// Policies and Terms

UK Tax Strategy Statement – December 31, 2017

This Tax Strategy Statement is prepared and published on behalf of the Multimatic UK Sub-Group of the Multimatic Group (a foreign group which is a qualifying group in the current financial year) under paragraph 19(2) of Schedule 19 of the UK Finance Act 2016.  As such, this Tax Strategy Statement applies in relation to UK taxation only.  “UK taxation” has the meaning prescribed in paragraph 15 of Schedule 19 of the UK Finance Act 2016.

Multimatic Limited (UK company) is the head of the Multimatic UK Sub-Group (“UK Sub-Group”) and Multimatic Holdings Inc. (Ontario corporation) is the head of the Multimatic Group (“Group”).

Tax Governance

The Group Chief Financial Officer is responsible for the UK Sub-Group’s tax strategy, which is overseen and approved by the Group Board of Directors.  The Chief Financial Officer delegates the implementation of the UK Sub-Group’s tax strategy to the Group Tax Director who is overseen by the Group Vice President Finance and Administration.  Finance personnel employed at various levels across the Group, including the UK Sub-Group, support the tax function as required.  The UK Sub-Group tax strategy is reviewed on a periodic basis, and significant changes are presented to the Group Board of Directors for approval.

Tax Risk Management

The UK Sub-Group is committed to complying with applicable tax law and practice. Accordingly, the UK Sub-Group’s tax risk management policy requires that up-to-date procedures, processes and frameworks be in place to minimize the impact of tax risks on the UK Sub-Group’s business and results, and to enable timely and decisive responses when such risks are identified.  The Group Tax Director, Vice President Finance and Administration, Chief Financial Officer and other members of Group management assess tax risks as they arise, including those reported by the UK Sub-Group’s operations.  Material risks are communicated to the Group Board of Directors.

Tax Risk Acceptance

Given the scale of the UK Sub-Group’s business and volume of tax obligations, risks may arise in relation to the nature of tax compliance arrangements and the interpretation of tax law and practice.  In circumstances of uncertainty or complexity, external professional advice is sought to minimize and/or manage any such potential risks.

The UK Sub-Group uses reliefs and incentives to minimize the tax costs of conducting it business activities, but not for purposes which knowingly breach, or contradict the intent of, applicable tax law or practice.

Tax Planning

The Group’s tax department works closely with all areas of the business to ensure tax decisions are consistent and compliment the UK Sub-Group’s overall business strategy.  All tax planning has a bona fide commercial rationale and business substance.  Tax planning also takes into consideration potential impacts on the reputation and broader goals of both the UK Sub-Group and the Group itself.

Dealings with HM Revenue and Customs (“HMRC”)

The UK Sub-Group engages with HMRC with honesty and transparency in respect of all tax matters.  The UK Sub-Group endeavours to work collaboratively with HMRC wherever possible to resolve issues or address uncertainties or complexities in the interpretation or application of tax law or practice.