We require all employees to adhere to ethical principles and employment standards to ensure that everyone is treated with fairness and respect. Subway® is an affirmative action, equal opportunity employer. Subway® does not tolerate discrimination of any kind on the basis of race, sex, sexual orientation, gender identity, creed, religion, colour or national origin. We value diversity and inclusion and bring employees together during office-wide activities and celebrate diverse interests with Employee Resource Groups.

At Subway®, we recognize that the prevention and eradication of modern slavery and human trafficking is a global challenge. Integrity in our operations, products and supply chain is of the utmost importance.

This statement addresses the Modern Slavery Act of the United Kingdom and the California Transparency in Supply Chains Act for the 2024 fiscal year.

Introduction
Subway Realty Limited and Eat-Commerce Limited, the UK incorporated affiliates of Subway Worldwide, Inc. (the "UK Entities") regard publication of this tax strategy document (the “UK Entities Tax Strategy”), which has been agreed to, and approved by, their respective boards of directors, as complying with their duty to publish a tax strategy under Paragraph 22 of Schedule 19 of the Finance Act 2016. The UK Entities Tax Strategy outlines the strategy utilized by the UK Entities for all UK taxes applicable to the UK Entities in the calendar year (and their financial year) ending 31 December 2023.

Subway Worldwide, Inc. is the parent company of the UK Entities and other affiliates and permanent establishments outside of the UK that operate a fast-food restaurant franchise business under the Subway® brand (collectively, “Subway”). 

Subway is committed to acting with integrity and transparency with respect to its tax obligations, to responsibly complying with applicable tax laws and to paying all tax obligations in a timely manner.

Management of UK tax risks
Tax compliance with the laws and regulations of the UK, as well as any required reporting, is a high priority for the UK Entities. The UK Entities take their responsibility in relation to all tax matters seriously and ensure that all areas related to taxation are reviewed each year. Internal and external systems and processes are actively monitored and reviewed to ensure compliance.

Responsibility for tax governance and tax risk management for the UK Entities falls under the corporate tax team in the Subway's US headquarters which, in coordination with its external advisors, monitors the tax risk inherent in the operations of the UK Entities and takes necessary steps to ensure compliance with UK tax laws and regulations. The corporate tax team in the US supports the management of the UK Entities in their performance of roles with respect to UK taxes.

Attitude towards tax planning and acceptance of UK tax risk
The UK Entities utilise available reliefs, deductions, and allowances under UK rules and regulations and only engage in tax planning that is aligned with commercial and economic activity.

The UK Entities do not have prescribed levels of risk that they are prepared to accept in relation to tax, butrather evaluate positions on a case-by-case basis. Guidance from external advisors is sought on any complex matters as appropriate to fully understand the laws that are relevant.

Working with HMRC
The UK Entities seek to provide all relevant information to HMRC that is necessary to review and understand their tax positions as reported in their submitted tax returns. The UK Entities aim to respond to any queries from HMRC in a constructive, timely and transparent way.