1. GROUP TAX STRATEGY IN RELATION TO UK TAXATION

The publication of this strategy statement in relation to UK taxation (the "Tax Strategy") serves to satisfy the statutory obligation under paragraph 16(2) of Schedule 19 to the Finance Act 2016 for Hellen Holdings Limited (the "Company") to prepare and publish a group tax strategy for the group in the year ending 31 December 2023.

For these purposes, the group consists of the Company and the entities whose results are reported on a consolidated basis in the consolidated financial statements of the Company (together the "Group" and each a "Group Entity").

2.  APPROACH TO RISK MANAGEMENT AND GOVERNANCE ARRANGEMENTS IN RELATION TO UK TAXATION

Within the Group, the overall responsibility for tax governance and strategy in relation to UK taxation lies with the board of directors of the Company.

This Tax Strategy has been approved by the directors of the Company and constitutes the Group's governance policy for UK taxation matters. The Company seeks to ensure that the Tax Strategy is applied consistently by the Group and is understood by the directors of each Group Entity.

The Group engages professional external advisors to assist with its UK tax compliance obligations, including with the preparation of any UK tax returns and with the preparation of this Tax Strategy,

The Group seeks professional UK tax advice with respect to transactions where there is a need for specialist guidance, such as in the event of a restructuring of the Group or a significant transaction which may affect the Group's UK tax position.

3.  ATTITUDE TOWARDS UK TAX PLANNING

The Group is committed to compliance with tax obligations. It does not engage in tax planning other than that which supports genuine commercial activity, and avoids structuring transactions in a way that will have tax results that are inconsistent with the underlying economic consequences unless there exists specific legislation designed to give that result. Where reliance is placed on such specific legislation, the Group will seek to satisfy itself that that the transaction is structured in a way that gives a tax result which is not contrary to the intentions of Parliament.

4.  LEVEL OF RISK IN RELATION TO UK TAXATION

Whilst the Group aims to structure its transactions in the most efficient manner, it has a low appetite for UK tax risk, and seeks to minimise the risk of uncertainty and disputes with respect to UK taxation. It does not seek to artificially manipulate its tax affairs to minimise tax liabilities. Within the Group, tax risks are identified and investigated. Appropriate controls to mitigate risk are implemented.

5.  RELATIONSHIP WITH HMRC

The Group is committed to ensuring compliance with its UK tax filing obligations and to maintaining a co-operative, professional, and transparent relationship with HMRC.  Significant uncertainties in relation to UK tax matters should be disclosed to HMRC, as and when appropriate.

Where there is significant doubt as to whether the tax result of a proposed transaction is contrary to the intentions of Parliament, Group Entities are encouraged to discuss their plans in advance with HMRC.