The Channel Link Enterprises Finance Group (€œthe Group€) comprises two companies: CLEF Holdings Limited, whose activity is that of an investment holding company holding the shares in its sole subsidiary, Channel Link Enterprises Finance Plc. Channel Link Enterprises Finance Plc is a securitisation company, taxable under the special tax rules for securitisation companies, SI2006/3296. Neither company has any employees.

This tax strategy document outlines how the Group manages its UK tax affairs.

The Group is committed to fulfilling its UK tax obligations. Compliance for the Group means paying the appropriate amount of tax at the right time. It involves disclosing all relevant facts and circumstances to the UK tax authorities and claiming reliefs and incentives where available.

Risk management & Governance

Overall responsibility for the Group€™s compliance with UK tax requirements and for the management of UK tax risks rests with Wilmington Trust SP Services (London) Ltd, who act as corporate service providers including acting as a corporate director to both companies. The Group€™s governance around tax matters follows formal procedures which are in line with other approved governance procedures implemented across the Group and maintains strong governance in respect of the management of its UK tax affairs. All tax compliance arrangements are subject to external review by advisors along with further advice from advisors in respect of any law changes, changes of approach or tax authority enquiries.

Local UK tax laws are managed by the Group and if there is wide-scale changes or complexities that impact the Group these are raised with the Board.

Tax Planning

In arranging or structuring its commercial activities the Group will consider, amongst other things, relevant tax laws, with a view to maximising value on a sustainable basis for its stakeholders. The Group is committed to ensuring that Channel Link Enterprises Finance Plc continues to meet the conditions to be able to be taxed in accordance with the special tax rules for securitisation companies. In certain cases, where there is significant uncertainty or complexity in relation to a tax position, external advice is sought.

The level of tax risk we are prepared to accept

In situations where applicable tax law is unclear or subject to interpretation, or a tax result or position is not free from doubt, the Group aims to consider, among other things, the commercial and other non-tax drivers and (when appropriate) guidance from and communications with the relevant tax authority. The Group intends to adopt tax positions that are supported by applicable tax law and legislative intent.

Approach to dealing with HMRC

The Group is committed to the principles of openness and transparency in its approach to dealing with HMRC, and in particular the Group commits to:

—Make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion.

— Seek to resolve issues with HMRC in a timely manner, and where disagreements arise work with HMRC to resolve issues by agreement where possible.

— Ensure all interactions with HMRC are conducted in an open, collaborative and professional manner.

This statement is intended to meet the requirements of Section 19 (2) of Schedule 19 of the 2016 Finance Act to publish an external tax strategy.