Effective date: January 1, 2023.

Introduction

This document sets out Foundever’s policy and approach to conducting its tax affairs and dealing with tax risk. In making this document available, Foundever and specifically its UK affiliates, fulfill its responsibilities under paragraphs 19 and 22, Schedule 19, of the Finance Act of 2016 in the UK. This document will be reviewed annually.

Overall Tax Policy

Foundever seeks to conduct its tax affairs with the following objectives by:

• Complying with all relevant laws, rules, regulations, reporting and disclosure requirements wherever we do business;
• Applying professional diligence and care in the management of tax matters and risksand ensure appropriate governance and assurance procedures; and
• Foster professional, transparent and constructive relationships with tax authorities based on concepts of integrity, collaboration and mutual trust.

Approach to Tax Risk and Governance

Given the scale and international breadth of Foundever’s business and volume of tax obligations, risks will predictably arise in relation to the interpretation of tax laws and the nature of compliance arrangements and obligations. Foundever seeks to ensure internal controls are in place to identify tax risks and analyze them appropriately and elevate and address at the appropriate levels within the organization. Diligent professional care and judgment is employed to assess tax risks to arrive at well-reasoned conclusions on how these risks should be managed. When uncertainties of the application or interpretation of tax law arise, appropriate professional advice or advance rulings or instruction from tax authorities may be obtained.

Attitude toward Tax Planning

Foundever undertakes tax planning and utilizes intended reliefs and incentives as a part of its overall business strategy. Foundever does not undertake transactions exclusively driven by a tax planning purpose. Foundever seeks to comply with all applicable laws and regulations in the countries in which we operate, acting in ways that reflect the intention of the law as well as the letter, while maximizing Foundever’s shareholder value. Foundever views compliance with tax legislation as a key to managing the company’s tax risk and understands the importance of tax in the wider context of business decisions.

Relationships with Tax Authorities

Foundever is committed to transparency and professionalism in its approach in interacting with taxing authorities wherever the company operates. All dealings with tax authorities and other relevant bodies are conducted in a collaborative, courteous and timely manner. Foundever strives for early agreement on disputed matters and achieving certainty whenever possible.