UK Tax Strategy, Ltd. (Heylean) is headquartered in London, United Kingdom. Heylean has international operations in numerous countries, including the United Kingdom. In structuring our commercial activities and expansion, Heylean complies with the tax laws of the countries within which    Heylean operates with a view to fulfilling our mission. Any tax planning undertaken will have commercial and economic substance, resulting from assets, people and activities, while considering the potential impact on Heylean's broader goals. Heylean does not undertake tax planning that    is contrived or artificial.

   The tax policy below applies to,Ltd. It has been published in accordance with paragraph 22(2) of Schedule 19 to the Finance Act 2016. The tax policy covers both direct and indirect taxes, including corporate tax, PAYE and VAT.

   Heylean's internal governance procedures are set at the executive level and through people, processes, and controls, Heylean manages tax risks and compliance with tax laws. When a tax risk is identified, Heylean's procedures require an escalation and prompt notification to the    appropriate senior personnel and executives.

   The procedures seek to ensure that all tax filings are made in compliance with local tax laws and that all taxes are paid on a timely basis. Heylean works to ensure that its tax positions appropriately reflect the business activities it undertakes in the UK, and the same approach is taken    whenever new tax legislation is introduced or HM Revenue & Customs (HMRC) changes their policies. When there is uncertainty or complexity in relation to the law or its application, expert advice may be sought. If this is insufficient to achieve certainty or to address the complexity,    Heylean may look to engage directly with HMRC to better understand the application of the law and ensure compliance.

   Heylean does not accept any form of behavior that facilitates the evasion of tax, whether in the UK or in any other jurisdiction.

   Heylean engages with tax authorities with honesty, integrity, respect, fairness, and in a spirit of co­operative compliance. If it becomes necessary, Heylean plans to engage with HMRC in the same manner. Heylean is prepared to defend its positions in court in cases where Heylean    disagrees with a ruling or decision of a tax authority, but we will first seek to resolve any disputed matters through pro­active and transparent discussion and negotiation.

   This strategy has been published for year ended 31 December 2021