UK Tax Strategy of the HOYA Group
March 29, 2024
The publication of this statement is in accordance with the statutory requirements under Paragraphs
19(2)1 and 22(2)2, Schedule 19 of the UK Finance Act 2016. This statement applies to all entities andbranches of the HOYA Corporation and its related companies (the "HOYA Group") in the UK from thedate of publication until it is superseded.
Unless otherwise stated, references to "HOYA UK" mean all UK entities and branches within theHOYA Group.
Company Background
The Hoya Group is engaged in the information technology and life care businesses. The company
operates in the Americas, Europe, the Middle East and Africa (EMEA), and Asia Pacific. It is
headquartered in Tokyo, Japan.
The HOYA Group believes that the key to earning the trust of stakeholders is not only the HOYA
Group's observance of laws and regulations but also the fair and faithful conduct of all Hoya Group
employees with high ethical standards. Based on this recognition, in 1997 HOYA formulated the HOYA
Business Conduct Guidelines 3 which clearly indicate the standard of conduct for each and every
employee. The Guidelines detail, in particular, the initiatives related to legal compliance, including tax
compliance, and the Group-wide efforts made to enforce such measures.
Risk Management and Governance Arrangements
HOYA UK has effective tax control measure in place to identify tax risks, escalate the risks to the global
or regional headquarters and manage those risks. HOYA UK is committed to conducting the company's
tax affairs in accordance with the following objectives:Comply with all relevant laws, regulations, reporting, and disclosure requirements,



Apply diligence and care in the management of the processes and procedures by which all tax
related activities are undertaken, and ensure that appropriate tax governance procedures are in place,Seek external advice to support tax decisions (where appropriate), and

Act in accordance with the HOYA Business Conduct Guidelines and implement the HOYA
Group's core ethical behaviors and values.

Attitude of the group to tax planning (so far as affecting UK taxation)
In alignment with the HOYA Group's core values, HOYA UK is committed to paying all the taxes thatit owes in accordance with the letter and spirit of all tax laws applying to its operations. HOYA UK will
not engage in tax planning other than that which is permitted by law and which supports genuine

1 This tax strategy is published by Vision Ease Lens Europe Limited.
2 This tax strategy is published by Pentax U.K. Limited, HOYA LENS U.K. Limited, WASSENBURG Limited,

ReadSpeaker Limited, HOYA Corporation Europe branch and SEIKO Optical Europe GmbH U.K. branch.
3 https://www.hoya.com/wp-content/uploads/2022/07/HOYA_COC_042822_English.pdf

1commercial aims. HOYA UK will consider the different tax outcomes when deciding how to undertake
business transactions and may consider the most tax efficient way to conduct its business transactions
whilst respecting and complying with the spirit and letter of the law. HOYA UK, however, does notparticipate in aggressive tax planning for the purposes of tax avoidance or engage in tax schemes thatgo against the intention of the legislative authority.

The level of risk in relation to UK taxation that the group is prepared to accept
HOYA UK's aim is to minimize the level of risk in relation to UK taxation at all times. HOYA UK is
not prepared to accept a level of risk that exposes it to reputational harm, or which could adversely
impact its relationship with the HMRC.

Approach to dealings with HM Revenue and Customs ("HMRC")HOYA UK's aim is to be open and transparent and to have a professional, courteous and constructive
relationship with HMRC. HOYA UK commits to making full and accurate disclosures in tax returns
and in its correspondence with HMRC. Where disputes arise with HMRC (or other tax authorities), inareas of doubt, or where legal interpretations differ, HOYA UK will endeavor to tackle the matter
promptly and to resolve it in a responsible, open, and timely manner.

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