Introduction

The tax policy is mandatory for all companies in which Egmont Fonden has a controlling interest.

Egmont’s approach to tax is grounded in responsible corporate citizenship. We seek to comply with the letter and spirit of the law in every jurisdiction where we operate, to contribute our fair share of taxes, and to support a transparent tax environment to promote sustainable business.

We align our approach to tax with Egmont’s overall purpose and values, and we aim to contribute to the societies in which we operate

Policy

In Egmont we are commited to:

• be fully compliant with the spirit of tax laws across all relevant jurisdictions.
• ensure paying the tax we are legally required to pay in all the countries in which we operate.
• apply tax incentives in the manner intended by governments and fiscal authorities.
• conduct transactions between group companies on an arm’s length basis and in accordance with OECD principles.
• support tax transparency and promote responsible tax behavior.

Policy For these purposes, “tax” includes taxes borne by Egmont (e.g. corporate income taxes) as well as taxes we collect and remit for the authorities (such as VAT, payroll and other withholding taxes).

Governance and tax risk management

The board of directors reviews the tax policy annually.

The tax policy aligns with how Egmont manages risks and controls in a wider perspective.

The Chief Financial Officer (CFO) is overall responsible for the implementation of the tax policy and the management of tax risks. The Head of Corporate Accounting and Controlling holds day-to-day responsibility. Key risks and issues related to tax are considered by the board of directors.

Egmont actively seeks to identify, evaluate, monitor and manage tax risks to ensure they remain in line with objectives, and continuously seeks to improve its tax governance over time.

Egmont is exposed to a variety of tax risks:

• Tax compliance and reporting risks: Risks associated with compliance failures, such as submission of late or inaccurate returns and the failure to submit claims and elections on time.
• Transactional risks: Arising where transactions are carried out or actions are taken without appropriate consideration of potential tax consequences, or where advice received is not correctly implemented.
• Reputational risks: Non-financial tax risks that may impact relationships with stakeholders, including tax authorities and the general public.

Tax risks may arise because of:

• Complex and/or unclear legislation.
• Lack of skills.
• Insufficient finance or operational systems and processes.
• Lack of timely involvement of relevant internal and/or external expertise in business decisions.
• Insufficient tax due diligence with respect to acquisitions.

There is no prescriptive level of tax risk that Egmont is prepared to accept, but the aim is to minimise the risk as far as possible.

Egmont aims to manage tax risk similarly to any other area of operational risk across the group, and to ensure a prudent approach to accounting for uncertain tax positions. Where appropriate, Egmont seeks to engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions. However, the subjective nature of many tax rules often makes it impossible to mitigate all known tax risks.

Egmont may seek advice from external advisors related to non-routine areas where there is complexity or uncertainty in order to support Egmont in complying with the spirits and letter of the laws in the countries where Egmont operates and to mitigate potential risk.

Tax compliance and relationship with tax authorities

Egmont is committed to calculating all taxes correctly in accordance with the law and paying them when due. Statutory tax returns for all taxes should be filed correctly, contain accurate information and be submitted on a timely basis. All other tax obligations in the jurisdictions in which Egmont operates should also be fully complied with.

Egmont seeks to maintain open and transparent relationships with tax authorities and other relevant bodies in the jurisdictions in which we operate. Any errors or mistakes in tax returns will be fully disclosed and notified to the relevant tax authority as soon Tax compliance and relationship with tax authorities We bring stories to life.

as practicable. Enquiries raised by tax authorities will be dealt with on a timely basis, answered openly, and with a full response to the enquiry. Advance tax clearance for key transactions will be obtained where tax treatment is uncertain and a tax clearance procedure is available.

Tax planning

Egmont recognises its responsibility to pay the correct amount of tax in each jurisdiction. We do not engage in aggressive tax planning, which we define as the exploitation of technicalities in a tax regime or inconsistencies between regimes to reduce tax liability.

In implementing sustainable business structures, Egmont will ensure that its tax position supports the business, reflects genuine commercial activity and complies with applicable laws and regulations. The business only carries out tax planning to the extent it reflects the commercial activity of the business and is not undertaken for artificial or purely tax-motivated reasons. In the spirit of the law, we may seek to benefit from legislative reliefs or incentives, such as capital allowances and tax deduction for charitable donations. In general, we try to avoid double taxation. Upon acceptance of incentives or reliefs offered by governments, Egmont will ensure that the implemented incentives align with the legislative intent of the incentives offered.

Transactions between group companies follow arm’s length principles and OECD transfer pricing guidelines. This ensures that Egmont’s global profits are properly allocated to the jurisdictions in which those profits are generated based on sound commercial activities.

Egmont supports international initiatives at OECD and EU level which discourages aggressive tax planning and tax avoidance. In line with these principles, Egmont exercises caution in its portfolio investments and does not invest in companies incorporated or tax resident in:

     a. Jurisdictions deemed “not compliant” by the OECD’s Global Forum on Transpa      rency and Exchange of Information for Tax Purposes1 , at the time of the investment.

     b. Jurisdictions included on the EU list of non-cooperative tax jurisdictions2 , at      the time of the investment.

1 Reference is made to the OECD’s website https://www.oecd.org/en/networks/ global-forum-tax-transparency/resources/ exchange-of-information-on-request-ratings. html 2 Reference is made to the European Commission’s website https://ec.europa.eu/ taxation_customs/tax-common-eu-list_en.

International developments and transparency

Egmont provides information about its tax position in accordance with regulatory requirements and continuously monitors international tax legislative developments and initiatives promoting responsible tax behaviour and tax transparency. We use best effort to comply with evolving international transparency and anti-avoidance regimes and to respond to stakeholder’s need for additional information regarding Egmont’s tax affairs.

International developments and transparency Regarding Egmont’s companies incorporated in the UK3:

Egmont regards the publication of this tax policy as complying with the duty under paragraph 16(2) Schedule 19 Finance Act 2016 to publish a tax policy for the financial year ending 31 December 2025.

3 UK companies covered by this tax policy:

• Egmont Holding Limited
• Story House Egmont Limited
• Egmont Publishing Limited
• Avalanche Studios Group Limited
• Supermassive Games Limited
• Supermassive Games 1 Limited
• Supermassive Games 2 Limited
• Supermassive Games 3 Limited
• Starshape Games Limited
• S360 Digital UK Ltd