Introduction

MoneyGram International, Inc. (together with our subsidiaries, "MoneyGram," "we," and "our") is a global leader in cross-border P2P payments and money transfers. Our consumer-centric capabilities enable the quick and affordable transfer of money to family and friends around the world. Whether through online and mobile platforms, integration with mobile wallets, kiosks, or any one of the hundreds of thousands of agent locations in over 200 countries and territories. Whether through our mobile application, moneygram.com, integration with account deposit and mobile wallets, kiosks, or any agent location around the globe, we connect consumers, primarily those who may not be fully served by other financial institutions, in any way that is convenient for them. As an alternative financial services company, we provide individuals with essential services to help them meet the financial demands of their daily lives.

As a business we are committed to complying with tax law and practice in all the territories that we operate, including the UK. Ensuring that we pay the correct amount of tax in a timely manner is one of our core responsibilities, meaning that disclosure of all relevant facts and circumstances are relayed to the tax authorities in an open and constructive manner.

This policy applies to all MoneyGram group subsidiaries based in the UK with the following principles and key components:

1. Tax risk management

Given the nature of our business, from time to time interpretation of tax law may give rise to risks in relation to our compliance arrangements. We proactively identify, assess and manage tax risks and account for them appropriately. Risk management measures over compliance processes are implemented to monitor the processes. Where there is uncertainly or complexity in relation to risk, we may seek external advice.

2. Tax Planning

We engage in efficient tax planning that supports the commercial and economic substance of our business and reflects the tax laws of the country within which we operate. We do not engage in planning of artificial tax arrangements and adhere to all relevant tax law with a view to minimize the risk of disputes and uncertainty. Entities are established in jurisdictions suitable to drive our business activities taking into consideration the regulatory environment and requirements. We conduct transactions between MoneyGram group companies on an arm's-length basis in accordance with OECD principles and proactively maintain and keep up to date with all legislative changes.

3. Commitment to Compliance

We take compliance seriously and are committed to comply with the law and practices in the UK. Paying the right amount of tax in a timely manner is paramount to ensuring we meet all our compliance requirements with full disclosure of all relevant facts and circumstances to the tax authorities are made, claiming reliefs where available.

4. Relationships with tax authorities

Transparent discussions and negotiation is how we engage with the tax authorities, seeking to build and sustain relationships. We are prepared to litigate where we disagree, but we will first work collaboratively with the tax authorities to resolve disputes to achieve agreement and certainty.

5. Governance

Our global Head of Tax oversees our approach to tax and is responsible for implementing our policies and procedures as well as ensuring the tax team has the skills and experience to meet expectations. This strategy is approved by the appropriate internal board(s), and our governance around tax matters follows procedures which are in line with other governance procedures.