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5.11 Tactical® UK Tax Strategy

5.11 Tactical® UK, a branch of 5.11 International Cooperatief U.A., Tax Strategy

In accordance with Schedule 19 of the Finance Act of 2016, 5.11 Tactical® UK sets out below its tax strategy. This tax strategy is owned by the Board of Directors of Compass Diversified Holdings (CODI), the ultimate parent entity of 5.11 Tactical® UK. It will be reviewed annually, updated as appropriate and approved by the Board.

Risk Management and Governance Arrangements:

5.11 Tactical® UK’s on-going approach to UK tax risk management and governance is based on the principles of reasonable care and materiality. We maintain on going application of tax governance with strong internal controls to substantially reduce tax risk to materially acceptable levels. We maintain quarterly procedures which include identification, evaluation, monitoring and reporting of tax issues and risks. We also seek external advice to support tax decisions and document appropriately.

Attitude Towards Tax Planning (so far as affecting UK taxation):

5.11 Tactical® UK will not engage in tax planning other than that which is permitted by law and which supports genuine commercial goals. Where commercial activities and transactions may be structured in ways which have different outcomes for tax purposes, we may structure those actions in a way which legitimately provides the most advantageous outcomes. We will not engage in tax efficiencies if the underlying commercial objectives do not support the position, or if the arrangements impact upon the reputation, branch, corporate and social responsibilities of the group.

Level of Risk in relation to UK taxation Prepared to Accept:

5.11 Tactical® UK’s goal is to minimize the level of risk in relation to UK taxation always. 5.11 Tactical® UK is not prepared to accept a level of risk that exposes it to reputational harm or which could adversely impact its relationship with HMRC.

Approach Towards Dealings With HMRC:

5.11 Tactical® UK will comply with all relevant legal disclosure and approval requirements and all information will be clearly presented to HMRC as appropriate. In its dealings with HMRC, we will act in an open, honest and transparent manner. 5.11 Tactical® UK’s strategic goal is to avoid unnecessary disputes with HMRC and therefore minimize tax risk.

5.11 Tactical® UK will comply with its legal obligations and interpret legislation in a reasonable way this is aligned with the intentions of Parliament. Where genuine differences of opinion occur on the application of tax law, we will seek to resolve these with HMRC through open dialogue and with reference to the relevant legislation and case law.