This document, approved by the board of Hachette Partworks Ltd. (“Company”), sets out the Company’s approach to conducting its tax affairs and dealing with tax risks for the year ending 31 December 2018.

Hachette Partworks is a company dedicated to publishing collectible magazines.

Hachette Partworks is committed to:

Following all applicable laws and regulations relating to its tax activities and submitting all returns by their due dates.

• Maintaining an open and honest relationship with the tax authorities based on collaboration and integrity.

• Applying diligence and care in our management of the processes and procedures by which all tax related activities are undertaken and ensuring that our tax governance is appropriate.

Risk management

The identified tax risks are assessed on a case by case basis, allowing the Company to arrive at well-reasoned conclusions on how each individual risk should be managed. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the Company’s decision-making process.

When reviewing the tax risks associated with a specific decision or action, the Company ensures that the following are considered:

• The legal and fiduciary duties of directors and employees.

• The requirements of any related internal policies or procedures.

• The maintenance of the Company’s corporate reputation, with particular regard to the way we interact with the communities around us.

Tax planning

The Company has clearly defined lines of responsibility for its tax affairs, ensuring that they are dealt with at an appropriate level.

In cases where the tax guidance is unclear, or the Company does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought to support the Company’s decision-making process.

Approach towards dealings with HMRC

The Company is committed to the principles of openness and transparency in its approach to dealing with HMRC. In particular, the Company is committed to:

• Making fair, accurate and timely disclosure in correspondence and returns, and responding to queries and information requests in a timely fashion.

• Seeking to resolve issues with HMRC in a timely manner, and where disagreements arise, working with HMRC to resolve issues by agreement where possible.

• Being open and transparent about decision-making, governance and tax planning.

• Reasonably believing that transactions are structured to give a tax result which is not inconsistent with its economic consequences (unless specific legislation anticipates that result), nor contrary to the intentions of Parliament.

• Interpreting the relevant laws in a reasonable way and ensuring transactions are structured consistently.

• Ensuring all interactions with HMRC are conducted in an open, collaborative and professional manner.

Company to which this strategy document relates

This strategy applies to Hachette Partworks Ltd. only (Company reg. number: 03642341). As the Company is part of a wider, global group, Lagardère SCA, the wider group’s tax strategies are dealt with across other locations. It should be noted that these strategies do not directly affect the process of compliance with UK tax laws and regulations.

The wider group owns UK companies that are not under the control and responsibility of Hachette Partworks.