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United Kingdom Tax Strategy

Company Overview

Gen Digital Inc. (“Gen”) (NASDAQ: GEN) is a global company powering Digital Freedom with a family of trusted brands including Norton, Avast, LifeLock and more. We bring award-winning products and services in cyber safety, covering security, privacy, identity protection and financial wellness to approximately 500 million users in more than 150 countries, empowering them to live their digital lives safely, privately, and confidently today and for generations to come. 

Today’s world is increasingly digital, and this has changed the way we live our lives every day. The last decade has brought increasingly impressive technological advances that have unlocked new ways to play and transact online, control smart homes, manage our life and more. The possibilities in the digital world will continue to unlock new possibilities. However, as our digital footprint expands, so do the risks and exposure. Cybercriminals use a mix of old and new tactics and technologies, including phishing, vishing, smishing, based on machine learning and generative artificial intelligence (AI) technologies, to execute highly advanced threats and attacks. We are our customers’ trusted ally that they can depend on to help secure and control their digital lives so they can be free to enjoy the promise of the digital world. We are committed more than ever to protecting and empowering people’s digital lives with personalized, human centered safety.

Gen has its dual headquarters in Tempe-Arizona, USA and in Prague, Czech Republic. As of 28 March 2025, Gen has employees in nearly 20 countries worldwide, including in the United Kingdom. This document is published on behalf of NortonLifeLock UK Limited, NortonLifeLock Security Services Holding Limited and Avast Limited (“Company”) in compliance with the obligations of paragraphs 19(2) and 22(2) Schedule 19 Finance Act 2016 for the financial year end 28 March 2025.

Our Purpose
Powering Digital Freedom.

Our Mission 
We create innovative and easy-to-use technology solutions that help people grow, manage and secure their digital and financial lives.

Our Values
Protecting people is what inspires us, and our people are at the core of what we do. We seek to attract talent that embraces the following values:

  • Customer Driven. Community Minded. We are customer obsessed and drive positive impact.
  • Think Big. Be Bold. We embrace change and innovate fearlessly.
  • Be Scrappy. Make it Happen. Big or small, we get things done irrespective of title or role.
  • Play to win. Together. We win for our customers, with passion and integrity.

 

Our tax strategy is based on the following key elements:

Risk management and governance arrangements

Management of risk aligns with the desire to achieve long terms value for Gen stakeholders, including shareholders, employees, regulators and customers.

Gen’s UK subsidiaries adhere to robust internal policies and procedures, with oversight provided by the Board of Directors, Chief Executive Officer, Chief Financial Officer, and Chief Accounting Officer. The Global Head of Tax, supported by qualified professionals, manages tax strategy and risk, with regular monitoring by Internal Audit & Compliance teams.

Gen complies with the financial and tax related disclosure requirements of the US Securities and Exchange Commission (SEC). Establishing and maintaining appropriate internal control over financial reporting is the responsibility of the Chief Executive Officer (CEO), Chief Financial Officer (CFO)  and the Chief Accounting Officer (CAO). The Board is ultimately responsible for the governance and risk management arrangements.

Gen risks, including tax risks, are disclosed in the Gen Form 10Q and 10-K filings.

The company operates within a prudent tax risk management framework, prioritizing responsible tax practices to protect corporate reputation and deliver long-term stakeholder value.The Global Head of Tax is supported by a team of qualified in-house tax professionals, who are responsible for the day to day tax filings, financial reporting obligations as they relate to tax, working with the business on tax related matters, and maintaining relationships with UK Revenue authorities.

The tax function engages suitably qualified external tax advisors and legal professionals where appropriate, in order to provide compliance support, advice and clarity on applicable tax law. 
Adherence to Gen’s internal policies and procedures are monitored on an ongoing basis by the Internal Audit & Compliance teams, including requiring employees to participate in training of the business’ policies.

Acceptance of Level of Tax Risk 

Gen operates within a prudent tax risk management framework, with a particular focus on being a responsible tax payer who takes measured actions. Gen’s tax affairs are managed with a focus on being compliant with its tax obligations in all the countries in which Gen operates, to protect the Company’s wider corporate reputation and to support in the delivery of long term value for the Company’s stakeholders. 


Attitude to Tax Planning

The Gen tax function supports the commercial needs of the business by ensuring that the group’s affairs are carried out in a tax efficient manner, in line with tax legislation. It is done by engaging external advisors when necessary.

Relationship with His Majesty’s Revenue and Customs (HMRC)

Gen maintains a professional, open, and constructive relationship with HMRC, committing to compliance, transparency, and timely resolution of disputes. The company may seek advance confirmation from HMRC to ensure certainty in its UK tax position.