Groupon - Modern Slavery Act Transparency Statement

MyCityDeal Limited, Groupon Shop Ltd, Groupon Europe GmbH, Groupon Goods Global GmbH, Groupon International Travel GmbH, and Groupon Goods UK Ltd (together, “Groupon“).

INTRODUCTION

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. You can click here to learn more about the Act.

At Groupon, we believe we have a responsibility to ensure that our business is conducted in an ethical way and we actively engage to address social 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 combatting slavery where possible.

As such, we are issuing this Modern Slavery Act Transparency Statement (the “Statement”), which includes a description of our 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.

ORGANISATION'S STRUCTURE

Groupon is part of a global e-commerce marketplace. Groupon Inc. is the ultimate parent company of the entities that make up Groupon. Groupon Inc. is headquartered in the United States (Chicago, Illinois).

MERCHANTS AND SUPPLY CHAIN

Groupon's merchants, vendors, and suppliers (together, “Merchants”) include but are not limited to:

· Merchants for whose services or goods MyCityDeal Limited sells vouchers;

· Merchants who sell goods to Groupon Goods Global GmbH and Groupon Shop Ltd (together, “Goods Merchants”); and

· Merchants for whom Groupon International Travel GmbH sells vouchers or makes available other travel-related products.

Groupon evaluates potential Goods Merchants it seeks to work with for compliance with applicable laws, including the Act, before they engage in any transactions with Groupon, as detailed below.

DUE DILIGENCE

As part of our initiative to identify and mitigate the risk of slavery and human trafficking occurring in our supply chain:

· We directly ask potential Goods Merchants whether they “engage in child labour, slavery, forced labour and/or human trafficking” in our Groupon Vendor Vetting Questionnaire. We refuse to do business with potential Goods Merchants who respond that they in fact engage in any or all of these practices;

· We ask our Merchants to confirm in our agreements with them that they comply with all applicable international, federal, state, local, and other laws, which would include laws related to child labour, slavery, forced labour and/or human trafficking; and

· We provide several methods for employees to report their concerns about modern slavery practices to Groupon’s Compliance Team, including by using our ethics hotline, EthicsPoint. We make clear in our policies that employees who report their concerns regarding violations of applicable laws or policies in good faith shall not be penalised.

MONITORING AND REPORTING

Concerns or complaints arising under or related to the Act should be reported to the Compliance Team at legalcompliance@groupon.com or via EthicsPoint at

https://secure.ethicspoint.com/domain/media/en/gui/31495/index.html . EthicsPoint complaints may be made anonymously.

The Compliance Team will promptly investigate any issues or complaints that arise 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 human trafficking Statement for the current financial year.

Julie Szudarek

Chief Operating Officer, EMEA

Date: September 16, 2016