Code of Conduct

At LSEG, we are committed to delivering excellence – both in our performance and our conduct. As a leading global financial markets infrastructure and data provider, we have a responsibility to protect our employees, customers and shareholders and to contribute towards wider economic stability.

The trust of our stakeholders is critical to our sustainable growth. We each share the responsibility for acting openly and honestly and treating all of our stakeholders as valued partners in our business.

LSEG wants our people to know that the Group offers a fulfilling, stimulating and respectful environment in which to work and develop their careers; our customers to know that they have chosen a partner who will support their businesses’ success; and our shareholders to know that their investment is in capable hands.

We know that the right culture is critical for us to achieve our ambitions. This means creating an inclusive environment where we can all perform, grow and develop and bring our whole selves to work

As a Group we are collectively bound by the commitments we make to each of our stakeholder groups.

We seek to work in partnership with our customers, building relationships that are founded on:

• An understanding of their needs and business ambitions
• A high-quality consistent and reliable service that represents value for money
• Fair, open and honest treatment

We look to:

• Enhance shareholder value and provide superior returns in a way which is consistent with our values and meets the principles of good corporate governance
• Forge long-term relationships based on open communication, mutual understanding, integrity and trust
• Provide our investors with timely, regular, full and accurate information on our activities, strategy and financial performance

We are committed to:

• A working environment that is safe, respectful, fulfilling and stimulating and which promotes diversity, inclusion, ongoing learning and equal opportunity
• Recruiting and promoting employees on the basis of the qualifications and abilities needed to perform their role and to develop meaningful careers
• Remunerating employees based on industry norms in the markets and countries in which we operate and business and individual performance
• Maintaining good communications with employees

LSEG seeks to establish mutually beneficial relations with our suppliers and business partners based on:

• Honouring and enforcing contractual terms to which we commit
• Operating in accordance with the principles of fair competition
• The operation of a strictly enforced Gifts and Entertainment Policy and Conflict of Interest Policy to ensure that nothing is given or received with the intention of inducing an individual to act improperly
• Zero-tolerance for modern slavery and human trafficking in either our own business or in any of our supply chains and
• Striving only to do business with organisations which uphold similar business principles

We actively seek to work with suppliers who share our ethical standards and commitment to sustainable business practices. This means we:

• Perform due diligence on third-party suppliers, including consideration of their sustainability practices
• Seek a diverse supply chain that reflects our employee base, customers and partners around the world
• Require prospective and current suppliers to be aware of the LSEG Supplier Code of Conduct and seek their commitment in following it

We are committed to:

• Meeting the obligations to which we are subject under the regulatory and legal frameworks in place in all jurisdictions in which we operate
• Maintaining orderly and proper markets that balance the needs of our diverse market participants, managing risk, supporting financial stability and providing appropriate transparency and protection for investors
• Open and proactive engagement with our regulators

In addition to the role the Group plays in the wider global economy as a result of capital allocation and job creation, LSEG seeks to have a positive impact on the communities in which we operate through:

• Displaying sensitivity to the cultural and social principles of those communities
• Providing financial support and grants to registered charities through the LSEG Foundation
• Offering all employees two days a year to volunteer for charitable causes
• Matching employees’ qualifying personal charitable giving and fundraising efforts
• Operating with integrity in our community relations at all times

• Our reputation is critical to our long-term success. We comply with both the letter and spirit of the law and we always aim to behave in a manner that is fair and just. We are honest and truthful in all our work-related dealings
• We are courteous, considerate and professional in our work-related activities, always respecting cultural differences and others’ views. These standards extend to our personal lives, to the extent that our behaviour could impact LSEG’s reputation
• We seek help if we have questions about the applicability or interpretation of any law, rule, regulation or LSEG policy

We treat others with respect and do not tolerate harassment of any kind in our workplaces, including sexual harassment and bullying. This means you must comply with the Group’s Anti-Harassment and Bullying and Diversity, Equality and Inclusion Policies and any local policies and procedures in your location. We support dignity in the workplace without regard for whether the person engaging in the conduct or the recipient is an employee, People Leader, business partner, customer, consultant or visitor and do not permit discriminatory conduct towards – or by – any of these groups. Even if local law does not prohibit these acts, we hold ourselves to a higher standard.

By putting a premium on fairness, equality, respect and dignity and not allowing discrimination, harassment or bullying, we aim to see that everyone who enters our workplaces feels protected and empowered to achieve their full potential.

A conflict of interest may arise whenever our personal interests appear to interfere with the best interests of the Group or appear to make it difficult for us to do our jobs objectively and effectively and without the appearance of divided loyalties. By recognising, avoiding and disclosing potential conflicts, we protect our reputation and our ability to do business effectively. We expect you to avoid real and perceived conflicts of interest at all times. This means you must comply with the Group’s Conflict of Interest Policy and:

• Put the Group’s interest ahead of any personal interest or gain in a business transaction 
• Take responsibility for identifying and avoiding situations that could appear to compromise your judgement, such as: 
  • Close personal relationships with subordinates
  • Personal financial interests in third parties, including significant ownership (of more than 1%) in a supplier or customer
  • Competition with LSEG: outside business activities or directorships which detract from our ability to devote appropriate time and attention to the Group, or conflict with our role or the objectives of LSEG
  • Use of LSEG resources for personal gain
  • Inappropriate or excessive Gifts and Entertainment given to or received from third parties

We value our reputation for security and integrity above all and recognise our customers’ trust in us.

By the nature of our work, we may have access to information that is non-public and price-sensitive about our investors, our investments, our customers, potential customers and suppliers or other companies with which the Group does business. This price-sensitive information is also called inside information or material non-public information. We treat this information lawfully and ethically and aim to avoid even the appearance of impropriety. We understand that the misuse of information could result in market abuse and other breaches of insider trading laws. These carry severe penalties including imprisonment.

To protect the information entrusted to the Group, you must comply with the Personal Account Dealing in non-LSEG Securities Policy and the Dealing in LSEG Securities Policy and must not enter or procure or advise others to enter into a personal transaction which:

• Is prohibited under law or regulation
• Involves the misuse or improper disclosure of confidential or proprietary information
• May give rise to a conflict of interest

This means we do not:

• Trade, or encourage another person to trade, on any inside information or confidential information obtained by any means
• Provide inside information or confidential information to, or leverage inside information or confidential information provided by, another party, outside of the duty to the Group
• Undertake any activity deemed or perceived to be market abuse

We believe in vigorous and fair competition. In competing for business, we do so fairly and ethically and in full compliance with competition and antitrust laws. These laws prohibit making agreements with competitors, customers, suppliers or other third parties that limit competition. You have personal responsibility for compliance and must familiarise yourself and comply with the Competition Compliance Policy. If an answer to a specific antitrust question is not clear, you should seek help and advice from Legal and Compliance.

We must always make independent business decisions. Antitrust laws generally prohibit making agreements with competitors, customers, suppliers or others to restrict competition. In particular, we must never discuss or agree with competitors to:

• Fix prices, terms or bids
• Allocate customers, territories or markets
• Limit production, supply or investment
• Not solicit each other’s customers or talent
• Share non-public competitively sensitive information (such as pricing or strategy) 

We have additional obligations in instances where we may have a significant market position or “dominance” (generally assumed to be over 40% market share). In addition, be guided by the following principles:

• Comply with the letter and spirit of applicable laws
• Recommend only products, services and solutions that we believe are the proper fit for each customer’s needs
• Remain transparent and forthright in all contracting
• Award contracts based on merit and clearly defined benchmarks
• Provide accurate and timely documentation
• Deliver on what we promise
• Be honest and accurate in advertising and marketing claims, avoiding exaggeration, misrepresentation and ambiguity
• Take special care when making comparative claims and do not disparage or unfairly criticise a competitor’s products or services 

Bribery, corruption, money laundering and terrorist financing, sanctions breaches, tax evasion and other financial misconduct destabilises governments and economies and undermines public trust. As a leading financial markets infrastructure and data provider, it is critical to our reputation and our financial success that we combat bribery and other financial misconduct wherever we see it. As such, you must comply with the Financial Crime Policy and the Anti-Bribery and Corruption Policy.

We never offer, give, authorise or accept a bribe. This means we do not offer, give, authorise or accept any gift or personal benefit to or from a third party – unless it complies with our Gifts and Entertainment Policy – and we report any attempted or actual bribe or improper payment or gift to Compliance.

In addition, we never offer, give or authorise an unofficial payment to a government or public official, even if the payment is to speed up a routine governmental action (such as visa processing or customs clearance). Payments to speed up routine actions are known as ‘facilitation payments’ and are prohibited at LSEG, even if they are allowed under local law. These requirements apply whether the other party is in the public or the private sector.

We understand that we could be held responsible for breaches by our business partners, so we:

• Carry out a level of due diligence appropriate to the risk before we engage suppliers, consultants and other business partners
• Communicate our expectations with respect to anti-bribery and anti-corruption to business partners at the outset of our business relationship and as appropriate thereafter
• Mitigate or terminate business relationships as appropriate if we learn that a business partner may have breached our standards 

Sanctions and Export control laws can be extremely complex and constantly changing and we are expected to know them and abide by them at all times. Even unintentional breaches could result in penalties – but the sooner we report and resolve the issue, the better. This means we:

• Know where to access the current list of sanctioned or embargoed countries/territories
• Do not do any business with: 
  • Sanctioned countries/territories or any individuals or entities resident in, organised under the laws of, or operating from any of these countries/territories
  • Any sanctioned organisation or individual or entity owned by a sanctioned organisation or individual
• Conduct due diligence on partners, customers and third parties as appropriate and appropriately screen partners and customers to ensure that they are not subject to sanctions or embargoes
• Seek guidance on proper export procedures before deciding to export any products or services
• Remain alert for sanctions red flags such as payments made through multiple accounts, requests that payments be made at odd times or in odd amounts and requests for refunds in forms that are different from the payment originally used
• Immediately alert the Sanctions and Export Controls Group if we have reason to believe anyone within LSEG or any third party may be intentionally or inadvertently doing business with a sanctioned country/territory, entity or individual
• Are expected to abide by sanctions and exports control policies and compliance procedures as defined by LSEG

Money laundering is the process by which funds generated through criminal activity (such as terrorism, drug dealing etc...) are processed through transactions in order to hide the source of the proceeds, avoid reporting requirements or evade taxes. We follow all anti-money laundering and anti-terrorist financing laws that are applicable to us and do not condone or facilitate money laundering. This means we must:

• Know and understand who we are dealing with (‘know your customer’), remain alert for possible instances of money laundering and immediately make an internal notification of any suspicious activity to Compliance (without informing the third party in question)
• Recognise that our regulated entities have enhanced obligations and those of us working in or on behalf of those businesses must make sure we understand and comply with these obligations

We believe the payment of tax is an important contribution to the economies and societies that LSEG operates in, and we believe in the obligation to pay our fair share of tax legally due in any country at the right time. Accordingly, we ensure the Group complies with all relevant tax laws and regulations, considering policy intent. To that end, LSEG does not undertake purely artificial transactions to obtain a tax benefit. The Group does not tolerate tax evasion.

In addition, we apply appropriate procedures and controls to prevent any person acting on the Group’s behalf from facilitating tax evasion. We understand that we could be held responsible for the facilitation of tax evasion and so we routinely review our procedures and controls to ensure they are reasonable to prevent the facilitation of tax evasion by an associated person of the Group.

Participation in government and politics can be an effective way to create change in our world. However, rules exist in various countries in which LSEG operates that require companies to track or limit certain political activities, including political donations – which are strictly regulated.

Although we encourage employees to participate responsibly in civic matters as individuals, LSEG does not support any political party, candidate or group or religious group. This means the Group:

• Never directly makes contributions to any religious or political group
• Never requires any employee to contribute to, support or oppose any religious or political group
• Does not express a preference for or support, directly or indirectly, any religious or political group

We take our public policy responsibilities very seriously and we engage with government, regulators, policy makers and political parties on various issues and topics that impact our business. When engaging on these issues with the relevant parties mentioned, we clearly identify ourselves as representing LSEG and follow applicable lobbying laws, restrictions and regulations.

You must contact the Group Head of Government Relations and Regulatory Strategy or relevant Government Relations and Regulatory Strategy Regional Head prior to contacting government officials or politicians (and/or their offices) about policy matters or speaking publicly about policy matters. 

We recognise our duty to respect human rights within our workforce and supply chain. We have a number of policies which directly or indirectly seek to respect human rights and are aligned with international human rights standards and principles. We respect workers’ rights to associate freely, join or form unions or work councils and bargain collectively in accordance with local law. We expect all employees to join LSEG’s commitment in protecting and preserving human rights.

LSEG recognises that modern slavery is a crime and a violation of fundamental human rights. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK’s Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we ensure against the use of forced, compulsory, trafficked or child labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.

 At LSEG, we are committed to creating a culture of openness and inclusion and building a workplace that embraces diversity of every kind.

Our success depends on our people, whoever they are and wherever they come from, working together to develop the best solutions to meet our customers’ needs. Creating a diverse and inclusive organisation is fundamental to the way we deliver on our promise – and our purpose. At LSEG we expect each of us – no matter our level, role, division or function – to play an active role in creating environments where people of diverse backgrounds are included and can do their best work.

Our diversity and inclusion (D&I) strategy is driven by data and focused on creating whole-business behavioural change. We embed key principles of inclusion in everything that we do, we track our progress and we hold our leaders accountable for our D&I goals. We partner with our Inclusion Networks to help create a culture that is inclusive for all our employees. Our four strategic priorities are to:

• Create a culture of belonging
• Build a diverse leadership team
• Accelerate internal progression of underrepresented talent
• Shape inclusion in our industry 

We are committed to encouraging diversity, equity and inclusion among our workforce and eliminating biased and discriminatory behaviours, processes and practices. We strive to create a culture of transparency and inclusion, and build a workplace that embraces diversity.

Our aim is for our workforce to be truly representative of all sections of society and our customers; for each of our colleagues to feel respected and able to perform at their best; and ultimately to create sustainable growth for LSEG and our people. We are also committed to providing equitable employment opportunities in every aspect of employment.

We do not tolerate discrimination on the basis of:

• Age
• Being pregnant or on maternity leave
• Citizenship status
• Disability
• Gender identity or expression
• Marital status
• Race – including colour, nationality, ethnic or national origin
• Parental status
• Religion or belief
• Sex
• Sexual orientation
• Trade union membership and activities
• Veteran status
• Any other classification protected by applicable laws or regulations 

We will, at all times, ensure that we comply with legislative requirements and promote best practice.

Our aim is that the make-up of our workforce should reflect that of the community and that all employees should be offered equal opportunities to achieve their full potential. Ensuring that our people processes are fair and objective is critical for us at LSEG and we encourage People Leaders to work towards that aim. This means we comply with the Diversity, Equity and Inclusion Policy. 

A safe and healthy workplace not only protects us from harm, but also builds trust, prevents costly accidents and enhances the Group’s reputation as a responsible corporate citizen.

To ensure that we minimise risk to the environment and protect our employees, business partners, customers, visitors and members of the public, every LSEG employee is responsible for helping to create a safe working environment. To prevent dangerous conditions in our workplaces you must adhere to the Health, Safety and Environment Policy and:

• Comply with both the letter and the spirit of all applicable occupational and environmental health and safety legislation and Group EHS Policy and Procedures
• Ensure that all contractors, vendors and employees understand and implement the LSEG EHS Standards and comply with local legislation
• Report incidents, injuries and illness at work and participate in any investigations to allow us to reduce any risk and prevent reoccurrence
• Complete all EHS training as required to improve our ability to safely carry out job roles and use LSEG equipment
• Identify potentially unsafe acts or situations and report them to ensure the Group can take action to remedy and learn from these situations
• Maintain accurate and up-to-date health and safety records

We do our part to ensure the security of our workplaces by complying with the Physical Security Policy and:

• Following all required security procedures and access controls in our facilities
• Speaking up when we see something that seems suspicious or threatening
• Participating in safety-related drills and preparations

Protecting confidential information and data privacy

Receiving confidential information is a routine part of our work and our competitive edge depends on the security, privacy and integrity of the information we hold – whether that information belongs to us or to others. How we handle confidential and personal information sets us apart from our competition and if we get it wrong, our customers, employees and the Group all could suffer. Improper handling could disadvantage us in the marketplace, harm consumers, leave us vulnerable to civil and criminal penalties, impede our innovation, hinder our performance and ultimately damage our business relationships.

Employees must never disclose confidential information to anyone, including individuals within the Group, unless there is a legitimate need to know and we are authorised to do so or where we are required to do so by law or regulation. We do not use such information improperly and information received must never be misused for personal or third-party benefits. We have established information security and privacy practices to protect data, whether it belongs to us, our customers or our business partners. This means we comply with the Confidentiality Policy, the Information Security Policy, the Privacy and Data Protection Policy and the Data Governance Policy and:

• Read, understand and follow the requirements for handling data
• Understand how data is classified across the Group and therefore how it must be handled
• Store information using only LSEG-approved storage devices
• Collect, use, retain and transfer data and information about individuals in accordance with applicable data protection and privacy laws and regulations
• Record all the processing of the personal data on the Records of Processing Activities (RoPA) and keep the Privacy Notice updated to accurately reflect the processing taking place, in line with the transparency obligations
• Obtain proper authorisation before sharing any confidential or personal information, which might include obtaining written authorisation and signing a nondisclosure agreement
• Respond to requests for information about our data-handling practices by following LSEG processes to ensure we do so safely and properly
• Respond to requests from individuals wanting to exercise their privacy rights within the required time limits in accordance with internal processes, applicable data protection and privacy laws and regulations
• Protect the Group’s confidential information even after we leave the organisation 

Respecting our intellectual property and that of others

From the systems and databases LSEG creates to empower our customers with information, to the processes we use in our workplaces, intellectual property is vital to our identity. Knowing how important it is to us and to others, we have a special obligation to protect the intellectual property that we create and to defend all intellectual property against improper use. By doing so, we put the Group, our employees and ourselves in the best position to innovate and win in the marketplace.

Employees must recognise when intellectual property should belong to the Group and take all necessary action to protect it. This means that all employees:

• Agree, to the extent permitted by law, that the Group owns all intellectual property (and related rights) that we create during the course of our employment, whether we create them in the office, at home or elsewhere, if they are related to LSEG business or created with LSEG resources
• Waive or assign to the Group all moral rights we may have under applicable law to intellectual property that we create as employees
• Promptly disclose any methods, systems, processes, designs, ideas or other patentable works we create as employees so the Group can take steps to protect them
• Report any unauthorised use of LSEG copyrights, patents, trademarks or other intellectual property of which we become aware
• Put copyright notices on all LSEG materials, information, services or other products intended for public distribution

All employees must respect the intellectual property of third parties – including competitors – and not use it in any way that would breach the law or our values. This means that all employees must:

• When necessary, get written permission to use or copy a third party’s copyrights, patents, trademarks or other intellectual property; obtain licenses; or, if the circumstances require it, purchase the intellectual property outright
• Ensure that licensing agreements permit copying or distribution where necessary and do not impair LSEG’s rights before we copy or distribute third-party software
• Ensure intellectual property belongs to the Group when it is created for us by third parties or contractors, where allowable by law

As a responsible corporate citizen, LSEG complies with financial reporting obligations in all the countries in which we operate. When we each take accountability for ensuring the financial records that we handle are accurate and complete, we protect the Group’s reputation for integrity and uphold our commitment to trust.

Reliable financial reporting also allows shareholders and investors to fairly assess our performance, provides management with information to allocate our resources most effectively and prevents breaches. We produce accurate, fair and timely records for management, directors, shareholders, government regulators and others. This means that all employees must:

• Take personal responsibility for ensuring all books and records – including time sheets, sales records and expense reports – are complete, accurate and documented
• Never keep unrecorded, undisclosed or off-the-books records
• Not falsify or distort facts of any transaction
• Record and disclose transactions in a timely manner, supported by documentation
• Exercise reasonable diligence when approving transactions and expenditures or signing
• Understand the importance of internal controls and consistently comply with them
• Pay business-related expenses with LSEG funds only if we have authorisation from our People Leader
• Provide full, fair, accurate, timely and understandable disclosures in reports or documents that we file externally or submit to regulatory authorities

 You have a responsibility to raise concerns, in good faith, about questionable accounting, auditing, disclosures or controls. LSEG and the Audit Committee of the LSEG Board of Directors are committed to facilitating employee efforts to make these concerns known and have established procedures for how complaints about accounting, internal accounting controls, auditing matters and disclosure controls are treated. This includes procedures for receiving, retaining and processing such complaints, as well as for confidential and anonymous submission of concerns. Refer to Section 16 for further information on how to raise concerns.

As a largely information-centric business, LSEG generates thousands of business records every day, in addition to financial records. These records must be created, stored and disposed of according to stringent legal and regulatory requirements. When records are easy to access and retrieve we provide a better service to our business partners, and we avoid risks around audits, regulatory issues or litigation. Records retained for longer than required by any regulation can create avoidable information security, privacy or legal risks.

We manage, store, retrieve and dispose of LSEG records according to applicable records management requirements. This means you must:

• Consistently organise our filing, storage and retrieval of electronic and physically recorded information
• Use the proper storage method specified by legal, fiscal, regulatory or operational requirements
• Protect records from loss, damage or inadvertent deletion
• Retain all records related to any pending or anticipated litigation or government investigation until otherwise directed by Group Legal
• Dispose of all records (electronic and physical) according to LSEG Records Management requirements.

LSEG is fully aware of the power of media and our responsibility to use it wisely. Our reputation and ability to compete can be affected by the information we make public. By being aware of the risks and not appearing to speak for the Group without authorisation, we can help make sure that we consistently get an accurate message across to its intended audience while also exercising our individual right to post independently on social media.

If we receive requests for information from outside of the Group, even seemingly simple ones, we refer them to employees authorised to act as LSEG spokespersons. These spokespersons must:

• Handle requests from media, shareholders, financial analysts and government authorities
• Disclose information according to the requirements of regulatory authorities
• Ensure that the information disclosed is accurate and that the Group is ready to go public with it

If you post information online, make a speech or give an interview about the Group, you could appear to be speaking on behalf of LSEG. You may need to make it clear that your views do not represent those of LSEG. You may also need additional approvals before taking part, so it’s always best to discuss these situations with your People Leader and the Communications department, who can advise accordingly, in good time ahead of the event.

Our willingness to seek help and to accurately and truthfully describe our concerns in a timely manner is of the utmost importance. You are encouraged to ask questions and seek help whenever you have a concern. Raise concerns promptly and seek guidance even if you are not sure something problematic has occurred.

For further guidance please seek help from your People Leader, your local or divisional Compliance, People Function or Legal contact.

If you witness or learn about inappropriate conduct in the workplace or which relates to LSEG, you must follow the Speak Up Policy and not look the other way, regardless of whether the individual who engaged in the behaviour is a People Leader, business partner, customer, consultant, visitor or other stakeholder.

We hold leaders, including People Leaders, to an even higher standard. We require our leaders to raise or address inappropriate conduct they learn about, even if they are aware of it indirectly or have not received a specific complaint about behaviour. This can be to the appropriate senior stakeholder or, in appropriate cases, via the Speak Up channels, in compliance with the Speak Up Policy.

The Code is reviewed regularly and changes approved in accordance with the Policy Governance Framework.

Self-certification Process

As our Code and our conduct are at the heart of all we do, the Code is subject to an annual self-certification process. This self-certification process is a mandatory requirement for our employees and extended workforce.

Reporting requirements for self-certification

The results of the annual self-certification and any material incidences of non-compliance will be reported to the Executive Committee and to the Board.

The following Group policies and guidelines must be read in conjunction with this policy and must be adhered to at all times: