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Optum UK 2021 tax strategy

The UK companies listed below (collectively, the "UK Companies") are part of the wider corporate group wholly owned by the US parent organisation business, UnitedHealth Group Incorporated (the "Group"). The Group is a diversified healthcare business and is involved in the provision of health benefits and services, including (but not limited to) clinical care resources as well as information and technology to meet the evolving needs of a changing health care environment.

The UK companies provide a range of consultancy and technology-assisted services to business clients and also to organisations within government and the public sector (including both the UK government and the National Health Service ("NHS"))

This tax strategy applies to the UK Companies and complies with the statutory obligations of section 161 and paragraph 19(2) of Schedule 19 of Finance Act 2016.

Approach to risk management and governance arrangements in relation to UK taxation
The UK companies want their tax affairs to be transparent and compliant with tax legislation and recognise that managing tax compliance is increasingly complex. Our internal structure is set up to ensure:

  • We meet all UK tax requirements, file all UK tax returns and make applicable UK tax payments.
  • The Board of Directors of each UK Company understands the importance of tax compliance and how it is achieved.
  • There is a constant dialogue between the Board of Directors of the various UK Companies and those individuals tasked with the operation of our finance function regarding the way our business manages its tax risks.
  • We keep under review how we meet our tax obligations by seeking external tax advice (as needed) and also how we manage our relationship with tax authorities.

The UK Companies are subject to the senior accounting officer rules, which require a senior employee of the Group personally to oversee UK tax compliance. The Group's senior accounting officer is a member of the boards of directors of each of the Group's active trading and holding companies.

Attitude to tax planning, as it affects UK taxation
The UK companies undertake tax planning as part of our overall business strategy. Professional advice is sought on a transactional basis, with the depth of such advice being driven by our assessment of the risk presented by each opportunity.

The UK companies do not undertake aggressive tax planning, the sole purpose for which would be obtaining a tax advantage. The UK companies have a responsibility to minimize their tax risk and their exposure to negative publicity through non-compliance with tax laws.

Level of risk in relation to UK taxation that we are prepared to accept
The UK companies see compliance with tax legislation as key to managing our tax risk. The UK companies understand the importance of tax in the wider context of business decisions and have processes in place to ensure tax is considered as part of our decision-making process.

The UK companies tax planning aims to support the commercial needs of the business by ensuring that the UK Companies' affairs are carried out in the most tax efficient manner whilst remaining compliant with all relevant laws. The tax function is therefore involved in commercial decision-making processes and provides appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made.

The UK companies have relationships with professional advisers that allow them to seek expert advice on complex areas of tax. Their approach is to ensure they are compliant and understand their responsibilities with regards to tax, rather than looking for ways to aggressively avoid payment of tax.

Approach to dealing with the UK tax authorities
Our communication with HMRC is focused around timely tax compliance, for example meeting relevant filing and payment deadlines for taxes. We commit to:

  • Making fair, accurate and timely disclosure in correspondence and returns, and responding to queries and information requests in a timely fashion.
  • Seeking to resolve issues with HMRC in a timely manner, and where disagreements arise working with HMRC to resolve issues by agreement where possible.
  • Employing the services of professional tax advisers to act as our agents, and, in a number of cases, such advisers liaise with HMRC on our behalf.

Country by Country Reporting
This is part of the Organisation for Economic Co-operation and Development initiative to require large multinational enterprises (MNE) to report details of taxes paid in each territory where they have a permanent 3 establishment and to enable these territories to share the information. This is applicable to all MNEs having consolidated annual revenue greater than €750 million.

The Group falls into this category and therefore all companies in the Group must comply with the country by country reporting requirements.

UHG coordinates (across the Group) the information to be reported (in compliance with the above -noted requirement) and submitted to the Internal Revenue Services (US tax authority) who in turn will share it with the relevant tax authorities e.g. HMRC.

UK Criminal Finances Act
The UK Companies conduct business in an honest and ethical manner by taking a zero-tolerance approach to facilitating tax evasion, whether under applicable UK law or under the applicable law of any foreign cou ntry in all the jurisdictions in which the UK Companies operate.

The UK Companies have a robust due diligence process in place providing for adequate risk assessments and remediation actions. Further, training sessions are provided across all lines of business impacted by the Criminal Finances Act.

Appendix

List of Optum UK companies covered by the tax strategy
   - Optum Health Solutions (UK) Limited
   - Optum Solutions UK Holdings Limited
   - Optum UK Solutions Group Limited

Ratified at the Board of Directors meeting on 9 th March 2021 and duly authorised by:

SERGEANT, Robin Charles Norman - Board Director and General Manager

ANDERSON, Neil David – Board Director and Senior Accounting Officer

MOURA, Ricardo Assuncao – Board Director and Director Finance