Primo Water Corporation - UK Tax Strategy

Introduction

Primo Water Corporation is a leading pure-play water solutions provider in North America, the United Kingdom, Portugal, and Israel, offering home and office bottled water, coffee and iced tea for the foodservice industry, and a leader in the production of beverages on behalf of retailers, brand owners, and distributors.

Our business activities generate a variety of taxes. We pay corporate income taxes, production taxes, stamp duties, employment and other taxes. In addition, we collect and pay employee taxes as well as indirect taxes such as excise duties and VAT. The taxes we pay and collect form a significant part of our economic contribution to the countries in which we operate.

Primo UK entities are required to adhere to the following UK Tax Strategy. A list of the relevant UK companies is available on request:

Tax Governance

• Primo’s global and UK tax policies, strategies and governance is committed to the highest ethical standards and integrity, consistent with Primo’s Corporate Code of Business Conduct and Ethics (the “Primo Code”).
• The Primo Code expresses the standards of integrity and business practice that support Primo’s own unique set of values, and guides us in complying with the laws, regulations, and ethical standards that govern our business practices that define us as a company. The Primo Code is available at https://primowatercorp.com/about/governance/
• Primo UK entities strive to comply with the Senior Accounting Officer (‘SAO’) requirements and work to continuously improve the tax accounting arrangements and adapt its tax governance framework.

Tax Risk Management

• Primo engages in appropriate tax planning that supports our business and reflects commercial and economic activity. Primo does not undertake any tax planning schemes or aggressive tax planning in any jurisdiction. Tax is a key factor when making business decisions.
• Primo follows its risk management system as part of our internal control processes. We identify, assess and manage tax risks and account for them appropriately. Risk management measures are implemented and their effectiveness is monitored regularly.
• Primo conducts intercompany transactions on an arm’s-length basis and in accordance with current OECD principles.
• Primo consults with external advisors from reputable professional firms to assess tax risk and/or support our tax position, as appropriate.

Transparency

• Primo always seeks to manage the tax that we pay and the risks that arise with the best interest of our shareholders, customers, employees, governments, and communities in mind.
• Primo is committed to ensuring that stakeholders are able to understand the important elements of Primo’s tax positions and that the information it provides is full, fair and accurate.
• Primo strives to comply with relevant tax laws, regulations and obligations regarding filing of tax returns, payment and collection of tax.

Relationships with Governments

• Our core tax objective is to ensure the integrity of Primo’s reported tax obligations and to comply with all relevant tax legislation as it relates to all entities within the company.
• If disputes arise with any taxing authorities, we strive to promptly resolve any outstanding issues in a professional, transparent and constructive manner.

The UK Tax Strategy is published in order to comply with the UK Finance Act 2016, Schedule 19.

This document is reviewed annually and revised as necessary. Reviewed and approved January, 2024.