Tax Strategy

Scope

AURELIUS Equity Opportunities SE & Co KGaA (“AURELIUS”) is resident in Germany and publicly
traded in the m:access segment of the Munich Stock Exchange and is the head of the AURELIUS
Group. AURELIUS has presently investments in more than 40 countries, inter alia in the United
Kingdom. AURELIUS is an international multi-asset manager investing in a wide range of sectors.
This strategy applies to the UK Investments in accordance with paragraph 19 of Schedule 19 to the
Finance Act 2016 (“FA 2016”). In this strategy, references to “the UK Investments” is to all the UK
entities that are ultimately held by AURELIUS. The UK Investments regard this publication as
complying with each of their respective duties under paragraph 19(2) Schedule 19 FA 2016 in
relation to the financial year ended 31/12/2020.

This strategy applies from the date of publication until it is superseded. References to “UK
Taxation” are to the taxes and duties set out in paragraph 15(1) of the Schedule which include
Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax.
References to “tax”, “taxes” or “taxation” are to UK taxation and to all corresponding worldwide
taxes and similar duties in respect of which the Group has legal responsibilities.

Aim

AURELIUS, together with the UK Investments, is committed to comply with tax filing, reporting and
payment obligations wherever it operates and to foster constructive and transparent relationships
with the tax authorities.

Governance in relation to UK taxation

Given the structure of the AURELIUS Group the oversight of the UK Investments tax affairs, the
day-to-day responsibility for ensuring adherence to the tax strategy, the supporting governance
framework, the management of tax risks and the handling of the respective tax filing, reporting and
payment obligations at the level of each of the UK Investment is assigned to the local companies’
management.

The local management shall also inform the Chief Financial Officer (“CFO”) and/or the tax and legal
team of AURELIUS about any material adverse tax events which arise at the level of each UK
Investment.

The monitoring of the overall AURELIUS Group tax aspects that impact the UK Investments (such
as country by country reporting, senior accounting officer rules, group tax reliefs, corporate interest
restrictions rules and further AURELIUS Group tax responsibilities) is assigned to the CFO of
AURELIUS and the Group Tax Director, whose responsibility is also to inform the Board of
AURELIUS about key tax events at the Group level.

This allows Board members to be adequately engaged in the tax affairs at the overall AURELIUS
Group level and thereby ensure that the UK Investments are adhering to their responsibilities.
There are five key principles to which AURELIUS Group and the UK Investments adhere to when
considering all aspects of taxation:
Risk Management: Given the scale and nature of the UK Investments we are aware that risks
associated with compliance and reporting failures as well as risks associated with undertaking of
transactions and reorganisations within the AURELIUS Group may arise. In cooperation with the
external tax advisors the local management as well as management of AURELIUS Group proactively
seek to identify, manage and monitor the tax risks. The oversights of the risk areas are supported –
in accordance with the respective responsibility – by the local tax teams (where available), local
management, AURELIUS Group tax team, AURELIUS Group Internal audit team and external tax
advisers.
Appropriately qualified team: At the level of the respective UK Investment the responsibility for
the tax affairs sits with appropriately qualified and experienced teams, consisting of finance and/or
tax professionals. At the level of AURELIUS the UK Investments are supported by an experienced
Group Tax Team consisting of the Group Tax Director and 5 Tax Managers who are supported by
local tax advisers. The Board of AURELIUS will continue to review the structure of the Group Tax
Team at suitable intervals to ensure it remains appropriate to the business environment and
external tax environment.
External advisers: To assist the UK Investments and the Group Tax Team of AURELIUS, external
advisers are engaged to provide technical expertise when necessary.
Attitude to tax planning: AURELIUS Group together with the UK investments have a strong
commercial focus and, as part of its duty to its stakeholders to mitigate unnecessary costs, utilises
tax reliefs and allowances available in the manner intended by the tax authorities and statute. Any
tax planning undertaken has commercial and economic substance and reasons and AURELIUS
Group including the UK Investments does not engage in any artificial tax arrangements.
The level of risk which the AURELIUS Group and the UK Investments accept in relation to UK
taxation is consistent with its overall objective of achieving certainty in the overall tax affairs. At all
times the AURELIUS Group and the UK Investments seek to comply with regulatory and other
obligations and to act in a way which upholds its reputation as a responsible corporate citizen.
Transparency with HMRC: The UK Investments seek to have an open and transparent relationship
with HMRC and will disclose all relevant facts and circumstances to HMRC and seek to resolve any
disputed matters through pro-active and transparent discussion.