Introduction

Darktrace is a global leader in AI for cybersecurity that keeps organizations ahead of the changing threat landscape every day. Founded in 2013, Darktrace provides an essential cybersecurity platform protecting organizations from unknown threats using its proprietary AI that learns from the unique patterns of life for each customer in real-time. Since inception, Darktrace plc and its subsidiaries (together ‘the Group’) have grown rapidly and today, Darktrace’s platform and services are supported by over 2,400 employees around the world who protect nearly 10,000 customers across all major industries globally. In October 2024, the Group was indirectly acquired by funds managed and/or advised by Thoma Bravo, LP. Following the acquisition, Darktrace plc delisted from the London Stock Exchange and became a private company, now known as Darktrace Limited. The Group’s tax strategy for the period ending June 30, 2025, has been prepared in accordance with paragraph 19(2) of Schedule 19 to Finance Act 2016. This strategy applies to all UK and worldwide taxes, which include, but are not limited to:

• All corporate income taxes

• Indirect taxes (e.g. VAT)

• Employment taxes (e.g. PAYE, National Insurance)

• Other applicable tax matters

The Group’s tax strategy aims to ensure that all tax affairs are conducted in a manner which is transparent and in compliance with local tax requirements in all material respects.

This strategy is reviewed annually and applies from the date of publication until superseded.

Governance

The Group Tax Department is responsible for the delivery of tax strategy approved by the Board of Directors (‘the Board’), overseeing all tax activities across the Group entities, the department is based in the UK and is an integral part of the central Group finance function. The Group Tax Department reports into the Finance Director (“FD”) who in turn reports to the Group Chief Financial Officer (‘CFO’).The Group Tax Department is responsible for all tax matters, providing advice and support to Group level functions, supporting the Group in respect of significant transactions, as well as managing tax compliance obligations. The Group Tax Department is also responsible for the development, maintenance and review of tax procedures, controls, and policies.

The Group’s FD and CFO participate in all substantive decisions involving tax matters and are regularly informed about relevant tax developments impacting the Group, raising tax issues to the Board as appropriate.

Attitude to Tax Risk and Tax Planning

As an international organization, the Group understands that it is exposed to tax risks arising from uncertainties in tax legislation as well as an increasingly complex international tax environment. While it is aware that these risks may not be eliminated completely, the Group endeavours to minimize the risk by ensuring compliance processes are implemented and reviewed, and that external advisors are engaged as and when appropriate.

The Group does not engage in high risk or aggressive tax planning, or artificial transactions whose aim is to gain a tax advantage. Any planning around tax is a result of genuine commercial activities and the Group seeks to structure itself in a manner which is compliant with all applicable tax regulations, but which is also efficient. For example, the Group takes advantage of available statutory reliefs, such as R&D tax relief in the UK, and follows arm’s length principles globally.

The Group will continue to structure itself in line with business requirements, while ensuring the Group has robust controls and processes to allow the Group to manage tax risks effectively. While being committed to paying the right amount of taxes at the right time and ensuring the highest integrity in all its tax reporting globally.

Relationship with HMRC and Other Tax Authorities

The Group supports open and transparent relationships with fiscal authorities, including HMRC and all other relevant global tax authorities. This is achieved through prompt exchange of requested information, proactive engagement with the authorities and through open dialogue to address any relevant tax matters.

Any accidental errors which may arise in tax submissions to HMRC or other tax authorities are disclosed as soon as possible once corrections have been identified.

Versioning

This policy (Version 4) was last amended on June 12, 2025. We update and review this policy annually. Any updates will be noted in the version notes below.

Previous Version 3 published July 1, 2024.

‍