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Item 16B. CODE OF ETHICS

WPP has in place a Code of Business Conduct that constitutes a “code of ethics” as defined in applicable regulations of the Securities and Exchange Commission. The Code of Business Conduct, which is reviewed annually by the Board, sets out the principal obligations of all directors, officers and employees. Directors and senior executives throughout the Group are required each year to certify compliance with this Code. The Code of Business Conduct was updated in 2025 to reflect latest updates in law and regulations, including the UK Economic Crime and Corporate Transparency Act's fraud offence which came into effect on September 1, 2025. The WPP Code of Business Conduct is available on the Company’s website, http://www.wpp.com/investors/corporate-governance.

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