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ModernSlavery andHumanTraffickingStatement
2022

Modern Slavery and Human Trafficking Statement 2022

Contents

About LSEG

01

Scope of statement

02

Policy and regulatory landscape03

Our commitments

04

Our suppliers

06

Governance and policies

07

Statement approval

10

Modern Slavery and Human Trafficking Statement 2022

About LSEG

LSEG is a leading global financial
markets infrastructure and data
provider. We play a vital social andeconomic role in the world’s financialsystem. With our trusted expertiseand global scale, we enable thesustainable growth and stability of ourcustomers and their communities.
LSEG is headquartered in the United
Kingdom, with significant operationsin 65 countries across EMEA, North
America, Latin America and Asia
Pacific. We employ 24,000+ people
globally.
Our purpose is driving financial
stability, empowering economies
and enabling customers to create
sustainable growth.

01

Modern Slavery and Human Trafficking Statement 2022

Scope ofstatement
Human rights are universal. This means that every
person around the world deserves to be treatedwith dignity and have their interests consideredequally. Governments have the duty to protect
individuals against human rights abuses. The UN
Guiding Principles for Business and Human Rights
also outline the responsibility of businesses torespect human rights.
While not all entities in LSEG are required
to publish a statement, LSEG is committed
to ensuring all Group entities operate in aconsistent and effective way regarding modern
slavery and human trafficking risk. The 2022
Statement covers all the companies controlled
directly or indirectly by LSEG, including thefollowing companies that are required to publish
a statement: London Stock Exchange Groupplc, London Stock Exchange plc, LCH Limited,
FTSE International Limited, Financial & Risk
Organisation Limited, LSEG Business Services
Limited, LSEG Employment Services Limited,
Refinitiv Limited, Refinitiv Transaction Services
Limited, LCH SA, LSEGH Inc., Frank Russell
Company, The Yield Book Inc., Financial & Risk
Transaction Services Ireland Limited, and Refinitiv
Australia Pty Limited.

02 Modern Slavery and Human Trafficking Statement 2022

Policy andregulatory
landscapeWe welcome the increased focus of governments
around the world on the issues of modern
slavery and human trafficking. The international
community rightfully expects businesses tofocus on supply-chain risks in keeping with theUN Sustainable Development Goals and otherinternational commitments. We acknowledge themeasures to strengthen reporting requirements
under the UK’s Modern Slavery Act, including
embedding modern slavery risks and humantrafficking throughout procurement process,and the introduction of a public registry of modern
slavery statements. As a global business, weespecially welcome international coherence
and mutual recognition of different reporting
requirements and standards, to help mobilise
global efforts.

We acknowledge the measures
to strengthen reporting
requirements under the UK’s
Modern Slavery Act, including
embedding modern slavery risks
and human trafficking throughout
procurement process, and theintroduction of a public registryof modern slavery statements.

03 Modern Slavery and Human Trafficking Statement 2022

Ourcommitments
LSEG has a vital economic and social role inenabling companies to access funds for growthand development. As such, integrity as well as
trust in our markets and in LSEG, are at the core ofwhat we do. We regard all forms of modern slavery
and human trafficking as a crime and a violationof fundamental human rights. We are committed
to implementing and promoting practices which
combat modern slavery in all its forms. Our
updated risk assessment conducted in 2022
indicated that LSEG operates in an industry where
the risk of modern slavery and human trafficking
is inherently low. However, we operate globallyand acknowledge the complexity of supply chains.
We recognise the risks of partnering with a broad
spectrum of global suppliers and the possibility ofmodern slavery occurring deeper in those complex
supply chains.
LSEG is a member of United Nations Global
Compact (UNGC). As part of our participation,
LSEG commits to the UNGC’s Ten Principles, which
include Principle 4: the elimination of all formsof forced and compulsory labour. Our HumanRights Statement provides an overview of how weendeavour to meet our responsibility with respect
to human rights, in addition to the principles andrequirements within our LSEG Code of Conduct,
which apply to all LSEG employees.

Our updated risk assessment
conducted in 2022 indicatedthat LSEG operates in an industry
where the risk of modern slavery
and human trafficking is inherently
low. However, we operateglobally and acknowledge thecomplexity of supply chains.

04 Modern Slavery and Human Trafficking Statement 2022

LSEG adheres to the UN Guiding Principles on
Business and Human Rights, together with theInternational Labour Organization Conventions andRecommendations within our working environment
in each location where we operate.
Our Supplier Code of Conduct requires that
suppliers pay wages in line with prevailing market
conditions or at least the minimum wage requiredby applicable laws and regulations and without
unauthorised deductions. LSEG is a Living Wage
Foundation-accredited employer in the UK andencourages everyone we do business with toconsider implementing the Living Wage. Ourcontracts with suppliers that have employees
working on LSEG premises in the UK including
temporary and contract workers includes a clausemandating the payment of the Living Wage orLondon Living Wage as applicable.

LSEG is a Living Wage
Foundation-accredited
employer in the UK andencourages everyone we
do business with to consider
implementing the Living Wage.

05 Modern Slavery and Human Trafficking Statement 2022

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Ourcommitments

Our suppliers

As part of the supplier-onboarding process, a risk
segmentation is carried out with a determination of low,
medium or high risk based on a range of factors. Due
diligence is conducted based on the segmentation toensure the appropriate assessment is carried out.
Our suppliers are additionally checked against LSEG’s
Country Risk List, which has been formed from external
indices and data such as the Corruption Perception
Index and the UK Foreign, Commonwealth andDevelopment Office’s Human Rights and Democracy
report. Countries on the risk list have a red, amber,green (RAG) status applied and are considered to poseelevated risks from reputational, geopolitical, economic
and social lens.
LSEG asks its suppliers to sign up to our Supplier Codeof Conduct before agreeing to onboard the supplier.
We continue to screen suppliers’ modern slavery andhuman rights risks through LSEG’s World-Check Risk
Intelligence database (World-Check). Specialist researchanalysts across the globe collate information fromreliable and reputable sources - such as sanctions lists,
government records, and media.
In 2022, we enhanced our processes and we arecommitted to continually refining our identification andassessment methods resulting in an improved prevention
and remediation of any identified cases.
We are consistently evolving our Third-Party Risk
Management and Supplier Relationship Management
functions to play a key role in building a stronger
partnership with our suppliers. Our ambition is tocontinue to be a leader in this space through facilitating
open dialogues with suppliers on the criticality ofmanaging Modern Slavery and Human Trafficking thataligns with our Risk Culture.

06 Modern Slavery and Human Trafficking Statement 2022

Governanceand policies
LSEG has a number of policies andstandards which support our approach tomodern slavery. These include the following:

Procurement Policy
LSEG maintains a Group Procurement Policy that applies
to all staff, contractors and officers. The policy requires
risk assessment of suppliers and proportionate due
diligence, including modern slavery risk, on all potential
suppliers before their engagement as a supplier toLSEG. The policy also requires written contracts to bein place for suppliers we consider to be medium andhigh risk from a critical usage point of view, to leverage
and embed our standard anti-slavery provisions. The
Group Procurement Policy (and local policies whererelevant) applies in all geographies in which LSEG
operates and to all staff or resources acting on ourbehalf in the engagement of suppliers. The policy
has been approved by the boards of all LSEG entities
and is sponsored by a member of the LSEG Executive
Committee and it is available to staff at all times via
LSEG’s intranet.

Supplier Code of Conduct

The policy requires risk
assessment of andproportionate due diligence,
including modern slavery risk,on all potential suppliers before
their engagement as a supplier
to LSEG.

07 Modern Slavery and Human Trafficking Statement 2022

Group Procurement is responsible for LSEG’s Supplier
Code of Conduct, which can be found here. The
code outlines LSEG’s expectation that its suppliers
should conduct themselves in a manner aligned toLSEG’s standards. The Code includes commitments forsuppliers to comply with all applicable laws, industry
standards across topics such as labour, and theenvironment. It requires commitments from suppliers
to avoid slavery in their own supply chains. It is agreed
with new suppliers during procurement due diligence,and a non-negotiable provision in our standard contract
templates and requirements. Considering breaches,
the Supplier Code of Conduct encourages any parties
with concerns about breaches of the code, slavery or
any similar topics to disclose them by confidential email
to LSEG. However, there were no such disclosuresthroughout 2022.

Governanceand policies
Code of Conduct
LSEG has in place a Code of Conduct, approved by theLSEG Board, which applies to all staff and contractors
working for LSEG. It includes the expectation that
all employees and all members of LSEG’s extended
workforce act in accordance with our corporate
commitment to avoid slavery in our organisation andbusiness dealings. All employees, and other in-scopeindividuals, are required to complete mandatory training
each year which reinforces the requirement to comply
with the Code of Conduct at all times. The Code ofConduct is available to all staff at all times via our intranet.

08 Modern Slavery and Human Trafficking Statement 2022

Governanceand policies
Sustainability Policy
This Policy, approved by the LSEG Board, includes
anti-slavery within its overarching commitments andis supported by a Human Rights Statement, both ofwhich are available here. The Policy is available toemployees at all times via the LSEG intranet site.
The CEO is ultimately responsible for sustainability
matters, supported by the Executive Committee. Oursustainability strategy is driven by the Sustainability
Committee, on which a number of Executive Committee
members sit. Delivery of the sustainability programme iscarried out by the Group Sustainability team.

Whistleblowing Policy
We operate a Whistleblowing Policy, aimed principally at
our employees but also available externally, including tothose working in our supply chains in all LSEG locations.
This policy encourages employees, customers, andother business partners to report any concerns about
LSEG activities, supply chains or business dealings that
may give rise to an enhanced risk of slavery or humantrafficking and other similar issues. This can be done
anonymously and confidentially via a global 24/7 online
portal and equivalent telephone hotline. The policy anddisclosure procedures are available to all employees
and other parties at all times via the intranet and external
website.

Anti-bribery and Corruption Policy
A Group-wide policy covering anti-bribery andcorruption is in place within the Group and is accessibleby all staff via the LSEG intranet. All employees
undertake mandatory training on this topic annually.

09 Modern Slavery and Human Trafficking Statement 2022

Statement approval

LSEG’s approach to reporting under the Modern Slavery Act wasdeveloped by the Group Sustainability team, drawing on resourcesfrom all functions, businesses and geographies. The Statement has
been considered and accepted by the Sustainability Committee,
Executive Committee and approved by the LSEG Board. Executiveresponsibility rests with the Group Executive Committee, whichhas primary accountability for the businesses and functions relevant
to particular human rights issues, including modern slavery andhuman trafficking.

David Schwimmer

Chief Executive Officer
London Stock Exchange Group PLC

Date: 01 March 2023

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Modern Slavery and Human Trafficking Statement 2022

LSEG is more than a diversified global financial
markets infrastructure and data business.
We are dedicated partners to our customers, with an open model and commitment to excellence. With extensiveexperience, deep knowledge and global presence across financial markets, we enable businesses and economies
around the world to fund innovation, manage risk and create jobs. It’s how we’ve contributed to supporting thefinancial stability and growth of communities and economies globally for more than 300 years.

Discover more at lseg.com

Modern Slavery and Human Trafficking Statement 2022
LSG2705342/3-23