UK Code of Conduct for ESG Ratings and Data
Providers
LSEG’S STATEMENT OF COMPLIANCE

Document Version 1.0
Date of issue: 24 July 2024

Header2

LSEG’s Compliance with the UK Code of Conduct
for ESG Ratings and Data Providers
The London Stock Exchange Group (“LSEG”) is pleased to outline how it complies with Principles 1-6 of the Code of Conduct for
ESG Ratings and Data Products Providers (“Code of Conduct” issued by the International Capital Market Association (ICMA) andInternational Regulatory Strategy Group (IRSG). This is further to its January 2024 endorsement.
The Code of Conduct, created by the ESG Data and Ratings Working Group, an industry working group formed by the Financial
Conduct Authority, represents industry best practices for ESG data and ratings providers and aligns with IOSCO’s recommendations
on ESG data and ratings. LSEG played a role in the development of the Code of Conduct as a Co-Chair of the working group.
LSEG fully supports global initiatives aimed at improving quality, reliability, and transparency of ESG scores and data. A core set ofuniversal principles guides the ESG scoring and methodologies of LSEG businesses, in line with key industry and international
standards. In July 2023, LSEG also endorsed the Code of Conduct for ESG Evaluation and Data Providers in Japan.
The information represented below is relevant to LSEG ESG Scores administered by the Sustainable Finance & Investment (SFI)
business within LSEG, and FTSE Russell ESG Scores administered by FTSE Russell. These businesses publish ESG scores anddata for close to 16,000 public and private companies by identifying publicly available data and information against transparent models
and a methodology that is based on global ESG reporting standards, including from the International Sustainability Standards Board(ISSB), its precursor the Taskforce on Climate-related Financial Disclosures (TCFD), the Global Reporting Initiative (GRI) and theEuropean Sustainability Reporting Standards (ESRS).

LSEG’S COMPLIANCE WITH THE CODE OF CONDUCT, PRINCIPLES 1-6:
PRINCIPLE 1 | GOOD GOVERNANCE
ESG RATINGS AND DATA PRODUCTS PROVIDERS SHOULD ENSURE APPROPRIATE
GOVERNANCE ARRANGEMENTS ARE IN PLACE THAT ENABLE THEM TO PROMOTE ANDUPHOLD THE PRINCIPLES AND OVERALL OBJECTIVES OF THE CODE OF CONDUCT.
LSEG ESG Scores and FTSE Russell ESG Scores are subject to robust governance arrangements within each respective business,
which aim to meet or exceed regulatory requirements and recognised industry standards, including the Code of Conduct. Roles andresponsibilities are clearly outlined in an Accountability Matrix for each business.
The LSEG ESG Scores are governed through the Sustainable Finance and Investment (“SFI”) Regulatory Governance Committee(“SRGC”). The SRGC oversees the application, development and changes to SFI products and reviews all regulatory-aligned
methodologies and policies related to LSEG ESG Scores. It also monitors and implements new regulatory requirements and industry
standards. The forum is comprised of representatives from all areas of the business involved in the administration of LSEG ESG
Scores, including individuals identified as having key roles and responsibilities within the SFI business, Risk and Compliance. The
SFI business is also governed by a Product and Commercial Board (PCB) that provides commercial and product-related decisionmaking capabilities to ensure that product launches and commercial policies lead to successful outcomes and better products.
FTSE Russell ESG Scores are governed through FTSE Russell’s Governance Framework, which includes input from the FTSE
Russell Sustainable Investment Advisory Committee, an external committee comprised of market practitioners and stakeholders.
Additional information on these forums, including a summary of Terms of Reference and key roles and responsibilities, is available
through the Governance Framework document, referenced above.

Document Version 1.0
Date of issue: 24 July 2024

Header
3

PRINCIPLE 2 | SECURING QUALITY (SYSTEMS AND CONTROLS)ESG RATINGS AND DATA PRODUCTS PROVIDERS SHOULD ADOPT AND IMPLEMENT WRITTENPOLICIES AND PROCEDURES DESIGNED TO HELP ENSURE THE ISSUANCE OF HIGH-QUALITY
ESG RATINGS AND DATA PRODUCTS.
LSEG’s businesses have established policies and procedures and relevant training materials across teams responsible for datacollection, quality controlling, model management and distribution to ensure high standards of data accuracy and integrity. LSEG and
FTSE Russell ESG Scores are based on publicly available information, whereby actual reported data is collected, storing the audit
trail to the source documents and is subject to thorough and robust internal controls to ensure high quality and auditability for each
ESG data point and score.
LSEG is also a technology focused business and is continually re-assessing and redesigning its systems to collect data in the mostefficient, accurate and timely manner possible, this includes automated algorithmic searching of corporate reporting and natural
language processing. However, to ensure accuracy, given the highly unstructured sources of sustainability information that are
published across multiple languages and formats there is a need for significant numbers of well-trained content analysts.
Our team of over 700 content analysts and quality controllers follow standardised procedures and are enabled through technology
and tools to capture in a timely manner ESG data that is accurate, transparent and comparable across the entire range of companies
in our coverage. Collected data is subject to manual audits and automated pre- and post-production quality checks. LSEG ESG
Scores are also subject to daily sample audits and regular reviews to address the accuracy and integrity of the data. To ensure data
is current, the database is updated on a continuous basis based on corporate reporting, controversy news and corporate actions.
More details of the processes and controls implemented for LSEG ESG Scores are included in the publicly available document,
Environmental, social and governance scores from LSEG.
Similarly, FTSE Russell ESG Scores follow a standardised approach to data collection whereby publicly available information is
captured for each company across each research cycle. Throughout the data collection and calculation process, FTSE Russell applies
several layers of quality control to ensure data accuracy. Checks are applied at the company and overall dataset levels. Details of
the collection and calculation processes and controls are available in FTSE Russell ESG Data Model Methodology (lseg.com).
At the staff level, LSEG operates effective recruitment and onboarding processes to identify and recruit top talent across all
businesses. In line with LSEG’s HR framework, employees are subject to continuous professional training and assessment to foster
development and high-performance standards in their roles. In addition to administering internal certifications for ESG data specialists,colleagues are also supported in pursuing external industry-recognised certifications.
ESG specialists at LSEG undergo extensive classroom and on-the-job training under close supervision and guidance from subject
matter experts. This involves significant technology training as new systems are developed and implemented. The quality of workand performance of ESG specialists are regularly assessed with feedback provided by management on an ongoing basis, in line with
the LSEG’s HR framework. LSEG’s data collection team operates an evaluation system established to nurture LSEG’s high-quality
data and ensure LSEG’s rules-based methodologies are followed.
To ensure alignment with industry standards and regulatory requirements, the performance of the policies and procedures in placeis also subject to the Group-wide assessments operated from time to time by LSEG Internal Audit.

Document Version 1.0
Date of issue: 24 July 2024

Header
4

PRINCIPLE 3 | CONFLICTS OF INTEREST

3.1 ESG RATINGS AND DATA PRODUCTS PROVIDERS SHOULD ADOPT AND IMPLEMENTWRITTEN POLICIES AND PROCEDURES DESIGNED TO HELP ENSURE THEIR DECISIONS ARE
INDEPENDENT, FREE FROM POLITICAL OR ECONOMIC INTERFERENCE, AND APPROPRIATELYADDRESS ACTUAL OR POTENTIAL CONFLICTS OF INTEREST THAT MAY ARISE FROM, AMONGOTHER THINGS, THE ESG RATINGS AND DATA PRODUCTS PROVIDERS’ ORGANIZATIONALSTRUCTURE, BUSINESS OR FINANCIAL ACTIVITIES, OR THE FINANCIAL INTERESTS OF THE ESG
RATINGS AND DATA PRODUCTS PROVIDERS AND THEIR OFFICERS AND EMPLOYEES.

3.2 ESG RATINGS AND DATA PRODUCTS PROVIDERS SHOULD IDENTIFY, AVOID OR
APPROPRIATELY MANAGE, MITIGATE, AND DISCLOSE ACTUAL OR POTENTIAL CONFLICTS OF
INTEREST THAT MAY COMPROMISE THE INDEPENDENCE AND INTEGRITY OF THE ESG RATINGSAND DATA PRODUCTS PROVIDERS’ OPERATIONS.
To manage conflicts of interest and establish appropriate control measures across the LSEG, all businesses follow the LSEG Global
Conflicts of Interest Policy which sets out the criteria and key requirements for identification, reporting and management of conflictsof interest.
The business and incentive structure for LSEG and FTSE Russell ESG Scores further mitigates potential conflicts of interest. LSEG
does not follow an “issuer pays” model for LSEG ESG Scores or FTSE Russell ESG Scores and the specialists involved in datacollection and calculation, which based on pre-defined rules creates automated scores, have no role in engaging assessed entities
or any clients. Employees involved in data collection and calculation of ESG Scores operate independently from sales functions andare not incentivised by fees charged to clients or revenue from ESG Score subscriptions.
In addition to the dedicated conflicts of interest measures in place across LSEG, the transparent process for the gathering of data
used in producing LSEG and FTSE Russell ESG Scores further ensures integrity, accuracy, and transparency. Publicly available
data is applied to objective, rules-based methodology and subject to multiple levels of controls for both LSEG ESG Scores and FTSE
ESG Scores, limiting the potential for undue influence due to a conflict of interest.
LSEG staff are also subject to the LSEG Code of Conduct and LSEG policies for dealing in securities, which require employees todisclose their holdings and seek pre-approval prior to trading in securities. Potential personal conflicts, such as roles outside LSEG
and close personal relationships relevant to an employee’s role, are required to be disclosed in a centralized compliance system. All
submissions are reviewed by the relevant stakeholders involved in the management of a conflict-of-interest process, and can include
multiple members of LSEG’s Compliance team, and in most cases, also the employee’s line manager. Annually, LSEG employees
must attest that they have followed LSEG policies and disclosed all potential conflicts of interest.
SFI and FTSE Russell have developed business-level conflicts of interest registers, which include coverage of ESG scores. This is
in line with LSEG policies, to capture potential and actual conflicts of interest and implement any necessary mitigating measures. The
identified conflicts and mitigating measures are periodically reviewed as part of the governance processes within SFI and FTSE
Russell.

Document Version 1.0
Date of issue: 24 July 2024

Header
5

PRINCIPLE 4 | TRANSPARENCY
ESG ratings and data products providers should make adequate levels of public disclosure andtransparency a priority for their ESG ratings and data products, including their methodologies andprocesses to enable the users of the product to understand what the product is and how it isproduced, including any potential conflicts of interest and while maintaining a balance with respect
to proprietary or confidential information, data and methodologies.
Transparency is central to ESG data collection, verification and scoring methodologies across LSEG. Product overviews,
methodology and calculation details are publicly available through the LSEG website. Because LSEG and FTSE Russell use anapproach that is data and rule-based driven, with transparent aggregation rules to provide numerical scores, it enables a higher
degree of transparency over alternative approaches seen in the market that require analyst judgement.
For LSEG ESG Scores, the Environmental, social and governance scores from LSEG, a document which is publicly available via the
LSEG website, describes details of the data collection process and how Scores are calculated, including the structure and compositionof Scores, factors and information considered for Scores, how underlying data is treated and weighed, and example data to ensure
full transparency and understanding for users and stakeholders. A link is provided for additional queries. An illustration of final ESG
Score calculations is also available for download within the document.
For FTSE Russell ESG Scores, the FTSE Russell ESG Data Model Methodology (lseg.com) describes the data assessment process,models for ESG Scores and underlying ESG data, and controls. It also provides details about the Score calculation process, including
Theme exposure, Pillar scores and overall ESG Score as well as case study examples, and a list of data sources to ensuretransparency and understanding for users and stakeholders. Links are provided for additional queries and a glossary of terms is
included. Additionally, FTSE Russell provides an FAQ Document that addresses common questions for the ESG assessment andscoring process.

PRINCIPLE 5 | CONFIDENTIALITY (SYSTEMS AND CONTROLS)
ESG ratings and data products providers should adopt and implement written policies andprocedures designed to address and protect all non-public information received from orcommunicated to them by any entity, or its agents, related to their ESG ratings and data products,
in a manner appropriate in the circumstances.
LSEG maintains a Data Policy, developed in line with international recommendations, which sets out the principles and standards fordata governance and management, and a Confidentiality Policy, which sets out the key requirements for handling confidential
information received from internal and external sources. Any potential policy breaches are reported and investigated, in line withinternal processes and procedures.
Data used in ESG scoring is sourced only from publicly available sources, such as annual reports, corporate social responsibility
reports and data from stock exchanges or corporate websites. Data collection specialists within SFI and FTSE Russell areappropriately trained in data sourcing and handling. Any information received from companies pertaining to ESG Scores will not beshared externally or considered for ESG Scores unless the information is first made publicly available.

Document Version 1.0
Date of issue: 24 July 2024

Header
6

PRINCIPLE 6 | ENGAGEMENT (SYSTEMS AND CONTROLS)

6.1 ESG RATINGS AND DATA PRODUCTS PROVIDERS SHOULD REGULARLY CONSIDER
WHETHER THEIR INFORMATION GATHERING PROCESSES WITH ENTITIES COVERED BY THEIRPRODUCTS LEADS TO EFFICIENT INFORMATION PROCUREMENT FOR BOTH THE PROVIDERS
AND THESE ENTITIES. WHERE POTENTIAL IMPROVEMENTS TO INFORMATION-GATHERINGPROCESSES ARE IDENTIFIED, ESG RATINGS AND DATA PRODUCT PROVIDERS SHOULD
CONSIDER WHAT MEASURES CAN BE TAKEN TO IMPLEMENT THEM.
6.2 WHERE FEASIBLE AND APPROPRIATE, ESG RATINGS AND DATA PRODUCTS PROVIDERSSHOULD RESPOND TO, AND ADDRESS ISSUES FLAGGED BY ENTITIES COVERED BY THEIR ESG
RATINGS AND DATA PRODUCTS AND BY USERS WHILE MAINTAINING THE INDEPENDENCE AND
INTEGRITY OF THESE PRODUCTS.
The information gathering process for LSEG ESG Scores and FTSE Russell ESG Scores is regularly discussed and reviewed throughthe respective governance processes. This includes discussions of any issues with the process or methods of collection of data,
complaints received and potential areas for improvement, identified internally or externally. Links to relevant client service teams arealso available to clients and assessed companies.
For LSEG ESG Scores, companies subject to evaluation are also provided free access to the ESG Contributor tool, where they canreview and edit existing data, provide new data and add timely updates to ESG initiatives for investors and stakeholders. Companies
are required to substantiate all data with reference to publicly disclosed sources and the edited or newly contributed data is reviewed
via the established control processes described above. A dedicated customer support team is available for clients to raise any ESG
data-related enquiries and challenges.
For FTSE ESG Scores, FTSE Russell’s process of engagement with companies subject to evaluation is provided in the Corporate
engagement within sustainable investment - Information for researched companies document. The document outlines the structured
engagement process, which is part of the standard operations for administering FTSE Russell ESG Scores. FTSE Russell strives toensure companies understand how ESG Scores are calculated and then provides them with access to the Sustainable Investment
Data Platform, which allows companies to review their Score and ESG data as part of the established “Company Review Process.”
Company feedback is then considered prior to final assessment and publication of the ESG Score. A dedicated client service desk
provides Subject Matter Expert services in multiple languages, and meetings are available for companies upon request. Companies
are also provided the opportunity to challenge potential ESG data inaccuracies and submit complaints or amendments in line with
the Sustainable Investment Data Recalculation Policy and Guidelines.

About LSEG
LSEG (London Stock Exchange Group) is a leading global financial markets infrastructure and data business. We play a vital socialand economic role in the world’s financial system. With our trusted expertise and global scale, we enable the sustainable growth andstability of our customers and their communities. We are leaders in data and analytics, capital formation and trade execution, andclearing and risk management.
At LSEG we believe that capital markets are key to solving the sustainability challenges that society faces globally, and we arecommitted to being a strategic enabler of sustainable growth. As a corporate entity, LSEG has set science-based emissions reduction
targets and our ambition is to reach net zero by 2040. Our Climate Transition Plan and Climate Goals set out how we plan to deliver
this. From our role at the heart of capital markets, we provide industry with tools, data, and access to capital to achieve sustainability
goals.

Disclaimer© 2024 London Stock Exchange Group plc and its applicable group undertakings (the “LSE Group”). The LSE Group includes FTSE
Russell as well as Refinitiv Limited and any entity that, from time to time, is directly or indirectly controlling, controlled by, or underDocument Version 1.0
Date of issue: 24 July 2024

Header
7

common control with those entities (“Refinitiv Group”). "Control" means the power to direct or cause the direction of the management
or policies of such entity, whether through the ownership of voting securities, by contract, or otherwise, and the terms "controlling"and "controlled" shall be construed accordingly. All rights reserved.
Refinitiv® and all other trademarks and service marks used herein (whether registered or unregistered) are trademarks and/or service
marks owned or licensed by the applicable member of the LSE Group or their respective licensors and are owned, or used underlicence, by Refinitiv Group.
All information is provided for information purposes only. All information and data contained in this publication is obtained by the LSEGroup, from sources believed by it to be accurate and reliable. Because of the possibility of human and mechanical inaccuracy aswell as other factors, however, such information and data is provided "as is" without warranty of any kind. No member of the LSEGroup nor their respective directors, officers, employees, partners or licensors make any claim, prediction, warranty or representation
whatsoever, expressly or impliedly, either as to the accuracy, timeliness, completeness, merchantability of any information or of
results to be obtained from the use of Refinitiv products, including but not limited to indexes, rates, data and analytics, or the fitness
or suitability of the Refinitiv products for any particular purpose to which they might be put. The user of the information assumes theentire risk of any use it may make or permit to be made of the information.
No responsibility or liability can be accepted by any member of the LSE Group nor their respective directors, officers, employees,
partners or licensors for (a) any loss or damage in whole or in part caused by, resulting from, or relating to any inaccuracy (negligent
or otherwise) or other circumstance involved in procuring, collecting, compiling, interpreting, analysing, editing, transcribing,transmitting, communicating or delivering any such information or data or from use of this document or links to this document or (b)any direct, indirect, special, consequential or incidental damages whatsoever, even if any member of the LSE Group is advised inadvance of the possibility of such damages, resulting from the use of, or inability to use, such information.
No member of the LSE Group nor their respective directors, officers, employees, partners or licensors provide investment advice andnothing in this document should be taken as constituting financial or investment advice. No member of the LSE Group nor theirrespective directors, officers, employees, partners or licensors make any representation regarding the advisability of investing in any
asset or whether such investment creates any legal or compliance risks for the investor. A decision to invest in any such asset should
not be made in reliance on any information herein. Indexes and rates cannot be invested in directly. Inclusion of an asset in an index
or rate is not a recommendation to buy, sell or hold that asset nor confirmation that any particular investor may lawfully buy, sell or
hold the asset or an index or rate containing the asset. The general information contained in this publication should not be acted upon
without obtaining specific legal, tax, and investment advice from a licensed professional.
No part of this information may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic,
mechanical, photocopying, recording or otherwise, without prior written permission of the applicable member of the LSE Group. Useand distribution of the LSE Group data requires a licence from Refinitiv Group and/or their respective licensors.

Document Version 1.0
Date of issue: 24 July 2024