UK TAX STRATEGY

For UK purposes, this policy is published by Graham Packaging European Services Limited. This policy is being published in December 2017 in compliance with paragraphs 19 and 22 (as applicable) of Schedule 19 UK Finance Act 2016.

We recognize our responsibility to comply with the law in respect of our obligations including corporate income taxes, employment taxes, social contributions, property taxes, import and customs duties, and indirect taxes.

Compliance, Controls and Governance

We are committed to complying with tax reporting obligations in the UK, and the other jurisdictions where we operate.

Oversight and governance of UK tax matters is established through internal review and approval procedures by appropriate levels of management including members of Tax leadership and the relevant UK entity's board of directors. This oversight and governance includes obtaining external advice, as and when required. These responsibilities are delegated, with appropriate oversight by the Board of Directors, in accordance with our enterprise risk management framework.

Tax Planning and Risk

Our global tax team partners with our businesses to provide tax planning and advice that aligns to our business operating strategy, enhances value and is in compliance with the relevant tax rules and regulations. We do not engage in artificial tax arrangements that lack economic substance. We evaluate potential options resulting from business transactions with a focus on tax efficiency and compliance. We are committed to the arm's length standard in transfer pricing and OECD guidelines for international tax matters. We have a low tolerance for tax risk and reject planning opportunities that are not in line with our responsibility to comply with the law. Where uncertainty exists, and when appropriate, we seek clarification from external advisors and/or governmental authorities.

Relationship with Tax Authorities

We are committed to engaging with the tax authorities in the UK and other countries in which we operate in a professional, courteous, honest and collaborative manner regarding all tax matters. In the event a tax authority disagrees with our views on the appropriate tax treatment of a given item, we will work constructively to try to resolve the issue timely through appropriate methods of dispute resolution. We seek to be a valued partner to governments and advocate for tax legislation that provides clarity and encourages innovation and growth.