CORPORATE

Global Tax Strategy

Date of issue: 20th November 2023

CORPORATE2

Global Tax Strategy
Objective
This document addresses management of tax compliance, risk and planning matters for the London Stock Exchange Group plc andits group undertakings globally (“LSEG” or “the Group”). Its primary purpose is to set out the Group’s framework for meeting its tax
obligations from an operational, governance and tax risk management perspective. While this is a Global tax strategy, HMRC
requires the publication of the strategy to satisfy LSEG’s statutory obligation under Para 16(2) Schedule 19, Finance Act 2016 forthe financial year ended 31 December 2023.

Scope and ComplianceThis strategy standard applies to all LSEG companies and joint ventures with an interest of 50% or more of the share capital.
Compliance levels are monitored and reviewed by appropriate governance bodies. The Policy covers all financial charges or levies(direct and indirect) including corporate income tax, VAT, payroll and other taxes applied by a Tax Authority.

Context:
Our core corporate values guide how the Group works, collaborates and engages with colleagues, customers and otherstakeholders. Accordingly, these values are engrained in our approach to the management of our tax obligations.

Principles:
Our Code of Conduct (“Code”) sets the standard for what is expected of everyone working at, or for, LSEG. Accordingly, the Groupmanages its tax affairs in compliance with the Code. And the principles we follow in the management of our tax obligations flowfrom the Code. These principles are as followed:

The payment of tax is an important contribution to the economies and societies we operate in and we believe in the obligation
to pay our fair share of tax legally due in any country at the right time.
We ensure the Group complies with all relevant laws and regulations, considering policy intent.

We ensure that the Group’s systems, processes and controls enable us to fulfil our tax obligations.

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We endeavour to establish open working relationships with tax authorities.

We act in a transparent, co-operative, accurate and timely manner when dealing with tax authorities in order to resolve issues
that may arise.
We consider the context of this Framework and balance the interests of stakeholders in making tax decisions.  When

necessary, we will make judgements that are properly documented, carried out by the Group’s qualified tax professionals

and supported by external tax advice where appropriate.


We instruct internal or external resource acting for or on behalf of the Group to act in accordance with this Framework so thatthey can discharge their obligations in a manner consistent with the Framework.
We support initiatives to increase public trust and transparency in national and international tax regimes, which is aligned withour core values of fairness, transparency and integrity.
We do not undertake purely artificial transactions to obtain a tax benefit.

Approach to Tax Risk Management Tax Risk
Tax risk can be defined as taking a tax return filing position that adversely affects the Group’s tax or business objectives and results
in an unanticipated or unacceptable level of monetary, financial statement or reputational exposure. Key tax risks relevant to theGroup include, among other things, application of tax risk assessment and judgement in advising on legitimately controlling taxcosts.

Date of issue: 20th November 2023

CORPORATEThe Group believes in legitimately controlling its tax costs while paying its fair share of tax legally due in any country at the righttime. The Group does not undertake purely artificial transactions to obtain a tax benefit. The Group complies with all relevant tax
laws and regulations.

3Tax Risk Assessment
In line with commercial objectives, the Tax Function will work with the business as an equal partner in advising on legitimately
controlling tax costs. We will make tax decisions and recommend tax strategies appropriate to the jurisdictions in which theeconomic activity occurs. For example, the UK offers various tax incentives to meet local policy objectives. And LSEG believes it
has a duty to avail itself of these opportunities.
When making decisions and recommendations on tax matters, the Group follows “the more likely than not” principle. For example,
we would only claim a tax position without a provision if it is at least more likely than not that our proposed treatment would sustain
an examination by a tax authority.
In regularly assessing the Group’s decision-making risk, we consider, among other things, our level of assurance that a tax position
will sustain challenge, a tax position’s technical, structural and compliance complexity, and the impact on corporate reputation.

Tax Authority Relationships:
Alongside the principles mentioned above, we seek to minimize the risk of challenge, dispute or damage to the Group’s credibility
by, among other things:
Documenting strong technical tax positions and the facts.

Clearly explaining those positions.

Being proactive in all interactions with tax authorities.

Implementing strong compliance procedures and controls to ensure accurate and complete tax returns.

Tax Reporting and Filing Procedures
We operate an effective tax control framework to meet our tax reporting and filing obligations through robust internal policies,processes, controls, training and compliance programs. Where compliance processes have been outsourced to a shared service
centre, contract employees, consultants, and any other third party, we ensure the principles herein are adhered to.
In line with this, the Group maintains procedures to prevent the facilitation of tax evasion in accordance with Part 3 of The CriminalFinances Act 2017. The Board of LSEG approves this strategy and annually monitors compliance via the Audit Committee, and, as
appropriate, on an ad hoc basis. We review this strategy as well as all our processes and controls at least annually but more
frequent as required, to ensure we take account of changes in the internal and external environment.

Date of issue: 20th November 2023