TAX STRATEGY POLICY

Bloom Fresh International Limited Tax Strategy

This statement is prepared in accordance with the requirements of Part 2, schedule 19 of the Finance Act 2016 in relation to the Financial Year end of 31st August 2023 and is applicable to Bloom Fresh International Limited and all its Affiliates (the “Group”).

This statement which is approved by the Board of Directors of Bloom Fresh International Limited, sets out the policy and approach to managing Tax Compliance and the Tax Risks of Bloom Fresh International Ltd and all subsidiaries in the UK and Overseas.

Approach to UK Tax Risk Management and Governance

The Group’s approach to Tax Risk Management and Governance is embedded within our Company Values. We believe that Corporate Social Responsibility is key in all areas of our business and especially in our dealings with Tax Risk Management and Governance.

We believe it is our responsibility to fairly contribute taxation where required and we have no intention of following a Tax Strategy that could question the Group’s reputation or damage its standing in our marketplaces.

Our policy on taxation delivers clear guidance to be used as a framework for tax decision making. Internal reporting is staffed by qualified accountants, with experience which supports compliance with our taxation policy, and ensures that management attention is given to this important area. Staff are provided with regular training to ensure they are abreast of changes in regulations and where doubt exists external taxation specialists will be tasked with ensuring compliance.

We have put in place measures to follow Transfer Pricing Policy and follow Base Erosion and Profit-Sharing regulations. This ensures that all intercompany transactions are carried out as if at arm’s length with a 3rd party.

Our systems and controls are built around our use of our Enterprise Resource Planning (ERP) system. We ensure our ERP system is frequently updated, and that all rates and calculations the system performs are monitored and reviewed to ensure they are compliant.

The Group’s largest tax risk exists in transactions outside of the day-to-day trading, and professional taxation expertise will always be sought to ensure compliance.

Attitude towards Tax Planning

The principal purpose of our tax planning is to support a commercial outcome for our activities. We seek to comply with the laws and regulations in place in the UK and all Overseas territories in which we operate, and to ensure that our tax liability properly reflects the economic reality of our activities. We aim to base our tax decisions on the best available advice. If we encounter new business opportunities that could expose us to unfamiliar areas for our Tax Planning, we will look to seek external Taxation Planning advice.

Acceptable Tax Risk

As a Group we minimise all Taxation Risk where possible. This prudent behaviour matches our Accounting Principles and ties in with our Company Values. We work closely with HMRC and the rest of Tax Administrations in all the countries where we operate and our Customer Compliance Manager (CCM) to ensure that we minimise any risk and continue to meet the Business Risk Review Criteria, so we maintain our low-risk status defined by the mentioned Tax Administrations.

Working with HMRC

Part of our Taxation Strategy is to have open and transparent relationships with HMRC and our CCM. We ensure we communicate clearly with HMRC and are proactive with our communication.

We ensure we communicate any material uncertainties with HMRC at the earliest opportunity. Any area where we have doubts or require clarification, we will contact our CCM or HMRC by any of the various methods to resolve our queries.