Tax Policy

Orion Pharma (UK) Limited

Tax Policy

This tax strategy approved on 31st December 2021 sets out the framework for tax compliance for Orion Pharma (UK) Limited under the guidance of the parent company. Orion Pharma (UK) Limited is part of the Orion Group (“Orion”), the parent company of which, Orion Corporation, is incorporated in Finland and is over 100 years old, requires all its subsidiaries to comply with the laws, rules and regulations of the countries in which they operate. Orion Pharma (UK) Limited is a UK tax resident company.

As a company specialised in healthcare products, Orion emphasises social, economic, ecological and ethical responsibility as well as fairness and transparency in its relationships with its employees, partners, customers, authorities and other interest groups. Our key stakeholders’ trust in the company is of crucial importance for our ability to pursue business and to create added value in a sustainable manner.

The Code of Conduct is a guideline explaining the ‘company policy’, or the key principles Orion applies to its employees and to its businesses all over the Group. It also explains what is expected of each Orion employee in order to attain our business goals. The way Orion operates is also the way of its employees. Therefore the company fully expects full commitment from every employee to the practices and procedures confirmed for the company.

The Code of Conduct stands for what we mean by good business practice, as well as our approaches and expectations towards our business partners. In relation with third parties, we prioritise those who share the same ethical, social and environmental values with us. These parties also comply with good healthcare industry practices and the standard requirements concerning human rights, labour, health and safety, and environmental protection.

Everyone at Orion carries a shared responsibility for the reputation of the company and the Orion brand, and for ensuring that no-one can question our integrity or incorruptibility. Our business and activities shall be in conformity with the principles provided in the Code of Conduct in all units of the Group, independently of geographical location.

The basic pillars of our business consist of our values and our mission to build well-being:

• Appreciate each other
• Strive for excellence
• Build the future

Orion expects every one of its employees to

• Act in accordance with ethical norms and laws
• Show loyalty to Orion
• Treat colleagues and fellow employees with fairness and respect
• Take into account the interests of other interest groups such as customers, business partners, authorities and consumers in a fair and appropriate way
• Be familiar with good business practice
• Show awareness and consideration of the harmful impacts of the operations on the environment and the climate
• Demonstrate professionalism and competence when performing work duties
• Respect the United Nations Declaration of Universal Human Rights
• Commit themselves to the promotion of well-being of mankind in a way that ensures sustainability continuing life on Earth

Compliance with the law is an unconditional requirement at Orion. Each employee is expected to be familiar with the laws and regulations applicable to his/her area of responsibility.

Orion develops innovative, new, more effective, safer and more cost-efficient drugs for healthcare needs. Every employee involved in Orion’s R&D activities is requested to obey the regulatory standards and ethical principles of pharmaceutical R&D.

Orion Pharma (UK) Limited is committed to complying with all applicable tax laws and deals with the tax authorities in an open, timely, constructive and transparent way to minimise the extent of all disputes.

The management team, overseen by the managing director, are responsible for the day to day running of the company and dealing with tax matters. This is overseen by the board of directors who report directly to the group CEO. Monthly management accounts are produced for the UK business and quarterly reporting is made to the group including tax calculations which is reviewed at group level.

Orion Pharma (UK) Limited has a simplistic set up and as a result adopts a low risk stance in relation to UK taxation. Tax is reviewed quarterly when instalments are made. External tax advice and review is taken on all company tax matters which include research and development expenditure claims.

Orion’s transfer pricing policy is to ensure the correct allocation of income to each function in different countries for taxation purposes. Our policy is to apply arm’s length transfer pricing principles according to OECD guidelines in all intra-group transactions which include mainly goods and services.

NOVEMBER 2024 / CORP-208da(5)