PENTON LEARNING SYSTEMS LLC

Penton Learning Systems recognises that modern slavery and human trafficking is a violation of fundamental human rights and is contrary to applicable laws, including but not limited to the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 (the "Acts").  We are committed to continually improving our practices to combat slavery and human trafficking and to encourage the same high standards from our supply chain and other business partners. 

OUR BUSINESS AND STRUCTURE.

This report is submitted on behalf of Penton Learning Systems, d/b/a International Quality and Productivity Center, a U.S. based limited liability company, and its affiliates and subsidiaries (collectively, the "IQPC Group").  The IQPC Group operates primarily in North America, Australia, Singapore, Western Europe and the United Kingdom.  The business of the IQPC Group is the provision of B2B conferences on various topics across these regions, together with web-based training and informational services for businesses.  Established in 1973, and employing nearly 1,000 employees across its regions, the IQPC Group sets the standard for professional marketing, educational and networking opportunities across its topics.  

OUR SUPPLY CHAINS/RISK ANALYSIS.

While mindful of our obligations, and our ongoing commitment to ensuring human rights are protected within our business and our supply chains, we do not consider that we operate in high-risk geographic sectors for human trafficking and modern slavery. Our supply chain partners are predominantly based in the regions where we operate (England and Western Europe, North America, Australia and Singapore), which are all jurisdictions with relatively high labour law standards. Thus, employees of our supply chain partners are protected under the relevant employment and human rights laws of those jurisdictions. The IQPC Group does not conduct business, or regularly contract with suppliers, in countries where there is active human trafficking and / or modern slavery.  

The IQPC Group's supply chain includes:

• Marketing and branding services, including advertising and public relations agencies, web design and media partners
• Suppliers associated with the operations of our conferences, including hotels/venue spaces, food & beverage, event security, décor and signage services, audiovisual companies and photographers for the event, and companies to assist in the set-up and breakdown of the event space
• Suppliers associated with the provision of entertainment during our conferences, including entertainers, local transport; and catering services
• Suppliers licensing various technical and business services, including document management services, sales software, music licenses.

The IQPC Group is mindful of the fact that some of our supplier industries (hospitality and other industries associated with the running of large-scale events, such as catering, cleaning, security and temporary labor) may themselves be service categories which present an elevated risk. Thus, the IQPC Group remains aware of the need to ensure that all companies within our supply chain share our commitment to treat their employees in a fair and ethical way.  The IQPC Group addresses this through the due diligence procedures and Company policies discussed below. 

DUE DILIGENCE, POLICIES AND TRAINING RESOURCES.

As part of our procurement process, the IQPC Group carries out appropriate checks on potential new suppliers to evaluate whether there is any risk of modern slavery or human trafficking. This includes checking if they operate in a high-risk country or industry.

If a potential supplier operates in a high-risk country or industry for modern slavery, the IQPC Group has the ability to undertake enhanced checks before determining whether to proceed with the potential business arrangement.  In addition to our own enhanced checks, we ensure that such suppliers have in place an anti-slavery policy, or agree in their contract with the IQPC Group to abide by those standards.  Further, it is our policy that significant supplier contracts, including contracts of a nature or in a jurisdiction which poses higher risks, must be reviewed and approved by our legal counsel before execution.  

The IQPC Group continues to assess its suppliers over the business relationship.  We may reassess our contract relationships where there is any material change in the supplier's geography, service type or risk profile, or if any other concerns arise over the course of that relationship.  If, in any existing supplier contract, we become aware of a failure to comply with the anti-slavery provision in that contract, we may terminate our relationship with the supplier or elect to work with the supplier to resolve such issues.

The IQPC Group has several written policies that reaffirm our commitment to human rights, fair labor practices and other anti-slavery requirements.  These policies include an Anti-Slavery and Human Trafficking Policy, embedded within our overall written Code of Conduct; our Employee Handbook, which includes our commitments to complying with fair labor standards and ethical practices throughout our business operations, and our Anti-Bribery and Corruption Policy.  

Our Code of Conduct is distributed to all IQPC Group employees and we require that each employee acknowledge that Code in writing.  Employees also receive training and awareness materials regarding the Code of Conduct, ethical business standards, anti-bribery requirements and reporting obligations during onboarding, with periodic refreshers as appropriate.  The IQPC Group's policies are regularly updated and redistributed across the company, and reside on the company's intranet system where they are accessible to all employees.  
The IQPC Group's policy frameworks, and our efforts to train and remind employees of these frameworks, reflect our top-down commitments to acting ethically and with integrity within our supply chains and more widely, across all of our business engagements.

The IQPC Group's policies also expressly encourage candid reporting of potential issues or concerns.  As set out in our Employee Handbook, we maintain a clear Whistleblowing Policy that details the processes for escalating and reporting any concerns, and which is regularly communicated to employees. The IQPC Group encourages all employees to report concerns regarding wrongdoing or breaches of policy (including any matters relating to forced or compulsory labour or human trafficking) through several available channels, including the HR Department, the Office of the General Counsel, or directly to senior management. The IQPC Group also maintains an explicit policy of non-retaliation in respect of any such reporting, in order to ensure that employees feel able to raise concerns freely and without fear of adverse consequences.

RISK AND COMPLIANCE.

Our supply chains are relatively simple, and primarily limited to jurisdictions with relatively high labour law standards, such as the UK, Europe and the USA. The IQPC Group's business does not include the manufacture, import or export of any physical products.  We do not consider that we operate in a high-risk sector for human trafficking and modern slavery. No incidents of modern slavery have been identified within our business or supply chain in the most recent financial year.

However, the company remains mindful of the worldwide issues of human trafficking and modern slavery, and of its responsibilities under applicable laws and under the principles of responsible corporate citizenship.  We will continue to review and update our policies as needed, to monitor our practices and our supply chains, and to update our policies and processes promptly in response to any changes in the law or circumstances.  

This statement has been approved by the Board of the IQPC Group on behalf of its members and all group entities and is signed by:

Michael R. Worden

Director and Chief Financial Officer

Updated June 2026