Modern Slavery and
Human Trafficking
Statement
London Stock Exchange Group plc
Modern Slavery and Human Trafficking Statement 2021

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Contents
Our Group											 3About this statement 										 4Regulatory and legislative landscape								 5Supplier assessment 									 6Training and communications								 9Progress on actions 									

10Looking forward 									

12Statement approval 									

12This statement describes the approach of LSEG as a single group following the acquisition of Refinitiv in January 2021.

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Our Group
Who we are

Our purpose

LSEG is a leading global financial
markets infrastructure and data
provider. We play a vital socialand economic role in the world’s
financial system. With our trusted
expertise and global scale, weenable the sustainable growthand stability of our customers andtheir communities.

Driving financial stability, empowering
economies and enabling customers to create
sustainable growth.

We are leaders in data andanalytics, capital formation andtrade execution, and clearing andrisk management.

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2021

Our vision
We are a leading global financial markets
infrastructure and data provider. We want toshape the future of our industry to serve ourcustomers and markets better.

Where we operate
LSEG is headquartered in the United Kingdom,with operations in 70 countries across EMEA,
North America, Latin America and Asia Pacific.
We employ 23,000 people globally, more thanhalf of whom are located in Asia Pacific.

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About this statement
Human rights are universal. This means that every person around theworld deserves to be treated with dignity and have their interests
considered equally. 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 to respect human rights.
This 2021 Statement covers all the companies controlled directly or
indirectly by LSEG, including the following companies that are required to
publish a statement:
London Stock Exchange Group plc, London Stock Exchange plc, LCH Group
Holdings Limited, LCH Limited, LCH SA, FTSE International Limited,
LSEG Business Services Limited, LSEG Employment Services Limited,
Refinitiv Limited, Refinitiv Transaction Services Limited, Financial and Risk
Transaction Services Ireland Limited, Financial & Risk Organisation Limited,
LSEGH Inc, Frank Russell Co, Yield Book Inc and Refinitiv Australia
Pty Limited.

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2021

While not all entities within LSEG are required to publish a statement, LSEG iscommitted to ensuring all Group entities operate in a consistent andeffective way with regard to modern slavery and human trafficking risk.
LSEG plays a vital economic and social role in enabling companies to accessfunds for growth and development. As such, integrity, and trust in our markets,and in LSEG, are at the core of what we do.
We have a very clear view of modern slavery: we regard all forms of modern
slavery and human trafficking as a crime and a violation of fundamental
human rights. They are fundamentally at odds with our own corporate values.
We are committed to implementing and promoting practices which combat
modern slavery in all its forms. Our updated risk assessment and researchin 2021 has indicated that LSEG operates in an industry where the risk ofmodern slavery and human trafficking is inherently low. However, we operate
as a global business and acknowledge the complex nature of supply chains.
We recognise the risks of partnering with a varied spectrum of global
suppliers and the possibility of modern slavery occurring deeper in thosecomplex supply chains.

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Regulatory and legislative
landscapeWe welcome the increased focus ofgovernments around the world on the issuesof modern slavery and human trafficking.
The international community rightfully expects
businesses to focus on supply-chain risks in
keeping with the UN Sustainable Development
Goals and other international commitments.
We acknowledge in particular the measures to strengthenreporting requirements under the UK’s Modern Slavery Act,
including embedding modern slavery risks and human trafficking
throughout procurement process, and the introduction of a public
registry of modern slavery statements.
As a global business, we especially welcome international
coherence and mutual recognition of different reporting
requirements and standards, to help mobilise global efforts.

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Supplier assessment
LSEG completes a risk assessment(segmentation) on all new suppliers
prior to onboarding, as required by
LSEG’s Group Procurement Policy.

Green based on specific risk factors, with Green
being the lowest risk and Red the highest. It isreviewed and updated (at a minimum monthly) by
LSEG’s Risk function (Group Risk) and includes
modern slavery-specific risk indicators.

Suppliers are segmented as low, medium, or highrisk, based on a range of risk factors.

Suppliers exposed to elevated geographic risk
must be risk accepted by the business and be
approved at a senior level, with referral toGroup Risk.

Different due diligence requirements apply
depending on which segment the supplier falls
into, and assessments are conducted by therelevant team based on the risk level. Suppliers
are checked against LSEG’s “Country Risk List”
during the segmentation process.
This list is based on external indices and datasuch as the Corruption Perception Index and the
UK Foreign, Commonwealth and Development
Office’s Human Rights and Democracy report.
This list informs LSEG’s new countries which pose
elevated risks from a reputational, geo-political,
economic, and social responsibility perspective.
Countries are rated as Red, Amber, Yellow, or

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2021

Countries with a prevalence of corruption,
sanctions, money laundering and human rights
and democracy concerns are more likely tohave a prevalence of modern slavery or humantrafficking and will not be rated ‘Green’. As such,they would require, at minimum, Group Risk
review and senior business acceptance.

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Third-party due diligence programme
LSEG has incorporated the use of our updated Supplier Code of Conduct andCountry Risk List into our due diligence procedures, with training provided toGroup Procurement to assist with identification of elevated modern slavery
risks associated with new suppliers.
LSEG completes several types of due diligence on our should readmedium- and high-risk suppliers which enables the identification of potentiallyelevated modern-slavery risk.
We review suppliers against our Country Risk List, detailed know yourcustomer review (KYC), and require suppliers to agree to the Supplier Code of
Conduct and checks for known supplier sanctions or conflicts of interest.
We have procedures in place for managing issues raised during the duediligence process, including referral to Group Risk, mitigation where possible
and risk acceptance by appropriate senior representatives.
Supplier Code of Conduct exceptions/disagreements are managed by Group
Procurement by seeking confidence that we share common ethical principles
with the supplier. In particular, this includes performing an equivalence checkon the supplier’s own code of conduct, where one exists, and clarifying theirstance on modern slavery and human rights.

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As part of our third-party due diligenceprogramme, we are required to provide
information about prospective suppliers to ourFinancial Crime and Sanctions team, which
performs due diligence on suppliers to determine
whether they present any risk of unlawful conduct,
including corruption and human trafficking.
We have provided training to employees
responsible for sourcing and related activities tohelp them identify and mitigate such risks early
on in our sourcing process. All third parties are
assigned with a risk rating of low, medium, or high,derived from our risk-scoring methodology.

Existing suppliers
We conduct an annual risk assessment acrossall LSEG suppliers providing services during thestatement year. We run an initial assessment
against the Global Slavery Index (GSI).
The assessment output has specific tiering forModern Slavery, ranging from Tier 1 (High SlaveryRisk) to Tier 5 (Very Low Slavery Risk). The tiering
indicates if a supplier is seen as potential highrisk, based on modern slavery risk drivers such as

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2021

GSI and spend categories aligned to our suppliersegmentation and tiering model, as well as
third-party risk tool indicators.
Those that are seen as high risk (Tier 1) are thenprocessed through our third-party risk tool andscanned for any association to modern slavery
or human trafficking. Where this is the case,
we follow up with the supplier to gather more
information about the governance and protocols
followed within their company to identify andmanage human rights risks.

Anti-slavery commitments in our
supplier contracts
LSEG seeks to agree contracts with suppliers
which align to our minimum standards.
Where possible we use standardised contract
templates and a key-terms library to contract with
our suppliers in all geographies.
These terms include:– Cross-jurisdictional anti-slavery provisions
such as the requirement for the supplier tocomply with all applicable laws including the UK
Modern Slavery Act 2015.

– Agreement with our Supplier Code of Conduct.
– Warranties that supplier employees andofficers have not been involved in modern
slavery or human trafficking and have sufficient
procedures to ensure there is no modern
slavery in any of its businesses or supply
chains.
– Rights of LSEG to audit their operations
and businesses.
Our standard terms are supplemented by
uniform requirements in our recruitment,
professional services and consultancy
agreements that the suppliers must vet theiremployees to best-practice standards prior toworking for LSEG (in countries where performing
such a check is legally permitted). Exceptions tothese minimum clauses must be reviewed andagreed with LSEG’s legal function (“Group Legal”)
in the first instance.

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Training and communications
Group Procurement and Group Legal teams havebeen provided with tailored training on modern
slavery. For Group Procurement teams, this training
focuses on modern slavery risk, risk assessment
and due diligence procedures which underpin ouranti-slavery approach, complemented by specifictraining for team members in how to complete risk
assessment and due diligence.
In Group Legal, the focus is on ensuring adequate anti-slavery
commitments are included in all suppliers contracts. New joiners in bothteams are also briefed, with detail provided on both modern slavery
supplier risk and contractual standards. LSEG’s Executive Committee
are briefed on the modern slavery and human trafficking risks faced by
LSEG to ensure the Executive Committee’s commitment and strategic
steer to this topic.
The LSEG Code of Conduct, which applies to all employees, includes
anti-slavery commitments and is available to employees at all times.

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Progress on Actions
The table below provides a summary of progress against the actions included in our 2020 MSA Statement:

ActionStatusSeek to obtain Supplier Code of Conduct agreement from the Tier 1, 2 and 3
suppliers identified from our most recent modern slavery risk assessment andanalysis, where we intend to continue using them as suppliers.

COMPLETE

Ensure our approach to establishing new international office locations
continues to consider the modern slavery and human trafficking risks
associated with those locations as part of its governance.

COMPLETE

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This will continue to be an ongoing action on the back of our yearly risk
assessments. Although there are some gaps across our supply base, we haveseen a significant increase in agreement with our Supplier Code of Conduct
throughout 2021. This process has been implemented within LSEG and theaction is considered complete. We will continue to address providers as partof our supplier management.

All new office locations opened this year followed the same process.
Confirmation is requested from local office suppliers to comply with the
Supplier Code of Conduct and our serviced office broker also takes into
account modern slavery requirements when providing services to LSEG.
This process has been implemented within LSEG and the action isconsidered complete. We will continue to address providers as part ofour supplier management.

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ActionStatusModern slavery to be embedded as part of our supplier relationshipmanagement approach through:

COMPLETE– Quarterly business reviews– Questionnaires– Supplier Code of Conduct engagement with wider supply base
– Further engagement with high modern slavery risk suppliers– More targeted dialogue with international suppliers not subject to the UK
Modern Slavery Act

We are progressing with embedding modern slavery throughout the
procurement lifecycle. This captures our supplier’s stance on modern slavery
at the earliest opportunity when building a relationship. It provides oversightand alignment on modern slavery and human trafficking with our suppliers as
we engage with them on our outlook and expectations of our supply chain.
This is an ongoing action that we will continue to persistently advance throughthis holistic view and enabled modern slavery reporting of our supply chain.

Incorporate modern-slavery items into our questionnaires and scorecards as
an integral part of tender-collateral and sourcing decisions.

COMPLETE

Increase transparency with the business and report internally any cases ofmodern slavery with material concern and the resulting mitigating actions.

CONTINUE

We have embedded specific modern slavery questions within our initialquestionnaires and scorecards to get insight on our potential supply chain
and include the information-making sourcing decisions.

No reported cases of material concern.
This is an ongoing activity which we plan to develop and further embedwithin the business as we move forward with our human rights and modern
slavery approach.

Extend our training programme to continue to grow awareness within LSEG.

CONTINUE
As we move forward as a single entity, we are aware of the need to extend
the training programme across LSEG*CONTINUE actions to be carried forward to 2022

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Looking Forward

Statement Approval

Upcoming activities in 2022 activities will be planned
considering the recommendations in “Preventing
Modern Slavery and Human Trafficking: An Agenda for
Action Across the Financial Services Sector” document
published in September 2021.

LSEG’s approach to reporting under the Modern Slavery
Act was developed by a working group coordinated by
the Group’s Sustainability function, drawing on resourcesfrom all functions, businesses and geographies.
This Statement was considered and accepted by thisworking group and approved by the Sustainability
Committee and the LSEG Board on 2 March 2022.

This will be further supported through our refreshedapproach to third-party risk management, including
better risk identification, assessment, mitigation, controls
and ongoing monitoring.

Executive responsibility rests with the LSEG Executive Committee, which has
primary accountability for the businesses and functions relevant to particular
human rights issues, including modern slavery and human trafficking.

David Schwimmer
Chief Executive Officer
London Stock Exchange Group

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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. Withextensive experience, deep knowledge and global presence across financial markets, we enablebusinesses and economies around the world to fund innovation, manage risk and create jobs. It’s
how we’ve contributed to supporting the financial stability and growth of communities and economies
globally for more than 300 years.

Discover more at lseg.com

LSG1569754/2-22