Whistleblowing at LSEG

LSEG and its subsidiary companies are committed to providing an open environment where our employees, customers, shareholders, vendors and other third parties feel comfortable raising concerns about adherence to our Code of Conduct, relevant laws and regulations, or if they consider something unethical or potentially harmful. 

Whistleblowing is the term for the confidential disclosure by an individual of a concern encountered in the workplace relating to a potential wrongdoing. Examples of such wrongdoings include but are not limited to:

• Conduct and behaviour which breaches or falls short of the LSEG Code of Conduct.
• Criminal activity, such as insider dealing, fraud, bribery or corruption.
• Breaches of regulatory or legal requirements e.g., competition or anti-trust laws, data protection, intellectual property, confidentiality or benchmark regulations.
• Breaches of financial, accounting, tax or auditing obligations.
• Breaches of IT security or other security policies.
• Breaches of health and safety requirements or damage to the environment.
• Conduct that harms the reputation, activities or financial well-being of LSEG.
• Miscarriages of justice.
• Retaliation or attempts at retaliation for raising a concern.
• Any attempt to conceal any of the above or other wrong-doing.
• LSEG’s confidential whistleblowing telephone and online reporting services are provided by an independent third party, Navex Global, who provide secure and confidential reporting through their platform Ethics Point.

Individuals may submit confidential and anonymous whistleblowing concerns online or through the local confidential telephone lines listed below. All local telephone lines are supported by experienced interviewers trained to recognise all potential forms of misconduct, and who will additionally translate any reports into English as part of the submission process. All services are available 24 hours per day, 7 days per week.

Our whistleblowing reporting service does not preclude any individual from reporting crimes to the competent authorities so as to avoid any risk of conflict and ensure compliance with all applicable local laws.

LSEG take whistleblowing very seriously. All concerns raised will be investigated in line with the Speak Up policy and associated procedures. Depending on the investigation findings, the appropriate and proportionate action will be taken to address any issues identified.

The Speak Up team will acknowledge receipt of every concern promptly and, in any event, within 7 days of receiving it.

The Speak Up team will endeavour, to the extent possible, to keep the person raising the concern informed when the investigation has been completed and, where appropriate and subject to any applicable laws and regulations, its outcome and any follow up actions.

If the investigation does not resolve the reporter’s concern, the reporter can lodge a complaint in writing to the Chair of the Audit Committee who consider all details of the complaint and take the appropriate action.

Please note that London Stock Exchange has separate processes and dedicated teams to consider concerns or enquiries relating to compliance with the relevant London Stock Exchange rulebooks by issuers admitted to our markets, member firms or nominated advisers, or which relate to potentially abusive behaviour from trading on one of our markets.

Details of where and how to raise concerns or enquiries over such matters and the relevant complaints and enquiries handling framework can be found here and here. For details of our rulebooks please refer to:  Rules of the London Stock Exchange; Admission and Disclosure Standards; AIM Rules for Companies; AIM Rules for Nominated Advisers; Securities Market Rulebook