HUNTSWOOD GROUP TAX STRATEGY

1. AIM

The Group is committed to full compliance with all statutory obligations and full disclosure to tax authorities and conducts its tax affairs consistent with the following objectives, to:

• Comply with all relevant laws, rules, regulations, and reporting and disclosure requirements, wherever it operates

• Ensure the tax strategy is at all times consistent with the Group’s overall strategy, approach to risk, and core values

• Apply professional diligence and care in the management of all risks associated with tax matters, and ensure that its tax governance is appropriate

• Maintain an open and honest relationship with the tax authorities based on collaboration and integrity

• Use incentives and reliefs to minimise the tax costs of conducting its business activities but will not use them for purposes which are knowingly contradictory to the intent of the legislation.

2. RISK MANAGEMENT

The Group maintains internal competence in corporate and transactional taxes to ensure company corporate tax returns are properly prepared and indirect and payroll taxes are properly accounted for and reported. Where there is uncertainty in how the relevant tax law should be applied, appropriate written advice evidencing the facts, risks and conclusions may be taken from external tax advisors to support the decision-making process as appropriate.

Responsibility and accountability for the Group’s tax affairs is clearly defined in accordance with a Tax Responsibility Matrix, where processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.

When reviewing the tax risks associated with a specific decision or action, the Group ensures that the following are considered:

• The legal and fiduciary duties of its directors and employees

• The requirements of any related internal policies or procedures

• The maintenance of the Group’s corporate reputation, having particular regard to the principles embodied in the Group’s social responsibility core value and the way it interacts with the communities around the Group

• The wider consequences of potential disagreement with tax authorities, and any possible impact on relationships with them

3. TAX PLANNING AND LEVEL OF RISK

The Group’s established ethical framework is such that deliberately failing to comply with tax law is unacceptable.

The Group manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

The Group is committed to observing all applicable laws, rules, regulations, and reporting and disclosure requirements, wherever there is a requirement to do so as a result of its business presence and transactions.

Importantly, the key tax process owners will collaborate with the business to provide advice and guidance necessary to ensure compliance. In cases where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice will be sought to support the decision-making process.

There are clear management responsibilities, backed up by regular monitoring and review, carried out by the key tax process owners. In addition, The Group’s processes and controls are regularly monitored, reviewed, and tested by its independent internal assurance and audit function as well as an annual review by third party external advisors. All process owners have the necessary skills and experience to deal with their area of tax and appropriate training is carried out to ensure up to date compliance. All internal tax policies / processes are documented and are reviewed on an annual basis.

4. RELATIONSHIP WITH HMRC

The Group is committed to the principles of openness and transparency in its approach to dealing with tax authorities.

All dealings with the tax authorities and other relevant bodies will be conducted in a collaborative, courteous and timely manner. In particular, the Group commits to:

• Adopting an open and collaborative professional relationship at all times with HMRC

• Engaging in full, open and early dialogue with HMRC to discuss tax planning, strategy, risks and significant transactions

• Make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion

• Seek to resolve issues with HMRC in real time and before returns are filed if possible, and where disagreements arise, work with HMRC to resolve issues by agreement (where possible)

• Be open and transparent about decision-making, governance and business transactions

• Reasonably believe that transactions are structured to give a tax result which is not inconsistent with the economic consequences and the intentions of Parliament

• Interpret the relevant laws in a reasonable way, and ensure transactions are structured consistently with a co-operative relationship.

This tax strategy is published in accordance with the requirements of Schedule 19 of the Finance Act 2016.