USA TODAY Co., Inc.

Risk management and strategy

We recognize the importance of assessing, identifying, and managing material risks associated with cybersecurity threats

(as such term is defined in Item 106(a) of Regulation S-K), including, among other things, operational risks, intellectual

property theft, fraud, extortion, harm to employees or customers, violation of privacy or security laws and other litigation and

legal risks, and reputational risks.

We employ various processes and controls to aid in our efforts to identify, assess, and manage our material risks from

cybersecurity threats and to protect against, detect, and respond to cybersecurity incidents (as such term is defined in Item

106(a) of Regulation S-K). To identify and assess material risks from cybersecurity threats, we consider and gather information

with respect to the confidentiality, integrity, and availability of our information systems (as defined in Item 106(a) of

Regulation S-K). We have adopted policies and procedures that are designed to assist us with managing identified risks at a

system and organizational level and with assessing the materiality of the risk, its severity, and potential mitigations or

remediations. Our enterprise risk management program considers cybersecurity threat risks alongside other company risks as

part of our overall risk assessment process.

The cybersecurity risk identification process includes: (i) identifying information systems and assets, including physical

and virtual devices, software, data, data transfers, external systems, and cloud resources; (ii) reviewing organizational business

processes, identities, access, and roles (including privileged access), asset configurations, technology policies, standards,

controls, and processes; (iii) determining if those systems or assets process or store customer and/or employee personal data,

(iv) analyzing the criticality of systems, assets and business processes and sensitivity of data; and (v) identifying vulnerabilities

and threats to the identified systems, assets, data, and processes, from both internal and external sources, including through

threat intelligence, previous cybersecurity incidents, and third-party assessments.

Our processes also consider cybersecurity risks associated with our use of third-party service providers and business

partners, including those in our supply chain and those who have access to our customer and employee data or our information

systems. Identified third-party service provider and business partner risks are managed by our cybersecurity risk management

program. In addition, cybersecurity and privacy considerations affect the selection and oversight of our third-party service

providers and business partners, as well as third-party specific integration plans. Additionally, we generally require those third

parties that could introduce significant cybersecurity or data privacy risk to us to agree by contract to comply with applicable

data protection laws, and to manage their cybersecurity risks by implementing appropriate technical and organizational

measures, and to agree to be subject to cybersecurity audits, which we conduct as appropriate.

We employ a range of tools and services to inform our risk preparedness, identification, assessment and remediation

processes, including, among others, continuous monitoring, regular reoccurring security and compliance activities, training,

threat intelligence, business processes, change management, strategic planning, annual assessments, and periodic testing and

assessments performed by qualified security personnel and by third-party firms. As part of the above-described processes, we

engage with third-party firms to perform independent assessments, including internal and external penetration tests,

configuration assessments, security plan and program assessments, compliance assessments, and incident response readiness

exercises to help identify areas for continued focus, improvement and/or compliance.

Identified risks are evaluated and assessed by the Company's security review council, comprised of various security,

technology, legal and privacy staff members and management. A member of management is assigned as the risk owner and

takes an active role in managing the risk, including approving the risk response and risk treatment plan, as well as participating

in assessing any residual risk after implementation of the treatment plan. Our Chief Information Security Officer oversees our

cybersecurity risk management program.

In the event of a potential material risk, the risk is reported to the Chief Information Security Officer, the Chief Technology

and Data Officer, the Chief Privacy Officer and to the legal department and the appropriate member of senior management

responsible for the function where the risk has been identified. The risk is then reviewed by the Disclosure Committee, which

includes among others, the Company's Chief Executive Officer, Chief Financial Officer, Chief Legal Officer, and Chief

Accounting Officer to determine whether the risk is material for disclosure purposes in accordance with applicable rules and

regulations.

In 2025, our business strategy, results of operations, and financial condition were not materially affected by risks from

cybersecurity threats but we cannot provide assurance that they will not be materially affected in the future by such risks or any

future material incidents. We describe whether and how risks from identified cybersecurity threats, including as a result of any

previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect us, including our business

strategy, results of operations, or financial condition, under the heading "Risks Related to Personal Information, Cybersecurity,

Artificial Intelligence, and Other Technology" under Risk Factors in this Annual Report on Form 10-K, which disclosures are

incorporated by reference herein.

Governance

Cybersecurity is an important part of our risk management processes and an area of increasing focus for our Board of

Directors and management. Our Board of Directors has delegated oversight of risks from cybersecurity threats to its

Nominating and Corporate Governance Committee (the "Governance Committee"). Quarterly or as needed, our directors

receive an overview from management of our cybersecurity program and strategy covering topics such as cybersecurity

incidents and response, progress towards pre-determined risk-mitigation-related goals, results from third-party assessments,

cybersecurity staffing, compliance status, and material cybersecurity threat risks or incidents and developments, as well as the

steps management has taken to respond to any such risks. In such sessions, our Chief Information Security Officer is available

to the directors to discuss any relevant cybersecurity matters. In addition, at least bi-annually, the Chief Information Security

Officer reports to the Governance Committee about cybersecurity threat risks, among other cybersecurity related matters.

Our cybersecurity risk management and strategy processes discussed above are led by our Chief Information Security

Officer and Chief Technology and Data Officer. Specifically, our Chief Information Security Officer has approximately 11

years of experience developing cybersecurity strategy, incident response, and implementing cybersecurity programs for public

media companies and is a certified boardroom Qualified Technology Expert and Certified Information Systems Security

Professional.