Anti Bribery & Corruption
Global Policy

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As a global organisation, Informa has a
responsibility to conduct our businesswith integrity and according to the law,wherever we work and whatever we do.
We have zero tolerance for any and allforms of bribery and corruption. We arecommitted to acting without corruption
in all of our dealings, and we choose towork only with those partners who arewilling to make – and act on - the samecommitment.
This policy sets out Informa’s approachto the prevention of acts of bribery andcorruption, and procedures that will help
us comply with global legislation.
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Key points
Never offer, accept, or authorise anything of value with the intention of obtaining any kind ofcommercial advantage for Informa
Ensure all accounts and financial records are complete and accurate. Make sure there are
no undisclosed or vaguely described transactions that could be concealing corrupt activity
Carry out appropriate background checks on current and potential business partners, sothat we can be as confident as possible that they meet our high ethical standards
Never offer any gift or entertainment to any government or public official without priorapproval. Get approval from your local lawyer, divisional compliance or Chief Finance Officerfor ALL such gifts or entertainment to ensure you are not breaking the law
If you are offered or asked for a bribe REFUSE – and report it immediately to your local
lawyer, Group Compliance or via Speak UpContext
Corruption and bribery cause significant damage. Whether it’s in the private or public sector, corruption
distorts markets, diverts money away from essential projects and those who need it, and makes it difficult
for businesses to succeed on merit alone.
Governments across the world have put in place anti-bribery and anti-corruption laws, many of which givethem jurisdiction over individuals and companies outside their national boundaries. As a global company,
we are subject to laws such as the UK Bribery Act wherever we do business and must ensure that we areaware of and comply fully with all relevant laws and regulations.
As part of Informa’s commitment to prevent bribery and corruption and our obligation to respect the law,
we have developed this policy to set out the standards we expect of all our Colleagues and those acting
on our behalf, wherever they are.

What is bribery?
A bribe can be anything – financial or otherwise – offered, given or received, that is intended to create
undue influence or a sense of obligation, induce or reward the improper performance of a business or
public function.

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It does not matter whether the bribe is given or received directly, or through a third party (such as
someone acting on Informa’s behalf, such as an agent, distributor, supplier, joint venture partner or otherintermediary). It does not matter whether it is for the benefit of the recipient, or some other person ororganisation.
Bribes can take many forms, including:
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Money (or cash equivalent such as shares or gift vouchers)
Extravagant or unjustifiable gifts, entertainment or hospitality
Kickbacks or inducements
Unwarranted rebates or excessive commissions (e.g. to sales agents ormarketing agents)
Excessive or unjustifiable allowances or expenses“Facilitation” payments - payments made to perform a normal job more
quickly and/or prioritise a particular customer
Political/charitable contributions
Employment or offers of employment, including access to unpaid internships
Uncompensated use of company services or facilities; oranything else of value.

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How do I know if something is a bribe?
In most circumstances, common sense will determine when a bribe is being offered or requested.
However, here are some questions you should ask yourself if in doubt:•••••

Am I being asked to pay something or provide any other benefit over and above the real cost of theservices being performed? This could be, for example, an excessive commission, a lavish gift, akickback or a contribution to a charity or political organisation.
Am I being asked to make a payment for services to someone other than the service provider?
Is the hospitality or gift I am giving or receiving reasonable and justified? Would I be embarrassed todisclose it?
What is the timing of this gift or payment? Do I know or suspect it is to encourage or reward
favourable treatment, to undermine an impartial decision-making process or to persuade someone todo something that would not be part of the proper performance of their job?
How would this look if it were in the news? Would I be embarrassed?

Policies and procedures
All forms of bribery and corruption are prohibited.
We will not tolerate any act of bribery or corruption. Any breach of this policy or local law could result in
disciplinary action being taken and ultimately could result in dismissal, in addition to any criminal
proceedings that may occur.
A bribe does not actually have to take place: you must never promise a bribe, or agree to receive one,even if you have no intention of acting on those promises or agreements. This is prohibited and against
the law.
Even the risk of an allegation of bribery should be avoided: be aware of how your actions could be
misinterpreted. If you are considering offering or accepting lavish hospitality or gifts, for example, could
other people see this as an attempt to gain influence?
Whether you are dealing with a person from the public or private sector, the provisions of this policy are
the same. It is worth considering, though, that many countries have specific regulations regarding dealing
with public officials, such as strict limits on the cost of hospitality: be careful to pay particular attention to
any specific requirements in these circumstances.

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Appropriate hospitality can be an
important way of developing ormaintaining a business
relationship

Gifts, entertainment and other expenses
Giving or receiving gifts or entertainment can be an important part of maintaining and developing
business relationships, but they can also be misused as a means of bribery.
All gifts and entertainment, including promotional expenditure, should be for a genuine purpose,
reasonable in cost, given in the ordinary course of business and should comply with local laws and theInforma Gift and Entertainment Policy, including any reporting or approval requirements.
Lavish or unreasonable gifts or hospitality, whether these are given or received, are unacceptable because
they can create the impression that we are trying to obtain or offer favourable business treatment byproviding individuals with personal benefits.
Be careful to avoid even the appearance that the giving or accepting of gifts or hospitality might influence
the decisions you take on behalf of Informa.

Facilitation payments
Facilitation payments are any unofficial payments, no matter how small, given to an official to increase thespeed at which they do their job, such as clearing customs, obtaining a license.
All facilitation payments are prohibited and any request for a facilitation payment should be reported toyour local legal team or Divisional Compliance.
We understand that, in very rare and exceptional circumstances, you may find yourself in a situation
where you feel you have no alternative but to make a facilitation payment to protect against loss of life,
limb or liberty. Your safety is our priority. Please report any such incidents as soon as it is safe to do so.

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Agents, distributors, suppliers and joint venture partners
Informa could be liable for the behaviour of people that act on our behalf. For this reason, where weengage contractors, agents, distributors, suppliers or joint venture partners (together referred to as “thirdparties”), we have an obligation to complete sufficient due diligence before entering into arrangements toensure that they are not acting corruptly, and to monitor their performance periodically to ensure ongoingcompliance. In short, if we can’t do it, neither can they.
Appropriate due diligence should be undertaken before we engage a third party, the level of which willvary depending on the circumstances (such as the location, type and size of contract) and you should use
your judgement on a case by case basis: the procurement or M&A teams will be able to advise on relativerisk.
As a minimum, all third parties should be made aware of the terms of the Informa Business Partner Codeof Conduct and of their obligations to comply with it. Where possible, agreement to comply with theBusiness Partner Code should be built into any contractual agreements.
In addition, all arrangements with third parties should be subject to clear contractual terms, including
specific provisions requiring them to comply with minimum standards and procedures in relation tobribery and corruption. Appropriate wording to be included in contracts can be obtained from your local
Legal counsel.
When conducting due diligence, questions you should be asking yourself include:
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Who are they – have I seen documents evidencing that they are who they say they are?
Who else have they worked with – do they have references?
Are they well established with a good reputation or are they more obscure so that I need to do more
to find out about them?
Do they operate in a territory where bribery is prevalent?
Are they happy to sign a contract agreeing to comply with anti-bribery procedures?
Do they have their own anti-bribery programme?
Have I done basic Google searches, business directory searches, etc.?
Are there inconsistencies between the provider of the services and the person I am paying?
Are commissions/payments in line with generally accepted market practice?

Some high-risk transactions will require further due diligence which may require independent
investigation: please speak to Group Compliance for advice on how to progress this.
Any joint venture arrangements must have appropriate due diligence conducted and prior approval fromGroup Legal before being entered into.
Sales Agents must also have due diligence conducted on them: please consult your Divisional Compliancelead for more details about how this is managed.
We must not engage any third party who we know, or reasonably suspect, of engaging in bribery.

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Payments to third parties
All payments and commissions to third parties must:••••

Be made in accordance with the Group Authority Framework and the local policies relevant in yourbusiness as set by your line manager or divisional CFO
Be made via bank transfer through the accounts payable system where possible, and be fully
accounted for
Be in line with generally accepted rates and business practice for the service in question and should
not be unjustifiably excessive or unsupportable; andBe made in accordance with the terms of the contract with the person or company providing theservices.

If you have any concerns that arrangements with a third party are not in accordance with this policy, you
should ask your local lawyer or Group Compliance for help.

Approvals
If you are required to approve any payment or expense, and especially if you are asked to provide preapproval, ensure that you have considered the implications or possible interpretations of what you areapproving. Ensure that you are informed of the business context and justification before providing
approval, and if you are unsure, please consult your local legal counsel or divisional compliance team.
If you are asked to provide approval AFTER something has been given or received and you do not believe
it was in accordance with this Policy, please contact Group Compliance or Legal as soon as possible.

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Dealing with public officials
Although this policy applies to both public and private sectors, dealing with public officials poses aparticularly high risk because of their potential influence and the strict rules and regulations that govern
them in many countries.
Public officials include those in government departments, such as civil servants or those working in local
government teams, but also employees of government owned or controlled commercial enterprises,
international organisations, political parties and political candidates. In some countries, this can be a
surprisingly extensive list, including banks and universities.
The provision of money or anything else of value, no matter how small, to any public official for thepurpose of influencing them in their official capacity is prohibited.
Prior approval from your Divisional Compliance team or local Legal Counsel is required for:•••Any payment in respect of fees, salary or commission (this does not include official fees)
Gifts and hospitality
Making charitable contributions or political donations in connection with dealings with a public official.

In addition, many public officials have their own rules regarding the acceptance of gifts and hospitality,
etc., and we must make sure we know and respect these rules where applicable.

Compliance with the policy
We must all act with integrity and ensure that we understand and comply with the policy. All Colleagues
will be required to confirm that they have understood and will comply with the policy when joining
Informa. Training will be provided to relevant employees throughout the group to support them incomplying with their responsibilities. If you are not selected for training but believe that it is relevant foryou then please ask your local HR manager or Group Compliance for further information.
A breach of bribery laws can result in fines for both the company and the individual involved and, in somejurisdictions, could also result in imprisonment.
Failure to comply with this policy, whether or not this is intentional, may lead to disciplinary action (up toand including dismissal), and criminal liability for the individual involved (up to and includingimprisonment).

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We want to know about any issues in our business, so we can take steps tomake them right.
If you see any action or behaviour that is unethical, dangerous or inappropriate,
we’re here to listen.
It could be a potential conflict of interest, a case of harassment, suspected fraud orsomething else. If you are genuinely concerned, or even if you are unsure and justwant to check, you can feel confident speaking up at Informa.

Speaking to colleagues
If you feel comfortable doing so,
speak to:Your senior leader or manager, orUsing our Speak Up service

HR, orHosted by an external third party:

Group Compliance

The service is available 24/7
in multiple languages
Go to informa.com/speak-up foryour regional phone number

Zero Retaliation
We do not tolerate retaliation in any form against
anyone who raises a genuine concern.

Policy Governance
Policy Owner:Group ComplianceApplicable:

This policy is applicable to all Colleagues and anyone acting on Informa’s
behalfClassification:

Internal Policy

Last updated:

March 2024

Additional information:

Please see the Gifts & Entertainment Global Policy

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