A FTSE250 Company Secretary writes...
Since companies are only required to report on contracts with a “significant connection” to the UK we are going to check first if there is a significant variance in our payment practices between our UK and non-UK based suppliers, to our main plc entity (which is the only UK entity above the reporting thresholds).
We are hoping there is little variance, in which case we may avoid diligence identifying contracts which meet the prescribed connection tests and can in practice just report on the UK based suppliers. Having to identify the various contracts which supply our PLC entity across Europe which meet the various “significant connection” tests is a potentially time consuming diligence exercise. How are other companies approaching this aspect?
This reply is from David Mensley.
I have raised this question at recent Company Secretary Group meetings; the general view is that this falls in the ambit of the Finance Department and that the Co Sec has little or no role. No advice has been forthcoming.