TAX STRATEGY

ACTIVATE GROUP LIMITED AND ITS SUBSIDIARIES (“ACTIVATE GROUP”)

FINANCIAL YEAR ENDING 30 SEPTEMBER 2023

This document, approved by the Board of Directors, sets out the tax strategy for all companies within the Activate Group (herein referred to as ‘AGL’ or “the Group” as it relates to taxation).

The publication of this statement is regarded as satisfying the Group’s statutory obligation under Para 19(2), Schedule 19, Finance Act 2016. At AGL we take good governance and our reputation seriously and this is reflected in our values and our tax strategy, as set out below.

This strategy applies from the date of publication until it is superseded.

APPROACH TO RISK MANAGEMENT AND GOVERNANCE ARRANGEMENTS

AGLs operations are overseen by our Executive Committee to ensure we follow rigorous governance processes across our activities.

Day to day management of the Group’s tax affairs is within the remit of the CFO who reports directly to the Board.  In this regard, the CFO is responsible for ensuring that tax risk issues are identified across the business and how these are responded to.  In the UK, this includes the identification, assessment, and management of tax risks in compliance with the Senior Accounting Officer requirements.  

This therefore allows the Group to arrive at well-reasoned conclusions on how each tax risk should be managed. Where there is significant uncertainty or complexity in relation to a risk, external advice is sought to support the conclusions and decisions reached.

TAX PLANNING

The Group recognises that tax is inherent in many commercial transactions. The CFO and the team are therefore involved in the decision-making process of material transactions and provide appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made.

The Group will not seek tax efficiencies if the underlying commercial objectives do not support the position, or if the arrangements impact upon the Group’s reputation, brand, corporate and social responsibilities, or future working relationships with HMRC. However, in order to maximise shareholder value, AGL may seek to structure commercial transactions in a legitimate tax efficient manner as permitted by law.  If the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought to support the decision-making process.

TAX RISK MANAGEMENT

AGL’s principal objective in relation to tax risk, where possible, is to ensure comprehensive and timely compliance with all relevant legislation and guidance whilst minimising the risk of additional tax liabilities, penalties, and damage to reputation. Our judgement of tax risk may naturally consider materiality, but we do not define thresholds for what is an acceptable or unacceptable level of risk. Instead, where we consider that a tax risk exists, this is escalated by the Group CFO via our governance framework as above and external advice is sought where there is significant uncertainty, complexity, and risk.

ENGAGEMENT AND APPROACH WITH TAX AUTHORITIES

AGL remains committed to the principles of openness and transparency in its approach when dealing with HMRC.

All dealings with the tax authority are conducted in a collaborative, courteous and timely manner with the aim to strive for early agreement on disputed matters or where there is uncertainty. In the unlikely event non-compliance is identified, the Group would seek to make an unprompted disclosure to HMRC on a timely and transparent basis.

Approved by the board on 22^nd March 2024.