This document sets out Fosun’s UK tax strategy and how the UK entities of Fosun
Group and its Sub-groups manage their tax affairs in line with this strategy.
Approved by the General Manager of Tax Department of Fosun Group
31 December 2023
OUR APPROACH TO TAX

for the year ended 31 December 2023
This document is published by Fosun International Limited on 31 December 2023 inorder to comply with its duty under Paragraph 16(2) of Schedule 19 of Finance Act
2016 to publish a tax strategy for the year ended 31 December 2023. The headings
below follow the scheme of the legislation and related guidance that has been issued
by HMRC.
OUR PRESENCE IN THE UK ABOUT THE BUSINESS

Fosun Group
Fosun Group (hereinafter as “Fosun Group” or “Fosun”) is a family focused
multinational enterprise which includes a group of companies with a headquarter ofFosun International Limited that is listed on the main board of the Hong Kong Stock
Exchange (00656.HK) since 2007. Founded in 1992, Fosun's total assets exceed
RMB834 billion (c.GBP91.2billion) as at 30 June 2023. Fosun's mission is to provide
high-quality products and services to families around the world with its focus onindustry operations. It now operates four business segments, namely Health,Happiness, Wealth and Intelligent Manufacturing.

Health Segment
The Health segment of Fosun focuses on the ecosystem of pharmaceutical business(Fosun Pharma, Shanghai Henlius and Gland Pharma), devices and diagnosis (SisramMed) and healthcare services and products (Fosun Health). It adheres to the “4 IN”
strategy (Innovation, Internationalization, Integration and Intelligentization) tocontinuously improve its product competitiveness and brand value.

Happiness Segment
Fosun’s happiness segment is centering on brand consumption, tourism and leisure.
The platforms within the brand consumption business include Yuyuan, Lanvin Groupand Fosun Sports, which engage in businesses such as jewelry and fashion, liquor andspirits, C-end platforms, fashion brands, food, catering, beauty andhealth, sports,
cultural business and pet care. Meanwhile, Fosun Tourism Group is the platform for1

the tourism and leisure business, engaging in four businesses segments including“Club Med and Others”, “Atlantis Sanya”, “Vacation Asset Management Center”, and“Foryou Club and Other Services”.

Wealth Segment
The Group’s Wealth segment mainly consists of financial services with insurance asthe core business. The Wealth segment is divided into two major business segments,
namely insurance and asset management. The insurance business includes overseas
and domestic insurance businesses, with major member companies including Fosun
Insurance Portugal, Peak Reinsurance, Pramerica Fosun Life Insurance and Fosun
United Health Insurance. The asset management business covers asset management(investment) and asset management (property). Asset management (investment)
includes Fosun Capital, Fosun RZ Capital, HAL and BCP. The asset management(property) business covers comprehensive real estate projects in China, Asia Pacific,
Europe and the Americas, covering asset types of residential properties, officebuildings, commercial properties, hotels, infrastructure and logistics facilities, etc.

Intelligent Manufacturing Segment
Fosun’s Intelligent Manufacturing segment mainly focuses on mineral oil and gas
resources and intelligent manufacturing, and actively expand into relevant industries
with high added value of technology, such as new materials and smart mobility. The
Group’s mineral oil and gas resources business, represented by Hainan Mining
continues to maintain rapid growth. At the same time, with the vigorous developmentof intelligent manufacturing services represented by Easun Technology, othercompanies under the Group’s Intelligent Manufacturing segment are expected tobenefit from the rapid development of the industry.

Fosun UK
Fosun Group has established a wholly-owned subsidiary, Fosun Management (UK)
Limited (hereinafter as “Fosun UK”), as its regional office in the UK since June 2014.
With approximate 11 employees, Fosun UK incorporates professional team whoperforms investment research and recommends to Fosun Group the investment
opportunities in the UK and Europe regions, as well as corporate functional teams
including HR, finance and administration. Fosun UK however does not have any
decision-making functions in investment strategy or what investments to be made.

Sub-groups
Fosun Group has business interests in various sectors. As part of Fosun Group, thefollowing businesses (hereinafter as “Sub-groups”) are the major operations of Fosunin the UK:
2Silver Cross

Silver Cross is a leading UK nursery brand and engages
in the business of designing and selling nursery productincluding strollers, furniture, car seats and etc. via retailer
or consumer directly.
Resolution Property
Resolution Property is a European real estate capitalmanagement company headquartered in London.
Wolverhampton
Wolves is a professional association football club based inWanderers
Football the city of Wolverhampton, West Midlands.
Club (Wolves)
Fidelidade
Fidelidade Group is spearheaded by Fidelidade –Companhia de Seguros, S.A. (“Fidelidade”), which is thelargest insurance company in Portugal. FidelidadeGroup’s operations in the UK comprise (i) a pure UK
holding company which owns shares in a listed company,and (ii) a UK property of mixed offices and retail.
HauckAufhäuser HAL is a leading private bank in Germany with a business
Lampe
Privatbank focus on managing, preserving, serving and tradingclients’ assets. HAL adopts diverse and asset-lightAG (HAL)
business models for running four core businesses, namelyasset servicing, private and corporate banking,investment banking and asset management.
Fosun Tourism Group FTG is a global leader in family leisure and tourism and(“FTG”)
is an integral part of the Happiness segment. FTG covers
three major business areas: resorts and hotels, tourism
destinations, and services and solutions in various
tourism and leisure settings. The resorts and hotels
business consist of Club Med, a Frenchbased allinclusive leisure and vacation experience resort, Casa
Cook, a lifestyle hotel, Cook’s Club, a new-generation
trendy resort, and other brands. In the UK, Club Med
mainly conducts distribution activities, i.e. sales of stays
in Club Med resorts and transport to/from the resorts tothe customers.
RISK MANAGEMENT AND GOVERNANCE ARRANGEMENTS IN RELATION TOTAXATIONFosun and the Sub-groups operate on a global basis. The UK is one of the importantcomponents of our global business. As a responsible taxpayer, we comply with all tax
rules and regulations in those territories in which we operate. With the constantly
changing and evolving tax environment driven by OECD BEPS, EU and UN work,
Fosun and the Sub-groups’ tax affairs and tax risks are regularly reviewed. Fosun andthe Sub-groups aim to keep up-to-date with the relevant knowledge and skills to identify,3assess, manage and mitigate tax risks in order to be complied with the relevant tax
legislations.
Fosun and the Sub-groups recognize their responsibility which is to deliver value toshareholders, as well as pay taxes arising from their businesses that contribute to thesocieties where it operates.
Fosun and the Sub-groups’ UK tax strategy applies to UK taxation and taxes of all othercountries in which they operate, in respect of businesses they control. For thebusinesses that Fosun has material interests in but do not have control of, Fosun will,
where possible, exercise its influence as shareholder to ensure that those businesses’
tax strategies are aligned to.
As part of our global tax policy, our tax strategy in the UK is focused on following four
key objectives:· Payment of taxes. We seek to ensure that we always pay the tax we are legallyrequired to and comply fully with our tax obligations in all territories in which weoperate. Our objectives are to align the tax payment outcomes with the commercial
reality and where profits are generated. We aim for the tax affairs to be transparent,sustainable and well governed.
· Dealings with tax authorities. We are committed to dealing with tax authorities
openly, honestly and proactively. This includes having a regular and constructive
dialogue with the relevant tax authorities across all taxes, seeking advanceclearance where the tax treatment is uncertain and a clearance procedure isavailable, discussing contentious issues as early as possible, and making full
disclosure of key transactions in relevant tax returns. It also includes full disclosureand early notification where it becomes apparent that errors or mistakes have beenmade.

· Mitigating tax liabilities. We seek to ensure that genuine commercial transactions
are structured with clear and unambiguous legislative support so that tax liabilities
are controlled and minimized. Artificial structures without commercial or economic
substance which give a result which is inconsistent with the underlying economic
position will not be considered.
· Mitigating and controlling tax risk. Our tax strategy sets out how tax risk is
mitigated and controlled by having documented principles for the involvement of
the in-house tax function in transactions and business developments, theallocation of responsibilities between the tax function and the businesses, and theinvolvement of external advisers. These principles, which are embedded into ourcorporate policies and documented processes, procedures and internal controls,4

ensure that tax implications are fully considered on corporate transactions andbusiness developments, as well as on day to day business operations.
At Fosun Group’s level, the group Chief Financial Officer (CFO) and the General
Manager of the tax department are responsible for developing tax policy and ensuring
the policy is implemented across the group. It is the responsibility of the CFO and theGeneral Manager of the tax department to keep the Board informed of all material
developments relating to the Group’s taxation position, especially financial or
reputational risks that may arise. The Group tax department maintains oversight ofcompliance activities across the Group and must be informed of any disputes with any
revenue authority and any proposed revenue audits by local tax authorities, including
the UK.
At each Sub-group’s level, the respective CFO are responsible for the tax policy inrelation to their own business and operations. For the Sub-group which isheadquartered in the UK or has significant operations in the UK, the local in-housefinancial or tax expertise are responsible for implementing the tax policy, managing thetax risks and monitoring the day-to-day taxation administration in the UK. Fosun andeach Sub-group’s tax departments communicate with each other on a regular basis tomake sure that the key tax policy is maintained and implemented consistently acrossthe whole group.
Fosun and the Sub-groups’ tax strategy is regularly reviewed and approved by theGeneral Manager of the Tax Department of Fosun Group while the Sub-groups’ CFOs
are responsible for overseeing and implementing their respective strategies at the Subgroup’s level. This tax strategy for the year ended 31 December 2023 was approvedby the General Manager of the Tax Department of Fosun Group on 31 December 2023.
THE LEVEL OF RISK IN RELATION TO TAXATION THAT WE ARE PREPARED TO
ACCEPT
Fosun and its Sub-groups have a low tolerance and conservative respect towards tax
risk, and do not undertake transactions led by a tax planning purpose. External
stakeholders have not sought to influence the level of acceptable risk.
Fosun and the Sub-groups are not aware of any group wide tax planning scheme thataims to reduce the tax liabilities in the UK, and have a strong focus on tax complianceas compared to tax planning. Fosun and the Sub-groups have low tolerance andconservative respect for tax risk for errors or omissions and late submission of tax
returns/ tax payments for routine and established tax compliance obligations.
OUR ATTITUDE TOWARDS TAX PLANNING (SO FAR AS AFFECTING UKTAXATION)

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Fosun and the Sub-groups mainly seek tax advice from one or more leading tax
practitioners when significant tax impact or uncertain tax risks may arise from thecontemplated transactions. Both Fosun and its Sub-groups retain significant in-house
tax knowledge and are able to utilise this expertise in the management of the taxrelated obligations, and in maintaining a robust internal review process which ensuresthat we meet our filing obligations and other tax requirements, in line with the objectives
which underlie the Group tax policy.
Given the UK’s relatively low corporation tax rate in comparison with the rates of tax inthe other major territories in which Fosun and its Sub-groups operate, there is very little
focus on tax planning in the sense of avoiding or reducing UK taxation.
OUR APPROACH TOWARDS OUR DEALINGS WITH TAXING AUTHORITIESFosun and its Sub-groups are committed to develop a strong relationship with all thetax authorities including HMRC and are willing to build an open dialogue with the tax
authorities based on integrity.
Fosun and the Sub-groups have regular correspondence with HMRC. In addition, it
engages with external professional expertise to ensure compliance and accuracy.
Fosun and the Sub-groups are committed to prompt disclosure and transparency in alltax matters with HMRC and recognize that there will be areas of different legal
interpretations with that of HMRC. In such situation, Fosun and the Sub-groups willengage with HMRC in a proactive manner to achieve an early resolution.

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