UK Tax Strategy

This document details the UK tax strategy of Ruby Intermediate 1, LLC (“Red Ventures”) and has been published to comply with the duty under paragraph 19(2) of Schedule 19 of the UK Finance Act 2016 in respect of financial year ending 31 December 2019. The UK tax strategy applies to all UK taxation and has been reviewed and approved by the CFO.

Our overall vision for Tax is compliance with the applicable rules and regulations in the jurisdictions in which the Group operates. Our vision is supported by the following strategic objectives on tax:

Tax Strategy objectives

Approach to tax risk management and governance

Red Ventures operates a wider risk management framework, which includes tax. The objective of our risk management framework is to put in place appropriate procedures, processes and controls to minimise tax risks that could affect the business.

We understand that in order to maintain our focus on getting better every day, and to continue to grow our world class learning environment, any failure or perceived failure to comply with our internal policies could negatively impact our business. To this extent, the responsibility of the day to day management of taxes rests with the VP of Tax who regularly reviews UK tax risks and controls with any material issues escalated to the CFO as deemed appropriate.

Level of risk in relation to UK taxation that the group is prepared to accept

Whilst there is no defined level of tax risk appetite, Red Ventures intends to operate within the law in the territory of operation. Red Ventures’ approach to UK taxation is compliance focused and managed in line with the internal code of conduct. In keeping with our compliance orientated approach, external advisors are engaged in the event of uncertainty or in the event of a resource gap.

Attitude to tax planning

Red Ventures is proud of its reputation for being a responsible corporate citizen and creating scalable, sustainable platforms that positively change the trajectory of people’s lives in the communities in which it operates. As such, Red Ventures’ goal is to enter into transactions with an underlying commercial purpose that supports our wider corporate objectives. Red Ventures’ objective is to structure transactions in a way that will not damage the brand’s reputation or negatively impact its stakeholders. Red Ventures Directors and Employees are committed to compliance with the company’s Code of Ethics and to maintaining high business conduct.

It is our intention that any transactions between Red Ventures and other Group companies are undertaken in line with the OECD’s Arms Length principle.

Where appropriate Red Ventures will engage external tax advisors to gain clarity over the interpretation of tax law. The engagement of external advisors is signed off by VP of Tax with any advice overseen by the CFO to ensure adherence to both Red Ventures core values and this tax strategy document.

Approach to dealing with HMRC

Red Ventures strives to achieve a timely, clear and transparent dialogue with HMRC. Where appropriate, discussions will be held over past, current and future tax events. Where there is uncertainty over the interpretation of tax law, advice will be sought as appropriate externally and/or from HMRC until sufficient clarity is attained on the situation and the appropriate tax treatment is determined.