The Tax Strategy Statement communicates the management of all UK taxes by UK entities (“the Group”) within the Walmart Group. The primary trading company in the UK is Asda Stores Limited.

This document is made available in accordance with Schedule 19 of Finance Act 2016 and is in relation to the finance year ended 31 December 2017. The Group considers the publication of this document as complying with the duty under paragraph 19(2)/22(2) and paragraph 25 of Schedule 19 of Finance Act 2016.

2 The approach of the Group to risk management and governance arrangements in relation to UK taxation

The UK CFO has responsibility for tax, and for communicating and advising on tax affairs and risks to the Board.

Day to day tax matters are delegated to the Vice President of Corporate Finance (“VP-CF”), who in turn delegates this to the Head of UK Tax who manages a professionally qualified tax team. When appropriate, external advice will be sought from leading professional advisers for complex or uncertain matters.

The Head of UK Tax updates the VP-CF on a regular basis, and in quarterly formal meetings with the CFO, to ensure that there is an awareness of any risks associated with UK tax affairs.

Asda maintains a suite of documented tax process controls which are audited by both the internal and external audit teams on an annual basis. These ensure compliance with the Sarbanes-Oxley Act, and the UK’s Senior Accounting Officer rules.

3 Attitude towards tax planning, so far as it affects UK taxation

The commercial needs of the business are paramount and all tax planning will be undertaken in this context. All transactions must therefore be driven by a business purpose or commercial rationale. The Group is committed to acting with integrity and transparency on all tax matters and complying fully with UK tax law.

4 Level of risk in relation to UK taxation that the Group is prepared to accept

The Group’s objective is to comply with legal requirements in a manner which ensures the right amount of tax at the right time, underpinned by an open and co-operative relationship with HMRC. We consider that we have a low tax risk.

5 Approach towards the Group’s dealing with HMRC

The Group complies fully with UK tax law, making sure that all HMRC filings are submitted on a timely basis, with full disclosure, and that any areas of uncertainty are discussed with HMRC on a timely basis. The Head of UK Tax and his team have regular communication with the HMRC Client Relationship Manager and specialist HMRC teams to promote a professional, collaborative working relationship which is based on principles of transparency and trust.

6th November 2017