This document, approved by the board of Hachette UK, sets out the Group’s approach toconducting its tax affairs and dealing with tax risks in compliance with schedule 19 of theFinance Act 2016 for the year ending 31 December 2023.
The Hachette UK Group is committed to:•

Following all applicable laws and regulations relating to its tax activities and submitting
all returns by their due dates.

•Maintaining an open and honest relationship with the tax authorities based oncollaboration and integrity.

•Applying diligence and care in our management of the processes and procedures bywhich all tax related activities are undertaken and ensuring that our tax governance isappropriate.

•Using incentives and reliefs to minimise the tax cost of conducting our business while
ensuring that these reliefs are not used for purposes which are knowingly contradictory
to the intent of the legislation.

Risk management
Managing the Group’s tax affairs is a complex process across many functional areas of thebusiness and as such there will inevitably be risks of error or omission within thoseprocesses (tax risks), which may result in the incorrect application of tax rules or calculationof tax returns. Eliminating tax risks entirely is impossible. Therefore, the Group’s attitude
towards the level of control required over the processes designed to reduce these tax risks
is driven by the likelihood of occurrence and scale of the impact of each risk.
The identified tax risks are then assessed on a case-by-case basis, allowing the Group toarrive at well-reasoned conclusions on how each individual risk should be managed. Where
there is uncertainty in how the relevant tax law should be applied, external advice may besought where applicable to support the Group’s decision-making process.
When reviewing the tax risks associated with a specific decision or action, the Groupensures that the following are considered:•The legal and fiduciary duties of directors and employees.

•The requirements of any related internal policies or procedures.

•The maintenance of the Group’s corporate reputation, with regard to the way weinteract with the communities around us.

Tax planning
The Group has clearly defined lines of responsibility for its tax affairs, ensuring that they aredealt with at an appropriate level.

The Group’s tax planning aims to support the commercial needs of the business by ensuringthat the companies’ affairs are carried out in the most tax efficient manner whilst remaining
compliant with all relevant laws. The tax function therefore aims to be involved incommercial decision-making processes and provides appropriate input into businessproposals to ensure a clear understanding of the tax consequences of any decisions made.
In cases where the tax guidance is unclear or the Group does not feel it has the necessary
expert knowledge to assess the tax consequences adequately, external advice may besought to support the Group’s decision-making process.

Approach towards dealings with HMRC
The Group is committed to the principles of openness and transparency in its approach todealing with HMRC. In particular, the Group is committed to:•Making fair, accurate and timely disclosure in correspondence and returns, andresponding to queries and information requests in a timely fashion.

•Seeking to resolve issues with HMRC in a timely manner, and where disagreements arise,working with HMRC to resolve issues by agreement where possible.

•Being open and transparent about decision-making, governance, and tax planning.

•Reasonably believing that transactions are structured to give a tax result which is notinconsistent with its economic consequences (unless specific legislation anticipates thatresult), nor contrary to the intentions of Parliament.

•Interpreting the relevant laws in a reasonable way, and ensuring transactions arestructured consistently.

•Ensuring all interactions with HMRC are conducted in an open, collaborative, andprofessional manner.

Companies to which this strategy document relates
As the Hachette UK group of companies is part of a wider, global group, Vivendi SE,registered in France, the wider group’s tax strategies are dealt with across other locations. It
should be noted that these strategies do not directly affect the process of compliance withUK tax laws and regulations.

The wider group owns UK companies that are not under the control and responsibility of theHachette UK group and, it is for this reason that a list of UK companies that this document
covers are listed in the following appendix.
Appendix – list of companies under the tax responsibility of the Hachette UK group as at
31st December 2023
Hachette UK (Holdings) Limited
The Orion Publishing Group Limited
Octopus Publishing Group Limited
Little Brown Book Group Limited
Hachette UK Limited
Headline Publishing Group Limited
Bookpoint Limited
Hodder & Stoughton Limited
Quercus Editions Limited
Storyfire Limited
Summersdale Publishers Limited
Hachette UK Distribution Limited
Short Books Limited
Laurence King Publishing Limited
Illuminate Publishing Limited
John Catt Education Limited
Welbeck Publishing Group Limited
Carlton Books Limited
Welbeck Publishing Group Services Limited
Mortimer Books LimitedAndrẽ Deutsch Limited
Welbeck Fiction Limited
Welbeck Non-Fiction Limited
Welbeck Children’s Limited

Company registration no. 03701589
Company registration no. 02663988
Company registration no. 03597451
Company registration no. 02304585
Company registration no. 02020173
Company registration no. 02782638
Company registration no. 00978415
Company registration no. 00651692
Company registration no. 05127683
Company registration no. 07893911
Company registration no. 03419533
Company registration no. 03541391
Company registration no. 03676036
Company registration no. 01263586
Company registration no. 07470163
Company registration no. 05762466
Company registration no. 11452965
Company registration no. 02625229
Company registration no. 11643182
Company registration no. 05156636
Company registration no. 02565846
Company registration no. 12142267
Company registration no. 12142220
Company registration no. 12142275