UK Tax Policy of JALUX Inc. for fiscal year ended 31 December 2019
This document, published on 31th March 2020, fulfils the requirements to publish a tax
strategy in accordance with Paragraphs 22 of Schedule 19 of the Finance Act 2016.

1. Tax risk management and governancea. Overview
The JALUX Group has a low tolerance for tax risk, while JALUX Inc. (JALUX) considers the tax
risk of its UK branch to be low.

b. Management of tax affairs in the UK
JALUX UK branch manages its own tax affairs. The ultimate responsibility for payment of therelevant taxes in the UK rests with the Managing Executive Officer (MEO) of JALUX. The Managerof the JALUX UK branch has the authority to consult with external tax advisers or Her Majesty`s
Revenue and Customs (HMRC) on matters which the Manager and staff of the UK branch do nothave the knowledge or expertise to administer.

c. Oversight of tax affairs in JapanThe Manager of JALUX UK branch will share audited financial statements and other tax
information, and consult on significant financial matters (including those related to taxation), withthe Finance and Accounting Department of the JALUX Group based in its headquarters in Tokyo.

The Finance and Accounting Department may request further information on accounting and taxmatters to JALUX UK branch in order to further manage tax risk. This Department also consultswith external advisers on tax matters it does not have the knowledge or expertise to administer,as part of the JALUX Group’s overall tax risk management.

d. Ultimate responsibility for taxation
In the JALUX Group worldwide, the Representative Director/Chief Executive Officer (CEO) ofJALUX has ultimate responsibility for compliance with tax regulations.

e. Group Code of Conduct
The Code of Conduct of the JALUX Group, available here, sets out the Group’s commitment tocompliance with all legislation applicable to it, including tax legislation.

2. Tax planninga. Overview
The JALUX Group is aware of and committed to its corporate responsibility to meet its tax
obligations in the UK and worldwide.

b. Motive for tax planning
As part of its overall commercial strategy, the JALUX Group may utilize tax incentives establishedby governments and fiscal authorities, including HMRC, in the manner intended.

c. Transfer pricing
The JALUX Group is committed to compliance with transfer pricing regulations and guidelines ineach jurisdiction where it operates, including the UK, and also to compliance with the OECD
Guidelines on Transfer Pricing for Multinational Enterprises, in line with the Group’s internaltransfer pricing policy.

3. Relationship with HMRC
a. Overview
The JALUX Group is committed to maintaining an open, transparent and constructive relationshipwith HMRC based on mutual respect and trust.

b. Consultations with HMRC
The JALUX Group seeks confirmation and clarification from HMRC in cases of uncertainty withregard to current, future and past tax issues to ensure it complies with the UK tax legislation.

c. Disagreement with HMRC
Should HMRC disagree with items included in a submitted tax return or any other tax events arise,
if due to error, the JALUX Group will amend the error without delay, abide by HMRC’s instructions
and pay any additional tax, interest and penalties required. If the disagreement is the result of adifference in interpretation of the law between the JALUX Group and HMRC, the JALUX Groupwill explain the position it has taken to HMRC.