Group Tax Strategy

Gymshark Topco Limited

(the “Company” or together with its UK subsidiaries the “Group” or “Gymshark”)

Group Tax Strategy

(the “Strategy”)

Background

This Tax Strategy applies to the Group (referred to in the first person), and has been approved by the Board of Directors. Gymshark is a fitness apparel manufacturer and online retailer based in the United Kingdom. We are committed to complying with tax law and practice in all territories in which we operate, including the UK, which is our main home of business.

Following legislation introduced in 2016, large companies trading in the UK are required by His Majesty’s Revenue and Customs (“HMRC”) to publish a Tax Strategy. This document sets out our Tax Strategy and the policies and procedures in place within our business which we are committed to following and successfully implementing.

The Group regards the publication of this Strategy as complying with its duty under paragraph 16(2) of Schedule 19 to the Finance Act 2016 in respect of the financial year ending 31 July 2025.

Overriding Objective

Our overriding objective is to manage the tax affairs of our Group in accordance with the spirit and letter of the law.

Aims

Our aims are:

to ensure we pay the right amount of tax, in the right place, at the right time;

to manage our tax affairs as efficiently as possible while also supporting our wider commercial objectives;

to maintain strong compliance controls;

to operate a policy of open and transparent communication with the tax authorities in each jurisdiction we operate in;

to maintain a low level of tax risk, as overseen by our Chief Financial Officer and our Board of Directors; and

to achieve these aims through the delivery of the key principles outlined below.

Key Principles

Effective Management of Tax Risks

This Strategy is part of our effective management of tax, setting the structures to ensure that suitable controls and processes are in place to enable us to meet our obligations in regard to tax reporting and compliance.

These controls and processes enable us to effectively manage the tax issues facing the business. Tax issues and the associated tax risks are managed by a senior leadership team which includes our Chief Financial Officer, Financial Controller and Senior Group Tax Manager.

Acceptable Level of Tax Risk

We have a low appetite for tax risk. We do not enter into transactions whose main purpose is to obtain a tax advantage, and we do not use contrived or artificial structures. Where the tax treatment of a transaction is uncertain, we seek to resolve that uncertainty before proceeding. We do this through external advice or, where appropriate, direct engagement with HMRC.

Our key tax risks, and any associated issues that develop, are monitored and presented on a regular basis to our Chief Financial Officer and managed by our Senior Group Tax Manager. Action is then taken to ensure the risks are minimised. Our Tax Strategy has been approved by the Board.

We’re continually developing and implementing control structures which underpin our Tax Strategy. These controls are subject to the attention provided by our Tax Department and managed by our Senior Group Tax Manager.

The responsibility for ensuring the:

day to day application of our Tax Strategy; and

the management of our tax affairs,

is managed by our Senior Group Tax Manager.

Responsible Attitude to Tax Planning

We will consider tax planning opportunities that deliver value and align with our commercial objectives, while always seeking to maintain a low level of tax risk. This includes seeking to benefit from available tax reliefs and incentives, in line with the spirit and letter of the law.

We consider the potential impact on our reputation and brand when evaluating the tax implications of significant business decisions and transactions. Any tax planning will have commercial and economic substance.

Appropriate advice from external advisors is sought where any unusual or complex matters cause significant uncertainty.

Constructive and Transparent Dialogue with HMRC

We engage with HMRC in open and transparent communication on any ongoing matters and, where appropriate, on a real-time basis to minimise tax risk as part of our effective management of tax.

In the event of HMRC enquiry into our tax affairs, we’ll always seek to engage with them in the spirit of co-operative compliance, which supports our tax objectives and aims as set out in this Strategy.

Approved by the Board of Directors and signed on their behalf:

Rich Sanders

Chief Financial Officer

April 2026