Code of Conduct

At LSEG, we’re committed to delivering excellence – both in what we do and how we do it. As a leading global financial markets infrastructure and data provider, we have a responsibility to protect our people, customers, partners and shareholders and to contribute towards wider economic stability.

Every year we set out clear, strongly aligned goals to help our company continue to grow and we each make a pledge about how we’re going to do it through our Code of Conduct.

We want people at LSEG to have a fulfilling, stimulating, safe and respectful environment where they can work, grow and develop their careers. We want customers to know they’ve chosen a partner who will support their businesses’ success. And we want our shareholders to know their investment is in capable and trusted hands.

LSEG’s reputation is influenced by the decisions and actions we each take every day. To help us make the right decisions, our Code sets out the core principles to follow at all times. It reflects how we want everyone at LSEG to think and feel about doing business and how we behave as an organisation. With employees in 65 countries, LSEG is subject to a wide range of complex laws and regulations. At times, we need to tailor our decisions and actions to specific facts and situations. No matter where we operate, the core principles in our Code and our values will not change. Our Code outlines our individual responsibilities and by linking our values to our day-to-day business policies and practices, commits us to:

• Ethical behaviour
• Taking ownership and being accountable for managing risk in our work and proactively raising concerns
• Competing fairly, avoiding abuses of power and identifying and managing conflicts of interest
• Working in partnership with our customers and providing them with high quality products, services and value
• Treating each other fairly and with respect
• Holding ourselves to the highest standards of corporate governance and complying with best practices

The objective of the Code is to set out the ethical and behavioural framework which governs LSEG’s activities, guiding how we engage with each other, our customers, our business partners and the communities where we work and live.

The Code applies to all LSEG employees and directors in all locations and to all subsidiaries and joint ventures in which LSEG has a controlling interest (except where LSEG has authorised a subsidiary entity to operate under its own analogous Code or where local laws and/or regulatory requirements explicitly conflict with the Code).

Compliance with the Code is mandatory. This means we’re each expected to read and understand the Code, as well as any supplemental materials, such as the policies referred to within it, that might apply to us and act accordingly. Breaches of the Code are viewed extremely seriously and will result in appropriate action being taken in accordance with local and global policies.

While the policy applies to LSEG’s employees, we expect all members of LSEG’s extended workforce, including contractors, consultants, temporary workers and agents performing services for, or on behalf of, the Group (such as our business partners) to follow the Code in connection with their work for LSEG, alongside the Supplier Code of Conduct. Failure of a member of our extended workforce or other covered service provider to follow the Code can result in termination of their relationship with LSEG.

If there are additional local legal or regulatory requirements or specific policies and procedures that govern how we are required to perform our roles, then employees must adhere to the higher standard in all cases.

Aligned with our culture and values, we expect everyone who works directly for us, and all of our extended workforce, to:

• Learn about, understand and comply with the laws, rules, regulations and policies that apply to your specific position
• Seek help if you have questions about the applicability or interpretation of any law, rule, regulation or policy
• Take responsibility for risk management and constructively challenge others
• Act responsibly to respect human rights and support sustainable and responsible business practices across our operations and value chain
• Speak up if you see or suspect unethical behaviour or a breach – whether of laws, policies or this Code. Confidential reporting systems are in place and we will never tolerate retaliation against anyone who, in good faith, brings such issues to our attention
• Complete mandatory training where applicable
• Respect the local customs of countries where we do business, as long as doing so does not breach laws or this Code
• Acknowledge on an annual basis that you have read the Code and understand your obligation to comply with it

We expect our leaders to build transparency, open communication, inclusion and trust that extends from employees to customers to business partners. To help achieve this, those of us who are leaders must:

• Live our People Leader expectations every day and lead by example
• Actively listen, take action and communicate outcomes when team members raise concerns – whether big or small
• Be knowledgeable about the laws, rules, regulations and policies that apply to our teams
• Personally escalate risk and compliance issues appropriately
• Highlight and recognise decisions that honour our values and long-term success over short-term gain
• Demonstrate accountability and a willingness to listen to all points of view
• Make time to discuss the importance of ethics and compliance regularly with our teams
• Encourage team members to seek guidance when issues or questions arise and to be timely and candid in reporting any unethical or illegal conduct or compliance issues

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 manage our business to:

• Deliver shareholder value, provide superior returns and meet 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:

• Creating a safe, respectful, fulfilling and stimulating working environment that supports diversity, inclusion, ongoing learning and equal opportunity, fostering a culture of belonging for all
• Merit-based recruiting and promoting of employees, based on the qualifications and abilities needed to perform their role and to develop meaningful careers, reflecting representation of all sections of society and our customers
• Remunerating employees based on industry norms in the markets and countries in which we operate, as well as business and individual performance, while leading the industry in promoting equality of opportunity for all
• Maintaining good communications with employees, valuing and leveraging diverse perspectives throughout LSEG

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, Entertainment and Hospitality Policy and Conflict of Interest Policy to ensure that actual or potential conflicts of interest are identified and managed and 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 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
• 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 and respecting their overall role and function

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’ eligible personal charitable giving and fundraising efforts
• Operating with integrity in our community relations at all times

Charitable donations must comply with our Financial Crime Policy, which means that no charitable donations should be given to third parties with the intent to solicit, obtain, or retain business/or political benefit gain. Charitable donations from LSEG funds must be approved by the LSEG Foundation team or the LSEG PAC, as appropriate, and follow the charity’s governance process. Fundraising events such as galas, social events or presentation ceremonies/dinners will not be funded by the LSEG Foundation and need Marketing and Communications approval as per the Brand Policy.

• Our reputation is critical to our long-term success. We follow all laws as they are written and also respect the purpose behind them, always aiming 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, understanding that our behaviour could impact LSEG’s reputation
• We seek help if we have questions about how any law, rule, regulation or LSEG policy could apply to us or be interpreted

We treat others with respect and do not tolerate harassment of any kind in our workplaces, including sexual harassment and bullying. We support dignity in the workplace for all, 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. This means you must comply with the Group’s Anti-Harassment and Bullying and Equity, Diversity and Inclusion Policies and any local policies and procedures in your location.

Even if local law does not prohibit these acts, we hold ourselves to the standard in our Code and policies.

By prioritising fairness, equality, respect and dignity and not allowing discrimination, harassment and bullying, everyone who enters our workplaces should feel 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. A conflict of interest can also 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 situations that give rise to an actual or perceived conflict and if that is not possible, to take the required steps to manage and mitigate it accordingly. 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, Entertainment or Hospitality, given to or received from third parties

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

Because of what we do at LSEG, we may have access to information that is non-public and price-sensitive about our investors, our investments, our customers, potential customers, issuers 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 actions 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, proprietary, inside and/or material non-public information
• May give rise to a conflict of interest or services

This means we do not:

• Trade, or encourage another person to trade, on confidential, proprietary, inside and/or material non-public information obtained by any means
• Provide such information to, or use such information provided by, another party, outside of the duty to the Group
• Undertake any activity deemed or perceived to be market abuse

We recognise that the giving and receiving of legitimate gifts, entertainment or hospitality must be transparent and reported in line with our requirements. We avoid giving or receiving gifts, entertainment or hospitality or other personal benefits if doing so could appear to improperly influence our own or a third party’s professional judgement and objectivity or breach anti-bribery and anti-corruption laws. This means you must comply with the Group’s Gifts, Entertainment and Hospitality Policy.

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 agree with competitors to:

• Fix prices, terms or bids
• Allocate customers, territories or markets
• Limit production, supply or investment
• Limit competing for each other’s customers or talent

Further, we must never share LSEG’s non-public competitively sensitive information (such as pricing, customer details or strategy) with competitors, nor receive such information about competitors (directly, or via a third party).

We have additional obligations where we may have a significant market position or “dominance” (generally assumed to be over 40% market share). We should never attempt to use a position of influence to unfairly disadvantage other market participants or restrict competition.

LSEG strives to understand our competitors in order to compete effectively. We obtain intelligence about our competitors only through lawful and ethical channels, based on public sources.

You must:

• Understand and follow all applicable laws and regulations before engaging in competitive intelligence gathering. Never misrepresent your personal or the Group’s identity to gain access to a competitor’s product or service
• Not breach contract terms or encourage others to do so (including colleagues formerly employed by a competitor) in order to help the Group obtain competitive intelligence
• Not distribute data or other confidential information about a competitor if it was received or accessed in circumstances that may breach our Competition Compliance requirements (this includes information about competitors received from customers, such as screenshots of pricing or product layouts)

We never offer, give, authorise, request or accept a bribe. This includes offering, providing or receiving a financial payment or anything of value where the intent is to improperly influence a decision, induce preferential treatment or obtain an undue business advantage. This includes payments to speed up routine governmental or other actions (such as visa processing, awarding of licenses or customs clearances). Known as “facilitation payments”, they are strictly 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 under applicable bribery legislation we could be held responsible for breaches by an employee, agent, subsidiary, associated person or other third party acting on our behalf and 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
• Include anti-bribery measures within annual risk assessments
• Regularly monitor and review the effectiveness of our anti-bribery measures
• Provide mandatory employee training and publish messages from our Board that reaffirm our position that bribery is never acceptable

Sanctions are legal restrictions adopted by governments and intergovernmental organisations to achieve specific foreign policy or national security objectives. Sanctions may restrict transactions, trade or business activity with certain countries, regions, governments, organisations, or individuals. They may also limit the provision of certain financial services or restrict access to certain financial markets, funds, securities, or economic resources.

Export controls, or trade restrictions, are legal requirements that regulate the transfer of certain goods, software, technology and services to specific destinations, end users or end uses for national security or foreign policy reasons. They may apply to both physical exports and the electronic transfer or disclosure of controlled software or technical information.

As a matter of policy, LSEG does not engage in activities involving countries, regions, organisations or individuals that are subject to sanctions and export controls except where the activity is permissible under applicable laws and regulations, any required licenses or authorisations have been obtained from relevant government agencies and the activity in question is within the Group’s risk appetite.

To manage sanctions and export controls risks, we must:

• Maintain policies, standards and procedures designed to identify, assess and mitigate sanctions and export controls risks
• Conduct appropriate due diligence and screening on customers, business partners and third parties to ensure they are not subject to applicable sanctions or trade restrictions
• Be alert to possible sanctions risks such as parties located in or associated with a sanctioned country, complex corporate ownership structures, requests to supply our products to third parties who are not our direct customers, or payments being made through unrelated intermediaries or multiple accounts
• Be alert to possible export control risks such as unclear or inconsistent end‑use information, unusual or unnecessary requests for our hardware or software, reluctance to provide required details about the customer or transaction, or involvement of higher‑risk countries, routes or intermediaries
• Assess any relevant sanctions or trade restrictions when doing business or exploring opportunities in new markets
• Understand whether any of our products or services are subject to export or import licensing requirements
• Seek guidance on export procedures before deciding to export any products or services to sanctioned or restricted countries, or to higher risk customers or third parties

Money laundering is a process used by criminals to make illegal proceeds appear to come from legitimate sources. This is done by disguising the source of funds and moving them through various entities, accounts, and transactions to avoid detection. Money laundering usually happens in three stages: placement, layering and integration.

Terrorist groups use violent or destructive acts to intimidate or coerce, and even influence, government conduct. Terrorist financing does not have distinct stages like money laundering, but it does produce similar red flags. It also uses the financial system to disguise the origin of funds. While terrorist financing is often associated with money laundering, there are some important differences as it always supports terrorist groups, uses either “clean” or “dirty” money and typically uses small amounts of money.

Proliferation financing is the act of providing funds or financial services for use, in whole or in part, in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer, stockpiling of, or otherwise in connection with the possession or use of, chemical, biological, radiological or nuclear weapons.

We follow all laws that are applicable to us and do not condone or facilitate money laundering, terrorist financing or proliferation financing. This means we must know and understand who we are dealing with (“know your customer” or “KYC”) by:

• Triggering the relevant checks before onboarding a customer
• Informing KYC teams of any material changes to our customer or our key customer data
• Ensuring that we maintain complete and accurate customer data records
• Remaining alert for possible instances of Financial Crime or “Red Flags” and immediately making an internal notification of any suspicious activity to the Financial Crime Compliance Team (without informing the party in question, as this could constitute a criminal offence)
• Following other applicable group policies for other entities or individuals we deal with including third parties, beneficiaries and security issuers, to ensure we know who we are dealing with and understand the associated risk or red flags
• Ensuring all new products, new markets or initiatives go through the relevant Group governance so that we can fully understand how those products may be abused to facilitate financial crime, or how specific jurisdictions may be higher risk, and the additional mitigants or controls that may be needed to protect LSEG

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.

Although we encourage employees to participate responsibly in civic matters as individuals, LSEG does not use corporate funds to make financial donations to religious groups or political parties, organisations or candidates. This means the Group:

• Does not directly make contributions to any religious or political group
• Does not require 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 advocacy and public policy responsibilities seriously and engage with governments, regulators, policymakers and public officials on various issues and policies which impact our business. When engaging on these issues with the relevant officials, we clearly identify ourselves as representing LSEG and follow applicable lobbying laws, restrictions and regulations.

You are required to comply with the Gifts, Entertainment and Hospitality Policy and ensure that Government Relations & Regulatory Strategy (GRRS) and Compliance are engaged before you agree to host or meet with any serving politician, member of Government, political advisor, Government official, or regulator.

Adhering to all LSEG policies is essential to ensure the Group remains aligned in its engagement approach and to prevent any unnecessary conflicts of interest or sensitivities with broader LSEG interests.

Any employee wishing to join a Trade or Professional Association membership on behalf of LSEG or any LSEG entity must follow Corporate Affairs & Marketing guidance on Connect.

LSEG carefully manages its reputation in a complex geopolitical landscape. To ensure consistency and avoid misinterpretation, we have clear requirements and guidelines around the running, management and related messaging at LSEG events.

LSEG respects the right of employees to hold personal political and religious views and expects employees who choose to participate in politics and civic matters as individuals to do so responsibly.

If LSEG employees plan to campaign for or serve in political office as individuals, we are careful to separate ourselves from the Group in these efforts, to disclose this activity in advance and to follow the applicable guidelines on LSEG Employee Political Activity on Connect.

Employees may choose to make donations from their own personal funds, including to a Political Action Committee (PAC) in the US, provided that the donations:

• Meet all legislative and regulatory requirements
• Are not being made on behalf of the Group or any Group entity
• Are not being made with the intention of appearing to be on behalf of the Group or any Group entity

As is common in the US, LSEG employees can make personal voluntary donations to support bipartisan Congressional candidates via LSEG’s colleague funded PAC. This is a federal PAC and does not engage in state or local races and complies fully with US Federal Election Commission rules, including public reporting of all contributions and expenditures.

We do not allow our political or religious views to affect our behaviour or decisions at work nor do we represent or construe our personal views as being the views of LSEG.

LSEG is committed to protecting the rights of people impacted by our operations – primarily our colleagues and the workers in our supply chain.

Whilst we recognise the full spectrum of human rights, certain rights are more relevant than others to our business. These include:

• Freedom from discrimination
• Freedom from all forms of slavery, forced and child labour
• The right to privacy
• The right to a safe and healthy working environment
• The right to work with equal and fair pay
• Freedom of association and the right to collective bargaining

All employees are responsible for proactively identifying and raising human rights concerns, helping ensure we prevent and mitigate harms before they occur. We expect all contractors, suppliers and business partners to apply the same level of scrutiny to their activities to ensure that violations of human rights do not exist anywhere in our value chain. We expect that our suppliers will hold their own suppliers to the same high standards.

Our policies and standards, including our Sustainability Policy, Human Rights Standard, Equity, Diversity and Inclusion Policy, Speak Up Policy, Anti-harassment and Bullying Policy, and Supplier Code of Conduct align with international human rights standards and principles, including the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and International Labour Organisation’s Declaration of Fundamental Rights at Work.

LSEG’s objective is to be a strategic enabler and steward of sustainable economic growth for the benefit of our customers. LSEG aims to enable sustainable growth and manage sustainability risk across our value chain. We seek to minimise our impact on the environment by embracing the principles of sustainable development and minimising greenhouse gas emissions, resource consumption and pollution across our value chain. We actively seek to reduce the impact we have both directly and indirectly on the environment and have a comprehensive programme to deliver on our climate targets.

We expect all employees to adopt behaviours that support LSEG’s ambition to reduce greenhouse gas emissions and mitigate negative environmental impacts in accordance with the Sustainability Policy and Climate Standard. We aim to achieve this through the development and implementation of our Climate Transition Plan.

We strive to create a culture of transparency and belonging, a merit-based workplace that is representative of all sections of society and our customers, that is inclusive for all, where diverse perspectives are valued and leveraged throughout the Group.

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 everyone feels included and can do their best work.

Our Equity, Diversity and Inclusion (EDI) 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 creating an inclusive environment. 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 for all
• Build a global and diverse leadership team that is held accountable for creating an inclusive culture
• Create merit-based processes, enabling attraction, retention and promotion of a global, diverse pipeline of talent
• Create opportunities to convene organisations to promote thought leadership and progress within EDI

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 legal requirements and promote best practice.

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 Equity, Diversity and Inclusion Policy.

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:

• Comply with both the letter and the spirit of all applicable occupational and environmental, health and safety legislation and the Group Health, Safety and Environment Policy, Standards 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 potential 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

We do not tolerate acts or threats of violence, intimidation or hostility in our workplace, whether directed at employees, business partners, customers or visitors. We also do not allow:

• Firearms, ammunition, other weapons (pepper sprays, knives, replica firearms or other hazardous devices) at any facilities leased or owned by the Group, at LSEG-sponsored functions or on any Group business regardless of any licence or permit held by the individual
• Behaviour that injures or is likely to injure another person
• The making or sending of harassing or threatening statements (regardless of how these messages are delivered)
• Behaviour that damages or is likely to damage property
• Stalking or surveillance of another person
• Committing or threatening to commit violent acts

Receiving and creating confidential information is a routine part of our work. Our competitive edge depends on the security, privacy and integrity of the information we hold – whether that information belongs to LSEG or to others. How we handle confidential information and personal data sets us apart and getting it wrong can have serious consequences. Improper handling could disadvantage us in the marketplace, harm consumers, expose the Group to civil, regulatory or criminal penalties, impede our innovation, hinder performance and damage our business relationships.

Employees must never disclose confidential information or personal data to anyone, including individuals within LSEG, unless there is a legitimate need to know and we are authorised to do so, or where disclosure is required by law or regulation. We must not use confidential information or personal data improperly and information received must never be misused. We have established information security and operational controls and processes to protect data, whether it belongs to us, or a third party. This means we comply with the Confidentiality Policy, the Information Security Policy, the Privacy and Data Protection Policy and the Data Governance Policy (as well as related Standards) and:

• Read, understand and follow the requirements for handling information
• Understand how information is classified and labelled across the Group and therefore how it must be handled
• Store information using only LSEG-approved storage devices and systems
• Comply with all third-party contractual obligations relating to the use of confidential or personal information
• Collect, use, retain and transfer data and information about individuals in accordance with applicable data protection and privacy laws and regulations
• Record all processing of the personal data in our Record 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
• 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 confidential information and personal data held, even after we leave the organisation

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

We have a responsibility to use AI-enabled technologies safely, ethically and in line with LSEG’s policies, values and legal obligations. These expectations apply whether you are using AI tools, supporting AI-enabled workflows, or developing new AI capabilities.

Our approach is guided by the LSEG Responsible AI Principles, which require that AI systems are:

• Accurate and reliable – performing consistently and delivering expected results
• Accountable and auditable – with clear governance, traceability and defined ownership
• Safe – designed and tested to prevent unintended harm to users, markets or the environment
• Secure and resilient – protected against unauthorised access, misuse and attacks
• Interpretable and explainable – providing sufficient insight into how outcomes are generated
• Fair, privacy protecting and IP respectful – ensuring appropriate safeguards for personal data, avoiding bias, and protecting both LSEG and third-party intellectual property

These principles guide how we design, procure, deploy and use AI throughout the Group and must be followed, in addition to the relevant LSEG policies including Privacy and Data Protection, Confidentiality, Information Security, Model Risk and Data Governance requirements.

This means you must:

• Use only approved enterprise AI tools for work-related purposes
• Protect LSEG data by entering only the minimum data required and never using unapproved or public AI tools for confidential or personal data
• Apply the same sensitivity classification to AI outputs as the data used to generate them
• Take accountability for AI generated outputs and validate them before using or sharing, ensuring that information is correct, complete and appropriate
• Be transparent when AI has been used to generate content that will be relied on by others
• Seek help early if you are unsure how AI policies apply to your work, or if you identify inaccurate, unsafe or inappropriate outputs
• Complete required training and ensure you understand the risks and limitations of AI tools you use

Employees involved in designing, procuring, configuring or deploying AI systems must embed the LSEG Responsible AI Principles throughout the lifecycle – from design and data sourcing to testing, deployment, monitoring and decommissioning.

Where partners, suppliers and other third parties use AI when handling LSEG data, you must ensure appropriate contractual terms are in place and relevant LSEG policies are followed, including ongoing monitoring throughout the engagement.

Operational resilience helps ensure that we can anticipate, detect, recover and learn from any disruptions impacting the services our customers and markets rely on. By acting responsibly, following agreed processes and raising concerns early, we each support reliable service delivery, customer trust and regulatory compliance. Operational resilience is a shared responsibility and depends on the everyday actions and decisions we all make. We expect everyone covered by the Code to:

• Follow established procedures for business continuity, operational resilience, incident response, change management and system use, and avoid bypassing controls or using unauthorised workarounds
• Use systems, data and assets responsibly, protecting their availability, integrity and confidentiality
• Identify and promptly escalate incidents, near misses or risks that could disrupt services, including technology or third party issues
• Complete required training and participate in resilience activities where relevant to your role
• Speak up in good faith if something does not seem right

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 documents
• 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 15 (“Speaking Up”) 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 create, use, store, and dispose of LSEG records according to applicable records management requirements. This means you must:

• Identify and classify your records based on the core activities the records relate to
• 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
• Store records in Systems of Record that possess the records lifecycle management functionality, as described above. Personal One Drives do not have this functionality and must not be used to store records
• Know who the Records Managers and Records Stewards are for your business area or function, as they facilitate the management of records within the appropriate System of Record, as required by the Enterprise Records Management Policy and Standard

LSEG engages with the media around the world. In doing so, the Group must comply with the relevant laws and regulations in every jurisdiction. You must only engage with the media if you have been authorised to do so. All communications activity must comply with the Media and Communications Policy.

You should only engage with media once authorised to do so by a member of the press office. Spokespeople are only authorised to speak on their areas of specialism. You should also consider that whenever you post information online, make a speech or give an interview, you could appear to be speaking on behalf of LSEG, so it’s always best to discuss these situations with your People Leader and the Communications department, who can advise accordingly.

Social Media plays a significant role in how we communicate with audiences and represent LSEG around the world.

Used correctly and responsibly, it can be a powerful channel for driving reputational value and revenue opportunities for the business. Used incorrectly it can heavily damage our reputation and revenue.

As a representative of LSEG, you need to be mindful of what you publish online, what is published online about you, and how your own personal social media presence can impact the business. Make sure that anything published online avoids any reputational risks that might impact LSEG’s legitimate business interests.

Blogs, micro blogs, photo sharing, personal social networks and accounts posting, commenting on posts, video sharing and various online technologies are all considered to be “social media”.

Only those authorised to use Group social media accounts should do so. Any advertising on social media channels should be coordinated with the Social Media team and adhere to the Social Media guidelines in the Social Media Handbook available on Connect.

We recognise that employees will be personal users of social media channels and guidelines are in place to help people manage their social media presence. Personal use of social media is defined in the Media and Communications Policy as any use of media or social media in a personal capacity that can be linked directly back to you and your responsibilities at LSEG, even if the use is not directly linked to your work email or your job or takes place outside of work hours (this will apply to all media or social media where your job title or place of work is visible on your social media or media accounts, or can be found through connections to those accounts). This policy does not impinge on your use of media or social media in your personal time, as a private individual with a personal email address or personal social media accounts, so long as you do not use it in a way that breaches any of our policies.

If you are posting imagery or video content in a professional or personal capacity, be considerate of anything in the content which may pose a risk to physical security for employees at LSEG (building layouts, presence at events, LSEG lanyards and badges).

Failure to comply with this policy could lead to reputational, financial, commercial or legal consequences.

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.

If your concerns relate to an issue which is personal to you, you should refer to your local policies or handbook for further guidance. If your concerns relate to behaviour which you believe is or was wrong, illegal, unethical or in breach of our Code of Conduct, policies or procedures, you should refer to our Speak Up Policy.

For further guidance please seek help from your People Leader or your Compliance or People Function 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. Raise concerns promptly and seek guidance even if you are not sure something problematic has occurred. We want you to feel confident about raising any concerns you have. LSEG does not tolerate retaliation made against those who raise concerns. Such behaviour may be considered as gross misconduct.

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 the behaviour.

You can submit concerns online through lseg.ethicspoint.com

Employees can also raise Speak Up concerns in a number of other ways. Please refer to ‘Speak Up’ on Connect for further information.

You can choose whether or not to remain anonymous.

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