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Code of Business Conduct and Ethics

Message from CEO David Craig

Welcome to the Refinitiv Code of Business Conduct and Ethics.

Refinitiv is a new company with a 167-year history of trust and integrity that has supported the growth and evolution of today’s $5 trillion financial industry. Continuing that legacy starts with each of us - Refinitiv employees - and the Code is here to help.

All of us are required to be familiar with the Code’s contents and to commit to upholding its standards. But the Code is much more than a check-the-box compliance exercise. It is a personal and professional commitment to hold ourselves up to the highest standards in how we work with each other, our customers and our resources.

The Code helps us work with our Refinitiv colleagues in ways that embrace diversity and are sensitive to the needs and feelings of others. It ensures that our interactions with our customers clearly uphold the law and are in the best interests of those customers and the overall financial community. It challenges us to combat bribery and other financial misconduct wherever we see it. It guides us in safeguarding the resources of our company, our customers, our vendors and the environment in which we live. It commits us to protecting human rights and workers’ rights wherever we do business. It encourages us to collaborate with our colleagues and partners to support our communities and inspire charitable work.

What we do every day is obviously extremely important to our business, but how we do our work is just as important. Please review the Code, so that you understand your commitments and know where to turn for guidance.

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Our values

Our Refinitiv values describe the actions we take everyday, the behaviors we embody, and the ways in which we work and show up both internally and externally. All are in service of our customers, partners and our people, and drive our purpose, mission and strategy.

Be Open. Trust One Another.

  1.  We act with integrity and independence. We do what is best for the company and our customers.
  2.  We are curious. We actively seek diverse ideas and perspectives.
  3.  We support and respect one another. We give and embrace constructive challenge to drive better outcomes.

Be Focused. Take Ownership and Action.

  1.  We take accountability and deliver. We commit to doing what we say.
  2.  We understand how we contribute. We are intentional about how we invest our time and energy.
  3.  We bring different views and ultimately align. We carry forward our decisions together.

Be Bold. Push Boundaries Together.

  1.  We act decisively. We capitalize on opportunities and take responsible risks.
  2.  We get the basics right and raise the bar. We challenge ourselves to learn, improve and innovate.
  3.  We celebrate our accomplishments together. We inspire each other to succeed.

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A global code

With thousands of employees around the world, Refinitiv operates under a wide variety of laws and regulations. At times, we tailor our decisions and actions to specific facts and situations. But wherever we operate, these core principles will not change. This Code provides a practical resource to check policies, guide decisions and help employees and others understand when and how to Seek Help.

This Code helps guide how we engage with our customers, our business partners, our colleagues and the communities where we work and live.

The Code applies to all employees, directors and officers of Refinitiv, as well as to consultants, contractors, temporary employees and agents performing services for us or on our behalf (such as our business partners). In the case of Refinitiv’s non-employee directors, compliance with this Code is subject to provisions of Refinitiv’s organizational documents and any investor agreements with Refinitiv. Any third parties acting for or on behalf of Refinitiv should be made aware of their obligation to comply with the Code.

The Code applies in every country where we do business. If there is ever a conflict between this Code and local laws and/or supplemental policies that apply to our job, we must comply with the most restrictive requirement. If any of us have questions about how the Code might apply, we should Seek Help.

Regulated entities

Regulated entities within Refinitiv may have their own policies and procedures that apply to staff acting on their behalf. These policies always take precedence over Refinitiv policies addressing the same topic. Seek Help for more information.

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Our responsibilities

Accountability for everyone

All Refinitiv employees have an obligation to hold themselves and each other to the policies and high ethical standards described in this Code. This means we each are expected to read and understand the Code, as well as any supplemental materials that might apply to us, and act accordingly. If you are unsure about any part of the Code or if you don’t know what supplemental materials apply to you or how to access them, you must Seek Help. In addition to upholding our values, we are all expected to:

  • Learn about, understand and comply with the laws, rules, regulations and policies that apply to our specific positions
  • Seek Help if we have questions about the applicability or interpretation of any law, rule, regulation or policy
  • Speak up if we see or suspect unethical behavior or a violation – whether of laws, policies or this Code
  • Complete mandatory compliance training
  • Respect local customs of countries where we do business, as long as doing so does not violate laws or this Code
  • Acknowledge that we have received and read this Code and understand our obligations to comply with it

Disciplinary action, up to and including termination and/or legal proceedings, may result from any failure to comply with laws, rules or regulations that apply to each of us; our Code; or any other Refinitiv policy or requirement.

Responsibilities of leaders

Leaders – including managers and supervisors – at Refinitiv are expected to hold themselves to the same high standards that they demand of their teams. Leaders play an essential role in building a culture of transparency, open communication and trust that extends from colleagues to customers to business partners. To help achieve this, leaders should:

  • Live our values every day and lead by example
  • Listen and take action when team members raise concerns – whether big or small
  • Be knowledgeable about the laws, rules, regulations and policies that apply to their teams
  • Personally handle or escalate compliance issues appropriately
  • Highlight and recognize decisions that honor our values and long-term success over short-term gain
  • Demonstrate accountability and a willingness to listen to all points of view
  • Make time to discuss the importance of ethics and compliance regularly with their teams
  • Encourage colleagues and others to contact their manager or a company lawyer for help when issues or questions arise and to be timely and candid in reporting any unethical or illegal conduct or compliance issues

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Making ethical decisions

Even those of us who are very familiar with our values, this Code and our policies may find ourselves in situations where we are unsure of what course to take. In such cases, we can Seek Help. Before moving forward, ask these questions:

Diagram for questions on business conduct and ethics

Seek help

We all have an obligation to speak up to report unethical or illegal conduct or if we reasonably believe that a violation of this Code has occurred. Our willingness to seek help and to accurately and truthfully describe the situation in a timely manner is of the utmost importance. Refinitiv values open communication.

You are encouraged to ask questions and seek help whenever you have a concern. Speak up and seek guidance even if you are not sure something problematic has occurred. You have several options for doing so. Your immediate resources whom you are encouraged to contact first are your manager, the People function (Human Resources), or a company lawyer who supports your business or function (referred to as a “company lawyer” throughout this Code).

Reports of suspected fraudulent activities by current or former employees, directors, officers, contractors or third parties should be reported directly to Internal Audit or immediately routed to Internal Audit if the initial report comes through one of the reporting channels noted above. In addition, attempts to inappropriately influence external auditors should be reported or routed to Internal Audit.

There may be cases where the Code specifies approval is needed before taking a certain action. In such cases, if the approver is not stated, you should talk to a company lawyer first.

Protecting confidentiality and prohibiting retaliation

Identifying yourself when making a report usually allows for a more thorough and effective investigation, and therefore we encourage you to identify yourself whenever possible. Confidentiality of reports will be maintained to the fullest extent possible, and information will be shared only on a need-to know basis.

If you are not comfortable contacting your manager about an issue (for example, if the issue concerns your manager), you may reach out to your People function representative or a company lawyer. You may also contact the Business Conduct and Ethics Hotline, which is a reporting tool managed by a respected third-party hotline provider. 

You are protected against retaliation. Refinitiv prohibits retaliation against anyone who makes an inquiry or reports through the Hotline. You will be advised if you work in a country subject to special reporting procedures.an allegation in good faith or who truthfully participates in an investigation. “Good faith” does not mean you have to be right or have incontrovertible proof – it just means you have to have a reasonable belief in the truth and accuracy of what you’re reporting. If you believe someone is retaliating or plans to retaliate against you or someone else, Seek Help.

Though we encourage you to identify yourself to aid the investigation process, you do have the option to report a matter anonymously to the Hotline if that is the only way in which you feel comfortable reporting. Refinitiv would much rather you make an anonymous report than not report at all. Please note that some local laws, rules or regulations may limit or prohibit anonymous reports or reports concerning particular subjects

Investigations process

Investigations will be conducted promptly and thoroughly, and confidentiality will be maintained to the fullest extent possible.

All reasonable efforts will be made to determine the relevant facts behind any reported violation and bring the investigation to a timely conclusion. Any employee who becomes involved in an investigation is obligated to cooperate. Failing to cooperate with an investigation may result in disciplinary action, up to and including termination and/or legal proceedings. Failure to cooperate includes:

  • Knowingly providing false or misleading information
  • Refusing to be available for a meeting or discussion during an investigation
  • Knowingly withholding, destroying or deleting pertinent information

Information regarding complaints and reports will be maintained by the People function, Legal and Compliance or Internal Audit teams, as appropriate, including records of any such reports or complaints, tracking their receipt, investigation and resolution.

Refinitiv will take prompt and appropriate action if it determines that a violation of the Code occurs, which may result in disciplinary action, up to and including termination of employment.

Waivers

In the unusual circumstance that you believe you may need a waiver of particular provisions of the Code, you should contact the General Counsel of Refinitiv.

Seek Help: Helpful contact information

Business Conduct and Ethics Hotline

+1 855 581 5184

Refinitiv Legal and Compliance Team

The Refinitiv Legal and Compliance Team homepage on the company’s intranet is your gateway to additional legal and compliance policies, resources and key contacts for various topics covered by this Code. 

Email: compliance@refinitiv.com

Internal Audit

Email: internal.audit@refinitiv.com

Privacy Office

Email: privacy.enquiries@refinitiv.com

Internal inquiries: privacy.issues@refinitiv.com

Global Security – Security Operations Center

International number: +44 (0) 20 7542 5660

Email: gsoc@refinitiv.com

Our people

Providing equal opportunities

We are committed to complying with applicable laws, rules and regulations governing nondiscrimination wherever we do business and providing equal employment opportunities with regard to hiring, compensation, promotion, classification, training, apprenticeship, referral for employment and other terms of employment for all persons without regard to the classifications listed in the Antidiscrimination section.

Fostering a respectful workplace

When discrimination, harassment and bullying are allowed to take root in a workplace, they inhibit communication and damage productivity. We cannot properly share ideas and concerns or work together as a team if any member of our team or partnership feels targeted or unsafe. Additionally, these types of acts may leave us vulnerable (as individuals and as a company) to fines, lawsuits and civil or even criminal proceedings.

By putting a premium on fairness, equality, respect and dignity and not allowing discrimination, harassment and bullying, everyone who enters our workplaces should feel protected and empowered to achieve their full potential.

Anti-discrimination

We do not tolerate discrimination. This means we do not allow unequal treatment on the basis of:

  • Race, color or ethnicity
  • Religion
  • Sex or gender
  • Pregnancy
  • Gender identity or expression
  • Sexual orientation
  • Age
  • Marital status
  • National origin
  • Citizenship status
  • Disability
  • Veteran status
  • Any other classification protected by applicable laws or regulations

Harassment and bullying

We also do not tolerate harassment of any kind at our workplaces, including sexual harassment and bullying. We support dignity in the workplace without regard for whether the person engaging in the conduct or the recipient is an employee, manager, business partner, customer, consultant or visitor.

This means we do not allow conduct that:

  • Has the purpose or effect of creating an intimidating, hostile or offensive work environment or otherwise adversely affects an individual’s employment opportunities
  • Explicitly or implicitly links submission to sexual conduct as a term or condition of employment or promotion decisions

Refinitiv will not tolerate discrimination, harassment or bullying in the workplace. Even if local law does not explicitly prohibit these acts, we hold our employees to a higher standard.

Examples of harassment and bullying

Examples of harassment can include:

  • Slurs, disparaging remarks, off-color jokes, insults, vulgar language, epithets and teasing
  • Displaying offensive posters, symbols, cartoons, drawings, computer images or emails

Examples of sexual harassment can include:

  • Unwelcome propositions, demands or advances of a sexual nature
  • Unwelcome physical contact such as hugging, kissing, grabbing, pinching, patting or brushing up against someone
  • Unwelcome and inappropriate remarks about someone’s body or appearance, sexual gestures or comments, or unwanted verbal or physical interactions of a sexual nature
  • Unwelcome vulgar or obscene gestures, language or comments

Examples of bullying can include:

  • Humiliation, threats or abuse
  • Aggressive behavior
  • Teasing or practical jokes
  • Pressuring someone to do something against his or her will

Reasonable accommodations

We also make reasonable accommodations for qualified individuals with disabilities and for colleagues with sincerely held religious beliefs. For these purposes, a “reasonable accommodation” is a modification or adjustment to job duties or the work environment that enables an employee to perform the essential functions of the job while not putting undue hardship on Refinitiv. Contact your manager or your People function representative if you believe you require an accommodation to perform the essential functions of your position, need a religious accommodation or have questions.

Bringing the Code to life

  • A: You shouldn’t assume that a disability will limit someone’s ability to perform his or her job. However, if you reasonably believe the disability would legitimately affect the individual’s ability to perform the essential functions of the job, you should contact your People function representative to discuss whether reasonable accommodations could be made.

Speaking up for safe workplaces

If you witness inappropriate conduct in the workplace, speak up and do not look the other way, regardless of whether the individual who engaged in the behavior is a manager, business partner, customer, consultant or visitor. If you are comfortable addressing the behavior directly with the individual who engaged in it, you may. However, you are not required to do so. In any event, you should contact your People function representative or Seek Help (and contact our security team/security operations center (SOC) if you believe the particular situation may require their involvement).

Refinitiv will take prompt and appropriate action if it determines that a violation of this policy occurs, which may result in disciplinary action, up to and including termination of employment.

Leaders

We hold leaders (which include managers and supervisors) to an even higher standard and require them to raise or address any inappropriate conduct they learn of in the workplace, even if they are aware of it indirectly or have not received a specific complaint about the behavior.

Bringing the Code to life

  • A: Even if an apparent target of the behavior does not make a complaint, he or she still may be uncomfortable. You should talk to your People function representative. While Refinitiv is always mindful of customer relationships, we never want our employees to be in an uncomfortable work environment. The company will take appropriate steps to address the behavior.

Diversity and inclusion

At Refinitiv we are committed to creating an inclusive business that:

  • Delivers market-leading solutions to our clients wherever in the world they are, and
  • Attracts the best talent from all corners of the globe 

The Refinitiv Diversity & Inclusion strategy is focused on creating whole-business behavioral change aimed at understanding the impact of our decision making, not only on our good intent. We will pay attention to the impact our preferences and biases have on the decisions we make, and what we can do as leaders in our day-to-day behaviors to interrupt dynamics where we see unequal outcomes for different groups of our people. Included in this behavioral change approach will be a focus on how we build differentiated relationships with all our customers wherever in the world they are located.

Our Diversity & Inclusion goals are focused on:

  • What we look like, that is, creating diversity at all levels, as well as,
  • What we feel like, that is, inclusion of all our people

And to deliver our goals, we will focus on three key strategic priorities aligned to our values to be Bold, Focused and Open:

  • We will build the skills of all our leaders, at every level, to lead inclusively
  • We will embed key principles of inclusion in everything that we do, and
  • We will build our brand as market leader and employer of choice

We will track our progress and hold our leaders accountable for our D&I goals. We will partner with our Business Resource Groups to help create a culture that is inclusive for all our employees.

Keeping workplaces safe, secure and healthy

A safe and healthy workplace not only protects us from harm but also builds trust, prevents costly accidents and enhances the company’s reputation as a responsible corporate citizen.

Health and safety

To prevent dangerous conditions in our workplaces and protect our colleagues, business partners, customers and visitors, we:

  • Comply with both the letter and the spirit of all applicable occupational and environmental health and safety laws
  • Understand and follow all safety policies and procedures
  • Report incidents, injuries and illness at work to ensure measures are put in place to minimize hazards
  • Take any mandatory or on-the-job training that improves our ability to safely perform job responsibilities and use company equipment
  • Know how to safely and legally handle and dispose of hazardous materials
  • Require that all contractors, vendors and colleagues abide by safety regulations
  • Identify potential safety violations and report them to ensure Refinitiv can take action to remedy these situations
  • Maintain accurate and up-to-date safety records

Security

We do our part to ensure the security of our workplaces by:

  • Following all required security procedures and access controls in our facilities
  • Speaking up when we see something that seems suspicious or threatening
  • Participating in safety-related drills and preparations

Threats, workplace violence and weapons

We do not tolerate acts or threats of violence, intimidation or hostility in our workplace, whether directed at colleagues, business partners, customers or visitors. We also do not allow:

  • Weapons or hazardous devices at any facilities leased or owned by Refinitiv, at Refinitiv-sponsored functions or on company business unless legally allowed and cleared with prior written approval from the Global/Regional Head of Security
  • Behavior that injures or is likely to injure another person
  • The making or sending of harassing or threatening statements (regardless of how these messages are delivered)
  • Behavior that damages or is likely to damage property
  • Stalking or surveillance of another person
  • Committing or threatening to commit violent acts

This policy may extend to activities outside of work if they adversely affect the company’s reputation or interests or the safety of our employees. If you feel someone is being threatened or subjected to violence, are concerned that someone may cause harm to him or herself or others, or see something suspicious, move out of harm’s way, call the local police, follow the instructions of emergency authorities and call the security operations center (SOC). If there is a life-threatening emergency, contact the local police or emergency services first, then the SOC. Seek Help.

Bringing the Code to life

  • A: If you have a domestic or personal issue that may apply to or affect safety in the workplace (e.g., an order of protection or a restraining order), you should report it to your People function representative and the SOC. That’s the best way to help ensure not only your safety but also that of your colleagues.

Drugs and alcohol

Drugs and alcohol can be a danger to everyone in the workplace. Refinitiv does not allow the possession, use, purchase, sale, attempted sale, distribution or manufacturing of illegal drugs in its workplaces. We also do not allow the abuse or misuse of alcohol and prescription drugs either in the workplace or when conducting company business.

This means we:

  • Do not report for work while impaired by drugs or alcohol
  • Do not possess or consume alcohol on Refinitiv premises without specific prior authorization from Refinitiv
  • Use good judgment when consuming alcohol at an event sponsored by Refinitiv, a customer or an organization that we’re supporting

Employees in violation of this policy will be subject to disciplinary action, up to and including termination. Violations also could lead to arrest and prosecution by law enforcement if such violations involve illicit drugs or other illegal activities. Where permissible by law, Refinitiv reserves the right to take appropriate steps to investigate compliance with this policy, including but not limited to drug and/or alcohol testing by qualified medical professionals and searches in the workplace.

If you believe someone in the workplace has violated this policy, contact your manager or People function representative.

Bringing the Code to life

  • A: Refinitiv offers a number of employee programs that may provide assistance. Please ask your People function representative about available services in your location.

Doing business with integrity

The importance of integrity

Refinitiv celebrates both our pride in our legacy and also the defining role we will continue to play as an integral and innovative part of the financial markets community. We believe in fair and efficient markets.

A rich part of our history is the long-standing commitment to integrity and specifically, the integrity, independence and freedom from bias (the “Integrity Trust Principle”) which is a key foundation to Reuters News business. We use our best efforts to ensure that the Integrity Trust Principle with respect to Thomson Reuters shall at all times be fully preserved.

Bringing the Code to life

  • A: Refinitiv fully respects the integrity, independence and freedom from bias of the Reuters News business. As such, it would be inappropriate to try to exert any influence over Reuters content or otherwise interfere with Reuters editorial integrity. The same principles would be true of anything Reuters publishes about Refinitiv or any of its investors.

Recognizing and avoiding conflicts of interest

A conflict of interest may arise whenever our personal interests appear to interfere with the best interests of the company or appear to make it difficult for us to do our jobs objectively and effectively. Undisclosed or unrecognized conflicts of interest can do financial and reputational harm to our company. By recognizing, avoiding and disclosing potential conflicts, we protect our reputation and our ability to do business effectively.

We avoid real and perceived conflicts of interest at all times. This means we:

  • Put the company’s interest ahead of any personal interest or gain in business transactions
  • Take responsibility for identifying and avoiding situations that could appear to compromise our judgment, such as:

– Close personal relationships with subordinates

– Personal financial interests in third parties

– Competition with the company

– Use of company resources for personal gain

– Gifts and benefits given to or received from third parties

  • Disclose any potential conflict in writing to the appropriate manager or to the People function, who will work to resolve the conflict, or pre-clear the conflict in writing with a company lawyer or by contacting the Business Conduct and Ethics Hotline

The following section contains additional guidance on some of the more common areas where conflicts arise.

Close personal relationships

We avoid putting ourselves in positions where our close personal relationships could appear to improperly influence our actions and decisions at work. This means we:

  • Avoid directly or indirectly supervising colleagues with whom we have a close personal relationship
  • Avoid taking part in decisions about the hiring, promotion, performance evaluation, compensation, benefits and opportunities of colleagues with whom we have a close personal relationship

Bringing the Code to life

  • A: For the purposes of the Code, a “close personal relationship” refers to a relationship with a spouse, domestic partner, romantic partner, close personal friend, parent, grandparent, sibling, child or grandchild. It can also refer to any member of your household or other person with whom your relationship outside of work is so close that it may appear to influence your judgment at work.

  • A: It is inappropriate for a manager to date one of his or her direct reports or another person who is subordinate in his or her group. Even if the relationship appears to be consensual, having one individual in a position of influence over the other could result in a conflict of interest. The individuals involved should address the issue with their People function representative and seek alternative reporting lines before continuing to pursue a relationship.

Personal interests in third parties

We do not participate in business transactions with a third party (such as a vendor, supplier or other business partner) that is owned by or employs a person with whom we have a close personal relationship unless this has been pre-cleared in writing by the appropriate manager, the People function, a company lawyer or through the Business Conduct and Ethics Hotline.

For example, it may be a conflict of interest if you or someone with whom you have a close personal relationship owns more than 1% of a supplier, a consultant, another business partner or a competitor.

Corporate opportunities and outside employment

We do not take for ourselves any opportunity that was created or discovered through our position at the company and we do not take on outside employment if it could compromise our ability to perform our job duties at Refinitiv to the best of our ability. This means we:

  • Use company property, company information and our position only to advance the company’s interests and not for personal gain or to perform work for second jobs, personal businesses, board memberships or civic positions
  • Recognize when a product, service, invention or business connection might be of interest to Refinitiv, and communicate it to the company
  • Do not compete with Refinitiv or work for our competitors
  • Do not accept outside employment if it would improperly affect our work at Refinitiv or cause us to disclose the company’s confidential or proprietary information
  • Obtain prior written approval from the People function or a company lawyer or through the Business Conduct and Ethics Hotline before taking on the role of director or officer for another company (other than private family companies that have no relation to Refinitiv or our businesses)

Organizational conflicts of interest

We watch for scenarios in which the company’s business or activities could be seen to give us an unfair competitive advantage in seeking work with the government or to affect our ability to perform work for the government objectively. This means that before and during any business with the government we:

  • Know and follow all requirements of the Federal Acquisition Regulation (FAR) in the United States and similar regulations in all the other countries where we do business
  • Work in good faith to address and resolve any claims of organizational conflicts of interest

Gifts and entertainment

We avoid giving or receiving gifts, entertainment or other personal benefits if doing so could appear to improperly influence our own or a third party’s professional judgment and objectivity, and we recognize that improper gifts can also violate anti-bribery laws. This means we consult the Bribery and Corrupt Payments and Gifts and Personal Benefits guidance outlined in this Code before giving to or receiving from a third party any gift or other personal benefit.

Dealing fairly and honestly

Anticompetitive practices harm customers and distort markets. These practices severely damage partner relationships by eroding their foundational trust. Competition and antitrust laws prohibit making agreements with competitors, customers, suppliers or other third parties that limit competition. Even though competition laws are complex and dynamic, we are expected to know the law in this area. If we fail to act lawfully, we can hurt the company’s reputation and leave Refinitiv and ourselves open to the potential of substantial fines and even criminal prosecution.

Fair dealing

We treat our competitors, customers, suppliers and security holders with fairness and respect. This means we:

  • Comply with the letter and spirit of applicable laws
  • Recommend only products, services and solutions that we believe are the proper fit for each customer’s needs
  • Remain transparent and forthright in all contracting
  • Award contracts based on merit and clearly defined benchmarks
  • Provide accurate and timely documentation
  • Deliver on what we promise
  • Are honest and accurate in advertising and marketing claims, avoiding exaggeration, misrepresentation and ambiguity
  • Take special care when making comparative claims and do not disparage or unfairly criticize a competitor’s products or services
  • Do not gather competitive intelligence in unlawful or unethical ways (see Competitive Intelligence)

Competition and antitrust

We abide by all competition and antitrust laws that apply to us, avoiding situations that could put us at risk of even appearing to violate these laws. This means we do not engage in discussions with competitors to:

  • Fix prices
  • Divide sales opportunities or territories
  • Agree not to solicit each other’s customers
  • Boycott or refuse to sell a particular product to a certain customer, supplier or vendor
  • Rig bids
  • Share confidential information about pricing, profits, costs, sale terms, credit terms, customers, discounts, promotions, marketing or strategic plans, mergers and acquisitions or any other sensitive information

Because competition and antitrust laws are so complex and there are some exceptions and variations from country to country, you should consult a company lawyer before taking any action that might be considered anticompetitive.

Seek advice before you act

We often negotiate agreements with customers, suppliers and distributors. To avoid antitrust issues, seek advice from a company lawyer before you:

  • Use customer pricing (such as deep discounts) or licensing terms to keep out or unduly hinder competitors
  • Sell anything below cost
  • Tie the sale of any product, service or discount to another product
  • Enter an exclusive dealing or lock-in agreement
  • Treat customers, suppliers or distributors inequitably for the same products
  • Restrict a distributor in terms of whom they can sell to and at what price or agree to a similar restriction on Refinitiv where we resell third-party products or services
  • Impose any noncompete or other similar restriction, or accept a similar restriction on Refinitiv

 

  • A: If you feel uncomfortable about any conversation with a competitor, it’s best to exit that conversation as quickly and as gracefully as possible. Remember, even if the employee didn’t reveal pricing or other sensitive information, she may have said something that could appear to violate antitrust laws to someone listening. Contact a company lawyer if you need more clarification or want to confirm that nothing happened that could be or could appear to be a violation.

Working in our global markets

Bribery, corruption, money laundering, sanctions violations and other financial misconduct destabilize governments and economies and undermine public trust. As a global company that provides trusted compliance and risk solutions, it is critical to our reputation and our financial success that we combat bribery and other financial misconduct wherever we see it. The law imposes significant penalties for such misconduct that can include fines and even imprisonment for involved individuals. We may even be held responsible for unintentional violations and violations by third parties acting on our behalf.

Bribery and corrupt payments

We never offer, give, authorize or accept a bribe. A bribe is any unofficial payment, gift or personal benefit that is given to a third party to try to secure an improper business advantage or to win or keep business. In addition, we never offer, give or authorize an unofficial payment to a government or public official, even if the payment is to speed up a routine governmental action (such as visa processing or customs clearance). Payments to speed up routine actions are known as “facilitation payments” and are prohibited at Refinitiv, even if they are allowed under local law. These requirements apply whether the other party is in the public sector or in the private sector.

This means we:

  • Do not offer, give, authorize or accept any gift or personal benefit to or from a third party, unless it complies with the guidance in the Gifts and Personal Benefits section
  • Where a government or public official is involved, never offer, give, authorize or accept any unofficial payment, or any gift or personal benefit of any value unless it is pre-cleared in writing by a company lawyer or is permitted under applicable internal anti-bribery and gifts policies
  • Record all payments and receipts honestly, accurately and completely, in compliance with applicable accounting standards, laws and our internal controls. Understand that an effort to conceal an improper payment could be a separate violation of the law that results in severe penalties
  • Understand that we could be held responsible for violationsby our business partners, and so we must:

– Carry out a level of due diligence appropriate to the risk before we engage suppliers, consultants and other business partners

– Communicate our expectations with respect to anti-bribery and anticorruption to business partners at the outset of our business relationship and as appropriate thereafter

– Mitigate or terminate business relationships as appropriate if we learn that a business partner may have violated our standards

– Report it to a company lawyer or to the Business Conduct and Ethics Hotline if we become aware of any attempted or actual bribe or improper payment or gift

If you have any questions about bribery or corruption, Seek Help.

Who is a government or public official?

Because of the risk of bribery and corruption, many countries severely restrict or prohibit all gifts and personal benefits where a government or public official is involved. Government and public officials can include not only elected or appointed officials, but also people employed by or acting on behalf of a government or a governmentowned or government-controlled entity or political party. Examples you may encounter include:

  • Customs and tax officials and inspectors
  • Military personnel and support teams
  • Law enforcement officers
  • Employees at government facilities
  • Public utilities and their employees
  • State-owned or controlled entities (such as state oil companies or public universities) and subsidiaries/affiliates and employees of those entities

If you are unsure whether an entity or individual is a government or public official, consult a company lawyer or the Business Conduct and Ethics Hotline.

The many forms of bribery

The giving or receiving of unofficial cash payments and equivalents (such as shares) is always prohibited at Refinitiv, and can be a clear sign of bribery. Other potential indications of bribery include:

  • Unacceptable gifts, entertainment or hospitality (see the Gifts and Personal Benefits section)
  • Excessive rebates, discounts or commissions
  • Inappropriate free or discounted use of Refinitiv services or facilities
  • Favors (such as job or internship opportunities or the hiring of a relative)
  • Payments or requests for payments that are vaguely described, are unsupported by receipts/orders or that lack a clear business justification
  • A: Yes. Refinitiv could be held responsible for the actions of the agents we hire. You must tell the agent from the start not to give gifts to a government or public official. More importantly, before engaging such an agent, it is important to conduct due diligence on the agent and get a contractual assurance that no improper payments will be made on behalf of Refinitiv.

Gifts and personal benefits

We stop and think before we offer, give, authorize or accept any gift or personal benefit involving a prospective or current customer, supplier or other business partner in the public or private sector. We recognize that improper gifts and personal benefits can create potential conflicts of interest and may even be a crime under anti-bribery and anticorruption laws depending on the circumstances.

This means we:

• Never offer, give, authorize or accept cash gifts to or from any third party

• Know that if a government or public official is involved, we may not offer, give, authorize or accept any gift or personal benefit of any value without prior approval from a company lawyer or permission under applicable internal anti-bribery and gifts policies

• Ensure all gifts and personal benefits offered or given to or received from any third party acting on our behalf are infrequent, are not excessive and comply with any applicable gift policies. Know and comply with the relevant gift policies that govern our business entity and that govern the third parties that might receive a gift from us. Understand that some business’ policies are stricter than others

• Refuse to give or accept anything of value to or from a third party if it could appear intended to secure an improper business advantage or if you would be uncomfortable disclosing it publicly. Refer to the Bribery and Corrupt Payments section for additional guidance

• Where a government or public official is involved, never offer, give, authorize or accept any unofficial payment, or any gift or personal benefit of any value unless it is pre-cleared in writing by a company lawyer or is permitted under applicable internal anti-bribery and gifts policies

What gifts and personal benefits are covered?

This guidance covers all unofficial payments, gifts and personal benefits, including:

  • Meals
  • Transportation/travel/accommodations
  • Entertainment/tickets or other gifts
  • Use of vehicles or lodging or other hospitality
  • Donations made to a favored charity/organization
  • Services
  • Equipment
  • Prizes
  • Products
  • Memberships
  • Discounts, rebates or loans
  • Speaker fees
  • Job opportunities (including unpaid internships)

Unacceptable gifts and entertainment generally include:

  • Cash or cash equivalents
  • Events, trips or even meals that have no business purpose or that are excessive in relation to the business purpose
  • Anything of value given to or received from a government or public official that was not pre-cleared by a company lawyer or permitted under applicable internal anti-bribery and gifts policies
  • Any gift or personal benefit that is inconsistent with applicable policies or could appear to make you or a third party feel pressure to take a particular business action

Sanctions, embargoes and export controls

Sanctions and export control laws can be extremely complex and constantly changing and we are expected to know them and abide by them at all times. Even unintentional violations could result in penalties, but the sooner we report and resolve the issue, the better. This means we:

  • Know the current list of sanctioned or embargoed countries/territories (for guidance, refer to the Trade Controls Group on the Company’s intranet which you can access through the Legal and Compliance Team homepage)
  • Unless consistent with applicable law and preapproved by a company lawyer in consultation with the Trade Controls Team, do not do any business with:

– Sanctioned countries/territories or any individuals or entities resident in, organized under the laws of or operating from any of these countries/territories

– Any sanctioned organization or individual, or entity owned by a sanctioned organization or individual

  • Conduct due diligence on partners and customers as appropriate, and appropriately screen partners and customers to ensure that they are not subject to sanctions or embargoes
  • Seek guidance on proper export procedures before deciding to export any products or services
  • Remain alert for sanctions red flags, such as payments made through multiple accounts, requests that payments be made at odd times or in odd amounts, and requests for refunds in forms that are different from the payment originally used
  • Immediately alert the Trade Controls Group directly or through the Business Conduct and Ethics Hotline if we have reason to believe anyone at the company or any third party may be intentionally or inadvertently doing business with a sanctioned country/territory, entity or individual

Bringing the Code to life

  • A: Most likely not. Export controls cover software as well as hardware and equipment. It also appears your customer may be representing individuals or entities from that sanctioned country. Seek Help before taking any action.

Anti-money laundering

Money laundering is the process by which funds generated through criminal activity (such as terrorism, drug dealing or fraud) are processed through commercial transactions in order to hide the source of the proceeds, avoid reporting requirements or evade taxes. We follow all anti-money laundering and antiterrorist financing laws that are applicable to us and do not condone or facilitate money laundering. This means we:

  • Emphasize the importance of knowing and understanding whom we deal with (“know your customer”), remain alert for possible instances of money laundering and immediately notify a company lawyer of any suspicious activity (without informing the third party in question). Suspicious activity by clients or prospects may include:

– Reluctance to provide basic information or documentation or providing false information or documentation

– Using shell companies (companies without a business purpose) or complex or unusual structures, particularly within multiple high-risk jurisdictions

– Requesting Refinitiv to provide them secrecy

  • Recognize that our regulated entities have enhanced obligations, and those of us working in or on behalf of those businesses must make sure we understand and comply with these obligations

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Our assets and information

Respecting our intellectual property and that of others

Intellectual property is the lifeblood of our business. From the systems and databases we create to empower our customers with information, to the processes we use in our workplaces, intellectual property is vital to our company’s identity. Knowing how important it is to us and to others, we have a special obligation to protect the intellectual property that we create and to defend all intellectual property against improper use. By doing so, we put our company, our colleagues and ourselves in the best position to innovate and win in the marketplace.

We recognize when intellectual property should belong to Refinitiv and take all necessary action to protect it. This means we:

  • Agree, to the extent permitted by law, that Refinitiv owns all intellectual property (and related rights) that we create during the course of our employment, whether we create them in the office, at home or elsewhere, if they are related to company business or created with company resources
  • Waive or assign to Refinitiv all moral rights we may have under applicable law to intellectual property that we create as employees
  • Promptly disclose any methods, systems, processes, designs, ideas or other patentable works we create as employees so the company can take steps to protect them
  • Report any unauthorized use of company copyrights, patents, trademarks or other intellectual property of which we become aware to a company lawyer
  • Put copyright notices on all Refinitiv materials, information, services or other products intended for public distribution

What are moral rights?

Moral rights are rights relating to intellectual property, and they include the right to be recognized as the creator and the right to the integrity of any works created. The waiver or assignment in this Code is designed to ensure that Refinitiv can take any action concerning works created by you during your employment with Refinitiv.

Intellectual property of others

We respect the intellectual property of third parties, including competitors, and do not use it in any way that would violate the law or our values. This means we:

  • When necessary, get written permission to use or copy a third party’s copyrights, patents, trademarks or other intellectual property; obtain licenses; or, if the circumstances require it, purchase the intellectual property outright
  • Ensure licensing agreements permit copying or distribution where necessary and do not impair the company’s rights before we copy or distribute third-party software
  • Ensure intellectual property belongs to Refinitiv when it is created for us by third parties or contractors, where allowable by law
  • Ensure proper usage of all names and marks that are owned by Thomson Reuters, including “Thomson,” “Reuters” and the Kinesis logo, which are used by Refinitiv under license from Thomson Reuters and its affiliated companies
  • Check with a company lawyer if we are in doubt about any intellectual property question

What is intellectual property?

Examples of intellectual property include:

  • The Refinitiv name and brand names that we use
  • Logo
  • Copyrights
  • Patents
  • Service marks
  • Trade secrets
  • Innovations
  • Software
  • Processes
  • Designs
  • Ideas
  • Images
  • Data

Bringing the Code to life

  • A: Even if it appears to be accessible by the public, some information still may be subject to intellectual property protection. Contact a company lawyer for guidance. 

  • A: This idea is the intellectual property of Refinitiv, as it likely was the result of knowledge, resources and opportunities obtained through your employment with the company. If you think it’s a viable idea, you should share it with your manager. 

Competitive intelligence

We strive to better understand our competitors through extensive research and study. We obtain intelligence about our competitors only through lawful and ethical channels. In addition to following our rules on respecting the intellectual property rights of others, this means we:

  • Understand and follow all applicable laws and regulations before engaging in competitive intelligence gathering
  • Do not distribute data or other sensitive information about a competitor if it was received or accessed in circumstances that may breach any of our Competitive Intelligence Guidelines
  • Never misrepresent our personal or company identity to gain access to a competitor’s product or service • Do not breach contract terms or encourage third parties to do so in order to help Refinitiv obtain competitive intelligence

Before seeking out or using any competitive intelligence, make sure you understand our Competitive Intelligence Guidelines. Contact a company lawyer if you have any questions about how to apply these guidelines.

Bringing the Code to life

  • A: You must not keep or share documents – in any format – related to the competitor’s business that you possessed as an employee of that competitor. Even in the case of information you simply remember, if the information is confidential, you have a personal legal obligation to your former employer to protect it from disclosure, just as you would with Refinitiv confidential information if you left the company for a competitor. Sharing such information with Refinitiv could also put you and us at risk legally. For the information you recall that you believe is not confidential, it is best to contact a company lawyer before revealing it to anyone.

Protecting confidential information and data privacy

Our competitive edge depends on the security, privacy and integrity of the information we hold – whether that information belongs to us or to others. How we handle confidential and personal information sets us apart from our competition, and if we get it wrong, our customers, colleagues and company all could suffer. Improper handling could disadvantage us in the marketplace, harm consumers, leave us vulnerable to civil and criminal penalties, impede our innovation, hinder our performance and ultimately damage our business relationships.

Confidential information

As part of our job or position, we may learn or have access to nonpublic or inside information relating to Refinitiv businesses, operations, business partners or customers. If this information is not in the public domain, we should treat it as confidential. We should not share confidential information with anyone, including individuals within Refinitiv, unless there is a legitimate need to know and we are authorized to do so. Confidential information includes some of our most valuable assets, such as the following examples:

  • Trade secrets
  • Pricing policies and information
  • Business or strategic operating plans and outlooks, including merger, acquisition or divestiture plans
  • Nonpublic financial information about Refinitiv or our employees, customers or business partners
  • Nonpublic information about another organization or person that we learn about in the course of our job or as a result of our position
  • New product, brand or marketing studies, developments, plans or forecasts
  • Customer data, including contact details, specifications, preferences and subscription lists
  • Contracts and agreements, including terms such as expiration dates, any exclusivity provisions and financial conditions
  • Legal information, including data or information covered by legal privilege
  • Data that Refinitiv has a legal or contractual obligation to protect (e.g., credit card data, healthcare records or personally identifiable information)
  • Information about our IT systems and infrastructure

Important information security practices?

There are many ways to protect data effectively.

For example:

  • Put sensitive documents in locked files or drawers
  • Use shredders or secure shred bins when discarding confidential information
  • Use password protection on computers and other devices and for sensitive documents, spreadsheets and presentations
  • Use encryption when storing and transmitting any files or documents containing confidential information
  • Take care when accessing information in areas where members of the public or other unauthorized persons, including other colleagues, might see it
  • Securely back up devices on a regular basis
  • Use caution when connecting to public Wi-Fi and utilize a virtual private network (VPN)
  • Report damaged or lost laptops and other devices, security incidents and personal data breaches immediately to the Global Service Desk

Data protection and privacy

Many countries have data protection and privacy laws and regulations that govern the collection, use, retention and transfer of certain information about individuals. This is a rapidly changing area of law, and each of us should consult the resources referenced in this section of the Code or contact a company lawyer with any questions regarding appropriate collection, use, retention or transfer of information about individuals, including our customers, business partners, marketing contacts, employees, contractors, consultants and other individuals.

Using and protecting our confidential information and other data

We have established information security and privacy policies and practices to protect data, whether it belongs to us, our customers or our business partners. This means we:

  • Read, understand and follow the Information Security Handbook and policies when it comes to handling data
  • Understand how data is classified at Refinitiv and therefore how it should be handled
  • Store information using only company-approved storage devices
  • Collect, use, retain and transfer data and information about individuals in accordance with applicable data protection and privacy laws and regulations
  • Obtain proper authorization before sharing any confidential or personal information, which might include obtaining written authorization and signing a nondisclosure agreement
  • Respond to requests for information about our data-handling practices by following company processes to ensure we do so safely and properly
  • Ensure that we are familiar with and comply with the company’s privacy policies
  • Protect Refinitiv confidential information even after we leave the company

 

Bringing the Code to life

  • A: Marketing opt-out requests can be made at any time and must be honored within specific, legally required time frames. Contact the marketing team immediately, and inform them that the customer wishes to opt out of marketing.

  • A: You should not refuse the request, as many privacy laws give individuals the right to access their personal data. Instead, you should refer the request immediately to a company lawyer or privacy.issues@refinitiv.com. You should do this as soon as you receive the request, as there may be legally enforceable time limits within which Refinitiv must respond.

Reporting data breaches

Any time we know or suspect that a breach of data security has occurred, whether accidental or intentional, we must report it immediately to the Global Service Desk. Doing so promptly can mitigate the effects of the breach and help us take the right actions quickly to manage the incident, secure the data and reduce the risk of future breaches.

Insider trading

Some of us have access to material nonpublic information about our investors, our investments, our customers, suppliers or other companies with which Refinitiv either does business or is negotiating a significant transaction or agreement. Misuse of material nonpublic information could result in violations of insider trading laws and carry severe penalties. We are careful to treat this “inside information” lawfully and ethically. This means we:

  • Do not trade in or encourage another person to trade in securities of public companies, including Thomson Reuters or Tradeweb, while in possession of material nonpublic information
  • Do not engage in “tipping” – the disclosure of material nonpublic information about other public companies, including Thomson Reuters or Tradeweb, to other people, such as relatives or friends, who may trade

Insiders

We have designated certain people as “Insiders” because of their position, managerial responsibilities, or access or potential access to material nonpublic information about Refinitiv that may be considered material nonpublic information in relation to Thomson Reuters and Tradeweb. As you may know, Thomson Reuters publicly reported financial results include its share of Refinitiv’s results. Insiders are subject to additional restrictions related to trading in securities of Thomson Reuters and Tradeweb. 

Insider information

Whether information is “material” and “nonpublic” depends on the facts and circumstances. Information is material if it would, if generally available, reasonably be expected to result in a significant change in, or have a significant effect on, the market price or value of any securities. Information also is material if it would have a significant influence on a reasonable investor’s investment decisions. Information is nonpublic if it is not generally known or available to the public through an official company communication, such as a press release, website posting, securities filing or distribution to shareholders, or through widely reported media coverage. Examples of material nonpublicinformation may include: 

  • Earnings results and any future financial forecasts or outlooks that have not been publicly disclosed
  • Significant changes in business operations or strategies
  • Significant potential acquisitions or sales
  • Gains or losses of major suppliers or customers
  • Introductions or launches of new, significant products or services
  • Actual or threatened significant lawsuits or material government or regulatory investigations

Using information and communications systems responsibly

Nearly all of the work Refinitiv does on a daily basis runs in some way through our information and communications systems. When we each take personal responsibility for using these systems properly, it protects the integrity of the data we store and transmit, and it ensures that we all have prompt access to the systems we need to help our company thrive. Likewise, improper use leaves us all vulnerable to hackers, data breaches, shutdowns and miscommunications, as well as legal repercussions.

We use company information and communications systems properly. This means we:

  • Limit personal use of email, the Internet and phones
  • Do not access, download or send material that is offensive, harassing, explicit or otherwise inappropriate for work unless we are authorized to do so as part of our job
  • Avoid careless, exaggerated or inaccurate statements that could be easily misunderstood or used against Refinitiv in legal proceedings
  • Think before we hit Send
  • Do not use personal software on work devices or download or redistribute copyrighted material, such as music and software, unless legally permitted
  • Never use unauthorized peer-to-peer software to share copyrighted material
  • Never share user IDs, passwords, access details, software, services or authentication devices (e.g., Secure ID tokens) that are intended for individual use to gain access to a system
  • Remain cautious when opening email attachments and follow the process of “think before you click”
  • Use collaboration tools like instant messaging on Refinitiv products only with prior authorization
  • Respect company security controls and access information only within our authorized level
  • Use personal devices to store or access company data only with prior approval
  • Report any suspected breaches or incidents to the Global Service Desk immediately

Bringing the Code to life

  • A: Yes, as long as you limit this practice; follow our guidelines about dangerous, illegal and inappropriate material; and do not let it interfere with your work. It’s important to remember when discussing personal matters on company systems that any message you send or receive through company communications systems and devices – including emails, social media posts, and text or SMS messages – may be the property of Refinitiv and may be accessed by the company.

Monitoring and recording

Where permitted by applicable law, Refinitiv reserves the right to monitor and record your use of information, communications, technology or infrastructure owned or supplied by Refinitiv.

Safeguarding our assets

Refinitiv computers, phones, office supplies and facilities exist for the purpose of helping us all maximize our performance as individuals, as a team and as a business. By respecting these assets, we ensure they remain accessible and fully functional when our customers and colleagues need them. We also help make sure company time and resources are used on positive initiatives, not on fixing preventable problems.

We use company assets for legitimate and authorized business purposes only. We consider misappropriation, carelessness or waste of assets to be a breach of our duty and the taking of assets from company property without permission to be theft. This means we:

  • Access company systems or information only when we are authorized and enabled to do so
  • Never use company assets for illegal activities
  • Limit personal use of company assets to when it does not interfere with our work and does not violate this Code
  • Prevent improper third-party use of company property
  • Immediately report any loss, theft, misuse, damage or waste
  • Stop using all Refinitiv assets in our possession or that we have access to and return them if we leave the company

Our assets

Examples of assets of Refinitiv include:

  • Computers, printers, copiers, scanners and monitors
  • Phones, tablets and other mobile devices
  • Intellectual property, such as software codes, licenses, brand names, business plans and inventions
  • Buildings and other physical property
  • Office supplies and equipment
  • Customer, supplier or distributor lists and information
  • Memos, notes and other documents made by us or a third-party business partner

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Our controls

Accurate financial records

Our global operations require us to comply with various financial reporting obligations. When we each take accountability for ensuring the financial records that we handle are accurate and complete, we protect the company’s reputation for integrity and uphold our commitment to trust. Reliable financial reporting allows shareholders and investors to fairly assess our performance, provides management with information to allocate our resources most effectively and prevents violations.

We produce accurate, fair and timely records for management, directors, shareholders, government regulators and others. This means we:

  • Take personal responsibility for ensuring all books and records – including time sheets, sales records and expense reports – are complete, accurate and documented
  • Never keep unrecorded, undisclosed or off-the-books records
  • Do not falsify or distort facts of any transaction
  • Record and disclose transactions in a timely manner, supported by documentation
  • Exercise reasonable diligence when approving transactions and expenditures or signing documents
  • Understand the importance of internal controls and consistently comply with them
  • Pay business-related expenses with company funds only if we have authorization from our manager
  • Provide full, fair, accurate, timely and understandable disclosures in reports or documents that we file externally or submit to regulatory authorities

Bringing the Code to life

  • A: No. Payments to vendors and contractors must be supported by appropriate documentation. They also must be accurate and complete, which includes making payments to the same person or company that we engaged.

  • A: No. Splitting an invoice into separate payments in order to meet an authorization level is considered a circumvention of our internal controls. If the vendor payment amount exceeds your authorization level, the next-level approver in your management chain will need to approve the expense.

Raising concerns

We have a responsibility to raise good faith concerns about questionable accounting, auditing, disclosures or controls. Refinitiv and the Audit Committee of the Refinitiv Board of Directors are committed to facilitating employee efforts to make these concerns known and have established procedures for how complaints about accounting, internal accounting controls, auditing matters and disclosure controls should be treated. This includes procedures for receiving, retaining and processing such complaints, as well as for confidential and anonymous submission of concerns.

In addition, it is unlawful to fraudulently influence, coerce, manipulate or mislead any independent public or certified accountant who is auditing our financial statements.

Seek Help for more information, including on how to submit reports anonymously.

Reportable auditing and accounting issues

You should promptly report complaints or concerns involving:

  • Fraud or deliberate errors in preparation, maintenance, evaluation or review of any Refinitiv financial statement or record
  • Deficiencies in or noncompliance with internal accounting controls
  • Misrepresentation or false statements to or by a senior officer or accountant regarding financial audits or records
  • Deviations from full and fair reporting of the company’s financial condition

Reportable fraud

Report any other types of fraud or dishonest activity that you have seen or suspect, including:

  • Questionable transactions with customers, agents, vendors or other consultants
  • Forgeries or other alterations of documents
  • Billings that are higher or lower than agreed-upon prices for products or services
  • Payments made for any reason other than described in a contract
  • Payments made through intermediaries that deviate from everyday business transactions
  • Transfers to or deposits in the bank account of an individual instead of the company we contracted with
  • Embezzlement, theft or misappropriation of company or customer assets
  • Verbal arrangements with customers or unauthorized written agreements that are outside of an official contract
  • Any activity intended to unfairly influence commission payments

Managing our records

As a largely information-based business, Refinitiv generates thousands of business records every day, in addition to financial records. These records must be created, stored and disposed of according to strict legal and regulatory requirements. When we can access records in a timely fashion, we provide better service to our business partners and we avoid risks around audits, regulatory issues or litigation. At the same time, records kept past their disposal dates can create avoidable information security, privacy or legal risks.

We care for, store, retrieve and dispose of our business records according to an applicable records management policy. This means we:

  • Consistently organize our filing, storage and retrieval of electronic and physical recorded information
  • Use the proper storage method specified by legal, fiscal, regulatory or operational requirements
  • Protect records from loss, damage or deletion, and back them up regularly
  • Retain all records related to any pending or threatened litigation or government investigation until otherwise directed by a company lawyer
  • Dispose of all records (electronic and physical) according to retention and disposal schedules

It may be a criminal offense to destroy or falsify documents or emails related to a legal proceeding.

Contact the Records & Information Governance team, which you can access through the Legal & Compliance homepage on the Company’s intranet, if you have questions about retention policies. If you have legal questions about whether a document should be retained, contact a company lawyer.

What is a record?

A record is any recorded information (electronic or physical) made or received and retained by an organization in pursuance of legal obligations or value to the government, or in the transaction of business.

Bringing the Code to life

  • If an email is not part of a business record and has served its business purpose and there is no legal or regulatory obligation to retain it, it should be deleted. If an email is part of a business record or there is a legal or regulatory obligation to retain it, you should remove it from your personal work email account and store it in an appropriate manner for future reference by the company (e.g., in a department network folder related to the record). Our records retention schedule identifies each category of records by business function. The record category typically includes:

    • A description of the types and classes of records to be retained
    • When the retention period begins
    • The length of the retention period. If you are subject to a “legal hold,” you should always retain emails until you’ve been notified by a company lawyer that the hold has ended

Contract authorization

Refinitiv is subject to different laws and regulations in all the places we operate. Even small errors or miscommunications made in contracting can mean that we don’t deliver what the customer expected, can’t get paid or are vulnerable to delays, legal action and fines. These issues also can fracture the precious trust we have built with our customers and business partners. Each of us should be involved in the contracting process only if we have been authorized and are experienced in doing so.

We strive to deliver and receive what was promised in our contracts and agreements. This means we:

  • Consult the Sourcing department for third-party vendor or supplier contracts
  • Enter into contracts or agreements or make proposals on behalf of Refinitiv only if we have proper authorization
  • Do not provide unapproved nonstandard terms or unauthorized “side letters” to customers or business partners
  • Ensure complete, accurate documentation of contracts, related orders and customer status in applications to process customer accounts
  • Follow the rules that govern public procurement when providing products and services to governments

Government contracting

Government contracting laws and regulations can be complex and are often subject to change. For guidance specific to your location, consult a company lawyer to verify that you are complying with applicable laws, policies and standards.

Unauthorized side letters

Unauthorized side letters are undisclosed, unapproved letters, emails, notes or verbal agreements that vary standard contract terms. They may bind us to something we cannot deliver or expose us to unwanted liability.
They can include:

  • Early outs, or the ability for the customer to terminate before the contract expires
  • Guarantees that the customer will achieve certain milestones
  • Statements that directly contradict parts of the contract, notably payment terms
  • Commitments for products or services Refinitiv is unable or unwilling to provide or perform
  • Offers of free or discounted products or services

The media and using social media responsibly

We are fully aware of the power of media and our responsibility to use it wisely. Our company’s reputation and ability to compete all can be affected by the information we make public. By being aware of the risks and not appearing to speak for the company without authorization, we can help make sure the company consistently gets an accurate message across to its intended audience while also exercising our individual right to post independently on social media.

If we receive requests for information from outside of the company, even seemingly simple ones, we refer them to colleagues authorized to act as company spokespersons.

These spokespersons:

  • Handle requests from media, shareholders, financial analysts and government authorities
  • Disclose information according to the requirements of regulatory authorities
  • Ensure that the information disclosed is accurate and that Refinitiv is ready to go public with it

Media appearances and public speaking

If we post information online, make a speech or give an interview about Refinitiv, we could appear to be speaking on behalf of the company. We may need to make it clear that our views do not represent those of Refinitiv. We may also need additional approvals before taking part, so it’s always best to discuss these situations with our manager and the Communications department, who can advise accordingly.

Social media

Refinitiv recognizes and encourages active participation in social media and online communications. We do so responsibly. This means we:

  • Are transparent and, if writing about Refinitiv or its products, services or industry, always disclose that we are employees, whether talking on behalf of the company or in a personal capacity
  • If writing personally and there is any risk of confusion, however slight, make it clear that the views expressed are personal and not the company’s views
  • Unless authorized by the company to do so, do not reveal confidential data or sensitive information about the company or its customers, vendors or suppliers
  • Are careful to avoid discussing company trade secrets, contracting, upcoming product releases or any other proprietary information
  • Act sensibly and follow the Social Media Guidelines if we post externally about fellow employees, customers, vendors or suppliers
  • Do not create Refinitiv-branded social media channels without proper approval
  • Make sure the time and effort we spend on social media do not interfere with our job duties
  • Are mindful of what we post, even when it’s not related to Refinitiv

Be aware that some of us in certain jobs may have supplemental policies regarding social media.

If you have any additional questions on personal or corporate social media use, Seek Help.

Where to refer inquiries

Inquiry from: > Refer to:
News or media > Communications
Regulatory or government agency > Legal and compliance
Elected official > Communications
Person seeking employment > The People function
Customer > Customer or sales representative
Vendor or partner > Communications

Bringing the Code to life

  • A: It’s best to refer this situation to Communications so they can properly investigate the issue and address it if needed. In general, you should avoid posting any information about Refinitiv products, strategies, customers or competitors, even if you’re trying to clear up confusion or false claims. It’s best to leave this to the company’s communications specialists.

  • A: Before posting such content, it is important to make sure that it doesn’t reveal confidential or nonpublic information about the company, our customers, our colleagues or other people or companies that we do business with. You shouldn’t cite or reference customers or business associates without their approval. Also, if you are commenting on products and services we sell or those sold or offered by our competitors, you should make it clear that you are employed by the company. In any event, you should make it clear that any opinions are your own and not those of Refinitiv. See the Social Media Guidelines, and if in doubt, talk to your manager, a company lawyer or Communications first. 

Our communities

Being a responsible global corporate citizen

Refinitiv works with thousands of professionals all over the world and we are committed to creating positive change in the areas of human rights and environmental responsibility. We are committed to treating all of our colleagues with dignity and respect, and we expect our business partners to do the same.

This cultivates a safe, skilled and reliable workforce across our global operations. We also are committed to protecting and preserving the environment, as well as seeking sustainable sourcing solutions. We know that our responsibilities are great, as are our opportunities, which is why we are committed to driving innovation and performance, proving to our business partners, our employees and the world that we are leaders committed to long-term success.

Human rights

We strive to protect human rights and worker rights wherever we do business. This means we:

  • Comply with local labor laws and practices and maintain our own high ethical standards of worker treatment
  • Do not condone or use forced or child labor, or engage in human trafficking or slavery
  • Engage workers on the basis of recognized employment or independent contractor relationships in accordance with local law
  • Provide clear information about wages and benefits to workers before they’re hired
  • Ensure wages and benefits comply with applicable laws
  • Respect workers’ rights to associate freely, join or form unions or works councils, and bargain collectively in accordance with local law
  • Work with high-quality suppliers and other business partners that have committed to operating under ethical standards equivalent to our own

If you believe you’ve encountered a violation of our human rights standards, either within one of our workplaces or involving one of our business partners, contact your manager, your People function representative or a company lawyer.

Environmental responsibility

We are committed to limiting our environmental impact. By managing our resources and seeking sustainable solutions, we can ensure a better future for all of us. This means we:

• Comply with all applicable environmental laws and regulations, meeting or exceeding their requirements

• Know and follow all company policies and procedures aimed at ensuring environmental safety and resource efficiency

• Understand the potential dangers and safe practices of any hazardous and/or regulated materials before allowing them into our workplaces

• Seek opportunities to support conservation and recycling in our workplaces

• Take responsibility as individuals and through our Sustainable Action Teams to find new ways to make our workplaces more sustainable

Responsible sourcing and the Supply Chain Ethical Code

We actively seek suppliers who share our ethical standards and commitment to environmentally sound and sustainable practices.

This means we:

• Perform due diligence on third-party suppliers

• Include renewable energy, pollution control and sustainability among the factors in our process of choosing suppliers

• Seek a diverse supply chain that reflects our employee base, customers and partners around the world

• Make prospective and current suppliers aware of our Supply Chain Ethical Code and seek their commitment in following it

Contributing to our communities

Refinitiv operates on a global scale and relies on local relationships and resources for support. When we improve our communities, we can improve the lives of our current and future workforce, as well as the lives of our customers. By seeking worthy causes to support and inviting collaboration and open communication, we can help our communities grow and succeed with us.

We collaborate with our colleagues and partners to support our communities and encourage charitable work.

This means we:

  • Listen to the concerns of community members and work together on solutions
  • Connect Refinitiv to charitable causes only with prior approval
  • Reward our colleagues’ commitment to serving communities through key programs
  • Offer all regular employees time off for volunteering consistent with regional or other policies that govern volunteering
  • Ensure all in-kind donations, such as equipment, are approved by our Tax and Finance departments
  • Have a program that matches employees’ qualifying personal charitable giving and fundraising efforts
  • Offer a volunteer grants program which provides a charitable grant to eligible nonprofits

What is sustainable leadership?

Addressing the world’s biggest sustainability issues requires collective leadership. This means exemplifying the behaviors that will bring about change and empowering others to do the same.

We foster a culture of openness, inclusion and partnership to ensure we deliver on our promise of high performance in both our people and products. Building on our strong legacy of local investment, we leverage the skills of our people through a range of global employee network groups, to drive positive impact and support causes in our communities.

Participating in government, politics and religious groups

Participation in government and politics can be an effective way to create positive change in our world. However, rules exist in various countries in which Refinitiv operates that require companies to track and/or limit certain political activities, including political donations which are strictly regulated.

Although we encourage employees to responsibly participate in politics and civic matters as individuals, Refinitiv does not support any political party, candidate or group or any religious group.

This means the company:

  • Never makes company contributions to any religious or political group
  • Never requires any employee to contribute to, support or oppose any religious or political group
  • Does not express a preference for or support, directly or indirectly, any political or religious group.

Lobbying

At times, we may discuss with government officials various issues and topics that could impact our business, regulators and politicians. When these discussions focus on the possible impact of proposed laws, rules or regulations on our business, we obtain prior approval from a company lawyer before taking an external position on potential legislation. If we do take a position, we clearly identify ourselves as lobbyists and follow all applicable lobbying laws, restrictions and regulations.

Personal public service and political activity

If we plan to campaign for or serve in political office as individuals, we are careful to separate ourselves from Refinitiv in these efforts and to disclose any such activity in advance to Refinitiv. This means we:

  • Notify a company lawyer about plans to campaign or serve as a government or public official (as defined within the Code)
  • Excuse ourselves from any political matters involving Refinitiv
  • Do not pressure or influence coworkers, customers or business partners whom we know through our job at Refinitiv in ways related to our own personal political activity
  • Do not reimburse employees or increase compensation to make up for personal political contributions
  • Abide by laws and regulations in those states and countries that limit political contributions by employees or their family members
  • Take special care to make it clear that our political activities and expressed political views are personal and not those of Refinitiv – especially if our business does business with a governmental entity

Supplemental policies

Be aware that some of us in certain jobs may have supplemental policies regarding lobbying and personal political activity.

Legal notice

This Code serves as a reference to you. Refinitiv reserves the right to modify, suspend or revoke this Code and any and all policies, procedures and programs in whole or in part, at any time, with or without notice. Refinitiv also reserves the right to interpret this Code and these policies in its sole discretion as it deems appropriate.

Neither this Code nor any statements made by any employee of Refinitiv, whether oral or written, confer any rights, privileges or benefits on any employee; create an entitlement to continued employment at Refinitiv; establish conditions of employment; or create an express or implied employment contract of any kind between employees and Refinitiv. In addition, all employees should understand that this Code does not modify their employment relationship, whether at will or governed by a written contract. The version of this Code that appears online may be more current and up to date and supersedes any paper copies or previous versions should there be any discrepancy between paper copies, previous versions and what is posted online.

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