MATERION CORPORATION UK TAX STRATEGY AND APPROACH

This document summarizes Materion Corporation and its worldwide affiliates’ (referred to together as “Materion” or “the Company”) strategy and approach to conducting its UK tax affairs and dealing with UK tax risks. The company regards this document as complying with its responsibility under the Finance Act 2016, Schedule 19. This strategy, approved by Materion’s Vice President of Tax and Treasury will be reviewed annually and will apply from the date of publication until it is superseded.

GOVERNANCE

As stated in the Company’s Code of Conduct, everyone at Materion is committed to observing the highest standards of ethics and integrity. By acting with honesty and integrity, the Company maintains the trust of its stakeholders which ensures its business success. Materion’s approach to tax aligns with its Code of Conduct.

Materion respects and obeys the laws, rules and regulations of all jurisdictions where the Company operates. As such, Materion is committed to observing and complying with all applicable UK tax laws, rules and regulations. Materion maintains internal policies and procedures to support its tax control framework. Where applicable, tax advice will be obtained from external advisors in respect of material transactions or when the tax department does not have the necessary expertise or skills required in that area. The Company strives to ensure all decisions are made at an appropriate level, with diligent professional care and judgement.

TAX PLANNING AND RISK

The Company’s tax planning supports its UK commercial strategies and economic activities. Materion’s UK tax planning strategies are deployed only when it is more likely than not the tax positions will be sustained upon audit. Materion aligns its transfer pricing with the OECD guidelines as well as the guidelines of the various jurisdictions in which the Company operates. Transactions between Materion affiliates are conducted on an arm’s-length basis and in accordance with UK tax laws.

WORKING WITH HER MAJESTY’S REVENUE AND CUSTOMS AGENCY (“HMRC”)

Materion is committed to the principles of openness and transparency with tax authorities. Materion’s intent is to ensure that all tax returns and the agreed tax payments are made within statutory deadlines and provide all relevant tax-related information that may be requested by HMRC on a timely basis.