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LSEG Supplier Code of Conduct

First published: October 2014
Last revised: April 2023

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Contents

1. Introduction

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2. Definitions

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3. Our Code of Conduct at glance3

4. The Code3

5. Violation of our Supplier Code of Conduct

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1. INTRODUCTION
A significant proportion of London Stock Exchange Group’s(“LSEG”/ “Group”) cost base is comprised of expense
incurred with third party suppliers. These suppliers provide a
range of physical goods and services to us, from everyday
commodities to the provision of critical market facing
services, IT hardware, networking and software applications,data and professional consulting.

These trusted relationships with our suppliers are an
important component in maintaining our unique role at theheart of the world’s financial community.

We have a responsibility to ensure that our selection processof these third parties, and oversight of the manner in which
they do business, are a positive reflection on both our brandand corporate values and enables us to comply with our
external obligations to regulators as well as to our clients.

LSEG plays a vital economic and social role in enablingcompanies to access capital for growth and development. As
such, maintaining integrity and trust in our markets, andacross the Group, are at the core of what we do. This Codesets forth the standards and practices we expect our
suppliers to uphold, wherever they are in the world.

We are committed to:•

Establishing mutually beneficial relationships with our
suppliers and business partners and honouring andenforcing the terms of our contracts.

•

Conducting our operations with integrity andaccordance with the principles of fair competition.

•

A zero-tolerance approach to bribery including nottolerating the offer or acceptance of any gift, hospitality orother inducement designed to influence unduly adecision.

in•

A zero-tolerance approach to the facilitation of corporate
tax evasion.

•

A zero-tolerance approach to modern slavery in any form.

•

Acting ethically and with integrity in all our businessdealings and relationships and implementing andenforcing appropriate, effective systems and controls toensure bribery, tax evasion, financial sanctions violations,and modern slavery are not taking place anywhere in ourown business or in any of our supply chains.

•

Complying with legal and ethical standards across theGroup relating to fundamental human rights as describedin in the International Labour Organisation’s International
Law on forced labour such as the Abolition of Forced
Labour Convention, and the Worst Forms of Child Labour
Convention•

Only doing business with organisations that upholdsimilar corporate and business principles.

•

Requiring and supporting our suppliers to comply with thiscode. In turn, LSEG expects its suppliers to apply thiscode to its own supply chain.

2. DEFINITIONS“LSEG”/ “Group” means London Stock Exchange Group
including any affiliate companies or subsidiaries, either partlyor wholly owned. As of 29 January 2021, this includes entities
that became part of the Group through the acquisition of
Refinitiv.
“Supplier” means any individual or third-party organisation(including any of their affiliate companies or subsidiaries or
any of their agents or subcontractors) providing services to
any LSEG company or their designees.
“Employees” in relation to LSEG means any individual
directly or indirectly employed by LSEG, including
permanently employed or contracted staff, and any
representatives or agents appointed to act on our behalf.

3. OUR CODE OF CONDUCT AT GLANCEThis Supplier Code of Conduct directly aligns to the principles
of our own Code of Conduct and has several pillars. Eachpillar of this Code is supported by action statements andbehaviours expected of our suppliers:
1. Environmental management: we expect our suppliers tocollaborate with us in the achievement of ourenvironmental goals, to comply with all applicable laws
and to strive for best practice.
2. Human and Social Rights: we expect our suppliers tocomply with applicable human rights and employment
laws and to support the protection of fundamental humanrights wherever they operate in the world.

4. THE CODE
In line with our own Code of Conduct, we expect our suppliers
to commit to:•

Behaving ethically, with integrity and honesty.

•

Competing fairly.

•

Working in partnership with our people and our customers
and avoiding conflicts of interest and abuses of power.

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not limited to, compliance with industry bestpractice standards for the sourcing of products.

•

Providing commercially competitive high-quality products,
services and value to LSEG, and its customers.

•

Treating LSEG employees fairly and with respect.

•

Have in place an effective
environmental commitment.

•

Dealingwith
ourbusiness
partners,clients,
representatives and other third-party suppliers fairly.

•

Reduce negative environmental impacts.
Suppliers must take action to reduce operational
environmental impacts. For example, suppliers
should take steps to conserve energy, water, andother natural resources, continuously improving
efficiency and reducing resource consumption,and using energy from renewable sources when it
is available.

•

Managing the relationship with the highest standards ofcorporate governance and best practice.

•Engaging on an “open book” basis with LSEG, complying
with the requirements of our supplier due diligence, onboarding and review and audit procedures, and openly
providing information to support these procedures whenrequested.

These principles align to specific behaviours and practices
required by LSEG suppliers:••

Compliance with all applicable competition, fair-trading,export, anti-bribery, anti-fraud, anti-tax evasion, antimoney laundering, financial sanctions, and human rights
laws wherever they do business.
Refraining from offering bribes or improper gifts, orentertainment for the benefit of LSEG employees, agentsor clients, and having reasonable procedures in place toprevent bribery.

•

Refraining from participating in or facilitating corporate tax
evasion and having reasonable procedures in place toprevent corporate tax evasion.

•

Compliance with all applicable current and future modern
slavery and human trafficking laws, regulations andethical standards wherever they do business.

•

Avoiding potential conflicts of interest which could, by
association, negatively impact on LSEG, its clients orpartners.

•, Upholding the Ten Principles of the UN Global Compact

4.1 Environmental Management
LSEG has an important role to play in the transition toa net-zero economy. For our own operations, we willachieve this through robust targets, cross-businessengagement, and a clear action plan to transform ouroperations. We expect our suppliers to collaborate with
us in the achievement of our environmental goals,
respond to challenges posed by climate change andwork toward protecting the environment.
As a part of this commitment, all LSEG Suppliersmust, without limitation:•

Comply with all applicable environmental laws,
regulations, and standards. This includes but isavailable

LSEG has set science-based targets approved by the
Science Based Targets Initiative (SBTi), to reduce ourown emissions by 50% by 2030 and will also engage
67% of our supply chain, by emissions, to set their own
science-based targets by 2026.
In line with this target, any suppliers who are
identified and have been notified by LSEG as inscope for LSEG’s supplier target must also comply
with the following:•

Have publicly available environmental
statement, policy, or commitment. Suppliers
are to maintain environmental policies,
objectives or targets.

•

Set own 1.5°C aligned climate targets:
suppliers must set a public target in line with a
1.5C and net-zero future•

Measure and report progress. Suppliersmust disclose complete, consistent, andaccurate scope 1 and 2 (GHG) emissions data.
If necessary LSEG can provide a template forcompletion. If requested by LSEG, suppliersmust provide plans to reduce greenhouse gas(GHG) emissions in alignment with LSEG’s
requirements. The timing of supplierconformance to this requirement may be
determined by LSEG standards andrequirements outlined in their contract withLSEG.

4.2 Human and Social Rights
LSEG supports the protection of human rights around theworld and is guided by fundamental principles such as thosein the United Nations Universal Declaration of Human Rights
and the International Labour Organisation (ILO) Core

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Conventions. This support is reflected in our policies andactions in the countries in which we do business. LSEG seeks
to support human rights throughout our supply chain byencouraging behaviours and practices that are consistent
with these principles.

expect that our suppliers will apply the same highstandards to their own organisation and supply chain.
–

We welcome relationships with our suppliers as opportunities
to improve and evolve practices and behaviours with respect
to Human Rights, Modern Slavery and Human Trafficking.

We expect our suppliers to support the following principles intheir own organisations and supply chains:•

Corporate commitment to compliance with all applicablecurrent and future labour, human and social rights laws,
regulations and standards including the publication of astatement on Slavery and Human Trafficking if required(as required under s54 of the Modern Slavery Act 2015).

•

Forced labour: We must under no circumstances use,
or in any way benefit, from forced labour in our supply
chain. We therefore expect our suppliers to takesufficient and reasonable steps to ensure LSEG is notindirectly benefitting from, or contributing to, modern
slavery or human trafficking in its supply chain. The useof forced labour, whether in the form of indentured
labour, bonded labour or prison labour by LSEG’s
suppliers is prohibited. Also prohibited is the support for
any form of human trafficking of involuntary labour
through threat, force, fraudulent claims or other coercion.

•

Provision of a safe, healthy work environment:complying with all relevant health and safety laws andproviding a working environment, for employees andvisitors, that minimises health and safety risks.

•Freely chosen labour: ensuring that all work iscompleted voluntarily. Employees, contractors andagents of the organisation are not forced, bonded,indentured or subject to threat or involuntary labour.
They must also be free to terminate their employment
with reasonable notice.

•

A commitment to anti-slavery: Modern slavery is acrime and a violation of fundamental human rights. It
takes various forms, such as slavery, servitude, forced
and compulsory labour and human trafficking, all ofwhich have in common the deprivation of a person'sliberty by another in order to exploit them for personal orcommercial gain.
––

We are committed to ensuring there is transparency
in our own business and in our approach to tacklingmodern slavery and human trafficking throughout our
supply chains, consistent with our disclosure
obligations under the UK Modern Slavery Act 2015
and the Commonwealth Modern Slavery Act 2018.
We expect the same high standards from all ourcontractors, suppliers and other business partners.
As part of our contracting process we strive to ensure
against the use of forced, compulsory or traffickedlabour, or anyone held in slavery or servitude and we

We expect our suppliers to take sufficient andreasonable steps to prohibit practices that are wellknown to contribute to the risk or proliferation ofmodern slavery such as charging workers recruitment
fees or effectively paying for the opportunity for
employment;
retaining
worker’s
identity
documentation such as passports; requiring workers
to lodge deposits or bonds; and contract substitution(where the contract with the employer does not matchthe contract the worker signed with the agent in thehome country).

•

Avoidance of child labour: Child labour should not be
used. Many countries have a minimum age for
employment for work and those requirements should be
respected, and employment should not be allowed
before the age for completing compulsory education.

•

Compliance with all applicable wage and working
hour laws: people must not be required to work morethan the maximum work week hours established by local
law, including overtime, except in extraordinary businesscircumstances and with the prior consent of theindividual.
Employees
mustbecompensatedappropriately in line with prevailing market conditions or
at least the minimum wage required by applicable laws
and regulations and provided all required benefits. They
must be compensated at a minimum in line with local
laws for overtime hours worked. LSEG is a Living Wageaccredited employer in the UK and encourages
everyone we do business with to consider implementing
the Living Wage. The Living Wage is calculated
according to what workers need in a particular place toafford a decent standard of living and may be higher thanthe minimum wage required by law.

•

Allow freedom of association: respecting the rights ofworkers in relation to freedom of association. Where theright of freedom of association and collective bargaining
is restricted under law, the supplier will not hinder thedevelopmentofalternative
means
for
informing/consulting with employees.

•

Protect the privacy of personal information:compliance with applicable privacy laws as well as
securing LSEG data against unauthorised access oruse.

•Treat people with dignity: protect human rights as
described in the United Nations Universal Declaration of
Human Rights. We expect our suppliers to not tolerate
physical violence and threats, corporal punishment,
mental coercion, verbal abuse or sexual harassment.

•

Grievance mechanisms and whistleblowing: we
expect our suppliers to have sufficient and reasonable
provisions for staff grievance and whistleblowing
mechanisms, so their workers have a confidential andsafe process for raising any concerns.

•

Communication to concerned staff: we expect
suppliers to take reasonable steps to ensure that any
staff or other third party resources or subcontractors

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used by the supplier in delivery of goods and services to
LSEG are made aware of this Code and are compliant
with it.

LSEG also recognises the importance of its suppliers as
strategic partners and stakeholders affected by our business
operations. LSEG is a signatory of the UK Prompt Payment
Code, which encourages and promotes best practice
between organisations and their suppliers.

4.3 Diversity and Inclusion
LSEG values diversity as a foundational element ofinnovation. We recruit, employ, promote and reward
employees solely on the basis of the qualifications,experience, abilities and competencies required for the roleand seek to attract, retain and motivate people from manybackgrounds and perspectives.
We will never tolerate bias, discrimination, intimidation orharassment of our people. We expect our suppliers to shareand support us in this commitment to diversity and inclusion,and ask our suppliers to commit to the following in theirrelationship with LSEG and also within their own
organisations and supply chains:•

Avoidance of discrimination: including, but not limited
to, discrimination based on race, religion, age, gender,
gender identity or expression, sexual orientation,nationality, social or ethnic origin, marital status,
pregnancy, disability, HIV, political affiliation, union
membership or any other status or characteristic that is
not related to the individual’s ability or performance or
the inherent requirements of the job. Promote a
workplace free from harassment, victimisation or any
other form of inappropriate behaviour or abuse on any
grounds.

•

Actively demonstrate a commitment to workplace
inclusion: documenting a Diversity and Inclusion
approach, which at a minimum should include
commitments to identify, measure and improve a cultureof inclusion for their organisation, wherever they operate
in the world.

•

Inclusive supply chain management: drive active
management of downstream supply chains as part of the
supplier’s commitment to inclusion and diversity, suchthat the principles of inclusion and accessibility are
required throughout their own supply chain. Where
possible, work with diverse businesses and ensure
inclusive sourcing activities and decisions are made withregard to downstream supplier selection.

sustainability and corporate responsibility. Our goal is to drive
excellence in these areas throughout our own organisation,and to support and influence positively the development ofthese areas in our supply chain.

Integrity and trust are at the core of what we do. We strive
only to do business with suppliers who share ourcommitment.

This Code outlines our expectations for suppliers we dobusiness with; we are committed to supporting our suppliersin this respect, including working together to improve thesupplier’s ability to meet these expectations.

Failure to comply with these standards, or with applicablelaws, and regulation may result in termination as an LSEG
supplier, where this right has been contractually agreed inadvance by both parties, and referral of the matter to local
authorities.

If you have questions about our Supplier Code of Conduct, orwish
toreportaviolation,pleasecontact
procurement@lseg.com. Any concerns will be reviewed in
the strictest confidence consistent with applicable law.

5. VIOLATION OF OUR SUPPLIER CODE OF
CONDUCT
LSEG’s role at the heart of the world’s financial community
puts us in a unique and privileged position for promoting

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London Stock Exchange Group
10 Paternoster Square London EC4M 7LS

Contact Details:
Group Procurement
E: procurement@lseg.com