UK Tax Strategy

1. Introduction

NeatResearch Laboratories Limited ("NeatResearch", "we", "us") is a UK-registered company operating the ProsperGene e-commerce platform and the Prosperity Network. Our business encompasses the sale of science-backed wellness supplements, skincare, and the BSR-1 Smart Ring, alongside a structured referral and commission programme for independent members worldwide.

This document sets out our approach to UK taxation in compliance with the requirements of Schedule 19, Finance Act 2016. It applies for the financial year ending in 2026 and will be updated annually.

2. Our Approach to Tax Governance

The board of directors of NeatResearch Laboratories Limited holds ultimate responsibility for the company's tax affairs. The board ensures that tax obligations are identified, assessed, and discharged accurately and on time in every jurisdiction in which we operate.

Day-to-day responsibility for tax compliance is managed by senior management, supported by external professional advisers where specialist knowledge is required. Our external advisers are instructed to operate within the law and to apply a conservative, risk-averse interpretation of tax legislation.

All material tax positions, obligations, and risks are reviewed at board level before submission to HMRC or any other tax authority.

3. Our Attitude to Tax Planning

NeatResearch is committed to paying the right amount of tax in the right place at the right time. We do not engage in aggressive tax planning, the use of tax havens, or contrived arrangements whose primary purpose is to achieve a tax advantage that is inconsistent with the commercial and economic reality of our business activities.

Where legitimate tax reliefs and incentives exist — for example, research and development tax credits relevant to the development of our BSR-1 biometric technology — we will claim them, as Parliament intended when enacting them. We do not use such reliefs in a manner that extends beyond their intended purpose.

We will not enter into any tax structure that we would be unwilling to disclose openly to HMRC.

4. Tax Risk Management

We recognise that tax law is complex and that our cross-border e-commerce and commission model creates inherent complexity. Key areas of tax risk we actively manage include:

• VAT / GST compliance: We monitor UK VAT thresholds, EU IOSS obligations, and sales tax nexus thresholds in international jurisdictions, updating our customer-facing disclosures accordingly.
• Transfer pricing: Transactions with any associated parties are conducted on arm's-length terms consistent with the OECD Transfer Pricing Guidelines.
• Withholding tax on commissions: Commission and referral payments to members in various territories are assessed for withholding tax obligations in the relevant jurisdictions.
• Customs & import duties: We maintain accurate product classification and ensure customs declarations correctly reflect the value of goods shipped internationally.
• Employment and self-employment status: The status of our Prosperity Network members as independent business owners rather than employees is assessed in accordance with HMRC guidance and relevant case law.

Where uncertainty exists, we seek formal clearance or professional advice before proceeding. We maintain documented records of all material tax decisions and the reasoning behind them.

5. Our Relationship with HMRC

NeatResearch is committed to maintaining a transparent and cooperative relationship with HM Revenue & Customs. We aim to:

• File all returns accurately and on time.
• Disclose uncertain or novel tax positions to HMRC proactively, rather than waiting for an enquiry.
• Respond promptly, accurately, and fully to any HMRC enquiries or information requests.
• Engage constructively with HMRC's digital and Making Tax Digital (MTD) initiatives.

We do not engage in behaviour designed to mislead HMRC or to obstruct legitimate tax enquiries. We seek to resolve any disagreements with HMRC through open dialogue before escalating to formal dispute resolution.

6. Our Commitment to Tax Transparency

We are proud to make this strategy publicly available in accordance with Schedule 19, Finance Act 2016. We believe that transparent tax conduct is part of our broader commitment to operating ethically and sustainably, in a manner that supports the communities — across the UK and globally — in which our members and customers live and work.