INVITATION DIGITAL LIMITED (“IDL”) - MODERN SLAVERY ACT TRANSPARENCY STATEMENTINTRODUCTION
The Modern Slavery Act 2015 (the “Act”) is an Act of the Parliament of the United Kingdom. It is designed to tackle slavery in the UK,
and consolidates previous offences relating to human trafficking and slavery. The Act also introduced a new corporate reporting
obligation requiring companies that qualify to set out the steps they are taking to tackle modern slavery issues in their businesses andsupply chains. IDL is in compliance with the corporate reporting obligation. You can click here to learn more about the Act.
At IDL, we believe we have a responsibility to ensure that our business is conducted in an ethical way, and we actively engage to addresssocial issues. We realise that modern slavery is such an issue, and take seriously our responsibility to comply with the Act and to assist
in preventing and combating slavery and human trafficking where possible.
As such, we are issuing this Modern Slavery Act Transparency Statement, which includes a description of our organizational structure,merchants and supply chain, efforts to identify and mitigate the risk of slavery and human trafficking in our supply chain, and information
about how to report concerns or complaints arising under or related to the Act.
ORGANISATIONAL STRUCTURE
IDL is part of Groupon’s global e-commerce marketplace. Groupon, Inc. is the ultimate parent company of IDL. Groupon, Inc. isheadquartered in the United States (Chicago, Illinois).
Until recently IDL operated two distinct businesses: Giftcloud and Vouchercloud. The Giftcloud business focusses on supplying reward
codes to customers of its clients. The Vouchercloud business focusses on supplying free discount coupons to customers, which can beredeemed with the original issuers. As of 1 February 2024, the Giftcloud business was transferred to a newly created subsidiary entity,Giftcloud Limited. For the purposes of this statement, the Giftcloud business will still be included due to the degree of control IDL had
over it until recently.
CLIENTS AND SUPPLY CHAIN
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IDL’s clients, vendors, and suppliers (together, “Merchants”) include but are not limited to:●●●●Merchants that supply coupons to IDL’s Vouchercloud business;Merchants that supply reward codes to IDL’s Giftcloud business;
Merchants that engage IDL’s Giftcloud business to provide reward codes to their customers; andMerchants who provide office-related operations (e.g., cleaning, catering, stationary, etc.)

DUE DILIGENCE AND RISK ASSESSMENT
IDL takes a zero-tolerance approach as it relates to any potential slavery or human trafficking issues and undertakes risk assessmentsof all potential merchants, vendors, and suppliers as part of our initiative to identify and mitigate slavery and human trafficking occurringin our supply chain:● Vouchercloud obtains most of its business via reputable agencies and affiliate networks, which have their own modern slavery
statements and compliance policies. In instances where Vouchercloud works directly with Merchants, it will only work with
reputable national or international brands that are of sufficient size and sophistication to be knowledgeable of and comply fully
with the Act.
● Similarly, Giftcloud only obtains supplies of reward codes from, and provides such codes to, reputable national or international
brands that it confidently feels are aware of the Act and effectively comply with it.
● We provide several methods for both employees and non-employees to report their concerns and/or complaints regarding
possible modern slavery practices to Groupon’s Compliance Team (which also covers IDL), including by using our ethics
hotline, EthicsPoint, which provides for making such a report anonymously. We make clear in our policies that employees whoreport their concerns or complaints regarding violations of applicable laws or policies in good faith shall not be penalised.
● Vouchercloud now includes explicit compliance commitments related to the Act in its standard contracts and will seek to include
such provisions in affiliate network terms it signs up to.
2|POLICIESVendor Code of ConductGroupon, Inc. has put in place a Global Vendor Code of Conduct (the “Vendor Code”) that sets out our requirements for all Merchants
who do business with or on behalf of Groupon, Inc. It is made binding on Merchants through our agreements with them.
The Vendor Code specifically states that Groupon, Inc. prohibits Merchants from engaging in child labour as well as any form of coercedlabour such as slave labour, prison labour, indentured labour, bonded labour, and any other form of involuntary servitude. The Vendor
Code also states that all Merchants are responsible for monitoring their global supply chains to ensure compliance with applicable
coerced labour and human trafficking laws.
We also offer an informational video for our Merchants that outlines our policies for working together and shares the resources available
to our Merchants through the Vendor Code. If Merchants have questions on the Vendor Code at any time, our Compliance team isavailable to support.
Anyone who has knowledge of an actual or potential violation of the Vendor Code is asked to make a report using the methods describedin the Monitoring and Reporting section below.
UK Whistleblower PolicyGroupon’s UK Whistleblower Policy, which pertains to all employees, contractors, consultants, and agency staff who work for Groupon
in the UK (including IDL), provides information about raising concerns and complaints, including those arising under or related to theAct, and provides methods for reporting such concerns and complaints, which are also detailed in the Monitoring and Reporting section
below.
TRAINING
Groupon provides training to its employees regarding our Code of Conduct, which covers broader ethical and compliance issues, andthe reporting mechanisms available to employees and non-employees to report concerns and complaints arising under or related to such
issues. This training is provided to new employees at onboarding, and to all employees every two years thereafter. In alternate years,
employees are required to complete a recertification quiz.
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Going forward, our aim is to provide training that covers our polices and processes in place to combat slavery and human trafficking
specifically and the reporting mechanisms available to employees and non-employees to report concerns and complaints arising underor related to the Act.

MONITORING AND REPORTING
Concerns and complaints arising under or related to the Act should be reported to the Compliance Team atlegalcompliance@groupon.com or via EthicsPoint at gr.pn/ethicspoint. EthicsPoint complaints may be made anonymously. TheCompliance Team will promptly investigate any concerns and complaints arising under or related to the Act and/or the objectives set
out in this Statement.
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Groupon’s slavery and humantrafficking Statement for the current financial year. It has been approved by the Invitation Digital Ltd Board on 11 June 2024.
James Norris________________________________
Authorized Signatory, Invitation Digital Ltd Board Member

James Norris (Jun 11, 2024 13:28 GMT+1)

James Norris

James Norris (Jun 11, 2024 13:28 GMT+1)
Date: ______________
Covering Financial Year 2022 (January - December)4|