Introduction

This document sets out the strategy and approach of HMD Global to conducting its tax affairs globally, including the United Kingdom (“UK”). This strategy is applicable to HMD global Oy’s branch in the UK (“UK branch”) and is in force as of the financial year ended 31 December 2017. Consequently, HMD Global regards the publication of this tax strategy as complying with the duty under Part 2, Schedule 19, of the UK’s Finance Act 2016.

HMD Global is performing its global business operations responsibly in order to meet all tax obligations in accordance with the applicable tax laws in every country of operations, including the UK.

Tax policy principles

The principles which govern HMD Global’s approach to its tax affairs: - Prepare all statutory tax compliance and reporting - Pay the right amount of tax in accordance with the tax laws - Structure transfer pricing models in accordance with the OECD Transfer Pricing Guidelines and the country-specific regulations - Consider tax in significant business decisions but not as the driver of such decisions - Maintain open and transparent relationship with all tax authorities, including the HMRC

Attitude towards tax planning

The Code of Conduct of HDM Global is to conduct all operations lawfully and with integrity. The objective is to ensure that all business arrangements are compliant with the laws and relevant regulations in the jurisdictions concerned. HMD Global does not engage in aggressive tax planning.

Tax function governance

The Board of Directors (“BOD”) of HMD Global is ultimately responsible for the business and strategy of HMD Group. Under the supervision of the BOD, the Chief Financial Officer (“CFO”) of HMD Global has ownership of HMD Group’s finance and tax operations along with all associated risks. The CFO is driving the tax function with the support of the Head of Tax of HMD Global, who reports to the CFO. The CFO has delegated the day-to-day management of the tax affairs to the Head of Tax, which includes also statutory tax compliance and reporting, as well as potential tax enquiries and tax audits globally. The tax affairs are performed either by using HMD Group’s own resources or external professional service providers, as may be needed.

Working with tax authorities

HMD Global believes in co-operative and transparent engagement with the tax authorities, with the aim of building a relationship based on mutual respect and compliance. HMD Global works with the tax authorities, includuing HMRC, to resolve any issues in a positive and professional manner and through active cooperation.