Business ethics
The standards and behaviours expected of all LSEG colleagues (including our extended workforce and business partners) regardless of geography or business area, are set out in the Code of Conduct.
It guides how we engage with each other, customers, business partners and the communities where we work and live. Closely connected to our policies and practices, it helps us uphold our purpose and values, manage risk, and deliver sustainable growth, the right way.
Compliance with the Code of Conduct is mandatory and forms part of the employment agreement. We require all colleagues to complete mandatory annual training on the Code and attest to complying with it.
You can read our Code of Conduct here.
Raising concerns
LSEG’s Speak Up Policy and process enable stakeholders to raise concerns about potential breaches of our policies and procedures, including the Code of Conduct, relevant laws and regulations, or any unethical behaviour. The Policy provides confidential - and, if preferred, anonymous - channels for reporting, and protects individuals from retaliation.
Anyone can raise a concern, including colleagues, supply chain partners, clients, contractors, and members of the public, as the platform is publicly available:
The Speak Up process improves our business practices by creating a safe and structured channel for concerns to be raised. This helps us to identify emerging risks early, strengthen our culture, and drive continuous improvement.
The process for raising concerns is detailed below:
- Report: For anyone: via the confidential, independent and anonymous 24-hour Speak Up hotline. For colleagues: with the People Leader or a colleague in the People Function, Legal & Compliance, or Risk.
- Communication: For colleagues: details on how to report concerns are set out in our Speak Up Policy and on our internal intranet. For anyone: details can be found on our website.
- Investigate: The Speak Up team acknowledge receipt of the report and ensure the matter is appropriately investigated or referred. Once the investigation is concluded, the investigator will inform the reporter of the conclusion of the matter, as appropriate.
- Action: Depending on the investigation’s findings, appropriate and proportionate action will be taken.
- Complaints: Any issues about the process can be raised with the Speak Up team, Chief Internal Auditor, or the Whistleblowing Champion who is the Chair of the Audit Committee.
- Board review: The Audit Committee is regularly briefed on whistleblowing matters and receives management information and updates on reports throughout the year.
Preventing financial crime
LSEG is committed to supporting government, law enforcement and international bodies to combat financial crime. Our Financial Crime Policy sets out requirements to minimise financial crime, which encompasses, but may not be limited to, money laundering, terrorist financing, international sanctions, bribery and corruption, tax evasion, fraud including false accounting, insider trading, and market abuse.
All colleagues complete annual online training on identifying and preventing financial crime. Based on risk, some colleagues undergo additional training which is subject-specific.
We conduct horizon scanning and assess changes in laws and regulations across all territories where LSEG operates. Proactive monitoring tools are deployed to identify emerging risks and new legal and regulatory requirements. Outcomes of investigations and intelligence are reviewed to inform our approach.
Our financial crime controls and procedures are independently assessed by Internal Audit and Compliance Monitoring and Assurance.
We also maintain a Competition Compliance Policy outlining the Group’s approach to applicable competition and anti-trust laws. This includes the following conduct, which is strictly prohibited: price fixing; no poaching agreements; bid rigging; dividing up markets or customers; and limiting production or technical input. The Group General Counsel is the executive responsible for the Competition Compliance Policy and the Group Executive Committee is responsible for its oversight.
Global tax strategy
The payment of tax is an important contribution 2040, the economies and societies in which LSEG operates and we uphold the obligation to pay our fair share of tax legally due in any country at the right time. This supports the stability of local, regional and national economies, as well as the funding of public services where we operate.
LSEG’s Tax Strategy sets out the Group’s approach to tax compliance and reporting, risk management and planning. The Group does not undertake purely artificial transactions without commercial substance to obtain a tax benefit and will under no circumstance knowingly evade tax.
We are committed to ensuring that our transfer pricing is based on arm’s length principles and intercompany transactions reflect the economic substance of the business to achieve fair and appropriate allocation of profits in all the jurisdictions we operate.
We ensure the Group complies with all relevant tax laws and regulations, considering policy intent. As part of this, we continuously monitor for changes to global regulations and guidance.
The Group Chief Financial Officer is the executive responsible for the Global Tax Strategy and the Audit Committee is responsible for its oversight. The Global Tax Strategy is reviewed and reissued annually.
Engaging with governments and regulators
LSEG does not use corporate funds to make financial donations to political parties, organisations or candidates. When engaging with governments, regulators or political parties, we clearly represent LSEG and comply with all lobbying and anti-trust laws.
We disclose advocacy activities via the EU Transparency Register and US Lobby Disclosure Act. Our engagement is transparent and based on evidence-driven positions.
As is common in the US, LSEG colleagues can make personal voluntary donations to support bipartisan Congressional conditions; via LSEG’s colleague funded US Political Action Committee (PAC), as long as it complies with regulatory and legal requirements.
LSEG’s PAC 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.
Health and safety
LSEG’s Environmental, Health & Safety (EHS) Policy demonstrates our commitment to compliance and the protection of colleagues, customers, visitors, and contractors.
It applies to all operations and colleagues, setting minimum EHS requirements, defining responsibilities, and supporting continuous improvement. Sponsored by the Chief Operating Officer, the Policy is reviewed annually to align with our strategic values.
We implement a structured EHS Management System aligned with ISO 45001 and ISO 14001 standards. It sets targets, monitors progress, and promotes a safe, healthy environment through a suite of supporting documents. The system is continuously improved to meet evolving business needs.
As part of our EHS assurance process, we conduct multiple levels of inspection and audit to ensure safe people, processes and workplaces. These include workplace inspections, detailed EHS compliance assessments and internal audits. As part of our EHS compliance reviews, we focus on local regulatory requirements through annual site visits.
We require all new joiners to complete mandatory EHS training and complete regular refreshers, covering EHS management, responsibilities, incident reporting, unsafe conditions, fire evacuation, and first aid.
