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UK Tax Strategy Policy

Modine Tax Strategy Policy
Published March 15, 2019

Business Overview

Modine Manufacturing Company and affiliates (“Modine” “we” “our” or “the Company”) specializes in thermal management systems and components, bringing heating and cooling solutions to diversified global markets.  Modine is a leading provider of engineered heat transfer systems and high-quality heat transfer components for use in on- and off-highway original equipment manufacturer vehicular applications.  In addition, we are a global leader in thermal management technology and solutions for sale into a wide array of commercial, industrial, and building heating, ventilating, air conditioning, and refrigeration markets.

A publicly traded company on the New York Stock Exchange, Modine is a global company headquartered in Racine, Wisconsin, United States.  Modine operates on five continents, in 20 countries, and employs approximately 11,700 persons worldwide.

Company Tax Strategy

The Company seeks to meet its United Kingdom and global tax obligations through utilizing a consistent approach to determine tax liabilities on a worldwide basis by adhering to OECD principles and local tax laws and regulations. We strive to align our tax strategy with the underlying substance of our business operations, and provide value for our shareholders through claiming credits, exemptions and incentives in addition to reducing the risk of double taxation.  Our Chief Financial Officer is ultimately responsible for the Company’s tax strategy, with approval and oversight from the Company’s Audit Committee and Board of Directors.  This document is published by all United Kingdom group entities in compliance with their duties under Schedule 19 of the Finance Act 2016 to publish a tax strategy for the fiscal year ending March 31, 2019.  

Risk Management

As a Company with global operations we are exposed to a variety of risks, which include tax risks due to: the complexity and subjectivity of international tax laws and interpretation of such laws; uncertainty due to continuous changes to local tax laws and regulations where we have business operations; and application of tax laws to new transactions due to business growth in new markets and jurisdictions.  The Company’s Tax Department works closely with appropriate business personnel to identify potential tax risks.  Where appropriate, the Company will obtain external expert advice to reduce or eliminate potential tax exposures.  The Company has implemented controls or standard practices, which are updated annually, to assist with meeting our tax obligations. 

Tolerance of Tax Risks

The Company consistently evaluates its tolerance for tax risk while complying with United Kingdom and global tax obligations.  We are focused on aligning our tax strategy with our underlying business operations and instituting a consistent approach to determine our global tax liabilities. 

Attitude Towards Tax Planning

The Company provides tax planning to assist with supporting the business operations in an efficient manner.  We are focused on appropriately reflecting revenue by the functions performed and risks assumed within each jurisdiction.

Approach to Dealings with the HMRC

The Company is committed to maintain an open and transparent relationship with the HMRC.  This is achieved through our professional demeanor and prompt response to questions and inquiries, and the Company’s continued focus to comply with the United Kingdom tax rules and regulations.