UK Tax Strategy: Financial year ending 31 December 2022

Quaker Houghton (NYSE: KWR) is the global leader in industrial process fluids. With a robust presence around the world, including operations in over 25 countries, our customers include thousands of the world’s most advanced and specialized steel, aluminum, automotive, aerospace, offshore, can, mining, and metalworking companies. Our high-performing, innovative and sustainable solutions are backed by best-in-class technology, deep process knowledge and customized services, and we are dedicated to deliver such solutions as well as a sustainable future for our customers, our business and the public. With 4,000 employees, including chemists, engineers and industry experts, we partner with our customers to improve their operations so they can run even more efficiently, even more effectively, whatever comes next.

This UK tax strategy is published in accordance with Paragraph 16(2), Schedule 19, Finance Act 2016 and applies to the Quaker Houghton UK group of entities. This strategy covers our approach to arranging our UK tax affairs and is comprised of five key components

1. Commitment to compliance

We are dedicated to being compliant with tax law and practice in the UK. By this we mean paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to the tax authorities and claiming reliefs and incentives where available. External advisors are engaged to provide corporate tax compliance services.

Where Quaker Houghton identifies a significant uncertainty or complexity in relation to a tax risk, we may seek to rely on external advice, and have strong ongoing relationships with large tax advisory firms. We are investing in ongoing training for the relevant members of our finance team to increase the awareness of tax principles to enable then to successfully carry out their tasks.

2. Responsible attitude to arranging our tax affairs

When making commercial decisions one of the many factors we will consider is the tax laws of the countries in which we operate. We establish entities in jurisdictions suitable to hold our overseas investments, giving consideration to our business activities and the prevailing regulatory environment.

We adhere to applicable tax law and we seek to minimize the risk of uncertainty or disputes through communication with the relevant tax authorities. We conduct transactions between Quaker Houghton group companies in accordance with the applicable laws of the countries where we operate, which embody the principles of the Organisation for Economic Co-operation and Development.

3. Effective risk management

Our approach to tax risk management is to ensure that tax risks are proactively identified, measured, managed and reported.

The following are key features of our approach:

• Creating an awareness of tax risk at all levels within the organization; and
• Instilling a culture of tax risk management and risk ownership.

Given the nature of our business and complexity of tax laws, we will have risks from time to time. We will seek to proactively identify and manage those risks. In some cases we may seek external advice, and where appropriate, risks will be escalated to the Chief Financial Officer (CFO), Audit Committee and Board for their consideration.

4. Constructive approach to engaging with HMRC

In any interactions with HM Revenue and Customs (HMRC), our employees are expected to act courteously and honestly, with integrity, respect and fairness and in a spirit of co-operative compliance. We respond to all HMRC information requests in full and in a timely manner. Wherever possible and appropriate, we will consult with HMRC on a real time basis, to increase tax certainty.

5. Governance

The group CFO owns and implements our approach to tax which is approved by the main board audit committee. The group EMEA tax manager is responsible for ensuring that policies and procedures that support the approach are in place, maintained and used consistently.

Quaker Houghton regards this publication as complying with its duties towards HMRC.