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17³Ô¹Ï advocates for public policy solutions that promote innovation, the global economy, and our industry interests. 17³Ô¹Ï is committed to engaging in public policy processes relevant to our operations in areas such as innovation and IP, taxation, global trade, and workforce.
17³Ô¹Ï¡¯ Political Activities Policy
With respect to political activities undertaken on behalf of 17³Ô¹Ï, the company is committed to compliance with applicable laws, rules, and regulations including, but not limited to, lobbying registration and disclosure laws, ethics rules, the Foreign Corrupt Practices Act, and anti-bribery laws worldwide.
Advocacy
17³Ô¹Ï may engage in direct advocacy with government officials on public policies, legislation, and regulations relevant to our company. The company may also engage in indirect advocacy through trade and industry associations, which are selected for their integrity and alignment with the policy interests of 17³Ô¹Ï and the broader tech community. Trade and industry associations represent broad and varying interests, so 17³Ô¹Ï¡¯ involvement with a particular association does not mean the company endorses its entire agenda.
All 17³Ô¹Ï advocacy via trade associations must be reviewed and approved in advance by Government Affairs.
Political Contributions
In fiscal 2024, 17³Ô¹Ï established 17³Ô¹Ï PAC as a separate segregated fund, as provided in U.S. federal law, to accept voluntary contributions from certain eligible employees and to make limited, disclosed contributions to support the campaigns of candidates for U.S. Congress who share 17³Ô¹Ï' legislative priorities and policy positions. While 17³Ô¹Ï defrays the administrative costs of operating the separate segregated fund, as permitted by U.S. law, 17³Ô¹Ï does not deposit corporate general treasury funds into it, and does not otherwise make contributions to political candidates, political parties or political action committees.
17³Ô¹Ï advocates for public policy solutions that promote innovation, the global economy, and our industry interests. 17³Ô¹Ï is committed to engaging in public policy processes relevant to our operations in areas such as innovation and IP, taxation, global trade, and workforce.
Individual Political Activity
17³Ô¹Ï employees are free to participate in political activities or contribute to political parties and candidates so long as they do so as individuals and in a personal capacity, not on behalf of 17³Ô¹Ï or that could be viewed in any way as being on behalf of 17³Ô¹Ï.
No employee may engage in grassroots lobbying activities where other employees are encouraged to contact government officials on an issue.
Employees may work in a personal capacity with a particular industry or trade association if pre-approved through 17³Ô¹Ï¡¯ Conflicts of Interest Portal and as long as the employee does not suggest in any way that he/she is representing 17³Ô¹Ï.
17³Ô¹Ï Trade Association Memberships
17³Ô¹Ï - United Kingdom Tax Strategy
Introduction
17³Ô¹Ï. (¡°17³Ô¹Ï¡±) is the U.S.-based parent of a multinational group that operates in the Electronic Design Automation, semiconductor IP, and software security and quality markets. 17³Ô¹Ï is an SEC registrant and NASDAQ listed company.
This document is a statement of the strategy of 17³Ô¹Ï (Northern Europe) Limited ("17³Ô¹Ï UK"), which is an indirectly held UK subsidiary of 17³Ô¹Ï, regarding UK taxation.
17³Ô¹Ï and 17³Ô¹Ï UK intend this statement to meet obligations with respect to Section 161 and paragraph 22 of Schedule 19 of the United Kingdom Finance Act 2016.
Risk management, risk appetite, and governance arrangements
17³Ô¹Ï maintains written policies applicable to all tax risks on a global basis. A goal inherent in 17³Ô¹Ï¡¯ policies and practices is achieving tax certainty through effective identification, evaluation, and management of tax risk. In addition, as an SEC registrant, 17³Ô¹Ï complies with standards for financial and internal controls that are among the highest in the world.
The Senior Vice President of Corporate Planning, Tax & Treasury is responsible for managing all tax risks, undertaking an annual review of 17³Ô¹Ï¡¯ overall tax strategy with 17³Ô¹Ï¡¯ CFO and Audit Committee. A supporting team of qualified and experienced in-house tax and finance professionals manage 17³Ô¹Ï¡¯ routine tax matters. This includes tax reporting compliance, tax authority relations, and financial reporting obligations, as well as supporting 17³Ô¹Ï¡¯ business functions to analyze potential transactions and identify, manage, and comply with relevant tax requirements.
17³Ô¹Ï obtains legal and tax advice to ensure adherence to applicable tax law and affirmatively engages with tax authorities, particularly where tax outcomes are significant or uncertain. Material matters are escalated to various levels of management and the Audit Committee, as directed by policies.
These policies and principles apply equally to the UK.
In general, 17³Ô¹Ï considers that it maintains a low threshold level of acceptable tax risk.
Attitude of the business toward tax planning
17³Ô¹Ï and 17³Ô¹Ï UK align their tax planning with their worldwide commercial activities and business objectives. Substantive changes within the business, such as acquisitions and expansion into new territories or markets, may necessitate planning to ensure efficient and appropriate taxation outcomes. 17³Ô¹Ï and 17³Ô¹Ï UK do not undertake aggressive tax planning but may avail of government-sponsored tax incentives in various forms for which the business activities of 17³Ô¹Ï qualify.
Both 17³Ô¹Ï and 17³Ô¹Ï UK apply high ethical standards in complying with applicable global tax laws and regulations.
Relationship with Her Majesty¡¯s Revenue & Customs (HMRC)
17³Ô¹Ï and 17³Ô¹Ï UK maintain high ethical standards in their dealings with all tax officials. 17³Ô¹Ï UK has met all its compliance obligations in relation to all UK taxes. In the past, 17³Ô¹Ï UK has sought and, where possible, will in the future seek, advance assurance with HMRC on UK tax matters that are significant or uncertain.
This statement is made pursuant to Section 161 of the United Kingdom Finance Act 2016 and was approved by the Directors of 17³Ô¹Ï (Northern Europe) Limited on 19 December 2024 and is effective as of that date.
Published: 19 December 2024.
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