Sally Beauty Holdings, Inc., “the Company”, is an international specialty retailer and distributor of professional beauty supplies. The Company operates through approximately 5,000 stores throughout the United States, the United Kingdom, Belgium, Chile, Peru, France, the Netherlands, Canada, Puerto Rico, Mexico, Ireland, Spain and Germany. We provide our customers with a wide variety of leading third-party branded and exclusive label professional beauty supplies, including hair colour products, hair care products, styling appliances, skin and nail care products and other beauty items.

The Company is committed to the highest legal, moral and ethical standards of business conduct, reflected in its Code of Business Conduct and Ethics. The Company conducts its business as a good corporate citizen and complies with all laws, rules and regulations applicable to it and the conduct of its business.

The Company takes its obligations as a taxpayer very seriously and its Tax Policy, which is relevant to all Sally Beauty Holdings, Inc. related UK Companies, is to ensure that, across the wide ranges of taxes that it deals with, it has the governance and risk management processes in place to allow it to meet all its continuing tax obligations.

Tax governance and strategy is led globally by the Chief Financial Officer, with oversight by the Board of Directors. The Head of Tax has day-to-day responsibility for each of these areas. The Tax function is supported by both in-house and external tax professionals, based primarily in the US, UK, and other jurisdictions in which we operate.

Corporate Governance is supported by a well-developed internal controls framework which is reviewed annually both internally and externally. Adherence to the framework helps ensure the company meets all its tax compliance, filing and payment obligations so that the right amount of tax is paid when it falls due.

In regards to UK specific tax risk, the Head of Tax works directly with UK management and UK external advisors to identify and manage risk, which includes monitoring proposed UK tax legislation, having direct involvement in significant internal transactions and regular communication with UK finance and legal staff on tax and financial matters.

Our approach to tax risk management is to comply with the applicable tax regulations and laws in the countries in which we operate, and to minimize the risk of challenge by the tax authorities. This includes forming the correct tax technical position, clearly explaining and documenting the facts to support the position, and lastly, having strong compliance procedures to ensure that the corresponding tax returns are filed accurately and on time.

We undertake tax planning as part of our overall business strategy. Country specific tax planning includes working with all levels of management to ensure that the substance of our commercial transactions are properly reflected and accounted for from a tax perspective. When needed, we leverage external tax advisors, particularly in regards to complex tax law, new tax legislation and material transactions. Outside advisors always serve in a supportive capacity and all decisions are made internally to ensure that actions taken are in line with our internal policies and align with our overall goals.

We maintain a transparent and proactive relationship with HMRC in the UK and with other tax authorities in the jurisdictions in which we operate. This includes initiating contact, when appropriate, regarding complex tax matters, and also responding to notices or audit requests in a timely manner. We see great value in fostering a constructive and professional relationship with HMRC and other tax authorities, with the aim of eliminating uncertainty and avoiding unnecessary dispute. Based on our dealings with HMRC, we have shown ourselves to be responsive, to have sound systems in place and to be fully transparent.