of the animal.
D. The Use of Support Persons
A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on Vela’s premises.
In situations where confidential information may be discussed, consent will be obtained from the customer, prior to any such conversation occurring in front of the support person.
E. Notice of Service Disruptions
In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, for example, wheelchair accessibility, reasonable efforts will be made for customers to be notified promptly or with advance notice.
Notifications will be clearly posted and will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
The notice will be placed in conspicuous places including at the point of disruption and entrances to the building as well as on Vela’s website.
F. Customer Feedback
Vela will provide customers the opportunity to give feedback on the provision of goods and services to people with disabilities. Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written or email) will be available upon request.
All feedback will be directed to Vela People Operations (People@velasw.com) or Local Human Resources.
Where possible, feedback will be addressed immediately. In some cases, feedback may require more review before an action is taken and Vela will respond as soon as possible in such circumstances.
G. Training
Vela will provide training to all employees and those involved in the approval of customer service policies, practices and procedures.
All Individuals will be trained including: Executives, Management and Non-Management employees and training will be provided to new employees within the first three months of their employment.
Training will include:
- a. A review of the purpose of any applicable accessibility or similar legislation and the requirements thereof;
- b. Vela’s policy and to provide accessible service to people with disabilities;
- c. Instructions on how to interact and communicate with people with various types of disabilities; and
- d. How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
Employees will also be trained when changes are made to this policy.
H. Notice of Availability
Vela will notify the public that accessibility policies are available upon request by visiting Vela’s website[3.1][PR3.2] or requesting a copy from your local Human Resources or Vela People Operations in a format that takes into account the person’s disability.