This policy statement is published in accordance with section 161 Finance Act 2016.

Corporate responsibility is a high priority for our Group Companies, and we see the proper administration of taxation matters as an important component of that responsibility. This document will be periodically reviewed by the Group Tax team, and any amendments will be approved by the Board of Directors. It is effective for the year ending 31 December 2017, and will remain in effect until any amendments are approved by the Board of Directors.

Our approach to taxation matters is to:

• Meet all legal requirements and make all appropriate tax returns and tax payments in a timely manner.
• Apply professional diligence and care in the management of all risks associated with tax matters, and ensure governance and assurance procedures are appropriate.
• Foster constructive, professional and transparent relationships with tax authorities, based on integrity, collaboration and mutual trust.
• Consider the effect of our tax affairs upon our reputation and brand.
• Ensure the Board is properly informed on all significant Group tax matters.

Tax management and governance arrangements

We want our tax affairs to be transparent and compliant with tax legislation, and recognise that managing tax compliance is increasingly complex. Our internal structure is set up to ensure:

• The Board of Directors understands the importance of tax compliance, and how it is achieved.
• There is frequent dialogue between the Board and those individuals tasked with the operation of our finance function, regarding the way our business manages its tax responsibilities.
• The business portrays a positive view towards tax compliance and the importance of meeting our obligations.

We manage compliance with our tax obligations by investing in tax training for our staff, obtaining external expert tax advice on complex technical tax matters, and maintaining good communications with HMRC and other tax authorities.

Our approach is to ensure we are compliant and understand our responsibilities for tax matters, rather than looking for ways to aggressively avoid payment of tax. The Board is conscious of the potential negative publicity attracted by a bad attitude towards tax, and sees strong internal processes and a good relationship with our professional advisors and with the tax authorities as the best way to maintain a high level of integrity in tax matters, and to minimize reputational risk.

The Group Companies, and their suppliers and customers are well-established, sophisticated businesses. While those factors do not completely eliminate tax risk, they do contribute to an operating environment that contains relatively low risk.

Relationship with HMRC

Our objective is to maintain a constructive, professional, and transparent relationship with HMRC (and other tax authorities), based on integrity, collaboration, and mutual trust. We employ the services of professional tax advisers to act as our agents, and to liaise with HMRC from time to time on our behalf. The Board views these measures as an excellent way to maintain a positive relationship of mutual respect with HMRC, thus reducing the risk of miscommunication.

Dubuque Holdings Limited, as a head of the UK sub group (under Paragraph 11 Schedule 19 of Finance Act 2016), regards this publication as complying with the duty under Paragraph 19(2), Schedule 19 of Finance Act 2016.

Precis (1136) Limited, as a head of the UK sub group (under Paragraph 11 Schedule 19 of Finance Act 2016), regards this publication as complying with the duty under Paragraph 19(2), Schedule 19 of Finance Act 2016.

Information Resources Software Limited regards this publication as complying with its duty under Paragraph 22(2), Schedule 19 of Finance Act 2016.