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We consider that the publication of this UK tax strategy complies with the obligations of the ������ý UK Group under Part 2 of Schedule 19, Finance Act 2016.

Commitment to Compliance

For ������ý, compliance means paying the right amount of tax in the right place at the right time, filing tax returns on a complete and timely basis, and ensuring that relevant facts and circumstances are appropriately disclosed. There is an expectation that all employees strive to comply with all laws and regulations in all territories where we operate.

Level of risk in relation to UK taxation that the group is prepared to accept

Due to the size and complexity of our business, risks may sometimes arise in relation to the interpretation of tax law or the nature of our compliance obligations.  ������ý has internal processes to identify, evaluate, manage and resolve such risks. In situations of significant uncertainty or complexity in relation to a specific risk, advice would be sought from external advisers.

Attitude of the group to tax planning

������ý Code of Conduct places the responsibility on each employee to conduct commercial activity lawfully and with integrity. In making commercial decisions, ������ý takes tax into account in the same way as any other legitimate cost. Where there is more than one way of structuring a commercial business arrangement, all factors are taken into consideration including tax. We ensure all business arrangements are compliant with the laws and relevant regulations in the jurisdictions concerned. We do not use marketed tax avoidance schemes, nor do we use any tax planning that is contrived or artificial.

Approach toward dealings with HMRC

������ý believes in co-operative engagement with tax authorities, with the aim of building a relationship based on mutual respect and compliance. We work with HMRC to resolve any issues affecting the ������ý UK Group in a positive and professional manner through pro-active discussion.

Approach of the ������ý UK Group to risk management and governance arrangements in relation to UK taxation

The senior leadership team of ������ý takes the lead in establishing a strong risk management culture and is responsible for the ������ý UK Group’s tax affairs and oversight of tax risk. The governance of tax risk follows formal procedures which are fully aligned with other governance procedures that are in place across ������ý in respect of a range of other risks to which ������ý is exposed. The UK tax affairs of the ������ý UK Group are managed by a team of suitably qualified tax professionals, supported where appropriate by external advisors. These arrangements ensure that all significant UK tax-related decisions are subject to review and approval, and that all UK tax obligations are met.

• 1. “������ý” refers to the worldwide group of entities whose ultimate parent company is Koch Industries, Inc

Last published December 2023