Public Country by Country Report (on income tax information)

Introduction

This report on income tax information has been prepared in accordance with Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021, amending Directive 2013/34/EU as regards to the disclosure of income tax information by certain undertakings and branches (the EU Public Country-by-Country Reporting Directive), as well as the template set out in Commission Implementing Regulation (EU) 2024/2952, which establishes a common template and electronic reporting formats for such reports. The principles guiding our approach to tax across all jurisdictions, affirmed by our Board and Chief Executive Officer, are as follows: • Complying with all applicable laws, regulations, disclosure requirements, the accurate payment of taxes and timely lodgement of returns; • Building and maintaining constructive relationships with revenue authorities, government bodies and all other relevant parties; • Making decisions at an appropriate level, supported by comprehensive documentation; • Confirming that technical filing positions include robust risk assessment with appropriate risk mitigation activities (e.g., professional opinions, appropriate disclosure); • Supporting tax positions taken with evidence, so they can be substantiated if reviewed by a revenue authority; • Immediate voluntary reporting of any detected errors/omissions to all relevant revenue authorities; and • Complying with all our group and tax-specific controls and maintaining evidence of their operation. Tax governance We only allow tax decisions to be made by the Board, CEO, Chief Financial Officer and Vice President Tax and Treasury. We have globally consistent authority levels required for tax decisions and approvals. These authorities are based on risk assessments which are consistent with broader business approvals and the risk tolerance levels applied to other decisions in our business. The processes and controls designed to manage our tax risks follow best practice standards and are in line with the Australian Taxation Office (ATO) Tax Risk Management and Governance Review Guide, United Kingdom (UK) Senior Accounting Officer guidance and the UK Regulations regarding tax strategy reporting requirements. We maintain contemporaneous evidence of our governance processes, which are reviewed annually by our Tax Governance team and subject to independent review at least every three years. Our tax affairs are also subject to regular review by tax authorities and our external auditors as part of normal local compliance and reporting processes. We employ a global team of qualified and experienced tax professionals, who are required to undertake continued professional development. We utilise external advisors to support our team on technical filing positions or in the interpretation of specific points of law. South32 Limited makes use of the centralized filing hub option provided under Article 48b(6) of the EU Accounting Directive (as amended by the EU Public CbCR Directive). As a result, it has designated South32 Finance 1 BV to publish the report containing group-wide information on behalf of South32 Limited with the Netherlands Chamber of Commerce, in accordance with the instructions issued by the Dutch authorities. Accordingly, this group report is intended to fulfil all reporting obligations of South32 Limited within the European Union. Dealings with tax authorities, including disputes We proactively engage with tax authorities in real time. We conduct our interactions openly and transparently, guided by our values and our Code of Business Conduct. We act responsibly in relation to all tax compliance matters and are committed to paying the right tax in the right jurisdiction. Given the global scope of our business and the complexities of tax laws, uncertainties can arise regarding their application, occasionally leading to disagreements with tax authorities over the amount of taxes paid. When a dispute arises, we constructively engage with tax authorities regarding how the law is being applied and seek to resolve any disagreements on a timely basis. At times, it will be appropriate for those matters to be resolved or clarified through legal proceedings. Tax incentives and grants We consider tax incentives and grants available in jurisdictions where we operate and view such incentives as beneficial when they support targeted investments or address specific challenges, such as advancing transition to a low-carbon economy. When we utilise incentives, we ensure full compliance with legislative intent and regulatory requirements. Supporting effective tax systems We actively engage with a range of stakeholders, including governments and industry associations, to contribute to the development of sustainable and effective tax systems. Through our membership with the International Council on Mining and Metals (ICMM), we contributed to the development of the Unlocking Prosperity: Tax Principles for Sustainable Mining report. We support the tax policy principles outlined in this report which support responsible mine development and optimised benefits for host jurisdictions. We remain committed to meaningful consultation and collaboration with stakeholders. This includes participation in consultation with civil society and the Extractive Industry Transparency Initiative.

Section 1. General information

Section 4. Omitted information

Section 5. Explanations for material discrepancies between income tax paid and accrued

Conclusion

International related party dealings As a globally diversified company, we have operations and support functions located in many countries. This operating model results in cross-border intra-group transactions and we prepare detailed documentation to support the understanding and pricing of these transactions. This documentation is provided to tax authorities and we also obtain independent expert advice confirming the transactions are completed on an arm’s length basis. We understand the importance of transparency and support initiatives that require companies to publicly share relevant data. We publish an annual Tax Transparency and Payments to Governments Report (which can be found at https://www.south32.net/investors/annual-reporting-suite). This report provides further disclosures and information on all global tax payments. The financial information used to prepare this country-by-country report is derived from the accounting records used for the preparation of the consolidated financial statements of the South32 Group and has been prepared in accordance with IFRS. Certain adjustments required for consolidation and external financial reporting may not be reflected in the data included in this report.