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Regulatory

In accordance with Schedule 19 of the Finance Act 2016, we set out below the tax strategy of Matheson & Co., Limited. ("the Company"). We believe that this strategy constitutes good corporate practice in the area of UK tax management and tax transparency, while balancing the interests of our stakeholders.

Overall Commitment

The Company will comply with its tax obligations which include making all appropriate returns covering all areas of UK taxes and ensuring the correct amounts of UK taxes are made by the due dates.

Working with the HMRC

The Company will maintain an open and transparent relationship with HMRC.

Tax Risk Management

When interpretation of the law is uncertain, the Company will seek to discuss the issue with HMRC at the time or refer to it when tax returns are filed. External advice will also be sought on matters of uncertainty or where there is no relevant specialist knowledge or experience in-house.

The Company operates a risk-based system of controls, processes and training in order to manage tax risks and minimise instances of error. The Company has a low tolerance for tax uncertainty.

Approach to Tax Planning

The Company adopts a prudent and low risk approach in tax planning. It will only utilise tax planning measures and opportunities for obtaining tax efficiencies where these comply with tax legislation, and when such tax planning is aligned with the commercial and economic activities of the Company. The Company will not use artificial structures that are intended for tax avoidance without bona fide business purpose, have no commercial substance or do not meet the generally understood intention of UK or international law.

The Company has a zero-tolerance policy towards tax evasion, any deliberate concealment of taxable income and benefits, or facilitating others in undertaking such activities.

Corporate Governance

The finance director manages the Company's tax function and consults with the tax team of its global parent company. The finance director ensures that the Company adopts the appropriate tax accounting treatment and reporting standards. The Board has ultimate responsibility for the Company's tax policies and ensuring its principles and approach are adhered to.

The Company follows the wider Jardine Group's Group Policy Manual and Code of Conduct to which all employees are required to subscribe and held to the highest standard.

The above document has been approved by the Board of Directors on behalf of the Company and applies for the year to 31 December 2019 and subsequent periods. The Company's tax strategy (which will be reviewed at least annually) will remain in effect until any amendments are approved by the Board of Directors.

December 2023