Tax strategy of Ingeus UK

Tax Strategy of Ingeus UK

Scope

This document sets out the tax strategy of Ancora UK BidCo Limited and its UK subsidiaries (“Ingeus UK”), operating as part of the APM[1] group. It applies to all United Kingdom (UK) taxes, including but not limited to corporation tax, VAT, PAYE, NIC, and customs duties.

Ingeus’ UK operations are subject to Schedule 19 of the Finance Act 2016, which requires disclosures about various aspects of the Ingeus’ UK tax strategy. Ingeus UK has prepared this document to meet these requirements for the year ending 30 June 2025 for the entities listed at Appendix 1. References to Ingeus in this document apply to all the companies listed.

Overview of Ingeus UK and APM businesses in the UK 

Ingeus UK provides services for people, businesses and communities to create and improve employment, skills, health and wellbeing and strives to deliver social impact through maximising the impact of core services, as well as delivering social value within each contract we operate. 

APM is a leading international health and human services organisation delivering services and programs to Enable Better Lives. APM seeks to deliver on its purposes of “Enabling Better lives” through the provision of service focused on enhancing an individual’s employability, health and well-being, and social and economic participation in the community.   APM operates in the UK through the Ingeus UK group.

Aim

Ingeus is committed to the highest standard of conduct, and statutory and regulatory compliance. Ingeus will conduct its business within the spirit and confines of all laws and regulations. 

Approach to UK Tax Risk Management and Governance

Ingeus UK’s Tax Risk Management is governed through a formal framework integrated within the APM group’s overall risk management system, which includes APM’s Risk Management Framework, Board Tax Policy (‘Tax Policy’), Tax Risk Management Framework (‘TRMF’) and related procedures. APM’s board has ultimate responsibility for establishing the Tax Risk philosophy of APM group and establishing the Tax Policy.  All APM’s subsidiaries and controlled entities (including Ingeus UK) are required to comply with these policies and frameworks.

Responsibility for UK business rests with the Board of Ingeus (‘Ingeus Board’). The Ingeus Chief Financial Officer (‘Ingeus CFO’) is the Executive responsible for tax matters. The Ingeus CFO's requirement is to monitor the integrity of Ingeus UK’s financial reporting system, internal controls and risk management framework includes those elements relating to taxation. The Ingeus Board and Ingeus CFO ensure that Ingeus' tax strategy is one of the factors considered in all significant business decisions taken. 

The Financial Controller (‘FC’) is responsible for the Management of Ingeus' tax affairs. The FC is responsible for the Finance department and ensures it is staffed with appropriately qualified individuals. The Financial Accounting Manager manages the Company's tax affairs on a day-to-day basis and reports to the FC and the Ingeus CFO on Ingeus' tax affairs and risks throughout the year.

Group Tax provides oversight on compliance and reporting and is engaged by the UK business to provide advice on taxation matters and support the UK business in identifying, assessing, monitoring and managing tax risks. 

Qualified external tax professionals are engaged to provide advice on complex matters and to provide tax compliance oversight and assistance.

UK tax risks are escalated to Group CFO, Group CEO and APM Audit Committee/Board as appropriate, in accordance with the TRMF.

Tax strategy and planning

Ingeus will balance considered Tax planning with appropriate Tax Risk management by:

• adopting valid and supportable positions and maintaining awareness of other prevailing views and risks, within the letter and spirit of the law; and
• only adopt positions that advance Ingeus’ commercial objectives and interests without the reliance on their Tax effect for their viability.

Ingeus will not engage in Tax planning that goes beyond support for genuine commercial activities.

Level of risk acceptable in relation to UK taxation

Ingeus maintains a low-risk appetite for UK tax matters. UK taxes will be managed with the objective that all Tax liabilities properly due under the Tax Law are correctly recorded, accounted for and paid.

The TRMF includes clearly defined approval and escalation procedures to ensure that any decision involving tax risk is made at the appropriate level. Escalation is based on factors such as the financial amount at risk, potential reputational impact, technical complexity, and the likelihood of changes in law. 

Where appropriate, we seek advice from external tax advisors and engage with revenue authorities to ensure our positions are well-informed and transparent. 

Relationship with HMRC

It is Ingeus’ general policy to be transparent and proactive in all interactions with HMRC. Ingeus have an open, honest and positive working relationship with HMRC and are committed to prompt disclosure and transparency in all tax matters.

This Tax Strategy Statement has been reviewed and signed off by Ingeus UK Board of Directors.

Appendix 1

Ingeus UK includes the following companies:

* Ancora UK BidCo Limited became the new UK parent of the Ingeus UK group on 28 May 2025. This strategy has been adopted by the new UK parent and applies to the UK group for the financial year ending 30 June 2025.