Tax Strategy Statement

1. Introduction and scope

In accordance with the requirements of paragraph 22(2) schedule 19 of the Finance Act 2016, the tax strategy for ASHI Group Limited (the “Group”) is detailed below. Board approval was obtained on 5th August 2026 and applies for the financial year ended March 2027.

ASHI Group Limited operates solely within the jurisdiction of the UK and is subject to a number of direct taxes, including the payment of corporation tax on its profits and national insurance contributions in connection with its employees. In addition, the Group collects taxes on behalf of UK tax authorities, including payroll taxes and indirect taxes such as VAT. The Group has no overseas operations and has minimal interactions with overseas tax authorities.

2. Risk Identification, governance and management

As a group operating within one geographic and commercial market, the Group encounters new risks primarily from changes in legislation and changes in approach by HMRC and other similar bodies.

The Board of Directors holds ultimate responsibility for the Group’s tax risk management and effectiveness of controls within the Group. As part of this, the Board is responsible for setting the tax strategy, tax risk appetite and the effectiveness of tax governance and controls for the Group and the Group Finance Director has overall responsibility for its implementation. The Group Finance Director is also the Senior Accounting Officer in respect of all relevant group entities.

The Group manages tax risk as part of its wider risk and control framework. Tax risks may arise from changes in legislation, HMRC guidance or interpretation, business change, systems and process changes, payroll and VAT processes, contractor and supplier arrangements, or any significant or unusual transactions.

The Group’s finance and compliance functions regularly monitor changes in relevant legislation and regulatory developments and escalates matters to the Group Finance Director, where they may affect the Group’s tax position, reporting obligations, controls or strategy. Where required, matters are escalated to the Board or relevant governance forum.

The Group’s finance and compliance functions regularly monitor changes in relevant legislation and regulatory developments and escalates matters to the Group Finance Director, where they may affect the Group’s tax position, reporting obligations, controls or strategy. Where required, matters are escalated to the Board or relevant governance forum.

The Group enters into very few significant complex transactions. On the rare occasion where such transactions occur, or where uncertainty is present, tax advice is obtained from suitably qualified third-party advisors to support compliance with applicable law and HMRC guidance.

3. Approach to Tax planning

The Group adopts a conservative and responsible approach to tax planning. Tax planning must support genuine commercial activity and must be aligned with the Group’s wider business strategy, values and legal obligations.

The Group does not undertake arrangements that are artificial, lack commercial substance or transactions which could be deemed as aggressive tax planning, tax avoidance or tax evasion. The Group will not pursue a tax outcome where the potential legal, reputational or stakeholder risk is inconsistent with its low-risk approach.

When considering tax planning opportunities, the commercial objectives of the Group will be the key driver in whether these opportunities are pursued but with full consideration of legal and reputational implications. External advice will be obtained where the application of tax law is uncertain or where specialist input is appropriate.

4. Level of tax risk the Group is prepared to accept

The Group has a low appetite for tax risk. It aims to comply with the letter and spirit of UK tax law and to pay the right amount of tax at the right time.

The Group recognises that tax law can be complex and that reasonable differences in interpretation may arise. In such circumstances, the Group seeks to manage uncertainty through appropriate internal review, escalation, documentation and, where appropriate, external professional advice or engagement with HMRC.

The level of tax risk accepted by the Group is influenced by the requirements of law, HMRC guidance, the Group’s governance framework, the expectations of the Board and senior management, and the potential financial, operational and reputational impact of any tax matter.

5. Communication with HMRC and Similar Bodies

The group is committed to maintaining a transparent, cooperative and open relationship with HMRC. and similar bodies. The Group aims to proactively engage with and supply information to the HMRC in a timely manner. Where HMRC takes a different interpretation of the tax impact of a particular business transaction, the Group seeks to resolve the matter through open and timely engagement and where appropriate, with support from external professional advisers.

Where an error or omission is identified in information provided to HMRC, the Group will assess the matter, take appropriate corrective action and make any required disclosure in accordance with applicable requirements.

6. Review and Governance

This strategy is reviewed annually and updated as necessary to reflect changes in the Group’s operations, tax environment, governance arrangements or risk profile. It The strategy is approved by the board and made available in accordance with legislative requirements.

The Group will publish its tax strategy on the website so that it is available to the public free of charge. The latest published strategy will remain available until the next annual strategy is published, in accordance with Schedule 19 to the Finance Act 2016.