Reach plc Modern Slavery Act Statement for financial year ending 29 December 2019

Reach plc (the ‘Company’ or ‘Reach’ or the ‘Group’ or ‘We’) is committed to ensuring there is no slavery or human trafficking within our supply chains or in any part of our business. This statement is made by the Group in accordance with the Modern Slavery Act 2015 (the ‘Act’). Reach fully supports the principles of the Act and outlined below are the steps we have taken during 2019 to ensure our continued compliance with the Act.

Our structure, business and supply chains We produce and distribute content to audiences across the UK and Ireland, through paid-for and free newspapers and magazines, and across the World through multi-platform digital sites (desktop, mobile and app). Our flexible operating model and tight financial control help drive efficiencies through a unified organisational structure ensuring our activities benefit all of our stakeholders and the Group overall. Further details on our business model can be found within our 2019 Annual Report, or on our website www.reachplc.com. It is crucial that we develop strong working relationships with our suppliers, so we can enhance the efficiency of our business and create value, and make sure we treat suppliers in line with our values and ethical standards. We outsource a number of our activities to third-party suppliers and providers. Our main supplier sectors include paper, contracted printing, product distribution services and waste management and recycling. We also engage suppliers of IT and communications services, cleaning, catering and other facilities management services. The Group’s operations and the majority of its suppliers are predominantly in the UK and comprise light manufacturing, office based activities and business travel. For this reason we believe we have a lower risk profile compared with other companies who have a significant overseas presence. A small number of our suppliers are spread over a wide geographical area, including organisations based in America, Ireland and Spain, and we are keen to ensure that the organisations we do business with recognise the importance of complying with the Act and other relevant slavery and human trafficking laws applicable in the regions in which we operate. We believe any suppliers who are based and operate in overseas territories potentially present a higher risk to the business.

We engage with our suppliers in the following ways: ● Logistics efficiencies and environmental management ● Supplier conferences ● Standard terms of business ● Regular supplier meetings, including business plan presentations ● Contingency planning ● Commitment to use of newsprint paper produced from fibre using recycled material or wood from certified sustainable forests ● Discuss key regulatory or governance changes including GDPR, Carbon or other CSR matters

By engaging with our suppliers we can ensure a good spread of supply on newsprint in UK / North America / Europe, maintain long-term wholesaler contracts with key suppliers, gain support from wholesalers for our CSR ambitions and retain ongoing route optimisation.

Due diligence & risk management processes for Modern Slavery and Human Trafficking Reach has an established Modern Slavery Working Group (the ‘Working group’) Chaired by the Chief Financial Officer who is a member of the Reach Board, which consists of senior managers from across the business. The Working Group is responsible for reporting, monitoring and responding to any modern slavery issues which may arise within the business. Whilst we believe our risk profile is lower than some other companies due to the UK centric nature of our operations, we recognise that the Group is exposed to greater modern slavery risks when dealing with certain suppliers, especially those operating in certain other territories. To identify and mitigate these risks, our terms and conditions for suppliers include confirmation of supplier compliance with the Act or applicable local laws. We have communicated our expectations to our suppliers, including their obligations to notify us of any breaches of the Act. If we are informed there has been a compliance failure, the Group is willing to engage with suppliers on a case by case basis and, if possible in the circumstances, senior management will seek to agree to a resolution with the supplier that is appropriate and in compliance with our Anti-Slavery Policy. All signed terms are logged by the appropriate function within the business. During 2019 the Working Group reviewed the current standard clauses found within the Company’s contracts and put in place steps to ensure all new contracts would include a standard clause requiring compliance with the Act. Further action would be taken on this in 2020. We have also made it easier for third parties to ‘blow the whistle’ on any behaviour which may be in contradiction to the requirements of the Act. We have provided a contact on our website, www.reachplc.com/contact-ir, for third parties to use to raise their concerns. Any concerns received would be reviewed by the Working Group and a plan put in place to engage with the identified supplier. This is in addition to the whistleblowing hotline which is detailed below. We expect our suppliers to engage with us in a constructive and responsible way in order to resolve any issues in a timely manner. The Group reserves the right to refuse to on board suppliers unable to demonstrate their policies on, and willingness to comply with, the Act.

Reach’s policies and training in relation to slavery and human trafficking In keeping with Reach’s commitment to act ethically, sustainably and with integrity in relation to all its business dealings, many of our existing policies are relevant and mutually supportive in ensuring that no modern slavery practices or human trafficking activities are tolerated in any part of our business. The Standards of Business Conduct apply to all employees within the Group. This policy is an overarching document that sets out, in practical, common-sense terms, what acting in a ‘professional’, ‘moral’ and ‘ethical’ manner means on a day-to-day basis. All staff are issued with our Standards of Business Conduct Policy when on boarded, which aids the promotion of our ethical standing within the business. The Anti-Slavery Policy details the signs that identify modern slavery, describes the responsibilities of staff to look out for such indications of modern slavery, and explains how to report any suspicions of modern slavery to senior management (including through the use of the whistleblowing hotline, described below). We have enabled our staff to understand more about modern slavery in the workplace by providing additional information and guidance, such as referring staff to the UK Government’s modern slavery website for additional helpful literature on this issue. The Group’s Procurement Policy seeks to ensure the Group does not take on unacceptable risks when on boarding a supplier, including those relating to modern slavery. The Group will not engage a new supplier if we are informed they exploit workers, disregard health and safety laws and wilfully damage the environment. A summary of the Group’s Procurement Policy and Standards of Business Conduct Policy can be found in the Corporate Governance section of our website www.reachplc.com.

We operate a Group-wide whistleblowing hotline to facilitate confidential reporting of illegal or unethical behaviour. Staff are able to report anonymously. All complaints raised by staff are investigated by senior management. We have embedded Group policies which strictly prohibit any form of discrimination based on gender, race, disability, sexuality, religion or age in the workplace. We respect the human rights of our employees through ensuring all employees are issued with clear contracts of employment, that working hours as standard are set within the working time directive maximum thresholds, and have committed to ensuring that no employee will be forced to opt out of applicable working time regulations. Our employees are paid for work undertaken and receive holidays and rest periods in line with regulations. We monitor employees’ holiday usage to ensure they take statutory entitlements, reducing the risk of breaches of regulations by publishing employee entitlements. Under our contracts all of our employees are paid above national minimum wage thresholds. The Group does not have any zero hour contracts. During 2019 we developed and launched a new corporate policy suite. All staff within the Group were required to read and confirm their understanding of each policy included within the module which consisted of the following policies; Anti-Slavery, Standards of Business Conduct, Data Protection, Disclosure, Anti-bribery and Payments, Fraud and Group procurement. By ensuring our staff know and understand our policies we can further mitigate any modern slavery risk within our workforce.

Effectiveness and ongoing compliance The Modern Slavery Working Group will continue to meet throughout 2020 in order to monitor the implemented controls and continue to develop the Group’s due diligence processes. The Company will periodically assess the suitability and effectiveness of the process and report on progress on an annual basis, in compliance with the Act. As the inherent supplier risks change over time, we will review and update our policies and approach to addressing slavery and human trafficking risks in the Group’s supply chain.

This statement is made pursuant to section 54(1) of the Act and constitutes the Group's modern slavery and human trafficking statement for the financial year ending 29 December 2019.

Approved by the Board of Directors of Reach plc on 15 June 2020,

Jim Mullen Chief Executive Officer

N.B. This statement is applicable to Reach’s wholly-owned subsidiaries as listed in the 2019 Annual Report and Accounts, an extract of the subsidiary list can be found below.

Subsidiary and associated undertakings as at 29 December 2019

The following subsidiary undertakings are 100% owned (all share classes) and incorporated in England and Wales, with a registered office at One Canada Square, Canary Wharf, E14 5AP.

Subsidiary name Express Newspapers Properties Limited Holdings Limited 0800 Recruit Limited Express Printers Manchester Limited Local World Limited 08000 Recruit Limited Express Property Management Limited London and Westminster Newspapers Limited Ad-Mag (North East) Limited Financial Jobs Online Limited London Newspaper Group Limited Advertiser North London Group Fish4 Limited (Holdings) Limited Mainjoy Limited Fish4 Trading Limited Advertiser North London Limited Manchester Morning News Limited Fish4Cars Limited AMRA Limited Markstead Limited Fish4Homes Limited Arrow Interactive Limited Mayfair Celebs Limited Fish4Jobs Limited Beaverbrook Newspapers Limited Media Wales Limited Gazette Media Company Limited Birmingham Live Limited Medpress Limited Gimmejobs Limited & Mail Meilin Limited (Exhibitions) Limited Gisajob Limited MEN Investment Limited Birmingham Post & Mail Trustees Limited High Street Direct Limited MEN Media Limited Blackfriars Leasing Ltd. Hot Exchange Limited Mercury Distribution Services Limited Blackmore Vale Publishing Hot Flats Limited Merseymart Limited Company Limited Hot Flights Limited MG Estates Limited BPM Media (Midlands) Limited Hotrecruit Limited MG Guarantee Co Limited Broughton Printers Limited Huddersfield Examiner Limited MG6 Limited Burginhall 677 Limited Huddersfield Newspapers Limited MGL2 Limited Buy Sell Limited I.T. Trade Publishing Limited MGN (86) Limited Camberry Limited Informer Publications Limited MGN (AW) Limited CDE Services Limited International Distribution 2018 Limited Century Communications Ltd. (In Strike-Off) MGN (Canada Square) Limited Channel One Liverpool Limited Internet Recruitment Solutions Limited MGN (Services) Ltd Chargestake Limited Isle of Wight Newspapers Limited MGN Limited Charles Elphick Limited Job Search Limited MGN Pension Trustees Limited City Television Network Limited Jobsfinancial Limited MGN Property Developments Limited Community Magazines Limited Jobsin Limited Micromart (UK) Limited Conrad & Partners Limited JobsinHRSolutions Limited Middlesex County Press Limited Coventry Newspapers Limited Jobsinlaw Limited Midland Independent Magazines Limited Limited JobsinUK Limited Midland Independent Newspaper & Media Sales Limited Investments Limited Joseph Woodhead & Sons Limited Midland Independent Weekly Daily Post Overseas Limited Just London Jobs Limited Newspapers Limited Daily Star Limited Kennyhill Limited Midland Leaflet Services Limited Denitz Investments Limited Kent Regional Newspapers Limited Midland Newspapers Limited Echo Press (1983) Limited Lancashire & Cheshire County Midland Newspapers Pension Newspapers Limited Trustees Limited Enterprise Magazines Limited Legionstyle Limited Midland Newspapers Printers Limited Examiner News & Information Services Limited Live TV Limited Midland United Newspapers Limited Export Magazine Distributors Limited Liverpool Web Offset Limited Midland Weekly Media (Birmingham) Limited Express Newspapers Liverpool Weekly Newspaper Group Limited Midland Weekly Media Express Newspapers Pension (Wolverhampton) Limited Trustees Limited Llandudno Advertiser Limited Midland Weekly Media Limited

136 Reach plc Annual Report 2019 Subsidiary and associated undertakings continued as at 29 December 2019

Midland Weekly Newspapers Limited Reach Nationals Limited The Graduate Group Ltd Mirror Colour Print Reach Network Media Limited The Green Magazine Company Limited (London No. 1 Plant) Limited Reach Pension Trustees Limited The Hinckley Times Limited Mirror Colour Print (London) Limited Reach Printing Services The Hotgroup Limited Mirror Colour Print (North) Limited (Midlands) Limited The Liverpool Daily Post and Echo Limited Mirror Colour Print Services Reach Printing Services (Oldham) Limited (London) Limited The People Limited Reach Printing Services (Teesside) Limited Mirror Colour Print Services Limited This Is Britain Limited Reach Printing Services (Watford) Limited Mirror Financial Services Limited TIH (Belfast) (Nominees) Limited Reach Printing Services Mirror Group Music Limited (West Ferry) Limited TIH (Cardiff) Limited Mirror Group Newspapers Limited Reach Printing Services Limited TIH (Chester) Limited Mirror Group Newspapers North Reach Publishing Group Limited TIH (Newcastle) Limited (1986) Limited Reach Publishing Services Limited TIH (Properties) Limited Mirror Projects Limited Reach Regionals Limited TIH (Teesside) Limited MirrorAd Limited Reach Regionals Media Limited TIH (Trustee) Limited Mirrorair Limited Reach Secretaries Limited TM Leasing Limited Mirrorgroup Limited Reach Shared Services Limited TM Media Holdings Limited MirrorNews Limited Reach Southern Media Limited TM Mobile Solutions Limited MirrorTel Limited Reach Work Limited TM North America Limited NCJ Media Limited Reliant Distributors Limited TM Regional New Media Limited Net Recruit UK Limited RH1 Limited TM Titles Limited Newcastle Chronicle and Journal Limited Scene Magazines Limited TM Tower Management Services Limited North Eastern Evening Gazette Limited Scene Newspapers Limited Totallyfinancial.com Ltd North Wales Independent Press Limited Scene Printing (Midlands) Limited Totallylegal.com Limited Scene Printing Web Offset Limited Tower Magazines Limited Nunews Limited Sightline Publications Limited Trinity 100 Limited O K Magazines Trading Co Limited Smart Media Services Limited Trinity 102 Limited O.K. Magazines Limited Southnews Trustees Limited Trinity Limited Odhams Newspapers Limited Sunday Brands Limited Trinity Mirror (L I) Limited Official Starting Prices Ltd. Sunday Express Limited Trinity Mirror Acquisitions (2) Limited OK! Magazine Holdings Limited Sunday People Limited Trinity Mirror Acquisitions Limited Parkside Accountancy Limited Surrey & Berkshire Media Limited Trinity Mirror Cheshire Limited Parkside Consulting Limited Syndication International (1986) Limited Trinity Mirror Digital 1 Limited Planet Recruitment Limited Syndication International Limited Trinity Mirror Digital Limited Planetrecruit Limited T M S Pension Trustee Limited Trinity Mirror Digital Media Limited Quids-In (North West) Limited The Adscene Group Limited Trinity Mirror Distributors Limited R.E. Jones & Bros. Limited The Advertiser Limited Trinity Mirror Finance Limited R.E. Jones Graphic Services Limited The Associated Catholic Newspapers Trinity Mirror Huddersfield Limited R.E. Jones Newspaper Group Limited (1912) Limited Trinity Mirror Marketing Direct Limited Reach Directors Limited The Birmingham Boat Shows Limited Trinity Mirror Media Limited Reach Magazines Distribution Limited The Birmingham Post & Mail Limited Trinity Mirror Merseyside Limited Reach Magazines Limited The Career Engineer Limited Trinity Mirror North Wales Limited The and Associated Reach Magazines Publishing Limited Trinity Mirror Printing (Cardiff) Limited Newspapers Limited Reach Magazines Worldwide Limited Trinity Mirror Printing (Liverpool) Limited The Newspapers Limited Reach Media Group Limited Trinity Mirror Printing (Newcastle) Limited The Echo Press Limited Reach Midlands Media Limited

Reach plc Annual Report 2019 137 Subsidiary and associated undertakings continued as at 29 December 2019

Subsidiary name United Magazines Publishing West Ferry Leasing Limited Services Limited Trinity Mirror Regional Newspapers Limited West Ferry Printers Pension Scheme Vectis Innovations Limited Trustees Limited Trinity Mirror Videos Limited Vibrant Limited & Echo Limited Trinity Newspaper Group Limited Vivid Group Limited Whitbread Walker Limited Trinity Newspapers Southern Limited Vivid Limited Wire TV Limited Trinity Publications Limited Wandsworth Independent Limited Wirral Newspapers Limited Trinity Retirement Benefit Scheme Limited Websalvo.com Limited Wood Lane One Limited Trinity Shared Services Limited Welsh Universal Holdings Limited Wood Lane Two Limited Trinity Weekly Newspapers Limited Welshpool Web-Offset Co. Limited Workthing Limited

The following subsidiary undertakings are 100% owned (all share classes) and incorporated in Scotland, with a registered office at One Central Quay, Glasgow G3 8DA.

Subsidiary name Insider Publications Limited Scottish and Universal Newspapers Limited Aberdonian Publications Limited Media Scotland Limited Scottish and Sunday Anderston Quay Printers Limited Metropolitan Free Newspapers Limited Mail Limited Dundonian Publications Limited Newsday Limited Scottish Express Newspapers Limited First Press Publishing Limited Northern Print Services Limited The Edinburgh and Lothians Post Limited Glaswegian Publications Limited Reach Printing Services (Saltire) Limited Trinity Mirror Printing (Blantyre) Limited icScotland Limited Saltire Press Limited Insider Group Limited Scotfree Limited

The following subsidiary undertaking is 100% owned (all The following subsidiary undertaking is 100% owned (all share share classes) and incorporated in England and Wales, with a classes) and incorporated in the United States of America, with registered office at 26–28 Bedford Row, London, WC1R 4HE. a registered office at 101 Avenue of the Americas, Suite 934, This entity is currently in liquidation. New York NY 10013.

Subsidiary name Subsidiary name Iberian Ediciones Limited Trinity Mirror Marketing LLC

The following subsidiary undertaking is 100% owned (all share classes) and incorporated in Ireland, with a registered office at The following subsidiary undertaking is 100% owned (all share 40 Upper Mount Street, Dublin 2. classes) and incorporated in Northern Ireland, with a registered office at 415 Holywood Road, Belfast BT4 2GU.

Subsidiary name Subsidiary name Reach Publishing (Ireland) Limited Trinity Mirror Limited

138 Reach plc Annual Report 2019