OpenText Approach to Global Tax Management, Governance and Transparency
The following tax principles outline OpenText’s approach to management of income, indirect taxes andemployment taxes in all countries in which OpenText operates, and reflect our position that tax is an
important interrelated component of our overall Environmental, Social and Governance (ESG)
responsibility and sustainable long-term performance.
1. Responsibility for Principles Relating to Governance, Tax Risk Management and Supporting
Control Framework
Development of and adherence to tax management principles is the responsibility of senior leadershipwithin the organization:• the Executive Vice President and Chief Financial Officer, Senior Vice President and Chief
Accounting Officer, and Vice President, Tax for income and indirect taxes;• Executive Vice President, Chief Human Resource Officer for employment taxes
The senior leadership’s effort to apply consistent standards to mitigate tax risk is supported by regional
tax management (Americas, EMEA, APAC) and by functional tax management (indirect tax, transferpricing) having global responsibilities.
The senior leadership provides regular updates to, and receives guidance from, the Chief Executive
Officer on tax matters, and reports quarterly to the Audit Committee of the Board of Directors, as well
as OpenText’s full Board of Directors on any material tax developments to ensure appropriate oversight.
2. Compliance with Tax Laws
OpenText is committed to accurate and timely tax compliance. We comply with all applicable tax laws in
the jurisdictions in which we operate and have a taxable presence and make all required disclosures andtax payments on a timely basis. In the event of claiming government sponsored tax incentives, weensure they are aligned with applicable statutory and regulatory frameworks.
3. Tax Planning
Our tax planning activities align with OpenText’s business model with a view to enhancing value in asustainable manner for our shareholders. OpenText’s strategic tax planning and optimization efforts aresupported by commercial and economic substance and reflect reputational considerations in-line withour culture and values.
Our intercompany group transactions employ best practices with a goal to comply with the “arm’slength standard” featured in local transfer pricing laws and the guidelines of the Organization for
Economic Co-operation and Development (OECD).
4. Tax Risk Management
OpenText exercises internal controls over processes for tax compliance, planning, tax payments andfinancial reporting of tax and assesses their effectiveness on a quarterly basis. We also continuallymonitor developments in tax jurisprudence and changes in tax laws to ensure consistent compliance.

Before we implement transactions having significant tax implications, we often seek input and review
from leading external tax advisors, and do not undertake tax positions which management determines
are not sufficiently likely to be sustained upon review from tax authorities.
Our internal processes also regularly evaluate, manage and monitor tax risks. We have clearly definedinternal processes for all employees to raise any questions or concerns in accordance with our Code ofBusiness Conduct and Ethics.
We reflect implications of tax risk in our consolidated financial statements as required by applicable
Generally Accepted Accounting Principles (GAAP).
5. Interaction with Tax Authorities
Our interactions with tax authorities are performed with openness, professional integrity and respect.
At times, we use approaches such as advance rulings to increase certainty of outcome of significant
transactions. We generally attempt to resolve any tax disputes through various alternatives ofadministrative appeals before proceeding to tax litigation.
6. Advocacy in Public Tax Policy
Through professional associations and industry specific groups, we monitor ongoing policy proposals
and at times directly support advocacy of positions which balance government revenue needs withmaintenance of sustainable investment conditions.
7. Transparency
We fully comply with disclosure requirements pursuant to financial reporting standards and applicable
tax laws and regulations. We publicly disclose:• Consolidated group level effective income tax rate;• Total income taxes paid for the consolidated group; and• Summary of our significant uncertain tax positions and location of major tax audits.
We also comply with the requirement to prepare the Country-by-Country Report (CbyCR) for theconsolidated group and provide it to the Canada Revenue Agency (CRA). The CRA shares the CbyCR withany countries that participate in an intergovernmental exchange of that information. OpenText’s CbyCR
is therefore available to all countries where tax authorities have agreed to the standards developed by
the OECD.