Tax Strategy Policy

Neuraxpharm UK Limited – UK Tax Strategy Statement

Neuraxpharm UK Limited (“the Company”) belongs to the Neuraxpharm Group (“the Group”), a leading European specialty pharmaceutical group specialising in the treatment of central nervous system disorders, with presence in a number of European territories including the UK. We are experts in improving existing pharmaceutical forms and upgrading new products with the aim to deliver relevant improvements in the life and wellbeing of patients with neurological and psychiatric disorders. We are guided by excellence, scientific rigour, quality and perseverance. The Company acts as a distributor of the Neuraxpharm portfolio of products in the UK market.

The Company is ultimately majority owned by funds advised by the Private Equity firm Permira (“Permira”) which acquired a controlling stake in the Group on 16 December 2020. Permira has structured its investment in the Group through Permira VI Investment Platform Limited, a holding company that has investments in businesses across a number of different activities and geographies, including the UK. Whilst this tax strategy document applies to the Company, it is aligned with the principles set out in the tax strategy document published by its ultimate parent company, Permira VI Investment Platform Limited.

This document, which has been reviewed by the Company’s Board, sets out the Company’s policy and approach to conducting its tax affairs and dealing with tax risk.

This UK tax strategy statement, for the period ended 31 December 2023, covers those taxes as defined in Paragraph 15, Schedule 19 Finance Act 2016, whilst the most material taxes for the Group include corporate taxes, property taxes, employment taxes and indirect taxes.

Management of UK tax risks

We have implemented a range of policies to help us ensure that we manage and operate our business prudently while complying with applicable laws and regulations. These policies cover aspects such as conflicts of interest, anti-corruption/anti-bribery, and anti-money laundering. We have also established an Ethic Code to guide the behaviour of all our professionals and underpin the way we operate. All employees of the Group (including the Company) are expected to conduct their activities in accordance with both the letter and the spirit of these policies/principles.

The ultimate responsibility for the management of UK tax risk resides with the Company’s Board of Directors. Under the oversight of the board, the Senior Accounting Officer is formally accountable for ensuring an appropriate tax governance and control framework is in place. The Company is committed to complying fully with all applicable UK tax laws and regulations and seeks to pay its ‘fair share’ of tax.

The Company looks to manage the UK tax risk within those parameters and has established tax risk management processes that enable the identification, assessment and mitigation of key tax risks along with the accurate recording and reporting of tax to HMRC. The Company engages with external advisers to ensure compliance with applicable UK tax rules and regulations, as well as with relevant international guidelines (e.g. the OECD guidelines) at all times and to support our relationship with HMRC.

Attitude to UK Tax Planning and Level of Risk in relation to this

The Company structures its activities in a manner that is aligned with the Group’s business strategy, reflecting genuine commercial activity. The Company has a robust and comprehensive approach to managing risk. The Company’s appetite for tax risk is considered to be low and the manner in which transactions are structured is determined by the commercial needs of the business. We conduct transactions with a view to optimizing value for our shareholders, whilst remaining consistent with our principle of continued compliance with UK tax laws and regulations.

Working with HMRC

The Company seeks to meet all of its UK tax obligations on a timely basis and to provide HMRC with accurate, transparent and complete tax returns.

The Company will respond fully and promptly to any questions from HMRC about the business and the implications for its tax profiles. When requested, based on legal grounds, the Company will offer full disclosure to HMRC. The Company aims to foster a spirit of cooperation, transparency and respect in its dealings with HMRC and resolve technical uncertainties in a collaborative manner.

The Company considers that the publication of the above tax strategy complies with its duties under paragraph 16 (2) of Schedule 19 of the Finance Act 2016.

Hemplix (UK) Limited – UK Tax Strategy Statement

Hemplix (UK) Limited (“the Company”) belongs to the Neuraxpharm Group (“the Group”), a leading European specialty pharmaceutical group specialising in the treatment of central nervous system disorders, with presence in a number of European territories including the UK. We are experts in improving existing pharmaceutical forms and upgrading new products with the aim to deliver relevant improvements in the life and wellbeing of patients with neurological and psychiatric disorders. We are guided by excellence, scientific rigour, quality and perseverance.

The Company is ultimately majority owned by funds advised by the Private Equity firm Permira (“Permira”) which acquired a controlling stake in the Group on 16 December 2020. Permira has structured its investment in the Group through Permira VI Investment Platform Limited, a holding company that has investments in businesses across a number of different activities and geographies, including the UK. Whilst this tax strategy document applies to the Company, it is aligned with the principles set out in the tax strategy document published by its ultimate parent company, Permira VI Investment Platform Limited.

This document, which has been reviewed by the Company’s Board, sets out the Company’s policy and approach to conducting its tax affairs and dealing with tax risk.

This UK tax strategy statement, for the period ended 31 December 2023, covers those taxes as defined in Paragraph 15, Schedule 19 Finance Act 2016, whilst the most material taxes for the Group include corporate taxes, property taxes, employment taxes and indirect taxes.

Management of UK tax risks

We have implemented a range of policies to help us ensure that we manage and operate our business prudently while complying with applicable laws and regulations. These policies cover aspects such as conflicts of interest, anti-corruption/anti-bribery, and anti-money laundering. We have also established an Ethic Code to guide the behaviour of all our professionals and underpin the way we operate. All employees of the Group (including the Company) are expected to conduct their activities in accordance with both the letter and the spirit of these policies/principles.

The ultimate responsibility for the management of UK tax risk resides with the Company’s Board of Directors. Under the oversight of the board, the Senior Accounting Officer is formally accountable for ensuring an appropriate tax governance and control framework is in place. The Company is committed to complying fully with all applicable UK tax laws and regulations and seeks to pay its ‘fair share’ of tax.

The Company looks to manage the UK tax risk within those parameters and has established tax risk management processes that enable the identification, assessment and mitigation of key tax risks along with the accurate recording and reporting of tax to HMRC. The Company engages with external advisers to ensure compliance with applicable UK tax rules and regulations, as well as with relevant international guidelines (e.g. the OECD guidelines) at all times and to support our relationship with HMRC.

Attitude to UK Tax Planning and Level of Risk in relation to this

The Company structures its activities in a manner that is aligned with the Group’s business strategy, reflecting genuine commercial activity. The Company has a robust and comprehensive approach to managing risk. The Company’s appetite for tax risk is considered to be low and the manner in which transactions are structured is determined by the commercial needs of the business. We conduct transactions with a view to optimizing value for our shareholders, whilst remaining consistent with our principle of continued compliance with UK tax laws and regulations.

Working with HMRC

The Company seeks to meet all of its UK tax obligations on a timely basis and to provide HMRC with accurate, transparent and complete tax returns.

The Company will respond fully and promptly to any questions from HMRC about the business and the implications for its tax profiles. When requested, based on legal grounds, the Company will offer full disclosure to HMRC. The Company aims to foster a spirit of cooperation, transparency and respect in its dealings with HMRC and resolve technical uncertainties in a collaborative manner.

The Company considers that the publication of the above tax strategy complies with its duties under paragraph 16 (2) of Schedule 19 of the Finance Act 2016.