Rubrik, Inc. – UK Tax Strategy for the Financial Year Ending 31 January 2026

The following statement sets out the tax strategy of Rubrik, Inc. (“Rubrik”) in the United Kingdom (“UK”) in accordance with Sections 161 and 19(2) of Schedule 19 of the UK Finance Act 2016. This tax strategy applies to all UK entities within the Rubrik Consolidated Group (including Rubrik UK Limited), for which Rubrik is the ultimate parent company.

Approach to Tax Governance and Risk Management

Rubrik’s approach to tax aligns with our core RIVET values, defined as Relentlessness, Integrity, Velocity, Excellence, and Transparency, as outlined in our Global Code of Conduct. We are committed to complying with all applicable tax laws and paying taxes in accordance with those laws. Our business activities result in a range of tax obligations, including corporate income tax, value-added tax (“VAT”), and employment-related taxes. 

Our tax function, tax governance, and tax strategy are supervised by the Head of Tax, with appropriate level of review by our Chief Accounting Officer, Chief Financial Officer, Chief Executive Officer, Audit Committee of the Board of Directors, and ultimately the Board of Directors. These teams include qualified professionals who ensure appropriate governance, robust internal controls, and timely identification and management of tax risks. Furthermore, Rubrik maintains a zero-tolerance approach to tax evasion and the facilitation of tax evasion, acting in alignment with the UK Criminal Finances Act 2017.

Where there is uncertainty in tax law or its application, we may seek guidance through external advisors to clarify and reduce risk. We also periodically review our tax policy in line with business and regulatory developments in the UK.

Approach to Tax Planning

Rubrik’s global tax function engages with internal and external stakeholders to facilitate strategic initiatives, growth, and development of its multinational enterprise. Our planning is guided by commercial business needs and is consistent with applicable tax laws. Our objective is to ensure that all transactions and structures are aligned with our commercial operations and our commitment to compliance.

We do not engage in artificial tax arrangements that lack commercial or economic substance. All intra-group transactions are conducted on an arm’s-length basis in line with OECD transfer pricing guidelines.

Approach to Tax Risk

Rubrik is committed to compliance with UK tax laws. Given the activities of Rubrik and the volume of tax obligations, tax risks will inevitably arise from time to time. We actively seek to identify, evaluate, monitor, and manage these risks to remain in line with Rubrik’s objectives and broad attitude towards any risk. 

Rubrik has a low-risk approach to tax. Potential tax risks are assessed, and internal controls are implemented to mitigate risks to an acceptable low level. Internal control procedures and processes are subject to regular reviews and internal audits. 

Relationship with HMRC

Rubrik maintains a transparent, collaborative, and professional relationship with HM Revenue & Customs (“HMRC”). We strive to comply with filing and disclosure requirements in a timely and accurate manner and are committed to maintaining an open and cooperative relationship with HMRC.