Year ending 31st December 2018

Introduction

Condé Nast Holdings Limited regards the publication of this tax strategy as complying with its obligations under paragraph 16(2) of Schedule 19 of the Finance Act 2016.

Condé Nast Holdings Limited is publishing this strategy in its capacity as Head of the UK sub-group which includes Condé Nast Publications Limited and all its UK subsidiaries (referred to as the UK Group).

This statement, approved by the board, sets out the UK Group’s approach to conducting its tax affairs and dealing with tax risks for the year ending 31 December 2018.

(1) Approach of the UK Group to risk management and governance arrangements in relation to UK taxation

The UK Group is exposed to to a variety of tax risks as follows:

Compliance and reporting risks: These are risks associated with non-compliance such as submission of late or inaccurate returns, or where systems and processes do not adequately support tax compliance and reporting requirements.

Transactional risks: Risks associated with undertaking transactions without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented.

Reputational risks: Non-financial tax risks that may have an impact our relationships with our clients, audiences, shareholders, tax authorities and the general public. Tax risks are assessed on a case by case basis, in order to arrive at well-reasoned conclusions on how each individual risk should be managed. In assessing tax risks associated with any specific situation, we will consider the legal and fiduciary duties of directors and employees; the requirement of related internal policies, the financial and commercial consequences; and the impact on relationships with our clients, audiences, shareholders & tax authorities.

Where there is uncertainty in how the relevant tax law should be applied, external professional advice will be sought to support the decision making process.

The Chief Financial Officer is responsible for identifying and monitoring tax risks across the group and keeps the board updated with significant matters on a regular basis.

(2) Attitude of the UK Group towards tax planning (so far as affecting UK taxation)

We we believe in safeguarding our reputation and relationships with clients, audiences, shareholders and tax authorities alike. Therefore, we do not promote abusive tax practices which would contravene our ethics and culture or the law.

The UK Group does not engage in tax planning in circumstances where it expects the planning to lead to an abusive result. We only engage in reasonable tax planning aligned to the interests of our stakeholders and economic activity. Where alternative routes exist to achieve the same commercial results, the most tax efficient approach in compliance with all relevant laws will be followed.

We always seek to interpret relevant tax laws and apply exemptions & incentives in a reasonable way taking external professional advice on these in appropriate cases.

(3) Level of risk in relation to UK taxation that the company is prepared to accept

The UK Group’s appetite for tax risk is governed by our overriding commitment to observing all applicable laws, rules, regulations, and reporting and disclosure requirements, when there is a requirement to do so as a result of our business transactions. We aim to pay the right amount of tax in accordance with the spirit of the law in all jurisdictions.

Where there is a level of uncertainty regarding the interpretation of a point of tax legislation, we would always seek professional tax advice and as much as possible take a position which if challenged, is more likely than not, to be seen by the tax authorities as a reasonable application of the law.

(4) Approach of the UK Group towards its dealings with HMRC

The UK Group is committed to the principles of openness and transparency in our approach to our dealings with tax authorities. All dealings with tax authorities and other relevant bodies will be conducted in a collaborative manner and will seek to achieve agreement and certainty on a real time basis wherever practicable. We aim to work positively, proactively and transparently with tax authorities, to achieve early agreement on disputed issues wherever possible.

This statement of tax strategy is approved by the board of Condé Nast Holdings Limited.

Jonathan Newhouse

On behalf of the Board of directors