Your concerns matter

LSEG and its Group companies are committed to providing an open environment where our employees, customers, shareholders, vendors and other third parties feel comfortable raising concerns about adherence to our Code of Conduct, relevant laws and regulations, or if they consider something unethical or potentially harmful.

Whistleblowing hotline

Whistleblowing is the term for the confidential disclosure by an individual of a concern encountered in the workplace relating to a potential wrongdoing. Examples of such wrongdoings include but are not limited to:

• general malpractice such as immoral, illegal or unethical conduct;
• gross misconduct;
• any potential or suspected breach of the code of conduct;
• a criminal offence that has been, is being, or is likely to be committed;
• a person who has breached, is breaching, or is likely to breach any legal obligation to which he/she is subject (i.e. negligence, infringement of intellectual property rights, or breach of contract);
• potential infractions of relevant regulatory requirements;
• a miscarriage of justice which has occurred, is occurring, or is likely to occur;
• a danger to the health and safety of an individual;
• inappropriate conduct has been, is being, or is likely to be deliberately concealed;
• discrimination of any kind which involves LSEG or any employees, customers or suppliers;
• persistent micro-aggressive comments, behaviour or any undue bias; and/or
• any other wrongdoing which will, or may, affect LSEG’s activities or LSEG’s reputation.

LSEG’s confidential whistleblowing telephone and online reporting services are provided by an independent third party, Navex Global, who provide secure and confidential reporting through their platform Ethics Point.

Individuals may submit confidential and anonymous whistleblowing concerns online using https://lseg.ethicspoint.com or through the local confidential telephone lines listed below. All local telephone lines are supported by experienced interviewers trained to recognise all potential forms of misconduct, and who will additionally translate any reports into English as part of the submission process. All services are available 24 hours per day, 7 days per week.

Our whistleblowing reporting service does not preclude any individual from reporting crimes to the competent authorities so as to avoid any risk of conflict and ensure compliance with all applicable local laws.

What will happen to your report?

All submissions will initially be assessed by the Group Chief Internal Auditor, taking into consideration any potential financial and regulatory implications. If necessary, some additional information might be requested at that time.

Once the assessment has been made, an independent person will be appointed to conduct the investigation according to the whistle-blowing procedure.

The investigation team will be led by an independent person (typically the Group Chief Internal Auditor who reports directly to the Chair of the Audit Committee). Depending on the complexity of the case or the nature of the concern, internal or external legal counsel and technical expertise might be required. The investigation will be conducted in a timely manner and the whistleblower will be updated regularly on its progress.

On conclusion of the investigation the lead investigator will decide if corrective actions are required and will ensure that they are carried out. The whistleblower will receive confirmation that the case has been closed and will be informed of the actions taken where appropriate.

The lead investigator is responsible for ensuring that the reporter is not subject to any victimisation either during or after the investigation.

If the investigation does not resolve the reporter’s concern, the whistleblower can lodge an appeal in writing to the Chair of the Audit Committee.

The nominated appeal officer (appointed by the Chair of the Audit Committee) will write to the whistleblower inviting him or her to an appeal hearing to discuss the matter, confirming the right to be accompanied. At the appeal hearing, the decisions taken during the investigation will be considered against the basis for the appeal. The appeal officer will notify the whistleblower in writing of the outcome with reasons, normally within ten days of the appeal hearing. This decision will be final and there will be no further right of appeal.

Whistleblowing hotline phone numbers

Confidentiality

The investigative team will always endeavour to keep the identity of the whistle-blower confidential and ensure that it remains so after the investigation is concluded unless disclosure is required by law or the regulators.