At T&P, we are unwavering in our commitment to conducting business with the highest standards of integrity, ethics, and transparency. This Anti-Bribery and Foreign Corrupt Practices Policy underscores our dedication to preventing bribery and corruption in all our operations.

Who it applies to

All agencies within the T&P group, including The&Partners London Limited, T&P Media Limited, Halpern Limited, Muster Agency Limited, ATN Agency Limited, and MFUSE Agency Limited.

Compliance and prohibited practices

It is T&P’s strict policy to comply with all applicable anti-bribery and anti-corruption laws and regulations in every jurisdiction where we operate. All individuals working for or on behalf of T&P are required to understand and obey these laws in the performance of their duties.

We have a zero-tolerance approach to bribery and corruption. This means:

• No bribes: It is a criminal offence to offer, promise, give, request, or accept any bribe, whether directly or indirectly. This applies not only to government officials but also to any private individual or entity.
• No facilitation payments: Facilitation payments, which are small payments made to secure or expedite a routine governmental action, are strictly prohibited by or on behalf of any T&P company.
• No improper influence: No T&P agency, employee, agent, or representative may give, or promise to give, money or anything of value to an executive, official, or employee of any government or its agency, political party (including candidates for political office), customer, other organization (including, in some cases, charitable organizations), or any other company or person if it could reasonably be construed as being intended to improperly influence a business relationship or gain an unfair advantage. This prohibition extends to, but is not limited to, inappropriate meals, gifts, gratuities, entertainment, and other business courtesies.

Consequences of violations

Violations of applicable anti-bribery and anti-corruption laws carry severe consequences, both civil and criminal, for individuals and for T&P. Any breach of this policy will result in disciplinary action, up to and including termination of employment or contract, and may also lead to legal prosecution.

Guidance and Training

This policy provides a framework but cannot address every specific situation or detail every law or regulation in each jurisdiction where T&P conducts business. Therefore, we encourage our people and partners to seek guidance when in doubt.

For specific questions or concerns regarding anti-bribery and anti-corruption matters, please contact T&P’s Global CFO.

All relevant individuals within T&P are required to complete WPP’s mandatory online training modules on an annual basis to ensure a thorough understanding of the impact of anti-bribery legislation and anti-foreign corrupt practices on our businesses.

Third-Party due diligence and business partners

T&P agencies must exercise vigilance and conduct appropriate due diligence in all dealings with third parties and business partners to ensure compliance with anti-bribery legislation. This is particularly crucial in the context of new acquisitions, joint ventures, or when engaging agents, consultants, or other intermediaries.

Specific areas of focus for due diligence include, but are not limited to:

• The percentage of the third party’s business derived from government contracts.
• Types and identities of agents and consultants used, and their compensation arrangements.
• Countries of operation.
• Involvement of government officials in the third party's business (either as owners, directors, or employees).
• The state of the third party's internal controls and books and records.

T&P agencies are required to obtain written assurances from such third parties confirming that they have not and will not violate anti-bribery legislation during their dealings with T&P agency.

Reporting concerns

If you have any concerns about potential bribery or corruption, or believe this policy has been violated, we provide multiple channels for you to raise concerns confidently and securely:

1. Email: You can send your concerns directly to our dedicated confidential email address: incident.response@theandpartnership.com. All concerns submitted via this channel will be treated with the utmost confidentiality. You have the option to raise your concern anonymously; please clearly state this preference when submitting your report.

2. Via WPP: If you prefer an alternative or feel uncomfortable using our direct email, you can report concerns (anonymously if preferred) through our parent company WPP Plc's independent Speak Up channels:

• Telephone: 0800 048 5874 (UK freephone)
• Online Portal: wpp.ethicspoint.com

We do not tolerate retaliation of any kind against anyone who raises a genuine concern.