Tax Policy

Introduction and overview
The aim of the Encirc Limited tax policy document (hereinafter referred to as “Encirc”, and/or “the
company”), is to set out the standards the Board of Directors applies in managing its taxes and the
governance framework it employs to ensure those standards are embedded throughout Encirc and
its subsidiaries (“the Group”). Our intention is to be flexible and responsive to changes.

1   Taxes covered by the policy
This should cover not only corporation tax, income tax and Value Added Tax (VAT), but should
also include other direct, indirect and overseas taxes which impact the Group.

2   Appetite for risk in relation to tax and core principals
     •     We comply with all applicable tax laws in every jurisdiction we operate in, and, where the spirit of
           the law is clear, we comply with both the letter and spirit of the law;
     •     We conduct our dealings with tax authorities with honesty, integrity, respect and fairness and in a
           spirit of co-operative compliance;
     •     We avoid any actions (or omissions) in respect of our management of taxes which could damage
           the Group’s reputation with its key stakeholders. Where the expectations of those stakeholders
           conflict we seek to ensure that they are balanced responsibly;
     •     Any significant tax risks will be identified, communicated and controlled and the tax perspective will
           feature in all significant business decisions.

3  Tax Compliance
     •     Encirc is committed to observing all applicable laws, rules and regulations in meeting the Group’s
           tax compliance and reporting responsibilities;
     •     It is our aim to file tax returns on time in a professional and diligent manner;
     •     We confirm that all Intercompany transactions are on an arms-length basis;
     •     Encirc Limited has identified Her Majesty’s Revenue Commissioners (HMRC), as the main party to
           which it reports and pays taxes to in Great Britain & Northern Ireland;
     •     Encirc Distribution Limited, a wholly owned subsidiary of Encirc Limited has identified the Office of
           the Revenue Commissioners, in the Republic of Ireland as the main collector of taxes on its behalf.

4   Tax Planning
     •     The Encirc tax strategy is aligned with the business strategy and tax planning opportunities are
            evaluated within clear risk parameters;
     •     Due to the operations of our business and volume of tax obligations, certain risks may periodically
            arise from time to time in relation to the interpretation of local and international tax law and nature
           of our compliance arrangements. Our approach will be to actively seek to identify, evaluate,
           monitor and manage these risks to ensure they remain in line with our objectives;
     •     Where uncertainty or complex matters arise, which are outside day to day compliance activity,
           external advice may be sought, particularly in relation to our international tax obligations.

5   Tax risk Management
Encirc aims to ensure that all staff with tax responsibilities, or whose business activities may have
a tax impact, have an understanding of how risk is identified, assessed, reported and managed.

6   Our Staff
     •     Encirc is dependent upon having a motivated workforce who act ethically and honestly when
           carrying out their duties;
     •     Encirc have identified particular tax risk areas and clear guidance has been provided to staff so
           that one off and unusual decisions are identified and addressed e.g. on how a particular expense
           should be treated and is answered by the correct person at the correct time;
     •     Encirc ensures that identified staff are supported and trained in all areas of tax matters to provide
           them with the skills and expertise required to carry out their role. Encirc have developed
           procedures to ensure we have skilled personnel at all times who can manage situations where
           personal are absent due to illness.

7   Document retention
     •     We remain in compliance with legislative requirements and industry regulations, but also we
            possess sufficient data backups necessary for recovery if needed.

8   Updating and implementation of the policy
     A review of this tax policy document will be undertaken annually to ensure the policy still:
         - remains consistent with day to day practices;
         - that it is being effectively communicated to staff; and
         - complies with the Board approval and decisions

9   Governance and oversight
     •     Responsibility for tax management and administration and the delivery of our core principles in
            respect of compliance rests with the Encirc Finance Team;
     •     The tax policy has been reviewed and approved by the Senior Accounting Officer.