ANTI-TAX EVASION VALUE STATEMENT

In light of the Criminal Finances Act 2017 (“Criminal Finances Act”), Beauchamp Estates (Mayfair) Ltd and its subsidiaries (“Beauchamp Estates” or the “Company”) has adopted a statement of our corporate values on anti-facilitation of tax evasion. It is our policy to conduct all our business dealings in an honest and ethical manner. The value statement governs all our business dealings and the conduct of all persons or organisations who are appointed to act on our behalf.

We request all our employees and all who have, or seek to have, a business relationship with Beauchamp Estates, to familiarise themselves with our anti-tax evasion value statement and to act at all times in a way which is consistent with this statement.

Beauchamp Estates has a zero-tolerance approach to all forms of tax evasion, whether under UK law or under the law of any foreign territory or jurisdiction.

Employees and Associates of the Company must not undertake any transactions which:

(a) cause the Company to commit a tax evasion offence; and or

(b) facilitate the commission of a tax evasion offence by any third party (whether they are an associate of the Company or not).

We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

For the purposes of the above statement the following definitions apply:

Associates includes company contractors or an agent of the Company or any person who performs services for and on behalf of the Company who is acting in the capacity of a person or business performing such services.

Tax Evasion means an offence of cheating the public revenue or fraudulently evading UK tax as defined in the Criminal Finances Act and is a criminal offence.

Foreign Tax Evasion means evading tax in a foreign territory or jurisdiction, provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK.

Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax or tax in a foreign jurisdiction by another person, or aiding, abetting, counselling or procuring the commission of that offence. Tax evasion facilitation is a criminal offence.

Tax evasion is not the same as tax planning. Tax planning is not illegal and involves taking steps, within the bounds of the law, to minimise tax payable (or maximise tax reliefs).

Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, stamp duty land tax, national insurance contributions and duty (and their equivalents in any non-UK jurisdiction) and any other form of taxation (however described).

January 2023