Giacom Topco Limited and subsidiaries (“Giacom”) Tax Strategy

1. Giacom’s Tax Strategy

This tax strategy covers all the Giacom companies and explains the group’s approach to tax compliance. Its publication follows the requirements set out in UK Finance Act 2016, Schedule 19 and adds to them where appropriate. It applies to the financial year ending March 2026 onwards and was approved by the Board on [TBC].

2. Giacom’s Tax Risk Management

The Giacom CFO is accountable for delivery of this strategy and for oversight of UK tax risk. Day to day management sits with the Group Financial Controller, supported by Business Unit Finance Directors and external advisers where specialist input is required.

In managing these risks, Giacom’s approach is driven by the following three principles:

• To act with integrity and transparency in our dealings with all relevant stakeholders, including the tax authorities in the UK

• To meet the tax compliance requirements required of us by filing returns and paying our tax liabilities on time

• To reduce the cost of doing business by utilising appropriate reliefs where it is legal and feasible to do so

Tax processes are regularly reviewed and refined, and Giacom carries out annual SAO reporting to HMRC.

3. Giacom’s attitude to tax planning

The Group is committed to acting with integrity and transparency. This is adhered to by the professionals who oversee all tax planning and compliance matters, to meet the high ethical standards demanded by the professional bodies to which they belong.

The relevant professionals involved in tax matters hold appropriate qualifications and experience and undertake regular CPD to continuously maintain their knowledge base and retain the latest relevant information.

Giacom’s attitude to tax planning is not to enter into or undertake transactions to gain a tax advantage and, not to make interpretations of tax law that are opposed to its original spirit.

Giacom seeks to structure its affairs in a tax efficient manner where there is a commercial benefit to do so. However, the Group will not use tax havens, take an aggressive interpretation of tax legislation or use artificial tax avoidance schemes.

Giacom has a zero-tolerance approach to acts of criminal facilitation of tax evasion.

To support us in ensuring that we have interpreted tax law and its spirit correctly, we seek advice where appropriate from accounting and legal firms and tax counsel who have experience of working with large complex groups.

In summary, we will only engage in tax planning when it is aligned to our commercial and economic activity and does not lead to an act of tax abuse.

4. Giacom’s tolerance to tax risk

Giacom’s level of acceptable tax risk is considered at least annually by the CFO and Board, with every member of the team having full access to the CFO. They will take the needs and interests of stakeholders into account when considering the level of risk while ensuring Giacom acts with integrity and transparency.

The Giacom finance team regularly communicate with one another on matters which may impact tax. The Group Financial Controller oversees tax compliance activities on a day to day basis, professional advice is sought for significant or complex matters to support robust, well documented conclusions, with escalation of salient tax matters to the CFO.

Positions that are material, novel, uncertain, or potentially sensitive from a reputational perspective are escalated to the CFO and, where appropriate, to the Board (or Audit Committee) for oversight.

December 2025