Appendix 1

UK Tax Strategy Statement pursuant to Schedule 19 of the Finance Act 2016

1. Group Overview
Singapore Telecommunications Limited (“Singtel”) and its subsidiaries (hereinafter referred to as the Group)
is one of the leading providers of a diverse range of communications services including fixed, mobile, data,internet, television, information and communications technology (“ICT”) and digital solutions to consumers,
businesses and governmental agencies.
The Group’s UK operations currently account for less than 1% of global turnover while net profit before tax for
financial year ended 31 March 2020 was less than £2.6 million.

2. Qualifying UK company’s duty to publish a company tax strategy
Finance Act 2016 requires certain qualifying UK businesses to publish their tax strategies.
(1) Amobee EMEA Limited(2) M86 Security International Limited(3) Singtel (Europe) Limited(4) Trustwave Holdings, Limited; and(5) Trustwave Limited.
(referred henceforth individually as “Company”), subsidiaries of Singtel, regards the publication of thisstatement as its compliance with Schedule 19 of the Finance Act 2016 for the financial year ended 31 March2021.

3. Risk management and governance in relation to UK taxation
Singtel, which is incorporated in Singapore and listed on the Singapore Stock Exchange, has established aBoard-approved Risk Management Framework (“Framework”) that applies to Singtel and all its subsidiaries
including the Company.
The Company’s approach to risk management and governance in relation to UK taxation is governed by theFramework which sets out our risk appetite and governance structure for managing risks and provides
guidance on our risk management approach, including a Tax Risk Management Framework for the soundgovernance of tax risk.
Under the Framework, the Board has overall responsibility for the governance of risks in Singtel and is assistedby the Audit Committee with regard to the management and oversight of tax risks. The Group Chief FinancialOfficer, under the appointment by the Audit Committee and supported by the VP of Group Tax supervises theefficacy of the Tax Risk Management Framework and our tax risk management practices.
The Company’s finance team is responsible for ensuring that the policies are implemented and adhered to.
The Company’s finance team will also update Group Finance and Group Tax on UK tax regulations changes
and highlight tax risks where necessary.

4. Approach towards UK taxation
The Company’s attitude towards tax planning in UK is guided by the Board-approved Singtel Risk Appetite
Statement. The Group is committed to achieving shareholder value without compromising our integrity, values
and reputation by risking, amongst others, regulatory non-compliance. Regulatory compliance includes tax
regulations compliance in UK where Singtel operates.
The Company is also committed to being a responsible corporate citizen in UK where tax affairs and processes
are driven by business strategies and aligned with commercial activities.
To-date, the Company has not been required to make any disclosure under the Disclosure of Tax Avoidance
Scheme. It also engages reputable tax advisors/agents for advice and assistance with its tax matters whereappropriate.

5. Level of Risk Appetite in UK
The level of risk that the Company is prepared to accept in relation to UK taxation is low.

6. Relationship with HMRC
The Company seeks to maintain collaborative and constructive relationships with HMRC. Where appropriate,
the Company will seek clarification or rulings from HMRC on material transactions or interpretation of tax law
relevant to the Company.
The Company is committed to being open and cooperative when HMRC initiates any tax audits.
Due to its limited UK operations, the Company: is not subject to UK Senior Accounting Officer requirements;
is not subject to HMRC business risk reviews; anddoes not have HMRC Customer Relationship Manager.

Published for Financial Year ended 31 March 2021