UK Tax Strategy Statement

Approach to UK Tax

The ION Group (“ION”) is a privately held group of companies headquartered in the Republic of Ireland, with a number of affiliated entities registered in the UK.

ION provides mission-critical trading and workflow automation software solutions to corporates, central banks and financial institutions. We are pioneers and visionary innovators of automation technology.

This UK tax strategy statement describes ION’s policy and approach to conducting our UK tax affairs; to dealing with UK tax uncertainties and risk and our approach to working together with HMRC; all of which align with the responsible and sustainable manner in which we carry out our business operations.

This statement applies to the UK affiliated entities of ION for the financial year ended 31 December 2021. It is reviewed by the Board of Directors (the “Board”) and will be republished annually.

The strategic tax objectives that are articulated in this document are designed to establish a clear approach to the various aspects of tax reporting, compliance and risk management in relation to ION’s UK tax affairs. The Board therefore require that ION’s UK tax affairs are managed in accordance with the following principles:

Tax Governance

The Board has overall oversight of the management of taxes, and accountability is delegated to the Chief Financial Officer supported by the Global Head of Tax, and the Global Tax Team.

Given the scale of our business and the volume of our tax obligations, tax uncertainties and risks will inevitably arise from time to time with respect to the interpretation of tax laws and the nature of our compliance obligations. We proactively seek to identify, evaluate, manage and monitor tax uncertainties and risks to ensure they are appropriately addressed in accordance with these principles. Responsibility and accountability for ION’s tax affairs is agreed and decisions will be taken at an appropriate level. Where the interpretation or application of tax laws is not clear, we will take well-reasoned positions considering legal precedents and administrative positions of HMRC and engaging external advisors where considered necessary.

We have implemented a UK tax risk control framework with controls in place to minimise adverse tax impacts. As part of our Senior Accounting Officer process, internal control systems and procedures are subject to regular internal review to provide assurance that they are effective in mitigating key tax risks to acceptable levels.

Commitment to Compliance

ION intends to fulfil its tax obligations in accordance with UK tax laws and practice. We ensure that appropriate arrangements are in place to calculate accurately our tax liabilities and to pay the appropriate amount of tax on a timely basis. We disclose relevant facts and circumstances to HMRC and claim reliefs and incentives where available.

In structuring our commercial activities, we consider the tax laws of the countries within which we operate with a view to maximising value on a sustainable basis for our stakeholders. We undertake tax planning that is in line with HMRC approved tax reliefs and exemptions. We do not undertake tax planning unless it is consistent with commercial objectives to support our growth and commitment to customers and key stakeholders. We review developing tax legislation and where relevant we engage with external tax advisers, presenting any significant tax-related issues to the CFO and/or Board.

We engage with HMRC with openness, honesty, integrity, respect and fairness and in a spirit of cooperative and proactive compliance. ION provides all necessary cooperation to HMRC where lawfully requested or required and is committed to upholding all relevant tax laws. We seek to avoid disputes and, where possible, we seek to resolve any disputed matter proactively using transparent discussion and negotiation.

This statement is published on behalf of ION and its affiliated UK entities and is approved by its board. The publication of this statement is regarded as satisfying the statutory obligation under Paragraph 16(2) and 25, Schedule 19, Finance Act 2016.