Turner Legal (EMEA) | Warner Bros. Discovery

Turner’s Legal Documents for the EU include:

Accessibility
Applicant Help
Advertising Policy – International
Distribution Information
Modern Slavery Act Statement
TAG Anti-Fraud Certification
Section 172 Statements
UK Tax Strategy

Accessibility Statement

Turner is an Equal Employment Opportunity employer committed to providing access to all individuals who are seeking information from our Web site.

If you are using assistive technology (such as a screen reader, etc.) and experience difficulty accessing information, or if you experience issues with the submission of your application for a posted vacancy found on Turner’s Career Page please contact Turner at WebsitesAccessibility@turner.com. Please state the nature of the accessibility problem. If the accessibility problem involves a particular Web page, please include the URL (Web address) of the page.

If the issue pertains to application submission, indicate in the email the Location, Job Title, and Requisition Number for the position(s) you are interested in applying. Please attach your resume and cover letter (as applicable). Notification will be sent to you once your resume is uploaded for the position(s) of interest.

We will try to respond to your accessibility concerns promptly.

Applicant Help

Is this job for you?

When you see a job you’re interested in, carefully review the job description and determine if you meet the minimum requirements. Those requirements are a must and it wouldn’t be productive to apply if you do not meet them.

In addition, you should review any “preferred” requirements that may be indicated. The more your background and skills are aligned with preferences and the requirements, the better the chance that you’ll be a good match with the company and vice versa.

Our recruiters review resumes for required experience, skills and abilities, education requirements and relocation consideration. They must identify the best candidates from the applicant pool; therefore those that do not meet the minimum requirements may not be contacted. Ensure that positions you are applying for are a match or a natural next step. The roles you have previously held should support and complement the position for which you are applying.

Turner Broadcasting System, Inc. Online Advertising Standard Terms and Conditions

1. APPLICATION The terms and conditions of this contract between Turner Broadcasting System, Inc. and/or any of its subsidiaries or divisions (“TBS”) and Agency and Advertiser shall apply to any purchase made by Advertiser, or by Agency on behalf of Advertiser, for the placement of advertising on any of TBS’s websites.

2. REPORTING AND INVOICING TBS will track ad delivery through its own reporting from its designated first party ad server. For contract based media buys, TBS will invoice Agency based on agreed upon contracted rate and payment schedule. For performance based media buys, TBS will report and invoice based on actual impressions delivered. Invoice reconciliation will occur at the request of the Agency where the difference between TBS’s reported impressions and the Agency’s third party ad server’s reported impressions is greater than 10%.

3. CANCELLATION AND TERMINATION Agency may cancel the Insertion Order (“IO”) with 30 days prior written notice. Notwithstanding the foregoing, except in the case of material breach by TBS, neither Agency nor Advertiser may cancel this Insertion Order if this Insertion Order incorporates inventory across multiple TBS media, (web and broadband are defined as one medium for the purpose of this provision) and/or the Insertion Order includes a Special Sponsorship Investment by Agency/Advertiser. TBS may terminate this contract at any time (i) upon material breach by Agency and/or Advertiser, (ii) if TBS considers that performance of this contract is in breach of applicable law, or (iii) if, in TBS’s reasonable opinion, the credit of Agency (or, where Agency is the Company, of Agency and/or Client) is impaired. Upon such termination, all unpaid accrued charges shall immediately become due and payable. Termination shall be without prejudice to any right or remedy accruing prior to the date of termination. TBS is not liable for any special, consequential or incidental loss or monetary damages of any type.

4. SHARE OF VOICE/SPONSORSHIPS Those media buys based on share of voice shall be billed on a flat fee. There is no impression guarantee for share of voice based media buys, regardless of the share of voice percentage. All sponsorships shall also be billed on a flat fee basis.

5. OMISSION OF DELIVERY If, as a result of a major news event, act of God, force majeure, public emergency, labor dispute, restriction imposed by law or other governmental order, technical failure or for any other cause beyond TBS’s reasonable control, TBS fails to serve the advertising materials referenced in the applicable IO (“Ad Materials”), TBS shall not be in breach hereof, but TBS shall be authorized to substitute a reasonably satisfactory date to serve the Ad Materials and if no such date is available the charges allocable to serving such Ad Materials will be waived.

6. ADVERTISING MATERIALS All Ad Materials shall be furnished to TBS and delivered to it at Agency and/or Advertiser’s sole cost and expense. Such materials, together with any instructions pertaining thereto, shall be delivered not less than five (5) business days in advance of the scheduled delivery. At TBS’s discretion, TBS may require Agency/Advertiser to submit a script, storyboard, and/or rough cut of the Ad Materials for TBS’s review up to ten (10) business days in advance of the first scheduled delivery date. All materials furnished shall not be contrary to the public interest, shall conform to TBS’s then existing program and operating policy and quality standards, and are subject to TBS’s prior approval and continuing right to reject, suspend the delivery of or require editing of such materials. Agency and Advertiser jointly and severally represent and warrant, and take full responsibility to ensure, that (i) they are authorized and have obtained all necessary clearances, permissions, approvals, authorizations, rights and licenses necessary for TBS’s delivery of all elements contained in the Ad Materials for uses of all types in all geographical areas; (ii) all Ad Materials comply with all applicable privacy laws and codes and laws, rules, and regulations relating to advertising content, and any industry codes or rules by which Advertiser or Agency may be bound; (iii) no Ad Materials contain any spyware, adware, or any other software designed to covertly gather user information through the user’s internet connection; (iv) no Ad Materials contain any unauthorized embedded interactive triggers or other software that automatically diverts users from any TBS site or service and (v) all Ad Materials are accurate and all claims contained therein have been substantiated. TBS will not be liable for loss or damage to such Ad Materials.

In the event that TBS or its designee creates or contributes to the Advertising Materials and Advertiser and/or Agency approves such materials, Advertiser shall indemnify TBS from any liabilities or expenses which may arise out of use of same. Advertiser shall acquire no rights to the Advertising Materials created by TBS or its designee.

7. INDEMNIFICATION Agency and Advertiser will jointly and severally indemnify and hold harmless TBS from and against all claims, demands, debts, obligations or charges (including reasonable attorneys fees and disbursements) which arise out of a result from (i) Agency’s and/or Advertiser’s breach of any obligations, representations, or warranties hereunder or (ii) serving the Ad Materials, preparation of the Ad Materials, or contemplated delivery of materials furnished by or on behalf of Agency or Advertiser or furnished by TBS at their request for use in connection with the Ad Materials. The provisions of this paragraph shall survive the termination or expiration of the applicable IO.

8. GENERAL

(a) In the event of any inconsistency between the terms of an IO and these Terms and Conditions, the terms of the IO shall prevail, on the condition that the IO has been mutually agreed and is signed by both parties.

(b) Subject to the terms and conditions hereof, TBS will make best efforts to display the Ad Materials covered by the applicable IO according to the terms set forth therein. TBS shall have no obligation to display the Ad Materials for the benefit of any person other than Agency and Advertiser or for a product or service other than that agreed upon by the parties.

(c) Agency and Advertiser acknowledge and assume full responsibility, jointly and severally, for payment of all advertising services and related expenses incurred, ordered, and provided on behalf of the Advertiser by TBS. Payment for all advertising services provided by TBS shall be due and payable within thirty (30) days from the date of the invoice. Interest shall be added to all amounts thirty (30) days or more past due at the highest legal rate permitted under the law of these terms and conditions, calculated from the date of invoice. Should timely payments not be made, Advertiser and Agency agree to pay all costs of collection, including attorney’s fees of fifteen percent (15%) and court costs, if collected by law or through an attorney at law.

(d) In the event that actual Deliverables for any advertising campaign fall below guaranteed levels, as set forth in the IO, and/or if there is an omission of any ad (placement or creative unit), Agency and TBS will endeavor to agree upon the conditions of a make-good flight of advertising, either in the IO or at the time of the shortfall. If no make-good can be agreed upon, Agency may execute a credit equal to the value of the under-delivered portion of the IO for which it was charged.

(e) Any discrepancy or disagreement by Agency or Advertiser with any services provided hereunder, or any related services, or the amount charged for the same, shall be reported to TBS in writing within thirty (30) days from the date of invoice relating to the same, time being of the essence. Failure to report in writing such discrepancy or disagreement within such time shall constitute a waiver of any claim by Advertiser and Agency for any such discrepancy or disagreement.

(f) Unless otherwise agreed upon by the parties, no cash discounts, volume discounts or other discounted rates will apply.

(g) This contract shall be construed in accordance with the laws of England.

(h) In the event of a breach hereof by TBS, the exclusive remedy of Advertiser and Agency therefor shall be a credit for substituted advertising time of equal value.

(i) The party executing this contract on behalf of Advertiser and Agency acknowledges that it has the authority to do so that they have taken all steps necessary and appropriate to authorize the execution and performance hereof and that by its execution has caused both Advertiser and Agency to be bound by the terms hereof.

Distribution Information

Turner International India Private Limited

Turner distributes its channels in India through Turner International India Pvt Ltd. The terms on which Turner International India Pvt Ltd distributes those channels are set out in the attached documents.

Reference Interconnect Offer of Turner International India Private Limited for digital distribution platforms, effective from 29 December 2018

Intimation regarding appointment of IndiaCast Media Distribution Pvt Ltd by Turner International India Pvt Ltd as its exclusive authorized agent in India, effective April 1, 2018

REFERENCE INTERCONNECT OFFER (“RIO”) OF TURNER INTERNATIONAL INDIA PRIVATE LIMITED –FOR DIGITAL ADDRESSABLE PLATFORM(S)

Information pertaining to Turner Channels in terms of [a] Clause 6(1) of The Telecommunication (Broadcasting and Cable) Services (Eighth) (Addressable Systems) Tariff Order, 2017 dated 03-March-2017 (as amended) and [b] Clause 34 of the Telecommunication (Broadcasting and Cable) Services Standards of Quality of Service and Consumer Protection (Addressable Systems) Regulations, 2017 dated 03-March-2017

Modern Slavery Act Statement for Turner Broadcasting System Europe Limited, a U.K. subsidiary of Warner Media, LLC

Warner Media, LLC (“WarnerMedia” or the “Company”), a leading media and entertainment company with businesses in television networks and film and TV entertainment, is formed and headquartered in the United States. WarnerMedia and its operating segments — Turner Broadcasting System, Inc., Home Box Office, Inc., and Warner Bros. Entertainment Inc. — have operations in the United States and, through subsidiaries, internationally, including in the United Kingdom. For more information on the Company’s structure and business, please visit the Company’s website at warnermedia.com.

This statement has been made and adopted by Turner Broadcasting System Europe Limited (“TBSEL”) pursuant to Section 54 of the Modern Slavery Act of 2015 (the “Act”). TBSEL is a WarnerMedia subsidiary with operations in the U.K. that meet the criteria set forth in the Act. This statement has been approved by the TBSEL Board of Directors in respect of its business activities for the fiscal year ending December 31, 2021, and also applies to all subsidiaries of TBSEL which meet the criteria set forth in the Act.

Standards of Business Conduct

WarnerMedia is committed to conducting global business with high ethical and legal standards, including within its supply chain. That commitment begins with WarnerMedia’s Standards of Business Conduct (“SBC”), available at https://www.warnermedia.com/us/basic-page/ethics-and-compliance. The SBC apply to all Company employees and serve as a model for comparable codes of conduct that have been adopted at each of WarnerMedia’s businesses, including offices outside the U.S. The SBC stress the importance of abiding by the law, acting with integrity, being truthful, being transparent in our business dealings and putting the needs of our shareholders and customers first.

Ethical Sourcing and Supply Chain

In addition to the SBC, WarnerMedia has policies on specific topics to provide guidance to employees and suppliers, including to tackle slavery and human trafficking in our supply chains. For example, the Company has adopted ethical sourcing guidelines (“Guidelines”), which apply to suppliers from whom WarnerMedia group companies purchase directly and to whom WarnerMedia subsidiaries license images, brands and characters. The Company’s supply chains include suppliers based in many countries providing a range of products and services. The Company’s main supply chains include vendors of IT support, data centers, transmission and distribution partners, local production partners, software and technology contractors. WarnerMedia has reviewed these to consider where there are areas of risk in relation to Modern Slavery. WarnerMedia appreciates that some of these sectors are higher risk for modern slavery and exploitation.

The Guidelines establish expectations for the supplier’s business operations as they relate to WarnerMedia and its businesses and reflect our commitment to conduct business in an ethical manner and in compliance with applicable laws and regulations. More specifically, the Guidelines set forth the Company’s expectations with respect to, among other areas: (1) child labour, (2) involuntary labour, (3) coercion, abuse and harassment of supplier employees, (4) working hours and compensation, and (5) worker health and safety. WarnerMedia expects our suppliers to comply with the Guidelines.

WarnerMedia reserves the right to take any actions it deems appropriate to monitor and promote adherence to the Guidelines. Contracts with suppliers are periodically reviewed to confirm whether the Guidelines have been incorporated. Failure to comply with the Guidelines could lead to termination of the contract with the relevant supplier.

For more information, please visit https://www.warnermedia.com/us/basic-page/ethical-sourcing-and-supply-chain.

WarnerMedia believes in the value of collaborating and sharing information to improve responsible sourcing efforts across the globe. WarnerMedia’s businesses are members of various industry working groups, including the International Licensing Industry Merchandisers’ Association (LIMA) and the Toy Industry Association (TIA).

Training

WarnerMedia understands that a key component of an effective compliance environment is employee training and education regarding the rules and policies that apply to their business activities, as well as WarnerMedia’s commitment to ethical business conduct. Employees receive training on the SBC when they join the Company, as well as regular ethics and compliance training on laws that apply to our business activities. These training initiatives reinforce the Company’s commitment to compliance with laws and ethical behavior.

Reporting and Monitoring Misconduct

Employees are encouraged to report any misconduct or unethical behavior. WarnerMedia and its businesses provide multiple means of reporting concerns, including a HelpLine monitored 24-7, which enables anonymous reporting where permitted by local law. Third parties can also report concerns, including through the HelpLine (where permitted by local law). These various means of reporting are an important mechanism for us to track the effectiveness of our modern slavery and human trafficking policies and they are listed in the SBC and publicized to employees and business partners. WarnerMedia and its businesses encourage anyone to report in good faith issues about potential ethical, legal, regulatory, slavery, human trafficking or human rights violations. WarnerMedia will investigate allegations and take appropriate remedial actions. In 2021 WarnerMedia did not identify any incidents of modern slavery in our business or supply chains.

This Statement was approved by the Board of Directors of Turner Broadcasting System Europe Limited on 1 July 2022 and signed by Ellie Browne, a Director of Turner Broadcasting System Europe Limited.

Sourced Traffic Disclosure

Click here to access information about sourced traffic to Turner.com

Trustworthy Accountability Group (TAG) anti-fraud certified

Turner meets requirements for prevention and combating of online transaction fraud, including fraud detection, source identification, process transparency and building accountability. For more information, view the TAG Certified Against Fraud guidelines.

Turner Broadcasting System Europe Limited

Section 172 Statement for the Year Ended 31 December 2021

The Companies (Miscellaneous Reporting) Regulations 2018 (the “Regulations”) have been in force with effect from 1 January 2019. The Regulations aim to extend sustainable and responsible governance practice beyond listed companies to private limited companies. The Regulations require Turner Broadcasting System Europe Limited (the “company”) to report how the directors of the company (the “board”) have considered their duties under section 172 (“Section 172”) of the Companies Act 2006 (the “Act”) during the reporting period.

The duty under Section 172 is owed by the directors to the company. In the context of a group of companies, being the Turner group of companies, which is wholly owned by AT&T Inc., the company’s directors owe their primary duty to the company and not the parent company (though of course the parent company is considered as part of stakeholder engagement). The board recognises that the overall framework that Section 172 promotes is to drive the long-term success and economic viability of the company for the benefit of its sole shareholder and other key stakeholders.

For details of the issues, factors and stakeholders the directors consider relevant in complying with Section 172 of the Act, and the main methods the directors have used to engage with stakeholders and understand the issues to which they must have regard, refer to the Engagement with Employees Statement and Engagement with Suppliers, Customers and Others Statement below.

The long-term

The company and the board strive to create value for its shareholders in the medium and long-term and to take into account interests of their wider stakeholder base and the impact of their decisions on these stakeholders and their interests. In order to achieve this objective the company implements and makes decisions which are aligned with the core values and the set strategy of the Turner Group and the AT&T Group as a whole. In line with its purpose, the company’s aim is to maintain a successful and sustainable business for the benefit of its direct and ultimate shareholders and other stakeholders, with whom the directors and senior management formally consult. Throughout the reporting year, the company has made a number of strategic decisions as part of implementation of its business strategy. The principal decisions made by the board of directors included:

the grant of powers of attorney for human resources-related matters to appropriate group company HR executives
the preparation and approval of the company’s Modern Slavery Transparency Statement

Further detail of these strategic decisions can be found in the ‘Principal decisions’ section below.

The board of directors of the company consider long-term consequences of their decisions during their decision-making process. When making decisions the directors do consider detailed financial information, the key risk reporting and whether the relevant approvals have been obtained. These supplementary informal discussions allow the directors to make informed decisions with the interests of the key stakeholders of the company in mind.

Stakeholders

The board does not delegate its stakeholder engagement responsibilities to senior management and instead opts to make considerations for the company’s impacts on stakeholders collectively when making decisions. The board considers its employees, subsidiaries, customers, it’s shareholder and the Warner Media group as a whole to be its key stakeholders. The company also operates within WarnerMedia’s Standards of Business Conduct (SBC) which applies to all employees (including directors) and serves as a model for comparable codes of conduct. The SBC stresses the importance of abiding by the law, being truthful, being transparent in business dealings and putting the needs of shareholders and customers first. The board uses this as part of their guiding approach when making decisions.

The company engages with its employees to discuss employee-related matters and to provide information via various channels maintained by a dedicated internal team. This ongoing engagement and line of communication is enabled by use of employee surveys, group’s intranet, business performance updates and presentations, among other things.

The impact of this engagement is detailed in the following section.

Decision making process

Board meetings are usually held on an ad hoc basis as and when there are significant decisions to be approved. The board meeting process consists of an initial discussion of agenda items with supporting board packs containing pertinent information to the items at hand. This ensures that decisions are made on the basis of high quality information being reviewed. The board considers their Section 172 duties during each board meeting and these considerations are documented in the relevant minutes. Board papers are prepared to provide the board with the right levels of information to consider all relevant issues before making a decision and ensure consistency in the way the required information is presented to the directors ahead of each meeting. The board also holds a number of annual board meetings to approve the annual accounts for the company and its annual Modern Slavery Act Transparency Declaration.

To support effective decision-making of the board, the directors take into account various group-wide governance policies and practices, including the existing delegations of authority and powers of attorney, the Modern Slavery Act, WarnerMedia’s SBC, WarnerMedia’s Ethical Sourcing and Supply Chain Policy, and the company’s Supplier Code of Conduct when making decisions on behalf of the company, together with established practices. These sources also feed into culture which is expanded on below.

Culture

The company follows the culture set by WarnerMedia LLC which applies to all of its subsidiaries on a global scale. This culture is composed of a series of group policies and procedures that have been devised to promote the long-term sustainable success of the group whilst ensuring that risk is mitigated and reputation strengthened – the standardisation of ways of conducting business and ways of behaving creates a culture set from the top down. The board of the company is conscious of the WarnerMedia culture and they aim to consider the policies within it whenever decisions are being made, both at board level and during the normal course of business.

The company and the board of directors ensure that the policies outlined above are implemented in the business as part of group-wide strategy and make all decisions with sustainable growth in mind by continuously seeking ways to enhance relationships with its direct and ultimate shareholders, customers, employees, and other stakeholders. Through adopting and following the key policies and procedures the company is able to set a clear course for its business and fulfill its purpose in the long-term. The company’s culture and its values are further reinforced by training on how to adhere to the organisation’s policies and procedures and maintain a continuously high standard of business ethics and making sure that the working environment is built on mutual respect and tolerance. Details of the key strategic decisions and developments taken by the company and its board can be found in the ‘Principal decisions’ section below.

Training

The current directors of the company have held their positions for a number of years and is fundamentally familiar with their statutory duties under the Companies Act 2006. At present, there is no formal induction process for new directors as there have been no plans to introduce new directors to the board of the company. The company is, however, considering implementing comprehensive Section 172 duties and wider regulatory requirements training to support the board with their obligations as regulations continue the trend of being tightened. This would include periodic refresher training as well as relevant informative material including new developments being provided. company directors also, as employees of the WarnerMedia Group, are required to undergo annual training, including on the corporate culture and code of conduct.

Board composition

The current directors, in addition to their roles as statutory directors of the company, also occupy key positions within the wider organization such as CEO, CFO and Senior Legal officer and ensure ongoing oversight of various segments of the business. The level of seniority, extensive business and industry experience and in-depth understanding of the company’s and the wider organization’s affairs enable the directors to identify the key stakeholders of the company and to recognize the nature and extent of the likely consequences, including the long-term impact, of their decisions on these stakeholders.

Principal decisions

Principal decisions are defined as those which: (i) are linked to matters of strategic importance; (ii) are commercially material matters of financial or operational importance; and (iii) impact key stakeholders are reserved for the board and include:

dividends;
changes to key investments owned by the company;
substantial reorganisation projects;
business contracts above certain value;
changes to the company’s strategic objectives; and
matters that will substantially affect the company’s employees.

In making its decisions, the board is required to consider the outcome of any stakeholder impact assessment that has been undertaken to support it making that principal decision.

The principal decisions made during the year were:

The grant of powers of attorney for human resources-related matters to appropriate group company HR executives.	For the purpose of ensuring suitable and appropriate group company HR executives were empowered to represent the company in respect of HR-related matters, for efficient and appropriate dealings with employees.
The preparation and approval of the company’s Modern Slavery Transparency Statement.	As an appropriate company statement in accordance with the requirements of the Modern Slavery Act 2015.
Response to the COVID-19 Pandemic	The board considered the wellbeing, health and safety of its employees and contractors to be of paramount importance during 2021. It took steps to ensure that all employees and contractors could perform services remotely and that any work where a physical presence on the company’s premises was deemed essential could be done safely and in accordance with all laws and regulations in force. The company also conducted periodic surveys of employees to ensure that it had feedback on the impact of remote working and the company’s response to the pandemic, enabling it to continue responding effectively.
Liquidation of Turner OTT Limited	Following the wind down of the business based in the United Kingdom the company elected to liquidate its subsidiary Turner OTT Limited.

Stakeholder Engagement Statement

The Company considers its employees, suppliers, customers and its direct and ultimate shareholder to be its key stakeholders. The Company aims to build and maintain lasting relationships with its key stakeholders in the countries where it operates. The Company engages with its key stakeholders and considers their differing needs and priorities as an everyday part of its business and uses the input and feedback to inform its decision-making.

The table below describes how the directors have had regard to the need to foster relationships with its key stakeholders, in a business relationship with the Company, and the effect of that regard, including on the key decisions by the Board of directors taken during the reporting period:

Stakeholder Group	Importance	What Engagement took place?	What influence did this have on the Board’s decisions?
Employees	For details on how the Company has engaged with Turner Broadcasting System Europe Limited’s employees, how the directors had regard to those employees’ interests, and the effect of that regard, including on the decisions taken during the reporting period, refer to the Engagement with Employees Statement in the directors’ report (details of which are set out below).
Suppliers	To receive a clearly stated set of requirements to understand the Company’s needs and expectations. To be part of a fair and respectful tender and supplier selection process. To be part of an ongoing supplier relationship based on mutual respect and treating each other as valued business partners.	The Company, through the Board, adopted and established a number of group-wide and Company-specific policies to ensure fair and respectful treatment of its actual and potential suppliers for the Company and its subsidiaries. The policies clearly set out the Company’s expectations in relation to the quality of supplier products and services delivered and requirements that need to be met to ensure smooth and mutually beneficial business relationships. The list of relevant policies includes: Supplier Code of Conduct WarnerMedia LLC’s Standards of Business Conduct Security Policy	The Board is provided with information and reports on significant transactions by relevant employees and the procurement team. The information received supports effective decision making by the Board and considering long-term consequences on relationships with suppliers and their interests.
Customers	To provide the Company’s customers with top quality services. To demonstrate excellence in service delivery on a global scale and build trust between customers and the Company. Ensuring that the products and services licensed by the Company meet the needs and expectations of both consumers and Customers. Ensuring that personal data is kept in a secure environment and only for the duration and purposes the data is collected for.	The Company adopted and established a number of group-wide and Company-specific policies aimed at ensuring ongoing security of personal data, and continued confidence and trust of our customers. The list of relevant policies includes: Supplier Code of Conduct WarnerMedia LLC’s Standards of Business Conduct Security Policy Data Protection Policy Examples of ongoing engagement includes Approving budgets for product development and new service launches; Discussion and approval of terms of engagement with customers including the rights granted to content and services.	The Board is provided with regular reports on renewals of, and negotiations for new, supplier agreements by key employees and business unit heads. The information received supports effective decision making by the Board and considering long-term consequences on customers well-being and satisfaction
Direct and Ultimate Shareholder	The Company is 100% owned by Turner Broadcasting System Europe Holdings Limited and is a subsidiary of WarnerMedia LLC, which is in turn wholly owned by AT&T Inc.	The Board of directors of the Company, in conjunction with senior management, make recommendations to declare dividends, coordinate and evaluate the amount of dividend and impact at local level, which is then approved by the Board. The Company reports to its direct shareholder and WarnerMedia LLC on a regular basis in the form of its financial performance, operational issues, business reviews, business plans and strategic plans as well as risk reporting.	The Company’s strategy is to pursue strategic growth to create long term value for its shareholder and the group as a whole The receipt of this information, and the coordination with Group functions, supports the Board’s delivery of the Company’s purpose and strategy and assists with the implementation of the Board’s business plan.

Employee Engagement Statement

The Company identifies its employees as its key stakeholders and recognizes their importance to the long-term success of the Company. Throughout the year, the directors engaged with the Company’s employees in various ways to provide information on matters of concern to them as employees, to take into account their views in making decisions likely to affect their interests, to encourage involvement in the Company’s performance and to achieve a common awareness on the part of all employees of the financial and economic factors affecting the Company’s performance.

Table below sets out the detail of how the Company engaged with its employees and how the directors have had regard to the employees’ interests and the impact of these considerations on the key decisions taken by the Board during the reporting period. Further detail of these decisions, and in particular the Principal Decisions in relation to the employees, are discussed in the s172 Statement below.

Employees’ interests	How have the directors engaged with employees	How the directors have had regard to employee interests, and the effect of that regard
Providing information on matters of concern to them as employees and to achieve an awareness of factors affecting the performance of the Company, such as annual results, strategy, sustainability, training, annual performance related bonus scheme, career development, office environment and diversity and inclusion.	The Board has adopted much of the engagement mechanisms operated by WarnerMedia LLC. The various policies put in place by WarnerMedia Group (including the Company) are applicable to all subsidiaries in the group and these act both as a type of engagement with employees and as guidance for how the Company should engage with its employees. Group wide developments in terms of performance, sustainability, strategy, diversity and inclusion is managed directly by WarnerMedia and this is promulgated by the Board of the Company. More localised forms of engagement are carried out by senior management and groups of employees including: Training programmes are managed by HR and include both career/management oriented training and more holistic well being during “make you matter” weeks. Employees are kept informed by ad hoc updates on key developments, changes to strategic objectives and priorities, updates on progress of ongoing projects, updates in regard to the merger of WarnerMedia and Discovery to form Warner Bros. Discovery, updates and announcements in respect of the Covid-19 pandemic. Employees also regularly receive emails and notifications from the Group as part of the Company’s wider engagement strategy.	The Company is committed to valuing the diversity of its people and it monitors and reports internally on aspects such as gender and ethnicity. The Company and the group are strongly dedicated to ensuring equal pay for all workforce across the organization regardless of gender, race or ethnic origin, disability, gender, sexual orientation, age, religion or belief and regularly report on a legal entity level.
Being consulted so that the views of employees can be taken into account in the decisions made by the directors which are likely to affect their interests.	There have been surveys on the employees attitude to working from home and returning to the office during the COVID 19 pandemic.	The views of employees and workers on returning to the office environment during the pandemic have been taken into account in the Company’s response to managing the workforce and ensuring that working from home is effective and sustainable.

Turner Broadcasting System Holdings (Europe) Limited

Section 172 Statement for the Year Ended 31 December 2021

The Companies (Miscellaneous Reporting) Regulations 2018 (the “Regulations”) have been in force with effect from 1 January 2019. The Regulations aim to extend sustainable and responsible governance practice beyond listed companies to private limited companies. The Regulations require Turner Broadcasting System Holdings (Europe) Limited (the “Company”) to report how the directors of the Company (the “Board”) have considered their duties under section 172 (“Section 172”) of the Companies Act 2006 (the “Act”) during the reporting period.

The duty under Section 172 is owed by the directors to the Company. In the context of a group of companies, being the Turner group of companies, which is wholly owned by Warner Media, LLC (“WarnerMedia”), the Company’s directors owe their primary duty to the Company and not the parent company (though of course the parent company is considered as part of stakeholder engagement). The Board recognises that the overall framework that Section 172 promotes is to drive the long-term success and economic viability of the Company for the benefit of its sole shareholder and other stakeholders.

The long-term

The Company and the Board strive to create value for its shareholders in the medium and long-term and to take into account interests of their wider stakeholder base and the impact of their decisions on these stakeholders and their interests. In order to achieve this objective the Company implements and makes decisions which are aligned with the core values and the set strategy of the Turner Group and the AT&T Group as a whole. In line with its purpose, the Company’s aim is to maintain a successful and sustainable business for the benefit of its direct and ultimate shareholders and other stakeholders, with whom the directors and senior management formally consult. Throughout the reporting year, the Company has made a strategic decision as part of the implementation of its business strategy.

The Board of directors of the Company consider long-term consequences of their decisions during their decision-making process. When making decisions the directors do consider detailed financial information, the key risk reporting and whether the relevant approvals have been obtained. These supplementary informal discussions allow the directors to make informed decisions with the interests of the key stakeholders of the Company in mind.

Stakeholders

The Board does not delegate its stakeholder engagement responsibilities to senior management and instead opts to make considerations for the Company’s impacts on stakeholders collectively when making decisions. The Board considers its subsidiaries, it’s shareholder and the Warner Media group as a whole to be its key stakeholders. The Company also operates within WarnerMedia’s Standards of Business Conduct (SBC) which applies to all employees (including directors) and serves as a model for comparable codes of conduct. The SBC stresses the importance of abiding by the law, being truthful, being transparent in business dealings and putting the needs of shareholders and customers first. The Board uses this as part of their guiding approach when making decisions.

Decision making process

Board meetings are usually held on an ad hoc basis as and when there are significant decisions to be approved. The Board meeting process consists of an initial discussion of agenda items with supporting board packs containing pertinent information to the items at hand. This ensures that decisions are made on the basis of high quality information being reviewed. The Board considers their Section 172 duties during each Board meeting and these considerations are documented in the relevant minutes. Board papers are prepared to provide the Board with the right levels of information to consider all relevant issues before making a decision and ensure consistency in the way the required information is presented to the directors ahead of each meeting. The Board also holds a number of annual board meetings to approve the annual accounts for the Company.

To support effective decision-making of the Board, the directors take into account various group-wide governance policies and practices, including the existing delegations of authority and powers of attorney, Modern Slavery, WarnerMedia’s SBC, WarnerMedia’s Ethical Sourcing and Supply Chain Policy, and the Company’s Supplier Code of Conduct when making decisions on behalf of the Company, together with established practices. These sources also feed into culture which is expanded on below.

Culture

The Company follows the culture set by WarnerMedia LLC which applies to all of its subsidiaries on a global scale. This culture is composed of a series of group policies and procedures that have been devised to promote the long-term sustainable success of the group whilst ensuring that risk is mitigated and reputation strengthened – the standardisation of ways of conducting business and ways of behaving creates a culture set from the top down. The Board of the Company is conscious of the WarnerMedia culture and they aim to consider the policies within it whenever decisions are being made, both at board level and during the normal course of business.

The Company and the Board of directors ensure that the policies outlined above are implemented in the business as part of group-wide strategy and make all decisions with sustainable growth in mind by continuously seeking ways to enhance relationships with its direct and ultimate shareholders and other stakeholders. Through adopting and following the key policies and procedures the Company is able to set a clear course for its business and fulfil its purpose in the long-term. The Company’s culture and its values are further reinforced by training on how to adhere to the organisation’s policies and procedures and maintain a continuously high standard of business ethics and making sure that the working environment is built on mutual respect and tolerance.

Training

The current directors of the Company have held their positions for a number of years and are fundamentally familiar with their statutory duties under the Companies Act 2006. At present, there is no formal induction process for new directors to the Board of the Company. The Company is, however, considering implementing comprehensive Section 172 duties and wider regulatory requirements training to support the Board with their obligations as regulations continue the trend of being tightened. This would include periodic refresher training as well as relevant informative material including new developments being provided. The directors also, as employees of the WarnerMedia Group, are required to undergo annual training, including on the corporate culture and code of conduct.

Board composition

The current directors, in addition to their roles as statutory directors of the Company, also occupy key positions within the wider organization such as CEO, CFO and Senior Legal officer and ensure ongoing oversight of various segments of the business. The level of seniority, extensive business and industry experience and in-depth understanding of the Company’s and the wider organization’s affairs enable the directors to identify the key stakeholders of the Company and to recognize the nature and extent of the likely consequences, including the long-term impact, of their decisions on these stakeholders.

Principal decisions

dividends;
changes to key investments owned by the Company;
substantial reorganisation projects;
business contracts above certain value;
changes to the Company’s strategic objectives; and
matters that will substantially affect the Company’s employees.

In making its decisions, the Board is required to consider the outcome of any stakeholder impact assessment that has been undertaken to support it making that principal decision.

Stakeholder Engagement Statement

There is active engagement with all the stakeholders of the Company, including subsidiaries, shareholder and the WarnerMedia group as a whole.

Turner Entertainment Networks International Limited

Section 172 Statement for the Year Ended 31 December 2021

The Companies (Miscellaneous Reporting) Regulations 2018 (the “Regulations”) have been in force with effect from 1 January 2019. The Regulations aim to extend sustainable and responsible governance practice beyond listed companies to private limited companies. The Regulations require Turner Entertainment Networks International Limited (the “Company”) to report how the directors of the Company (the “Board”) have considered their duties under section 172 (“Section 172”) of the Companies Act 2006 (the “Act”) during the reporting period.

The duty under Section 172 is owed by the directors to the Company. In the context of a group of companies, being the Turner group of companies, which is wholly owned by Warner Media LLC (“WarnerMedia”), the Company’s directors owe their primary duty to the Company and not the parent company (though of course the parent company is considered as part of stakeholder engagement). The Board recognises that the overall framework that Section 172 promotes is to drive the long-term success and economic viability of the Company for the benefit of its sole shareholder and other stakeholders.

The long-term

The Company and the Board strive to create value for its shareholders in the medium and long-term and to take into account interests of their wider stakeholder base and the impact of their decisions on these stakeholders and their interests. In order to achieve this objective the Company implements and makes decisions which are aligned with the core values and the set strategy of the Turner Group and the WarnerMedia Group as a whole. In line with its purpose, the Company’s aim is to maintain a successful and sustainable business for the benefit of its direct and ultimate shareholders and other stakeholders, with whom the directors and senior management formally consult. Throughout the reporting year, the Company has made a strategic decision as part of the implementation of its business strategy.

Stakeholders

Decision making process

To support effective decision-making of the Board, the directors take into account various group-wide governance policies and practices, including the existing delegations of authority and powers of attorney, WarnerMedia’s SBC, WarnerMedia’s Ethical Sourcing and Supply Chain Policy, and the Company’s Supplier Code of Conduct when making decisions on behalf of the Company, together with established practices. These sources also feed into culture which is expanded on below.

Culture

The Company follows the culture set by WarnerMedia LLC which applies to all of its subsidiaries on a global scale. This culture is composed of a series of group policies and procedures that have been devised to promote the long-term sustainable success of the group whilst ensuring that risk is mitigated and reputation strengthened the standardisation of ways of conducting business and ways of behaving creates a culture set from the top down. The Board of the Company is conscious of the WarnerMedia culture and they aim to consider the policies within it whenever decisions are being made, both at board level and during the normal course of business.

Training

The majority of the current directors of the Company have held their positions for a number of years and are fundamentally familiar with their statutory duties under the Companies Act 2006. At present, there is no formal induction process for new directors to the Board of the Company. The Company is, however, considering implementing comprehensive Section 172 duties and wider regulatory requirements training to support the Board with their obligations as regulations continue the trend of being tightened. This would include periodic refresher training as well as relevant informative material including new developments being provided. The directors also, as employees of the WarnerMedia Group, are required to undergo annual training, including on the corporate culture and code of conduct.

Board composition

Principal decisions

dividends;
changes to key investments owned by the Company;
substantial reorganisation projects;
business contracts above certain value;
changes to the Company’s strategic objectives; and
matters that will substantially affect the Company’s employees.

In making its decisions, the Board is required to consider the outcome of any stakeholder impact assessment that has been undertaken to support it making that principal decision.

Stakeholder Engagement Statement

There is active engagement with all the stakeholders of the Company, including subsidiaries, shareholder and the WarnerMedia group as a whole.

Cable News International Limited

Section 172 Statement for the Year Ended 31 December 2021

The Companies (Miscellaneous Reporting) Regulations 2018 (the “Regulations”) have been in force with effect from 1 January 2019. The Regulations aim to extend sustainable and responsible governance practice beyond listed companies to private limited companies. The Regulations require Cable News International Limited (the “Company”) to report how the directors of the Company (the “Board”) have considered their duties under section 172 (“Section 172”) of the Companies Act 2006 (the “Act”) during the reporting period.

The duty under Section 172 is owed by the directors to the Company. In the context of a group of companies, being the Turner group of companies, which is wholly owned byWarner Media, LLC (“WarnerMedia”), the Company’s directors owe their primary duty to the Company and not the parent company (though of course the parent company is considered as part of stakeholder engagement). The Board recognises that the overall framework that Section 172 promotes is to drive the long-term success and economic viability of the Company for the benefit of its sole shareholder and other key stakeholders.

The long-term

The Company and the Board strive to create value for its shareholders in the medium and long-term and to take into account interests of their wider stakeholder base and the impact of their decisions on these stakeholders and their interests. In order to achieve this objective, the Company implements and makes decisions which are aligned with the core values and the set strategy of the Turner Group and the WarnerMedia Group as a whole. In line with its purpose, the Company’s aim is to maintain a successful and sustainable business for the benefit of its direct and ultimate shareholders and other stakeholders, with whom the directors and senior management formally consult.

From March 2020 the Company responded to the COVID 19 pandemic and took into account the impact on its employees, many of whom were involved in news gathering and the production of programming.

Further detail of this strategic decision can be found in the ‘Principal decisions’ section below.

Stakeholders

The Board does not delegate its stakeholder engagement responsibilities to senior management and instead opts to make considerations for the Company’s impacts on stakeholders collectively when making decisions. The Board considers its employees, consumers, it’s shareholder and the Warner Media group as a whole to be its key stakeholders. The Company also operates within WarnerMedia’s Standards of Business Conduct (SBC) which applies to all employees (including directors) and serves as a model for comparable codes of conduct. The SBC stresses the importance of abiding by the law, being truthful, being transparent in business dealings and putting the needs of shareholders and customers first. The Board uses this as part of their guiding approach when making decisions.

The Company engages with its employees to discuss employee-related matters and to provide information via various channels maintained by a dedicated internal team. This ongoing engagement and line of communication is enabled by use of employee surveys, the group’s intranet, business performance updates and presentations, among other things.

The impact of this engagement is detailed in the following section.

Decision making process

Board meetings are usually held on an ad hoc basis as and when there are significant decisions to be approved. The Board meeting process consists of an initial discussion of agenda items with supporting board packs containing pertinent information to the items at hand. This ensures that decisions are made on the basis of high-quality information being reviewed. The Board considers their Section 172 duties during each Board meeting and these considerations are documented in the relevant minutes. Board papers are prepared to provide the Board with the right levels of information to consider all relevant issues before making a decision and ensure consistency in the way the required information is presented to the directors ahead of each meeting. The Board also holds a number of annual board meetings to approve the annual accounts for the Company.

To support effective decision-making of the Board, the directors take into account various group-wide governance policies and practices, including the existing delegations of authority and powers of attorney, the Modern Slavery Act, WarnerMedia’s SBC, WarnerMedia’s Ethical Sourcing and Supply Chain Policy, and the Company’s Supplier Code of Conduct when making decisions on behalf of the Company, together with established practices. These sources also feed into culture which is expanded on below.

Culture

The Company and the Board of directors ensure that the policies outlined above are implemented in the business as part of group-wide strategy and make all decisions with sustainable growth in mind by continuously seeking ways to enhance relationships with its direct and ultimate shareholders, customers, employees, and other stakeholders. Through adopting and following the key policies and procedures the Company is able to set a clear course for its business and fulfil its purpose in the long-term. The Company’s culture and its values are further reinforced by training on how to adhere to the organisation’s policies and procedures and maintain a continuously high standard of business ethics and making sure that the working environment is built on mutual respect and tolerance. Details of the key strategic decisions and developments taken by the Company and its Board can be found in the ‘Principal decisions’ section below.

Training

The current director of the Company has held her position for a number of years and are fundamentally familiar with their statutory duties under the Companies Act 2006. At present, there is no formal induction process for new directors as there have been no plans to introduce new directors to the Board of the Company. The Company is, however, considering implementing comprehensive Section 172 duties and wider regulatory requirements training to support the Board with their obligations as regulations continue the trend of being tightened. This would include periodic refresher training as well as relevant informative material including new developments being provided. Company directors also, as employees of the WarnerMedia Group, are required to undergo annual training, including on the corporate culture and code of conduct.

Board composition

The current director, in addition to her role as statutory director of the Company, also occupy key positions within the wider organization such as Senior Legal officer and ensure ongoing oversight of various segments of the business. The level of seniority, extensive business and industry experience and in-depth understanding of the Company’s and the wider organization’s affairs enable the directors to identify the key stakeholders of the Company and to recognize the nature and extent of the likely consequences, including the long-term impact, of their decisions on these stakeholders.

Principal decisions

dividends;
changes to key investments owned by the Company;
substantial reorganisation projects;
business contracts above certain value;
changes to the Company’s strategic objectives; and
matters that will substantially affect the Company’s employees.

In making its decisions, the Board is required to consider the outcome of any stakeholder impact assessment that has been undertaken to support it making that principal decision.

The principal decisions made during the year were:

Response to the COVID-19 Pandemic

The Board considered the wellbeing, health and safety of its employees and contractors to be of paramount importance during 2021. It took steps to ensure that all employees and contractors could perform services remotely and that any work where a physical presence on the Company’s premises was deemed essential could be done safely and in accordance with all laws and regulations in force. The Company conducted periodic risk assessments to ensure workplace safety. The Company also conducted periodic surveys of employees to ensure that it has feedback on the impact of remote working and the company’s response to the pandemic, enabling it to continue to respond effectively.

Stakeholder Engagement Statement

The table below describes how the directors have had regard to the ned to foster relationships with its key stakeholders, in a business relationship with the Company, and the effect of that regard, including on the key decisions by the Board of Directors taken during the reporting period.

Stakeholder Group	Importance	What Engagement took place?	What influence did this have on the Board’s decisions?
Employees	For details on how the company has engaged with Cable News International Limited’s employees, how the directors had regard to those employees’ interests, and the effect of that regard, including on the decisions taken during the reporting period, refer to the Engagement with Employees Statement in the directors’ report (details of which are set out below).
Suppliers	To receive a clearly stated set of requirements to understand the Company’s needs and expectations. To be part of a fair and respectful tender and supplier selection process. To be part of an ongoing supplier relationship based on mutual respect and treating each other as valued business partners.	The company, through the board, adopted and established a number of group-wide and Company-specific policies to ensure fair and respectful treatment of its actual and potential suppliers for the Company and its subsidiaries. The policies clearly set out the Company’s expectations in relation to the quality of supplier products and services delivered and requirements that need to be met to ensure smooth and mutually beneficial business relationships. The list of relevant policies includes: Supplier Code of Conduct WarnerMedia LLC’s Standards of Business Conduct Security Policy	The board is provided with information and reports on significant transactions by relevant employees and the procurement team. The information received supports effective decision making by the Board and considering long-term consequences on relationships with suppliers and their interests.
Direct and Ultimate Shareholder	The company is 100% owned by Cable News International Inc. and is a subsidiary of WarnerMedia LLC, which is in turn wholly owned by Warner Bros. Discovery Inc.	The company reports to its direct shareholder and WarnerMedia LLC on a regular basis in the form of its financial performance, operational issues, business reviews, business plans and strategic plans as well as risk reporting.	The company’s strategy is to pursue strategic growth to create long term value for its shareholder and the group as a whole The receipt of this information, and the coordination with Group functions, supports the board’s delivery of the company’s purpose and strategy and assists with the implementation of the board’s business plan.

Employee Engagement Statement

The company identifies its employees as its key stakeholders and recognizes their importance to the long-term success of the company. Throughout the year, the directors engaged with the company’s employees in various ways to provide information on matters of concern to them as employees, to take into account their views in making decisions likely to affect their interests, to encourage involvement in the company’s performance and to achieve a common awareness on the part of all employees of the financial and economic factors affecting the company’s performance.

Table below sets out the detail of how the company engaged with its employees and how the directors have had regard to the employees’ interests and the impact of these considerations on the key decisions taken by the Board during the reporting period. Further detail of these decisions, and in particular the “Principal Decisions” in relation to the employees, are discussed in the s172 Statement.

Employees’ interests	How have the directors engaged with employees	How the directors have had regard to employee interests, and the effect of that regard
Providing information on matters of concern to them as employees and to achieve an awareness of factors affecting the performance of the Company, such as annual results, strategy, sustainability, training, annual performance related bonus scheme, career development, office environment and diversity and inclusion.	The Board has adopted much of the engagement mechanisms operated by WarnerMedia LLC. The various policies put in place by WarnerMedia Group (including the company) are applicable to all subsidiaries in the group and these act both as a type of engagement with employees and as guidance for how the Company should engage with its employees. Group wide developments in terms of performance, sustainability, strategy, diversity and inclusion is managed directly by WarnerMedia and this is promulgated by the Board of the Company. More localised forms of engagement are carried out by senior management and groups of employees including: Training programmes are managed by HR and include both career/management oriented training and more holistic well-being during “make you matter” weeks. Employees are kept informed by ad hoc updates on key developments, changes to strategic objectives and priorities, updates on progress of ongoing projects, updatesin regard to the merger of WarnerMedia and Discovery to form Warner Bros. Discovery, updates and announcements in respect of the Covid-19 pandemic. Employees also regularly receive emails and notifications from the Group as part of the Company’s wider engagement strategy.	The Company is committed to valuing the diversity of its people and it monitors and reports internally on aspects such as gender and ethnicity. The Company and the group are strongly dedicated to ensuring equal pay for all workforce across the organization regardless of gender, race or ethnic origin, disability, gender, sexual orientation, age, religion or belief and regularly report on a legal entity level.
Being consulted so that the views of employees can be taken into account in the decisions made by the directors which are likely to affect their interests.	There have been surveys on the employees attitude to working from home and returning to the office during the COVID 19 pandemic .	The views of employees and workers on returning to the office environment during the pandemic have been taken into account in the Company’s response to managing the workforce and ensuring that working from home is effective and sustainable.

UK Tax Strategy

This document applies to the Time Warner Holdings Limited UK sub-group and each of its affiliated UK sub-groups (collectively referred to as “UK Warner Media”). UK Warner Media considers that this publication meets the requirements of paragraph 19 (2) and paragraph 22(2), Schedule 19, Finance Act 2016 to publish a UK tax strategy for the financial year beginning on the 1st January 2022 and outlines the approach to conducting its tax affairs and dealing with tax risk.

UK Warner Media is a responsible taxpayer and its approach to UK tax seeks to align the long-term interests of stakeholders, including owners, employees and governments. UK Warner Media seeks to create value on a sustainable basis by ensuring commercial activities are organized in a tax efficient manner and comply with tax law, regulations, and disclosure requirements in the UK.

This document has been approved by the Board of Directors of each UK sub-group and applies to the members of each UK sub-group.

Attitude towards tax planning

Tax planning undertaken by UK Warner Media supports commercial objectives and its ability to invest and gives due consideration to its core values and any potential impact on its reputation, legislative and regulatory requirements, brand, and corporate and social responsibility.

UK Warner Media acknowledges that many governments shape their taxation policies to attract international business with the aim of stimulating investment, job creation, and skills development. Where it is aligned with its business and commercial strategy, UK Warner Media makes use of credits and incentives to support business activities.

Governance and management of tax risk

UK Warner Media takes the view that tax risk can be financial, reputational or operational in nature. Given the scale of UK Warner Media’s businesses, risks inevitably arise from time to time in relation to interpretation of complex tax laws. Accordingly, UK Warner Media dedicates resources to supporting an internal tax department of trained, experienced, and licensed experts who liaise directly with constituent parts of the business, providing relevant and business focused advice. Where the application of tax is complex or uncertain, UK Warner Media engages external accounting firms, law firms and/or directly with government agencies (i.e., HMRC) to lower the level of tax risk and uncertainty.

Working with tax authorities

UK Warner Media is committed to compliance with tax law and practice and to paying tax calculated in accordance with applicable legislation. UK Warner Media has an open and transparent relationship with HMRC and engages cooperatively, honestly, and proactively with HMRC, acting with integrity and professionalism. The aim is to avoid disputes, strive for early agreement on disputed matters, and to achieve certainty wherever possible.