2012 - Falck Group

1 Falck Group Tax Policy 2012. Falck Group Tax Policy | 1. CONTENTS. 1 Introduction 2. 2 Overall policy/principles 2. 3 Responsibilities 3. 4 Commercial Rationale 4. 5 Policy on Disclosure 4. 6 Use of external advisors 5. 7 Review of Group Tax Policy 5. Group Tax Falck Group Tax Policy | 2. Falck Group Tax policy 1 Introduction The purpose of this document is to set out the Group tax policy of the Falck Group and the general guidelines within which Group Tax will operate. Falck is a part of the joint taxation with Lundbeckfond Invest A/S and is thus to comply with the joint taxation agreement entered into with Lundbeckfond Invest A/S. This policy set out the guidelines for how to address direct taxes and does not include indirect taxes such as VAT and duties. 2 Overall policy/principles Falck is committed to being a responsible taxpayer. This means that: Tax compliance is ensured and documented professionally Tax is paid in a timely manner and in accordance with local rules Tax planning is only performed if in compliance with legislation and based on valid business purposes Being a responsible taxpayer Falck manage tax risks proactively ensuring that tax legislation is complied with.

2 In general tax is considered to be a cost as any other cost in the Group . Tax planning in accordance with tax legislation should be made to lower the overall tax cost by: Taking initiatives to reduce the effective rate of corporation tax and all other tax liabilities of the Group Avoiding loss of tax compensation from carry forward losses Providing high quality and solution-driven tax advice Reducing withholding taxes on internal dividend steams, capital gains taxation and optimize the overall interest deduction Falck pays taxes where profits are earned in accordance with local tax legislation taking international transfer pricing rules into consideration. The Falck Group has a balanced tax risk profile and does not engage in tax-avoidance activities. Moreover Falck does not participate in any double dip arrangement. Long term effects and risk involved must always be considered including Falcks reputation, brand, corporate and social responsibilities and impact on relationships with governments.

3 The Falck Group aim for certainty on tax positions adopted. The Falck Group aim to ensure that the tax position would, more likely than not, be settled in our favor. The Falck Group will only enter into transactions which would be justifiable should they become public. Group Tax Falck Group Tax Policy | 3. 3 Responsibilities The Board of Directors has the overall responsibility for the Group tax policy of the Falck Group . Following instructions from the Executive Management and the Board of Directors it is the overall responsibility of the Group CFO to ensure that the guidelines laid down in this Policy is being observed and complied with. The Group CFO can delegate the assignment (but not the responsibility) related to the daily tax management to Group Tax. Group Tax must perform these duties in due consideration of and in compliance with the guidelines of this Policy. It is the obligation of the Group CFO to keep the Executive Management and the Board of Directors (Audit Committee).

4 Informed about the tax risks within the guidelines of this Policy. The responsibilities of Group Tax are two folded: Managing the tax compliance including correct and efficient processing of all the fiscal data in accordance with tax law provisions Providing tax advice including tax risk management and tax planning ensuring the optimal tax situation for the Group and also act as a sparring partner for the Business Units More specifically Group Tax takes the following responsibility: Task Tax planning Prepare tax and transfer pricing policies for the Group and manage major tax risk for the Group Evaluate tax impact of all major changes to Group structures and activities within the Group Monitor new legislation and related impact of such on the Group Optimize the tax structure and avoid loss of tax losses Advise on and prepare transfer pricing documentation and review existing updated documentation Compliance Prepare and analyze Group effective tax rate on a monthly, quarterly and annual basis Prepare the Danish tax returns including filing and calculation of taxes payable Coordinate and evaluate all tax and transfer pricing audits globally Approval of all intra Group agreements Tax optimization Suggest potential tax optimization possibilities on an ongoing basis Group Tax Falck Group Tax Policy | 4.

5 Each Business Unit within the Group is responsible for: Task Local tax planning Local optimization of taxes within the local tax regulation The monitoring of new local legislation and report significant changes to Group Tax Local compliance Preparation of corporate income tax returns including filing and payment of local taxes Reporting Preparation of monthly and annual tax reporting Preparation of Tax Risk questionnaire for selected entities Immediate information to Group Tax Informing Group Tax when changes in local structures or activities are under consideration Group . Informing Group Tax of notification of local tax audits Informing Group Tax of the need for special tax provisions in respect of possible tax risks Discussing tax losses which are not capitalized with Group Tax Reporting significant changes in tax risks to Group Tax 4 Commercial Rationale The commercial needs of the Group are the key focus and all tax planning and advice will be provided in this context.

6 Where alternative paths exist to achieve the same commercial result, the most tax efficient approach should generally be applied. Due consideration will be given to the Falck Groups reputation, brand and corporate and social responsibilities when considering tax related opportunities and risk. 5 Policy on Disclosure Compliance with all relevant legal disclosure requirements will be adopted and all information will be clearly presented to the relevant Revenue Authorities as appropriate. Group Tax Falck Group Tax Policy | 5. 6 Use of external advisors External advisors will be used in significant matters where Falck does not hold sufficient knowledge to analyse all aspects of the matter. In case of major transactions with a major tax exposure a tax assessment will be requested from an external advisor. 7 Review of Group Tax Policy The guidelines laid down in this policy will be reviewed on an ad hoc basis when considered necessary.

7 Any change to the policy must be approved by the Executive Management and the Board of Directors. Group Tax