Mandarin Oriental Group - Tax Strategy

In accordance with Schedule 19 of the Finance Act 2016, we set out below the tax
strategy of Mandarin Oriental Group’s UK companies* (“the Group”). We believe that
this strategy constitutes good corporate practice in the area of UK tax management
and tax transparency, while balancing the interests of our stakeholders.
Overall Commitment
The Group will comply with its tax obligations which include making all appropriate
returns covering all areas of UK taxes and ensuring the correct amounts of UK taxes
are paid by the due dates.
Working with the HMRC
The Group will maintain an open and proactive dialogue on UK tax matters withHMRC to foster a strong and transparent relationship. We will meet with the HMRC
when requested or where otherwise necessary, to discuss relevant material UK tax
issues impacting the Group and strive to resolve any differences in a timely andconstructive manner.
Tax Risk Management
When interpretation of the law is uncertain, the Group may seek guidance from theHMRC at the time or refer to it when tax returns are being prepared and/orfiled. External advice may also be sought on matters of uncertainty or where there is
no relevant specialist knowledge or experience in-house.
The Group operates a risk-based system of controls, processes and training in orderto manage tax risks and minimise instances of error. The Group has a low tolerance
for tax uncertainty. A high standard of compliance by operational management
teams with procedures in relation to tax is regularly tested by the Group’s internal
audit processes and finance/tax executives who report their findings to senior
management, and the Group’s Directors and shareholders.
Approach to Tax Planning
The Group adopts a prudent and low risk approach in tax planning. It will only utilise
tax planning measures and opportunities for obtaining tax efficiencies where thesecomply with tax legislation, and when such tax planning is aligned with thecommercial and economic activities of the Group. The Group will not use artificial
structures that are intended for tax avoidance without bona fide business purpose,
have no commercial substance or do not meet the generally understood intention of
UK or international law.
The Group has a zero-tolerance policy towards tax evasion, any deliberateconcealment of taxable income and benefits, or facilitating others in undertaking suchactivities.

Corporate Governance
The Group’s Regional Finance Manager based in London manages the Group’s tax
function and consults with the tax team of its global parent company. The Regional
Finance Manager oversees the administration of the Group’s tax accounting
treatment and reporting standards, in accordance with the Group’s overall tax
strategy. The Group’s Directors have ultimate responsibility for the Group’s tax
strategy and ensuring its principles and approach are adhered to.
The Group follows a Code of Conduct to which all employees are required tosubscribe and adhere to. In addition, the Group has issued policies, procedures andguidelines to establish standards and implement best practices and principles forGroup employees to follow in the course of conducting its business operations in theUK.
The above document has been approved by the Group’s Directors on behalf of theGroup and applies for the year to 31 December 2023 and subsequent periods. The
Group’s tax strategy (which will be reviewed at least annually) will remain in effectuntil any amendments are approved by the Group’s Directors.

*The Mandarin Oriental Group’s UK companies comprise of the following legal entities: Mandarin Oriental
Hyde Park (Investment) Limited, Mandarin Oriental Hyde Park Limited, Mandarin Oriental London Limited,Mandarin Oriental Residences Management (UK) Limited and Mandarin Oriental (UK) Limited.