ANNUAL TAX STRATEGY

The Devro group of companies, headed by Devro Limited (we, Devro, the Group) was acquired on 14 April 2023 by SARIA Nederland B.V. an indirect subsidiary undertaking of SARIA SE & Co. KG. (the Acquisition).

Devro strives to comply with both the spirit and the letter of all relevant tax laws and regulations in the countries where it operates, and it is committed to a transparent and open approach to reporting on tax. Our policy is to file all tax returns on time, and to pay tax as it falls due.

The Group has a low risk tolerance for uncertain tax positions in the jurisdictions in which it operates. We do not undertake any aggressive or unreasonable tax planning schemes for the purpose of tax avoidance, and broadly aim to align tax payments to revenue generation. We do not knowingly help others avoid their tax obligations.

Devro’s approach is to develop open and straightforward relationships with the tax authorities in the jurisdictions in which it trades, including the HMRC in the UK.

At the date of this strategy, Devro’s commitments on taxation are enshrined in both our Global Business Conduct Statement and Business Conduct Policy, on which training is provided. Employees across the business are also regularly required to verify their compliance with our Business Conduct Policy. Tax compliance risks are managed through the Group’s risk management framework. We expect in the months following the completion of the Acquisition, to align how Devro’s commitments on taxation will be recorded and managed in future as part of the broader SARIA group.

This tax strategy has been prepared in accordance with the requirements of section 161 of the UK’s Finance Act 2016 and of subordinate legislation (collectively the Legislation). The Board of Devro Limited reviewed this strategy on 11 May 2023 and was satisfied that it met the company’s responsibilities under the Legislation for the financial year ending 31 December 2023.