he following information is provided for the Syensqo UK Group for the year ended 31 December 2023 in compliance with the requirements of paragraph 19(2), Schedule 19 Finance Act 2016. The publication of this tax strategy is regarded as complying with the Group’s duty under paragraph 16(2), Schedule 19 Finance Act 2016.
Tax Governance
Syensqo is committed to the highest governance principles and promotes a sustainable culture of long-term value creation. Fulfilment of the Group’s tax obligations is key for the reputation and reliability of Syensqo.
Syensqo closely follows international tax developments, including international case law, discussions about the taxation of multinational enterprises, and publications by Non-Governmental Organisations (NGOs) and other organisations. Syensqo’s objective is to be fully compliant with national and international tax legislation, including the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations issued by the OECD (“OECD Guidelines”)
Syensqo’s tax team of skilled tax experts ensure compliance with the group’s policies and procedures. The Global Tax Director reports to the Group Controller. The Group also takes external advice if and when needed, for example benchmarking analysis to support transfer pricing arrangements.
Relationship with tax authorities
Syensqo facilitates an open and positive dialogue with tax authorities. Where appropriate, the group may enter into Advance Pricing Agreements to ensure upfront clarity and eliminate uncertainty about the tax implications of certain potential positions.
Transfer Pricing
In line with the OECD Guidelines, tax laws in all major countries worldwide require that prices of “controlled transactions” (i.e. transactions between related parties) shall be “arms-length”. Accordingly, Syensqo has developed Transfer Pricing Policies & Procedures based upon the OECD Guidelines. These Transfer Pricing policies are prepared annually for each Group legal entity that requires such documentation.
Syensqo UK operations
Syensqo has substantial presence in the United Kingdom, which makes a significant contribution to the UK Exchequer in relation to taxes e.g. tax and national insurance contributions on benefits/expenses, employer national insurance contributions, duties, and taxes collected on behalf of other businesses and employees in respect of VAT, income tax and employee national insurance contributions.
Syensqo UK has a team of professionally qualified and experienced employees. The UK entities comply with the Senior Accounting Officer (SAO) requirements. Compliance is further supported by Internal Audit department reviews. The UK legal entities publish externally audited financial statements which reflect the tax position of Syensqo’s UK operations.
As part of doing business in the UK, the group has tax losses which originate from operational activities in the past and from contributions to pension funds to reduce pension deficits. As a result, Syensqo is estimating that it will not have any corporate income tax obligations in 2023. UK entities benefit from claiming R&D tax credits and from other tax incentives and exemptions. The attitude of the group towards tax operations so far as affecting UK taxation is to ensure that the group meets its taxation obligations.
The acceptable level of risk in relation to UK taxation is consistent with the group’s tax policies and procedures and its approach to tax. Syensqo carries out effective risk management and seeks external tax advice in areas of tax uncertainty or complex matters in order to meet its tax obligations.
Syensqo’s UK entities are transparent in their dealings with HMRC, fully cooperate with any enquiries in relation to all taxes and ensure any inadvertent errors are fully disclosed to HMRC as soon as reasonably practicable after being identified.
In March 2022, Solvay Group announced plans to separate the group into two independent publicly traded companies. EssentialCo would comprise leading mono-technology businesses including Soda Ash, Peroxides, Silica and Coatis, which are reported as the Company’s Chemicals segment, as well as the Special Chem business. SpecialtyCo would comprise the Company’s currently reported Materials segment, including its high-growth, high-margin Specialty Polymers, its high-performance Composites business, as well as the majority of its Solutions segment, including Novecare, Technology Solutions, Aroma Performance, and Oil & Gas. In the context of the proposed split, the SOLVAY name is maintained for EssentialCo, a leader in essential chemistry while SYENSQO becomes the new name of SpecialtyCo, which will explore the future of science.
Solvay SA/NV held its Extraordinary General Shareholders’ Meeting in Brussels on 8 December 2023 where the partial demerger was approved by the shareholders. The separation of Solvay into two independent companies, the new Solvay and Syensqo, was confirmed and became effective at midnight on this date.
Background
This statement is made on behalf of the UK subsidiaries of Syensqo S.A. of Belgium (‘Syensqo’) for the financial year ending 31 December 2024. This includes: Cytec Engineered Materials Ltd (02851421); Solvay Solutions UK Ltd (00036833); and Oldbury Energy Solutions (UK) Ltd (13535021).
This statement is made under the provisions of the Modern Slavery Act 2015 (the ‘Act’) and with reference to the guidelines issued from time to time by the Home Office. It sets forth steps taken by Syensqo during the financial year to minimise the risk of any slavery or human trafficking, (together, ‘Modern Slavery’) taking place in any part of its business or in any of its supply chains. Modern Slavery encompasses slavery, servitude, human trafficking and forced labour.
Syensqo is committed to acting ethically, and to maintaining a fair and honest business environment for its employees, customers, suppliers and the public in general. This includes a commitment to respecting and supporting human rights with regard to its employees, the communities in which it operates and its business partners as expressed in the internationally recognised standards, many of which are referenced in Syensqo’s policies. Syensqo operates a number of initiatives to combat Modern Slavery which are further explained below.
Our commitment to combatting Modern Slavery
Syensqo Code of Business Integrity
Syensqo has adopted its Code of Business Integrity which lays out the core values and principles of how Syensqo strives to do business in an ethical way. To ensure that ethical conduct is always at the core of Syensqo’ employees’ daily conduct, all employees must take the annual mandatory training and obtain a passing score on the test pertaining to the Code of Business Integrity and its core values. Syensqo Code of Business Integrity is easily accessible on Syensqo intranet and on its external website in the 34 countries where the Group operates and translated into 19 languages.
The Group has concomitantly implemented a Speak Up program accessible to employees and third parties (including contractors, suppliers and customers) 24/7 through a dedicated phone line or on the Syensqo website. Reports can be made anonymously or not, as decided by the reporter. All reports are reviewed by a member of the Ethics & Compliance team composed of dedicated professionals, in accordance with the Speak Up policy, and in full respect with the confidentiality and non-retaliation principles.
Human Rights Principles and Policies
Syensqo is strongly engaged in respecting human rights and acting responsibly and diligently to avoid any violation of human rights or any adverse impact on or abuse of such rights. To this effect, in July 2024 Syensqo published its first Human Rights Progress Report which is accessible on the Syensqo website.
Syensqo is a member of the UN Global Compact and as such has committed to the 10 principles ensuring compliance with the universal principles concerning human rights, working conditions, respect for the environment and anti-corruption in all of its operations worldwide, including in countries that have not yet ratified these conventions.
Syensqo’s commitment to these principles is further evidenced by its global framework agreement with the IndustriALL Global Union. By adhering to this agreement, Syensqo commits to respecting international social standards as defined by the International Labour Organization and complying with the principles of the United Nations Global Compact as indicated above.
The agreement also highlights Syensqo’s commitment to the OECD’s Guidelines for Multinational Enterprises and reinforces Syensqo’s existing commitments in terms of health & safety at work, the management of risks related to its activities as well as environmental protection and human rights.
As part of its dedication to the 10 principles, Syensqo also recognizes the importance of, and is committed to complying with, the forced and indentured labour laws and regulations of the jurisdictions in which it conducts business.
Furthermore, Syensqo’s commitment to human rights is overall reinforced in Syensqo’s Human Rights Policy which incorporates well-known internationally recognized standards such as the UN Universal Declaration of Human Rights, and which goes through an approval process involving the highest governance level of the Group.
The Better Life program, the third area of Syensqo’s ESG principles, is based upon two goals: (i) no gender pay gap; and (ii) paying a living wage to 100 % of our employees by 2026.
Syensqo’s Human Rights Policy and Speak-Up policies were revised in July 2024. In addition, Syensqo adopted in July 2024 an Ethical Recruitment & Employment Practices Policy which encompasses ethical recruitment and employment principles reflecting Syensqo’s common practices in different regions. The revised policies were approved by Syensqo’s Executive Leadership Team as well as the Board of Directors. These policies are available on our website.
Furthermore, Syensqo’s One Dignity program includes the Inclusion and non-discrimination policy. We train and engage our employees around fairness and inclusion matters.
Syensqo has also implemented a Conflict Mineral Policy which has also been revised in July 2024. Although Syensqo is not involved in the mining, processing or import of, tin, tantalum, tungsten (3TG) and gold and does not have direct supply relationships with mines or processors, Syensqo is eager to contribute to the transparency and protection of human rights along the supply chain of 3TG by taking into account the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as well as the standards of the EU Regulation on Conflict Minerals.
Supply Chain Due Diligence
As advancing sustainable development through human rights is an integral part of the Group strategy, Syensqo is committed to creating stable, reliable and transparent relationships with its suppliers based on shared values including adherence to human rights principles. Syensqo expects its suppliers and sub-contractors to respect these fundamental principles in the same manner.
To that end, Syensqo has adopted a Supplier Code of Business Integrity (SCOBI), requiring its suppliers/contractors’ written commitment (via contractual clause or separate acknowledgement) to abide to the principles of the SCOBI which include human rights principles described above, such as not engaging in any form of forced or compulsory labour. As a general principle, Syensqo’s suppliers have either i) reviewed and agreed to abide by the SCOBI; or ii) certified that they have their own Code of Conduct with principles similar to the SCOBI. Non-compliance with such written commitments may conduct to the termination of the business relationships to the extent that the non-compliance issue is not diligently remedied by the suppliers/contractors. Syensqo has launched a contractors’ training program, to ensure that they are fully aware and aligned with the Group SCOBI, and expects this to be completed at its UK sites by the end of 2025.
Syensqo is a member of the Together for Sustainability (TfS) initiative. TfS is an initiative of multinational leading chemical companies which have joined forces to develop and implement a global supplier engagement program that assesses and audits, through an independent process, sustainability sourcing practices with respect to the Environment, Labour and Human Rights, Health and Safety, and Fair Business Practices (including a CSR assessment on Corruption & Bribery). Syensqo’s suppliers are assessed and/or audited on corporate social responsibility criteria depending on their risk profile and/or strategic importance. Syensqo purchasing agreements include a provision allowing Syensqo to assess its suppliers’ compliance with, among other laws, human rights laws, including forced and compulsory labour laws. The inclusion of this clause allows Syensqo to identify potential gaps and have an in-depth discussion with its suppliers regarding their compliance with human rights laws and the maturity of their compliance programs. Syensqo undertakes these risk assessments and operational reviews on a periodic basis, with the frequency depending on the supplier’s risk profile. Syensqo also performs a due diligence process of its suppliers through screening tools and questionnaires.
Syensqo’s suppliers must also ensure that their employees and contractors can anonymously report non-compliant behaviors with the SCOBI through the Speak Up line. A specific entry for “Human Rights” is integrated in the Syensqo Speak Up hotline, in addition to all other topics referenced in the Code of Business Integrity and the SCOBI.
The Ethics & Compliance team at Syensqo works closely with the Procurement team and other business entities. The team is responsible for defining and updating the Code of Business Integrity and the applicable compliance policies, and for deploying effective communication and training related to these policies. Any violation of these policies are investigated by Syensqo in order to implement appropriate actions, including but not limited to disciplinary actions, mitigation actions and discontinuation of business relations, in accordance with applicable laws and existing contractual agreements.
Ben Moore
UK Country Director
17th June 2025
Modern Slavery Statement (Print Versions)
Cytec Engineered Materials Ltd’s Gender Pay Gap Statement
At Cytec Engineered Materials Ltd (“CEM”), we are confident that our male and female employees who work in the same or similar jobs are paid equally. For the year 2024, we do have a mean pay gap of -10.4% for reasons set out below.
Figures for 2024 show that we have an average gender pay gap of -10.4%. This means that the average hourly rate is 10.4% higher for women. In context, this is partly related to the smaller number of women working at CEM (81) compared to men (418). The highest paid employee this year at CEM was female, as was the lowest paid employee. 23.4% of the highest paid roles at CEM were occupied by women and 36% of all women were in this top pay quartile.
Manufacturing has been a historically male-dominated industry, and this is reflected in the make-up of the business, as significantly more men are employed at CEM than women. However, women are represented at every pay quartile, highlighting that both genders have the opportunity to occupy various roles and responsibilities at CEM. The majority of women in CEM are employed at management level and this has led to the gender pay gap being in favour of women.
As a company, we remain committed to promoting careers within manufacturing to both males and females, and to evaluating individual job applicants solely on their merits without any regard to sexuality, race, age, gender identification and religion.
From children looking to the future, to adults well-established in their careers, CEM recognises that equality of opportunity for all genders is vital, and a worthwhile task.
Cytec Engineered Materials Ltd’s Gender Pay Gap Statistics
The mean gender pay gap in hourly pay is -10.4%
The median gender pay gap in hourly pay is -16%
The mean bonus gender pay gap is -29.6%
The median bonus gender pay gap is -552.3%
The proportion of males and females receiving a bonus payment is: Male 86.2% and Female 87.1%
The proportion of males and females in each pay quartile:
Upper Quartile
Men 76.6%
Women 23.4%
Upper Middle Quartile
Men 84.8%
Women 15.2%
Lower Middle Quartile
Men 88.8%
Women 11.2%
Lower Quartile
Men 84.8%
Women 15.2%
Ben Moore
Director
26 March 2025