The following Code of Business Conduct has been approved by the Board of Directors of The & Partners Group Limited (“T&P”) and 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.T&Pis part of the WPP network, and we also abide by WPP’s Code of Conduct.In the unlikely event of a conflict between the two codes, the WPP code will take precedence.

T&P operates in many markets and countries throughout the world.In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act, the US Foreign Corrupt Practices Act, and the UK Modern Slavery Act where relevant, and industry codes of conduct. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.

We, the officers and staff of all companies in our group, recognise our obligations to all who have a stake in our success including our staff, partners, clients and suppliers.

Information about our business shall be communicated clearly, and accurately in a non-discriminatory manner and in accordance with local regulations.

We select and promote our people on the basis of their qualifications and merit, without discrimination or concern for race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability.

We believe that a workplace should be a safe and civilised place, and that all of our employees have a right to feel safe at all times whilst working for or representing us in the marketplace. We believe that employment must be freely chosen; we will not tolerate harassment, discrimination or offensive behaviour of any kind towards or by our staff, partners, clients or suppliers.This includes (without limitation) the persistent demeaning of individuals through words or actions, any aggressive, intimidating, threatening or violent words or behaviour, the use of sexist, homophobic or racist or otherwise offensive language, the display or distribution of offensive material, or the use or possession of weapons on T&P or client premises, or at T&P or client hosted events.We expect our people and those we work with (including our clients and suppliers) to behave ethically and with integrity, treating anyone they deal with in a professional and courteous manner.

We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol.

We will treat all information relating to T&P’s business, or to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain.

We are committed to protecting consumer, client and employee data in accordance with national laws and industry codes.

We will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability.

We will not undertake work which is intended or designed to mislead, including in relation to social, environmental and human rights issues.

We will consider the potential for clients or work to damage T&P’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights.

We will consider the potential for our clients and suppliers to damage T&P’s reputation prior to taking

them on. This includes reputational damage from association with suppliers that participate in

activities that contribute to the abuse of human rights.

We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, clients and brokers or their representatives. We will collectively ensure that all staff understand this policy through training, communication and by example.

We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts this.

We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties.

We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business.

No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees, without the prior written approval of the T&P Board of Directors.

We will continue to strive to make a positive contribution to society and the environment by: maintaining high standards of marketing ethics; respecting human rights in our business supply chain and through our client work; respecting the environment; supporting community organisations; supporting employee development; and managing significant corporate responsibility risks in our supply chain. Our Sustainability Policy and our Human Rights Policy Statement provides more detail about our commitments in these areas.

Actual or potential conflicts with this Code should be reported promptly to T&P’s Global CFO.

Complaint procedure

We want to encourage a culture of integrity and transparency and we want our people to do the right thing automatically.Part of this culture is making sure that anyone we work with (including our colleagues, clients and suppliers) are encouraged to speak up about any concerns that they have about behaviour which may be a breach of this Code of Business Conduct.To allow anyone we work with to raise a concern in complete confidence, please email our dedicated confidential email address: incident.response@theandpartnership.com. Any concerns you raise this way will be treated completely confidentially and you have the option of remaining anonymous if you wish (please confirm when you raise the concern).

Alternatively, concerns can be raised to our Global Head of People (alex.mowle@theandpartnership.com) or Global CFO (david.graham@theandpartnership.com). Again, with concerns raised in this way you have the option of remaining anonymous if you wish (please confirm when you raise the concern).

If you feel uncomfortable with reporting concerns in this way, you also have the option of raising any concerns via our group company WPP Plc’s confidential Speak Up helpline: (please see here for full details, including contact details: RTS_UK-NI.pdf (wpp.com)).

We do not tolerate any retaliatory behaviour against individuals reporting concerns.We are committed to providing a safe and confidential way for people with genuine concerns to raise them, and to do so without fear of reprisals.If you raise a concern, please be aware that in some cases, for example for legal reasons, we may not be able to provide you with a report of how any subsequent investigation is concluded.Where we can provide a response, we will aim to do so within five working days of the conclusion of the investigation.

If the result of the investigation indicates that corrective action is called for, such action may include disciplinary measures up to and including termination of the employment of the offender, or if the offender is a client or a partner then we may seek to end that client relationship.

Annual compliance

All staff are required to complete the mandatory WPP training modules, details are available from the People Team.The People Team are responsible for ensuring that their team members have completed the training, and that their businesses are being operated on a day-to-day basis in compliance with the Code of Business Conduct.