Tax Strategy

Premier Paper Group - UK Tax Strategy (for the year ended 31 December 2025)

Introduction

This strategy applies to Premier Paper Holdings Limited and its UK subsidiary companies (here after referred to as ‘The Group’) in accordance with paragraphs 19 and 22 of Schedule 19 of the Finance Act 2016. Premier Paper Holdings Limited is a wholly owned subsidiary of Japan Pulp and Paper Co., Ltd, a company incorporated in Japan and listed on the Tokyo Stock Exchange.

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The Group regards the publication of this tax strategy as complying with its duty, under paragraph 16(2) of Schedule 19 of the Finance Act 2016, to publish its UK tax strategy for the financial year to 31 December 2025.

References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule 19 of the Finance Act 2016.

1. The approach of the group to risk management and governance arrangements
   1. The UK Supervisory Board / Audit Committee is ultimately accountable for ensuring that tax risks are being identified and managed with due care. Overarching responsibility for the oversight of UK Finance, tax risk identification and compliance reside with the Group’s CFO (who is a member of the UK Supervisory Board / Audit Committee).
   2. A tax risk management framework is in place which assigns responsibilities for tax compliance with line management in business areas and head office functions. Daily responsibility for tax matters come within the remit of the Group’s CFO.
   3. Tax processes and controls are assessed annually by Group Internal Audit in support of Senior Accounting Officer reporting requirements.
   4. Training is providing to staff that are involved in processes which have tax implications. In addition, training has been provided to staff more broadly about Corporate Criminal Offence (CCO) legislation. CCO risk assessments have been undertaken to ensure that necessary precautions are being taken.
   5. The UK Group’s books, records, accounts and financial statements are maintained in appropriate detail, accurately reflect its transactions and conform to applicable legal and accounting requirements.
   6. The UK Group is committed to complying with all applicable tax laws, both UK and foreign obligations.
2. The attitude of the group towards tax planning (so far as affecting UK taxation)
   7. Premier Paper Group Limited’s head office is in the UK, and its parent company is and will remain a UK tax resident company.
   8. The UK Group ensures its tax planning is aligned with its business activity, with tax being one of the factors considered when making business decisions. The Group will, where it is responsible and appropriate to do so, take steps to reduce its tax liabilities. It will claim properly available allowances, deductions, reliefs, incentives, exemptions and credits where it is beneficial to do so.
   9. The UK Group is committed to ensuring that stakeholders can understand the important elements of its tax position and that the information it provides is full, fair and accurate.
3. The level of risk in relation to UK taxation that the group is prepared to accept
   10. The low level of risk which the Group accepts in relation to UK tax matters is consistent with its overall objective of complying fully with all its tax obligations.
   11. Where tax legislation is complex, external advice is sought.
4. The approach of the group towards its dealings with HMRC
   12. The UK Group is committed to engaging with HMRC in a constructive and transparent manner and to responding to tax queries on a timely basis.
   13. The UK Group consults with HMRC about significant transactions and changes in the business or where there is uncertainty over the interpretation of tax legislation.
   14. Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

This strategy applies to all UK group companies as named below:

• Premier Paper Holdings Limited
• Premier Paper Group Limited
• Graphic and Paper Merchants Northern Ireland Limited
• Premier Paper UK Investment Limited
• Wine Box Company Limited
• Sarcina Packaging Limited

Simon Taylor

Group CFO
December 2025