UK Tax Strategy

BMI Group UK Tax Strategy
2025

Our UK tax strategy has been approved by the Board of Directors of BMI Group Holdings UK Limited (‘’BMI’’) and applies to BMI and its controlled entities in all countries where we operate (“BMI Group”). We regard the publication of this document as complying with our duty to publish a Tax Strategy in relation to UK taxation under paragraphs 19 and 22 of Schedule 19 of the UK Finance Act 2016 for BHP’s financial year 2025.

BMI Group is a part of Standard Industries company, the largest roofing and waterproofing manufacturer in North America. Together, we are the largest roofing and waterproofing business in the world. We deliver innovative roofing and waterproofing systems, designed to transform the way people live and work.

Tax Vision

Our overall vision for tax is to support our businesses whilst ensuring compliance with our regulatory and legal obligations. Our strategic tax objectives below ensure we achieve our vision for tax alongside our wider commercial objectives.

Approach to Risk Management and Governance

The Board of Directors approves our Tax Strategy and Principles and holds ultimate responsibility for supervising our risk management framework and internal control systems.

Executive responsibility for tax is delegated to the Chief Financial Officer (CFO). Day-to-day accountability for managing tax risks and implementing internal controls rests with the BMI Group Tax Director.

To ensure tax is considered in all commercial decisions, our regional tax professionals (including for UK operations) are embedded within the business. This structure provides real-time tax advice and integrates risk management directly into our operations.

Risk management is embedded across our critical business activities and processes through the following framework:

• Risk identification: we operate a continuous process to identify, assess, and monitor known, new, and emerging tax risks.
• Level of acceptable tax risk: Our internal governance processes do not set rigid quantitative levels for risk, but mandate that all tax positions taken must be robust, sustainable, and defensible. We ensure all decisions align with the commercial substance of our business.
• Risk materiality: we rely on our local teams to consider the likelihood and impact of each area of risk and escalate as appropriate. They are supported by central processes to ensure consistent judgement and appropriate escalation.
• Risk escalation: Our processes define rigid approval and escalation points that ensure the appropriate decision makers, up to and including the Board.
• Risk controls: We design and implement robust controls for all material risks. The effectiveness of these controls is periodically reviewed and tested.
• External validation: Where appropriate, we engage external advisors to validate our internal positions and provide independent assurance on complex or material risk areas.
  

Attitude Towards Tax Planning

Our approach to tax planning is to ensure all business transactions are consistent with their commercial and economic substance. We are committed to creating a sustainable business and do not engage in contrived arrangements.

We fully support and are committed to complying with the OECD's international tax reforms (BEPS), including the Pillar Two (GloBE) rules. In line with this, all our international transactions are priced in compliance with the OECD Transfer Pricing Guidelines, based on the arm’s length principle.

We utilise legitimate government-sponsored tax incentives and reliefs in the manner intended by law. However, we do not undertake transactions where the sole or main purpose is to achieve a tax advantage.

We believe paying the appropriate amount of tax is a vital contribution to the societies where we operate. This approach, which balances shareholder value with wider stakeholder interests, is fully aligned with our overall business vision. To ensure compliance we seek independent external tax advice in relation to material uncertain tax positions.

Approach to Dealings with HMRC

We act with integrity when engaging with tax authorities to support positive and sustainable relationships. Where possible, for the purposes of obtaining certainty of our tax positions, we engage with tax authorities regarding the application of the tax law and to identify and resolve any disagreements on a timely basis.

We interpret legislation using supporting guidance and, should any uncertainty arise, we work with tax authorities to obtain rulings or guidance on future tax risks and the interpretation of tax law.

Furthermore, we seek independent external tax advice in relation to uncertain tax positions to help reduce the risk of disagreements with tax authorities. If any disputes were to arise, we would work cooperatively with tax authorities to try and achieve an early agreement and resolution.

Our internal stakeholder relationships also are important to us and our people are essential to the successful delivery of our tax strategy.