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UK Tax Strategy Statement 2022-23

This tax strategy is published in accordance with paragraph 16(2), Schedule 19 Finance Act 2016

Section 1: Introduction & Overview

Our Business Strategy and Tax Objectives

Ward Commerce Group is committed to complying with all applicable tax laws in the UK and all the countries in which it operates.

It is recognised that taxation matters are often significant in a corporate transaction, and therefore a key objective of our strategy is to ensure that the tax affairs of Ward Commerce Group are in good order and uncertainties are minimised.

Risk Management and Risk Appetite

Ward Commerce Group’s established ethical framework dictates that failing to comply with tax law is unacceptable.

Our appetite for risk is primarily governed by the aim of retaining our low-risk rating from HMRC. We have a low tolerance to tax risk, and whilst we do not undertake transactions led by a planning purpose, we do as part of our commercial activities consider the tax consequences.

When evaluating a taxation matter, consideration will be given to
the level of risk, the ease of implementation and consideration of any tax reliefs or opportunities available to us that are clearly within
the legislation and related HMRC guidance.

Tax control environment

Ward Commerce 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, whilst tax guidance and advice is obtained from external tax advisors as appropriate. Reliance is placed on external advisors for advice relating to tax in the context of commercial transactions, updates and interpretations of tax legislation.

Compliance is the responsibility of the business but will be monitored where appropriate by local external tax advisors.

The UK and International Finance teams are responsible for the maintenance of an appropriate tax control framework and a register of tax risks is maintained and updated quarterly to the internal risk management system, which is overseen and reviewed quarterly by the Risk and Compliance function regularly by the Board.

Section 2: Governance

Strategy Oversight and Sponsorship

The Board is responsible for sponsoring and overseeing the overall Group Tax Strategy.

Appropriate accounting and financial oversight is exercised through the Audit Committee with our CFO having oversight responsibility for the Group Board.

Management Reporting of Tax Risk

Ward Commerce Group’s CFO reports annually to the Board. The Board is provided with a monthly report, prepared by the CFO which provides an update on key issues covering tax and compliance matters.

Relationship with Revenue Authorities

Ward Commerce Group maintains open relationships with Revenue Authorities in all countries in which it operates and has a transparent approach to dealing with the relevant Tax Revenue Authorities.

In the UK, Ward Commerce Group operates a real-time working relationship with its dedicated customer relationship manager at HMRC with regard to taxation.

Ward Commerce Group will raise any matters with HMRC, particularly to avoid uncertainty, for example where it considers that HMRC may take a different view, or where Ward Commerce Group is seeking confirmation of a particular approach.

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