Thomson Reuters Code of Business Conduct English 20080423c

8/3/2019 Thomson Reuters Code of Business Conduct English 20080423c

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homson Reuters | Code of Business Conduct and thics2

O Commm 3

How h Cod Wo 4

Business etHiCs AnD PrACtiCes

Protecting ssets and Resources 6

se of Computer and Communication ystems 7

Conicts of nterest and Corporate pportunities 9

Working for ther Companies and Board Positions 10

Condential nformation 1ccuracy of Records and nformation Reporting 14

ccounting, uditing or isclosure Concerns and raud Reporting 15

Records Management 16

Media, Public and Governmental nquiries 17

Political and Charitable Conduct and Contributions 18

WOrk envirOnent

qual mployment pportunities 19

iscrimination and arassment 20

afety and Workplace Violence 22rugs and lcohol 23

LeAL AnD COPLiAnCe

Compliance with Laws, Rules and Regulations 24

ecurities Laws and nsider rading 25

ntellectual Property 27

Contractual uthorization and Process 28

Giving or Receiving Gifts, ntertainment or Payments 29

air Competition, ntitrust and Competitive ntelligence 32

Dcplay Aco fo Cod volao 34

Qo ad How o rpo Coc ad volao 35

Hlpfl Coac ifomao 37

Fom of Acowldgm 38

Lgal noc 39

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ear Colleagues

othing is more important to our business than the trust our customers put in us. We earn that trust every day by dealing honestlyand fairly with each other and with every customer, business partner and competitor. ssential to maintaining this trust is homsonReuters dedication to excellence and to compliance with the laws and ethical standards everywhere we do business.

We’ve earned our reputation over many decades. t could be destroyed in a single day, by one thoughtless action. hat’s why youneed to carefully review our Code of Business Conduct and thics, even if you’ve read it before. t’s there so we all understand theconduct that is expected of us, and it tells you whom to consult for guidance on complex issues. t’s vitally important to me - and ’msure it is to you as well - to be part of a company with such a long-established reputation for integrity.

ntegrity matters. Judge every action not only by whether it’s legal or permitted by this Code but whether it’s right.f you see any of our colleagues breaking or even bending our guidelines, report that immediately to your manager, the umanResources department or the attorney who supports your business. ailing that, the otline is available to you in many languages, 24hours a day, 365 days a year. t is every employee’s right and responsibility to use one of these avenues to report improper activities.

o business deal or strategic objective is worth sacricing the reputation that we worked so hard to build and of which we are all so justiably proud.

incerely,om

om GlocerChief xecutive fcerhomson Reuters

eptember 2011

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Who h Cod appl o – he Code of Business Conductand thics applies to all ofcers, directors and employeesof homson Reuters Corporation and its subsidiaries. orconvenience, we refer to all of these entities as “homsonReuters” in this Code. ubsidiaries are entities in which homsonReuters owns, directly or indirectly, more than 50% of the votingrights, or homson Reuters otherwise has the power to controlthe entity.

ntities that homson Reuters may have an interest in but doesnot control should be encouraged, as far as possible, to adoptpolicies and guidelines that are consistent with the principlesand values set out in this Code.

utside consultants, contractors, temporary employees andagents engaged by homson Reuters are required to abide bythe policies, principles and values set out in this Code whenperforming services for, or on behalf of, homson Reuters.

spplmal thomo r polc ad gdl– You are responsible for reading and abiding by this Codetogether with any supplemental homson Reuters policies andguidelines that apply to you. number of homson Reuters

policies and guidelines that complement this Code are availableon our intranet. f you do not have access to our intranet, youcan obtain a copy of any of these policies from your umanResources department or a homson Reuters lawyer whosupports your business. f you have any questions about otherpolicies or guidelines that may apply to you, please consult withyour manager or a homson Reuters lawyer who supports yourbusiness.

lobal ach – his Code applies in all countries where weconduct business. f there is any real or apparent conictbetween this Code and supplemental policies, guidelines, lawsor regulations applicable to your job, you should comply withthe most restrictive requirement. f you become aware of sucha conict and are unsure what action to take, you should seekguidance, based on the intent and spirit of this Code, from yourmanager or a homson Reuters lawyer who supports yourbusiness.

Adc, gdac ad pog – f you have a concern orquestion or do not understand a provision of this Code, yourrst resource is usually your manager. owever, dependingon the concern or question, you or your manager may wishto contact your uman Resources department or a homsonReuters lawyer who supports your business. hrough ourintranet, you can access contact information for umanResources representatives, and homson Reuters lawyers. fyou are uncomfortable speaking with your manager, a umanResources representative and/or a homson Reuters lawyer, orif you need an anonymous or condential outlet, you can contactthe homson Reuters otline (see the section “Questions and

ow to Report Concerns and Violations” for more information).Violations of this Code should always be reported promptly,regardless of which communication channel you choose.homson Reuters has a policy prohibiting retaliation if you makea good faith complaint regarding conduct that you reasonablybelieve is unethical or that violates the law, this Code or ourother policies.

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iddal codao – ecisions or situations that involvelegal or ethical issues are often complex. When you’re faced witha decision or situation and you’re not clear as to what action youshould take, ask yourself the following questions:

• o have all of the facts and information that need to make adecision?

• ave considered and identied other options or alternatives?

• s the action legal?

• s the action ethical?

• oes the action comply with this Code and other policies orguidelines applicable to my job?

• ow will my decision affect others, including our customers,shareholders, employees and the community?

• ow will my decision look to others?

• ow would feel if my decision were made public? Could thedecision be honestly explained and defended?

• Would be happy if my conduct were described on the front

page of my hometown newspaper or on the internet?• hould consult with or contact my manager, my uman

Resources department or a homson Reuters lawyer whosupports my business?

Please refer to the section of this Code, “Questions and ow toReport Concerns and Violations” for more information abouthow to ask questions and/or report any possible Code violations,including how to do so anonymously and condentially.

t Pcpl – n observing this Code, you should bear inmind the homson Reuters rust Principles, which guide ourbehavior. hese principles apply to everyone at homson Reutersand state:

• homson Reuters shall not at any time pass into the hands ofany one interest, group or faction;

• he integrity, independence and freedom from bias of homsonReuters shall at all times be fully preserved;

• homson Reuters shall supply unbiased and reliable newsservices to newspapers, news agencies, broadcasters andother media subscribers and to businesses, governments,institutions, individuals and others with whom homsonReuters has or may have contacts;

• homson Reuters shall pay due regard to the many interestswhich it serves in addition to those of the media; and

• o effort shall be spared to expand, develop and adapt thenews and other services and products of homson Reuters soas to maintain its leading position in the international news andinformation business.

Acowldgm qm – fter reading this Code,please acknowledge that you have received access to andread this Code and that you understand your obligations tocomply with this Code. Pla o ha yo wll b xpcdo comply wh h Cod gadl of whh yoacowldg cp.

f you can, you should submit your acknowledgmentelectronically. nformation is available on our intranet as to howto submit your electronic acknowledgment. f you do not havecomputer access, you should sign a copy of the acknowledgmentform at the end of this Code and return it to your local umanResources department.

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Q: We have a closet fullof ofce supplies thatcontains things likecomputer paper, pensand notepads. Can takesome home with me? can’t imagine anyonewould miss what need,which isn’t that much!

: nless you are takingofce supplies so you canwork from home and your

manager has approvedit, this is not permitted.

aking home homsonReuters property, such asofce supplies, can resultin signicant costs forhomson Reuters.

homson Reuters assets are highly valuable and are meantfor business use. We all have a responsibility to protect andsafeguard these assets from loss, theft, misuse, damage andwaste in order to preserve their value.

exampl of thomo r a – homson Reutersassets include, but are not limited to:

• Computer systems, equipment and technology (includinglaptops, tablets and mobile devices);

• Phones, copiers, scanners and fax machines;

• Books;

• Business plans;

• ntellectual property, such as software codes, licenses, ideas,concepts, content and inventions;

• Customer, supplier and distributor lists and information,including customer search or trading information;

• Buildings and other physical property;

• fce supplies; and

• he homson Reuters name, our various brand names andlogos.

homson Reuters assets also include all memos, notes, lists,records and other documents (whether in paper or electronicformat) that you or our third party business partners orconsultants make or compile relating to our business.

Pop of a – You should use our assets appropriatelyfor legitimate and authorized business purposes. You should notaccess systems or information unless you’ve been authorizedand enabled to do so, and the extent of your access must beconsistent with the scope of your authorization. homsonReuters assets should never be used for illegal activities.homson Reuters allows and permits limited and occasionalpersonal use of homson Reuters e-mail, messaging, theinternet and phones if use is not excessive, does not interferewith work responsibilities and otherwise does not violate thisCode.

Misappropriation of our assets is a breach of your duty tohomson Reuters and may be an act of fraud against homsonReuters. aking homson Reuters property from our facilitieswithout permission is regarded as theft. n addition, carelessnessor waste of homson Reuters assets may also be a breach ofyour duty to homson Reuters. f you become aware of loss,theft, misuse, damage or waste of our assets or have anyquestions about your proper use of them, you should speak withyour manager, uman Resources department, Global ecurityor a homson Reuters lawyer who supports your business. or

more information you may visit the Global ecurity and ecurityMatters sites on our intranet.

rg a – f you leave homson Reuters, or uponhomson Reuters request, you must return any and all of itsassets in your possession.

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We provide e-mail, messaging, internet and intranet access,telephones and other forms of communication technology tohelp you do your job. hese tools help many of us work moreproductively and efciently. t the same time, it’s everyone’sresponsibility to help maintain the condentiality, integrity andavailability of our information, communications and technologyinfrastructure.

Pop of –mal ad commcao ym – Whenusing our information, communication and technologyinfrastructure, please remember:

• hese systems are for business purposes. owever, homsonReuters does understand the need for limited and occasionaluse of our e-mail and messaging systems, the internet,intranets and phones for personal purposes.

• se good judgment. f homson Reuters becomes involvedin litigation or an investigation, your communications mayhave to be turned over to third parties. Communications cansometimes be recovered even after you have deleted them.void careless, exaggerated or inaccurate statements thatcould be misunderstood or used against you or homson

Reuters in a legal proceeding. Before you hit “send,” think andre-read. on’t access, send or download inappropriate contentor information that could be offensive, insulting, derogatoryor harassing to another person, such as sexually-explicitmessages, jokes or ethnic or racial slurs.

• on’t forward internal communications or send condentialmaterials outside of homson Reuters unless you are explicitlyauthorized to do so.

• Respect intellectual property laws. ownloading, duplicatingor redistributing copyrighted material, including music, movies,images or software, may violate the law or regulations in manycountries and can result in disciplinary or legal action. nlyperform these activities if you are legally permitted to do so.

• nstant messaging or use of collaboration tools from your workcomputer is only permitted if you’re using homson Reutersproducts or as otherwise approved by your department ormanager.

• Manage and keep condential (do not share) your computeruser s, passwords and authentication devices.

• xercise caution when opening les attached to e-mail,especially those that are not business related or not from aknown source. f you have any concerns, you should not openthe attachment and should forward the e-mail to your department.

• Be careful of people outside of homson Reuters asking fornancial, customer or corporate information through e-mail orphone scams.

• he use of personal software on your work computer ormodication of homson Reuters-provided software is notpermitted unless approved by your department. he use ofpeer-to-peer (P2P) software to share copyrighted material is

prohibited.• on’t use or access homson Reuters information,

communications and technology infrastructure beyond yourauthorized level. or further guidance speak with your manageror uman Resources representative.

• homson Reuters property shouldn’t be left unsecured.

• on’t allow improper third-party use of homson Reutersproperty.

• on’t intentionally compromise or subvert homson Reuterssecurity controls.

• Report any suspected computer security exposures or incidentsto your local security ofcer or department immediately.

• n some instances, your business may allow the use of personalsmartphones or other devices. f you have approval from yourmanager to use a personally-owned device for the purposeof storing or accessing corporate data, you may, however itwill be subject to the same security and data managementpractices as a company-owned device. his may include, butis not limited to, requiring you to use an inactivity passwordlockout and data encryption. he company will have the rightto retrieve, erase or wipe company data from the device. indfurther guidance for the use of personal devices on our intranet

• se care when accessing and using social media sites suchas acebook, witter and Linkedn that allow user-uploadedcontent. n some cases, this content can be malicious in natureso use good judgment when following links, accessing contentand accepting friend or network requests. More informationregarding the use of ocial media can be found in the ocialMedia Guidelines on our intranet.

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Q: Can use the homsonReuters e-mail system tosend personal messagesto friends and familymembers?

:his is if the e-mailsare limited and you’reprimarily using ourcomputer networksfor business purposes.owever, we recommendthat you avoid sendingmessages that are highlypersonal from your workcomputer.

Q: Can install P2Psoftware like Bitorrentor Limewire on mycomputer in orderto share my musicand movie les with

my friends and workcolleagues?

: bsolutely not. naddition to being illegalin many countries,intellectual property isof fundamental valueto homson Reutersbusinesses and wemust show the same

respect for other people’sintellectual propertyas we would expect forour own. lso, certainunapproved softwareor websites couldcompromise the security

and integrity of homsonReuters network andapplications.

Q: Can use my personalphone (iPhone, ndroid,etc.) to access mycompany e-mail andintranet?

: his is if youunderstand andfollow the guidelinesestablished for personalphone use includingobtaining manager

approval where required.ind the guidelines thatapply to your business onour intranet.

Pacy ad thomo r fomao – Messages thatyou send and receive through homson Reuters information,communications and technology infrastructure, including, butnot limited to e-mail, the internet and other forms of electronicand paper communications may be the property of homsonReuters. You should not assume or expect privacy when usinginformation, communications and technology infrastructureowned or supplied by homson Reuters. Where permitted byapplicable law, we reserve the right to monitor and record youruse of information, communications, technology or infrastructureowned or supplied by homson Reuters.

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Q: What does “closerelationship” mean forpurposes of this policy?

: You are alwayspresumed to be in a

“close relationship”with members of yourimmediate family orhousehold. n addition,if your relationship witha partner, cousin, more

distant relative or friendcould inuence yourobjectivity, you shouldassume that you have a“close relationship” withthat person as well.

We expect that you will act in the best interests of homsonReuters and avoid conicts of interest by making reasoned andimpartial decisions. conict of interest may arise whenever apersonal interest interferes with - or even appears to interferewith - the interests of homson Reuters. conict of interest canalso arise when you take an action or have an interest that makesit difcult for you to perform your work objectively and effectively.While we respect your right to manage your personal businessand investments, you should place homson Reuters interest inany business transaction ahead of any personal interest or gain.

idfy ad p-cla coc – s an employee, it’s yourresponsibility to identify potential conicts when they ariseand to notify an appropriate manager, uman Resourcesrepresentative or a lawyer who supports your business if you areunsure whether a relationship or transaction poses a conictbefore engaging in the conduct or as soon as you learn of thepotential conict. n appropriate manager or uman Resourcesrepresentative will be able to pre-clear or resolve certainconicts, or will be able to contact someone else at homsonReuters who can. ach homson Reuters director is required toinform the Board of any potential or actual conict of interest

that he or she may have with homson Reuters.exampl of coc – he following are examples of conictsof interest that could arise, and are prohibited unless they havebeen pre-cleared or resolved in advance:

• You or someone with a close relationship with you receivesimproper personal benets (such as cash, gifts, entertainment,services, discounts, loans, guarantees or being selected byhomson Reuters as a supplier, consultant or business partner)as a result of your position at homson Reuters;

• Your work as an ofcer, director, employee or consultant toanother company interferes with your ability to do your jobat homson Reuters, will lead to disclosure of condentialinformation or the other company competes with homsonReuters;

• You take for yourself a business opportunity which youdiscovered through homson Reuters property or informationor through your position at homson Reuters without rstoffering it to homson Reuters, if homson Reuters mightreasonably have a business interest;

• You use homson Reuters property, information or yourposition at homson Reuters for personal gain;

• omeone with a close relationship with you is in a directreporting relationship with you, or you have the ability tosupervise, review or inuence the job evaluation, hiring, pay orbenets of someone with a close relationship with you who alsoworks at homson Reuters; or

• You allow any investments held by you or someone in a closerelationship with you to inuence you in your work for homsonReuters. xcept under any arrangements made for employeesby homson Reuters, you must not use any homson Reuterstransaction for your own – or any other individual’s – personalinvestment purposes. his does not apply to the use of ahomson Reuters product which is directed to the consumermarket.

n addition, it may be a conict of interest if you own, or someonewith a close relationship with you owns, more than 1% of acompetitor’s, customer’s or supplier’s shares. f someone with aclose relationship with you works for a competitor, customer orsupplier of homson Reuters, both of you should take specialcare to comply with the duties that each of you owe to youremployer.

eep in mind that not all conicts are prohibited and the listabove does not address every example. ome conicts arepermissible if they are disclosed and approved. Because it’simpossible to describe every potential conict, we rely on you toexercise sound judgment and to seek advice when appropriate.

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Working outside of homson Reuters or serving as a directorof another company may create a conict of interest. Being adirector or serving on a standing committee or advisory board ofsome organizations, including government agencies, also maycreate a conict, whether the position is compensated or not.

slf-am – Before agreeing to work outside ofhomson Reuters or joining the board of a charity or non-prot

organization, you should assess whether working outside ofhomson Reuters or joining a board would have the potentialto be a conict of interest, depending on the nature of theposition and your involvement. n any case, working outside ofhomson Reuters or joining a board should not interfere withyour job at homson Reuters or lead to disclosure of condentialinformation. When in doubt, you should seek advice from yourmanager.

he homson Reuters rust Principles (see the section of thisCode “ow the Code Works”) should always be considered aspart of any self-assessment. f you or your manager believe thatthe second job or position potentially conicts with the homsonReuters rust Principles, a further discussion should take placewith a more senior manager, uman Resources representative ora homson Reuters lawyer.

Before accepting an appointment to the board or a committeeof any organization whose interests may conict with homsonReuters interests, employees must receive written approvalfrom a homson Reuters lawyer who supports their business.o employee may serve as a director of another publicly tradedcompany unless you’ve received approval from the CorporateGovernance Committee of the homson Reuters Board ofirectors.

Pmbl poo – mployees are permitted, however,to serve on the board of private family businesses that have norelation to homson Reuters and its businesses. Prior approval isnot required for these types of situations.

f you hold a position with an outside organization and if youspeak publicly for the entity, you should ensure that you are seenas speaking on behalf of the entity or as an individual, and not on

behalf of homson Reuters.f you’re permitted to work outside of homson Reuters or joinanother company’s board, you may not divulge any condentialor strategic information about our businesses and must not voteon any board issues that are related to dealing with homsonReuters.

ny permitted outside work/positions should be separated fromyour position at homson Reuters and should not be done onhomson Reuters time or using homson Reuters equipment,property, information or supplies. Your outside work/positionshould not interfere with or prevent you from devoting the timeand effort needed to fulll your primary duties and obligationsas a homson Reuters employee and the business must not

compete with homson Reuters.

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Q: have been offeredan opportunity toparticipate as aconsultant in anexpert network. s thispermissible? will notdo it during workinghours and will not

use homson Reutersresources.

: homson Reutersgenerally does notpermit employees toserve as consultantsfor other organizationsin relation to the

subject matter of theiremployment, experienceor responsibilities athomson Reuters. hiswork could lead to aconict of interest orimproper disclosureof homson Reuterscondential information.

f you, with the supportof your manager, wishto undertake this typeof work, seek expresswritten approval from ahomson Reuters lawyerwho supports yourbusiness.




s part of your job or position, you may learn or have access tononpublic or inside information relating to homson Reutersbusinesses, operations or technology. f information is not in thepublic domain, you should treat it as condential. You should notshare condential information with anyone, including individualswithin homson Reuters, unless there is a legitimate “need-to-know” and you are authorized to do so. mproper disclosureof condential information could put us at a competitivedisadvantage or could hurt or embarrass homson Reuters orother employees.

exampl of codal fomao – Condentialinformation includes some of our most valuable assets, such asthe following examples:

• rade secrets;

• Pricing policies and information;

• Business or strategic operating plans and outlooks;

• onpublic nancial information about homson Reuters or ourcustomers, business partners and suppliers;

• ew product, brand or marketing studies, developments, plansor forecasts;

• Customer data, including contact details, specications andpreferences;

• Contracts and agreements, including terms such as expirationdates, any exclusivity provisions and nancial conditions;

• Competitive intelligence that you or our third party businesspartners or consultants make or compile on homson Reutersbehalf (see the section of this Code on air Competition andntitrust);

• ubscription lists;

• mployee, client, business partner and supplier lists with orwithout associated contact information;

• oftware or computer programs;

• Merger, acquisition or divestiture plans;

• Personnel plans or major management changes; and

• nternal communications such as webcasts, audiotransmissions of conference calls, memoranda to staff andtranscripts or minutes of company meetings.

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Q: ow can better protectcondential information?

: ome suggestionsinclude: put sensitivedocuments in lockedles or drawers; utilizethe password protectionon your computer ifyou leave your desk

for a period of time;periodically change yourcomputer passwords;make sure that thereare nondisclosureor condentialityagreements in placebefore you share anycondential informationwith third parties;and use encryptionfor electronic lesduring storage and

transmission. or furtherguidance, please reviewthe homson Reutersnformation ecurityandbook or visit theecurity Matters site onour intranet.

Q: oes this policy restrictme from mentioning

homson Reuters in apersonal blog?

: t’s to mentionhomson Reuters in apersonal blog. owever,if you maintain apersonal blog, it shouldnot contain or discussany condential ornonpublic information

about homson Reuters,our customers or otherpeople or companiesthat we do businesswith. You should not citeor reference customersor business associateswithout their approval.f your blog mentionshomson Reuters, itshould be clear that anyopinions that you expressare your own, and notthose of homson

Reuters. ven then,you should be mindfulof the rust Principlesin discussing homsonReuters or any of itscompetitors. urther,personal blogs shouldnever be used for internalcommunications amongfellow employees andyou should not use a

personal blog to air anydifferences with peopleor companies that wedo business with. omehomson Reutersbusinesses may havetheir own supplementalpolicies and guidelineson blogging.

Q: f use a laptop, what

can do to help preventagainst the risk of data orinformation thefts?

: ome recommendationsinclude: (1) don’t letyour laptop out of sightin a public location; (2)don’t check your laptopwith your baggagewhen traveling by air; (3)keep an eye out whengoing through airportsecurity screening— thieves working inpairs are experiencedat distracting peoplewith laptops; (4) if youtake a laptop with you,a nondescript bag willdraw less attention thana traditional laptop bag;(5) if you need to putyour laptop down, try

to put it in front of you,and not behind you or toyour side; (6) if you needto leave your laptop inyour car, lock it in thetrunk; (7) when travelingwith highly sensitiveinformation, considerusing a removable harddrive and packing it

separately; (8) lock upyour laptop wheneverpossible; (9) routinelyback up your laptop tothe network; and (10) ifyou store highly sensitivepersonal informationabout homson Reutersemployees or customerson your laptop, such associal security numbersor credit card numbers,you should make sure

that this information isencrypted. f you lose ormisplace a laptop, reportit immediately to yourlocal and/or securitydepartment.

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safgadg codal fomao – f you havecondential information, you should store or safeguard it whereunauthorized people cannot see or access it. You should usecaution if you discuss condential information in elevators,restaurants, airplanes or other places where your conversationmay be overheard. lso use care when speaking in front offamily members, who may not know that you are discussingcondential information and may later inadvertently disclose itto others. You should also be careful not to leave condentialinformation in unattended conference rooms, or discardcondential information in a public place where others can

retrieve it. n addition, use good judgment when using cell

phones, laptops, wireless devices and any forms of unsecuredcommunications.

Your obligation to safeguard homson Reuters’ nonpublicinformation or other condential information applies to you evenafter you leave homson Reuters for as long as the informationremains condential and is not generally available to the public.

You should only disclose condential information outside ofhomson Reuters after appropriate steps have been taken,such as obtaining written authorization to do so and signing acondentiality agreement with the receiving party to prevent

misuse of the information.



thd Pay fomao – We respect condential informationregarding other organizations or people, including ourcustomers, business partners, and suppliers. f you learn ofcondential information about another organization or person inthe course of your job or as a result of your position, you shouldprotect it the same way that you would condential informationabout homson Reuters. f you are a member of our ditorialstaff you should follow the policies and requirements of the

Journalism andbook or seek guidance from your manager or ahomson Reuters lawyer who supports your business.

Misuse or improper disclosure of condential information by anemployee of third party information can be harmful to homsonReuters and could be the basis for legal action against homsonReuters and/or the employee responsible for the disclosure.

Daa Poco ad Pacy Law – Many countries havedata protection and privacy laws and regulations that affectthe collection, use, retention and transfer of certain informationabout individuals.

his is a rapidly changing area of law, and you should consultwith a homson Reuters lawyer who supports your business ifyou have any questions regarding appropriate collection, use,

retention or transfer of information about individuals, includingour customers, business partners, suppliers, marketing contacts,employees, contractors, consultants and other individuals.

he collection, use, retention and transfer of certain informationabout individuals raises legitimate concerns for clients,regulators and the individuals themselves. homson Reutersexpects its employees, third party consultants, contractors,business partners and suppliers to:

• Collect, use, retain and transfer information about individualsin accordance with all applicable data protection and privacylaws and regulations;

• Comply with applicable data protection and privacy laws andregulations; and

• Comply with homson Reuters standards of information anddata security which are designed to protect our information,communications and technology infrastructure resources frombreach.

Misuse or improper disclosure of condential information andinformation about individuals could be the basis for civil orcriminal penalties as well as public censure.

f you are unsure whether specic legal requirements orhomson Reuters policies or guidelines apply to you andyour job, or how to apply them, consult with your manager ora homson Reuters lawyer and/or compliance contact whosupports your business. ailure to comply with applicable data

protection or privacy laws or regulations may have serious,adverse consequences for homson Reuters and you.

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Q: t’s the last week ofthe 1st quarter. n

order to stay within ourbudget, ’m thinkingabout booking certainexpenses in the 2ndquarter for supplies andother materials thatwe received earlier thismonth. Can do this?

: bsolutely not. llexpenses and revenuesmust be recorded in

the period that they areincurred or realized.

Q: was on a business tripand misplaced a fewreceipts for cash that paid for taxis and meals.Can still get reimbursedif don’t have anything todocument my expenses?

: Maybe. f you accidentallylost your receipts, youshould review the traveland entertainment

(&) policies that applyto you and contactyour manager to nd

out whether you canbe reimbursed. orexpenses in excess ofa particular amount,our policies or yourmanager may refusereimbursementwithout receipts. venif you are allowed tobe reimbursed, anydocumentation that you

are required to producemust accurately reectyour expenses. t is never

acceptable to createa false, misleading orerroneous expense forreimbursement.

Pop acal ad accog codpg – ur nancialand accounting records are used to produce reports for homsonReuters management, directors, shareholders, governmentaland regulatory authorities and others. herefore, we must allprotect homson Reuters reputation for integrity by ensuringcomplete and accurate nancial and accounting records that arenot misleading. mplementing appropriate control systems helpsto make sure this happens.

• ll of your books, records and accounts - including time sheets,sales records, invoices, bills and expense reports - must becomplete, accurate and reliable.

• nrecorded, undisclosed or “off-the-books” funds or assetsshould not be kept for any purpose.

• ever falsify any document or distort the facts relating to aparticular transaction.

• ransactions should be recorded in a timely manner andsupported by appropriate documentation.

• You should not incur or pay the costs of anything usinghomson Reuters funds if the incurrence or payment is

not authorized by your manager or supervisor or is notreimbursable.

• inancial records that reect homson Reuters activitiesand transactions should be maintained in accordance withhomson Reuters accounting policies and procedures and incompliance with applicable standards, laws and regulations.

exal thomo r dclo – We also requirefull, fair, accurate, timely and understandable disclosure inreports and documents that we le with, or submit to securitiesregulatory authorities and stock exchanges, as well as inother public communications made by homson Reuters. fyou’re involved in the preparation of homson Reuters publicdisclosures, or if you provide information as part of the process,you have a responsibility to ensure that disclosures andinformation are provided in compliance with homson Reutersdisclosure controls and procedures and our related disclosurepolicies.

CCRCY RCR RM RPRGP CMPL, CCR RLBL RCR.




We have a responsibility to report in good faith, mattersregarding questionable accounting, auditing or disclosureconcerns. n order to facilitate the reporting of employeecomplaints, the udit Committee of the homson Reuters Boardof irectors has established procedures for the receipt, retentionand treatment of these concerns.

exampl of accog ad adg o po –You

should promptly report any issues relating to accounting,auditing or disclosure concerns, which may include actionsinvolving:

• raud or deliberate errors in the preparation, maintenance,evaluation, review or audit of any nancial statement ornancial record of homson Reuters;

• eciencies in, or noncompliance with, homson Reutersaccounting policies or internal controls;

• Misrepresentation or false statements to or by a senior ofceror accountant regarding a matter contained in the nancialrecords, nancial reports or audit reports of homson Reuters;or

• eviations from full and fair reporting of homson Reutersnancial condition.

exampl of fad o po –You should report any othertypes of fraud or dishonest activity that you become aware of, orhave good faith suspicions about. xamples include:

• Questionable transactions with customers, vendors, agents orconsultants not in accordance with homson Reuters policies;

• orgeries or other alterations of documents;

• Billings made higher or lower than normal prices for productsor services at a customer’s or vendor’s request;

• Payments made for any reason other than as described in acontract or other documentation;

• Payments made through intermediaries that deviate fromordinary business transactions;

• ransfers to, or deposits in the bank account of an individual,rather than in a company account or the account of a companywith which we are doing business; or

• mbezzlement, theft or misappropriation of homson Reutersassets or customer assets that we have been entrusted with.

n addition, it is unlawful to fraudulently inuence, coerce,manipulate or mislead any independent public or certiedaccountant who is auditing our nancial statements.

You should report fraudulent activities as promptly as possibleby current or former homson Reuters employees or contractorsto one of the following responsible parties:

• irect Manager or upervisor;

• uman Resources Representative;

• ivisional C;

• homson Reuters Legal epartment;

• Corporate Compliance and udit; or

• Business Conduct and thics otline.

raudulent activities against homson Reuters by externalparties or entities should be reported to a homson Reuterslawyer or Global ecurity.

Please refer to the section “Questions and ow to ReportConcerns and Violations” of this Code for more information,including how to submit reports condentially and anonymously.

CCG, G RCLR CCR R

RPRGPRMPLY RPR Y CCG, G R CLR CCR Y MY V R R Y BCM WR .

Q: f suspect that someonein my business may beinvolved in fraudulent ordishonest conduct, can investigate it myself?

: o. You should promptlyreport your concernsto your manager, the

homson ReutersCorporate Complianceand udit department,a homson Reuterslawyer or the homsonReuters otline. Youshould not initiate afraud investigation on

your own. Generallyspeaking, the homsonReuters CorporateCompliance and uditdepartment and/orthe homson ReutersLegal departmentwill be responsible for

determining whether aninternal investigation iswarranted, and if so, willselect an appropriateinvestigation teamand determine thenature and scope of theinvestigation.




Q: ow long do need toretain e-mails?

: f there is no businessreason to keep an e-mailmessage and if there isno legal or regulatoryobligation to retain it, itshould be deleted. f youare subject to a “legalhold,” you should alwaysretain e-mails untilyou’ve been notied by a

homson Reuters lawyerthat the hold has ended.

ur information and records are valuable corporate assets andmust be managed with due care. We must comply with legaland regulatory requirements that relate to document and recordretention and disposal. s a result, we have an establishedpolicy for properly caring for, storing, retrieving and disposing ofhomson Reuters records. You should manage our records andinformation in a manner that ensures:

• Consistently organized ling, storage and retrieval of recordedinformation;

• Record maintenance in whatever media satises legal, scal,regulatory and operational requirements;

• Protection of records (including backups);

• eeded documentation in the event of litigation; and

• Proper and timely disposal of records no longer of value, bothin paper and electronic format.

homson Reuters has a records retention schedule that identiesby title each category of records it maintains. retentionschedule typically outlines by record category:

• description of the types and classes of records to be retained;• When the retention period begins; and

• he lengths of time records are to be retained.

f you are informed about pending or threatened litigation or agovernmental investigation, you may not destroy any records(including e-mails) unless you have been authorized to do so by ahomson Reuters lawyer. t may be a criminal offense to destroyor falsify documents or e-mails that are subject to a subpoenaor other legal process. ny employee who fails to comply withthis policy, as well as applicable laws and regulations, is subjectto disciplinary action, up to, and including, termination and mayalso face criminal or civil prosecution, with possible nes andprison terms.

You should contact the Records Coordinator for your businessor department or the homson Reuters Records Managementdepartment ([email protected]) ifyou need more information or have questions about retentionpolicies applicable to you. You should also familiarize yourselfwith what’s required. f you have any legal questions aboutwhether a document should be retained, you should confer witha homson Reuters lawyer who supports your business beforeproceeding.

here is more information on the Records Management sectionof our intranet.

RCR MGMCMPLY W RCR MGM PLC PPLCBL Y ’ RY R LY CM R -ML Y LR LG R VG.




Q: What should do if get a call from themedia asking me forinformation about aproposed acquisitionthat homson Reutersannounced through a

press release? s it forme to comment since thenews is public?

: You should refer the callto your Media/PublicRelations department(even if the informationis public) unless youare authorized to speakon behalf of homsonReuters. ven if homson

Reuters has made apublic announcementabout a development ortransaction, you shouldnot comment.

Q: trade magazine wantsto do a feature on one of

our new products. Can speak to the reporterwho’s writing the story?

: You can only commenton or provide pressinterviews about ourproducts or servicesif you have beenauthorized to do so.therwise, you shouldrefer the call to someone

who is authorized tospeak on behalf ofhomson Reuters.

Q: Can comment orrespond to commentsabout homson Reutersor any of our businesses

in a blog, online chatroom or bulletin board?

: You should not postany information aboutour products, stockperformance, operationalstrategies, nancialresults, customers orcompetitors, even inresponse to a false

statement or question.Refer these matters toyour Communicationsdepartment so we canappropriately investigateor address the issue.or further information

see the ocial MediaGuidelines within theocial Media Communityon our intranet.

n order to state our positions and views in a consistent manner,we have professionals at homson Reuters who are trained andqualied to release information to the public. When membersof the media, shareholders, nancial analysts or governmentauthorities contact homson Reuters to request information, theresponse can have far-reaching implications, including effects onthe homson Reuters stock price and homson Reuters abilityto compete. When we provide information on our products,operational strategies or nancial results, we must ensure boththat the information is accurate and that homson Reuters isready to “go public” with that information.

n addition, we must comply with the requirements of securitiesregulatory authorities and stock exchanges about how and whenwe disclose information. or these reasons, it is critical that onlyauthorized persons speak on behalf of homson Reuters.

exal q fo fomao – f you receive a request forinformation from outside homson Reuters (even if it seems likea simple request or innocent question), you must forward it tothe appropriate department if you are not authorized to speak onbehalf of homson Reuters.

Pblc pag ad pblcao – Before publishing, makinga speech or giving an interview in your capacity as a homson

Reuters employee or executive - or if a publication, speech orinterview might in any way be connected to your position athomson Reuters - you should obtain approval from your PublicRelations or Communications department.

iqy fom: rf o:

inancial community orshareholders

nvestor Relations (R)

ews or media Public Relations (PR)

Regulatory andgovernmental agencies

Legal department

lected ofcials Public Relations (PR)

Persons seekingemployment information

uman Resources (R)

M, PBLC GVRMLQR’ P BL M RR L Y R

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Q: Can volunteer someof my time for a localcharity?

: Yes, we encourageemployees to volunteerand time can betaken during workhours. urther guidancecan be found in ourvolunteering policy.

Q: Can volunteer someof my time for a localpolitical campaign?

: ur volunteeringpolicy does not permitemployees to take paidtime off for politicalcampaigning activities.ny volunteering youundertake in this respectmust be done outsideworking hours.

Q: would like to make acharitable contributionon behalf of homsonReuters to a charity thatmy key client supports,can do this?

: t depends. f yourmanager approves yourexpenditure and youfollow the guidelinesset forth in this Codeand associated policies

you can be reimbursedfor certain charitable

contributions on behalfof a client. You shouldalso keep in mind thischaritable contributionis a gift and must alsofollow the guidelines forgiving and receiving a giftset forth in this Code.

Polcal codc ad cobo – We strongly support andrespect your personal right to participate in political activities.owever, no one at homson Reuters may require you tocontribute to, support or oppose any political group or candidate.

homson Reuters does not give support – directly or indirectly –to any political party, candidate, group or religion nor does it takesides in national or international conicts or disputes. n keeping

with this policy, you must not identify the name of homsonReuters (or any of our businesses) with any political party orgroup or any one side in such conicts or disputes.

You should also be aware that:

• mployees are not reimbursed for personal politicalcontributions, and compensation will not be increased orotherwise adjusted to reect political contributions made.

• n some countries, laws and regulations may restrict or limitpolitical contributions by employees or their family members,particularly if the business unit conducts business with agovernmental entity.

• f you publicly express political views, you should make it

clear that they are individual, personal views and not those ofhomson Reuters.

• You must notify a homson Reuters lawyer who supports yourbusiness if you plan to campaign for, or serve in, public ofce,and avoid conicts of interest by excusing yourself from anypolitical matters involving homson Reuters if you do so.

We may discuss various issues and topics with governmentofcials regarding the possible impact to us of proposed laws,rules or regulations. f you’re in doubt as to whether a particularaction might compromise our impartiality, you should consultwith your manager or a homson Reuters lawyer who supportsyour business.

Chaabl codc ad cobo – We encourage

employees to contribute personal time and resources to charitiesand non-prot organizations. owever, if you are afliated witha charity or nonprot organization that seeks to do businesswith, or receive donations, assets or services from homsonReuters, you should disclose this to your manager and obtainthe appropriate approval from your business. n-kind donations,such as equipment, should be approved by your ax and inancedepartments. ny donations of technology equipment shouldalso be approved by your department and, in some cases,the nvironmental ealth and afety Group to ensure properdispensation. Check our intranet for the proper local contactsor email: [email protected].

PLCL CRBL CC CRBPLCL CRB M BL M RR

R PRM. CRBL CRB M BL M RR RQR PPRVL.




Q: am planning to promoteone of two employees.ne is a man, and theother is a woman who hasbeen talking in the ofcefrom time to time abouther plans to eventuallystart a family. Can promote the man if thinkthe woman is likely tohave children soon andmight leave homsonReuters?

: o, this would be aviolation of our policy. ncertain jurisdictions, forexample, a promotionbased on these factswould also violateapplicable laws andregulations.

O commm – We are committed to providing equalemployment opportunities for all persons regardless of:

• Race;

• Color;

• Religion;

• ex/gender, including pregnancy;

• Gender identity and expression;

• ge;

• Marital status;

• exual orientation;

• ational origin;

• Citizenship status;

• isability;

• Veteran status; or

• ny other classication protected by applicable federal, state,

provincial or local laws or regulations.ur management is dedicated to ensuring the fulllment ofthis policy with respect to hiring, discharge, compensation,promotion, classication, training, apprenticeship, referralfor employment, or other terms, conditions and privileges ofemployment. We comply with applicable laws and regulationsgoverning nondiscrimination in every location in which we havefacilities.

raoabl accommodao –homson Reuters is committedto reasonably accommodating qualied individuals withdisabilities in order to provide employment opportunitiesfor them. homson Reuters is also committed to reasonablyaccommodating employees’ sincerely held religious practices.

or purposes of this policy, a “reasonable accommodation” is amodication or adjustment to a job, the work environment, or

the way things usually are done that does not pose an unduehardship to homson Reuters.

f you believe you have a disability that may require anaccommodation to perform the essential functions of yourposition or need a religious accommodation, you should contactyour uman Resources department or manager to request anaccommodation. homson Reuters will work with you to identifyany reasonable accommodations.

QL MPLYM PPRW PRV WRPLC R QL MPLYM PPR.




Zo olac polcy – homson Reuters is committed toensuring that its employees work in a safe and respectfulenvironment where high value is put on equality, fairness,respect, courtesy and dignity. homson Reuters has zerotolerance for unlawful discrimination or harassment, whethercommitted by an employee, supervisor, customer, vendor,supplier, consultant, visitor or any other person on homsonReuters premises or conducting homson Reuters business,regardless of location. ero tolerance means that homsonReuters will take immediate and appropriate action if a violationof this policy occurs, which may result in disciplinary action, upto, and including, termination.

ny form of discrimination or harassment on the basis of race,color, religion, age, sex/gender (including pregnancy), maritalstatus, sexual orientation, gender identity or expression, nationalorigin, citizenship status, disability, veteran status or any otherclassication protected by applicable laws or regulations isa violation of this policy and will be treated as a disciplinarymatter. urther, in order to provide a respectful and professionalworkplace, conduct that does not violate the law or regulations,but that is inappropriate in the workplace, is also prohibited.

Haam – While it’s not easy to dene harassment,it includes verbal, visual or physical conduct that:

• as the purpose or effect of creating an intimidating, hostile oroffensive work environment or unreasonably interfering with anindividual’s work performance; or

• therwise adversely affects an individual’s employmentopportunities.

xamples of conduct that may be regarded as harassmentinclude:

• sing slurs, disparaging remarks, off-color jokes, insults, vulgarlanguage, epithets and teasing;

• isplaying offensive posters, symbols, cartoons, drawings,computer displays or e-mails; or

• hreatening another person, or blocking someone’s way.

sxal haam includes conduct of a sexual nature where:

• ubmission to the conduct is made an explicit or implicit termor condition of employment;

• ubmission to, or rejection of advances is used as the basis ofemployment or promotion decisions; or

• he purpose or effect of the conduct creates an intimidating,hostile or offensive work environment or unreasonablyinterferes with an individual’s work performance.

exual harassment can include all of the examples ofharassment described above. ther examples of conduct thatmay be regarded as sexual harassment include:

• nwelcome propositions, demands or advances of a sexualnature;

• nwelcome physical contact, such as hugging, kissing,grabbing, pinching, patting or brushing against another

person;• nappropriate remarks about a person’s body or appearance,

sexual gestures or comments, or unwanted verbal or physicalirtation; or

• Vulgar or obscene gestures, language or comments.

CRM RMY’R PC CR WR VRM ’ R CRM, RM PPRPR CC.




Q: usually meet one ofour suppliers every few

months to discuss ourupcoming requirements.ne salesperson inparticular regularly jokesaround a lot and oftentells me how sexy hethinks that look. don’tnd this welcome. Can do anything about this?

: homson Reutersprohibits harassment

and discriminationby our employees, aswell as by individuals

with whom we have abusiness relationship. fyou nd the conduct ofa supplier’s salespersonoffensive, you shouldtell the salespersonthat you feel this way,if you are comfortabledoing so. f you do notfeel comfortable doingthis, or if he fails to l isten

to you, you should tellyour manager or umanResources representative

of your concerns so wecan take steps to addressyour concerns.

Q: oes this policy ondiscrimination andharassment apply allover the world?

: Yes. homson Reutersbelieves that itsemployees throughout

the world should havea safe and respectfulwork environment.

hese standards applyeven where the lawor regulations do notdirectly address theconduct.

Po ad pog – s a general guide, you should notallow an inappropriate situation to continue by not reporting it,regardless of who is creating the situation. f you believe that youhave been subjected to discrimination or harassment, you shouldreport your concerns to your manager or uman Resourcesrepresentative and cooperate in any investigation that isconducted. lternatively, if you are uncomfortable speaking withyour manager or uman Resources, or require an anonymous orcondential outlet, you can also contact the homson Reutersotline. n certain countries, callers to the otline will be advisedthat it cannot be used anonymously to report discrimination/harassment due to privacy and legal restrictions. dditionalinformation on otline procedures and exceptions can befound on the otline page on our intranet. very supervisoror manager, who learns of an employee’s concern aboutharassment or discrimination, whether in a formal complaint orinformally, must immediately report the related issues to theiruman Resources representative.

igao poc – very report of discrimination orharassment will be promptly and thoroughly investigated.We will attempt to keep the investigation condential to theextent possible. uring the investigation, we will generallyinterview the complainant and the individual(s) about whom he/she complained and we will conduct additional interviews asnecessary.

no alao – We prohibit any form of retaliation againstindividuals who make good faith reports of alleged harassmentor discrimination or otherwise cooperate in the investigation ofsuch reports. owever, we reserve the right to discipline you ifyou make an accusation without a reasonable good faith beliefin the truth or accuracy of the information or if you knowinglyprovide false information or make false accusations. f youbelieve that you have been retaliated against, you should use thereporting procedures outlined in this Code. n accordance withthis Code, we will take appropriate disciplinary action for anysuch retaliation, up to and including termination.

CRM RMRPR CCR B CRM RM.




homson Reuters endeavors to provide a healthy and safe workenvironment for its employees. n this regard, you must:

• Conduct our operations in a manner that complies with theletter and spirit of applicable occupational health and safetylaws, regulations and the public policies they represent toprotect the health and safety of our employees, customers,contractors and visitors;

• ollow work instructions or procedures on health and safetylaws, regulations and risk management;

• ake any mandatory or on-the-job training which helps in thesafe delivery of job responsibilities;

• nsure company records reect your current emergencycontact information;

• Be vigilant in the workplace, raising any safety or securityconcerns you have to your manager or uman ResourcesRepresentative.

Woplac olc ad holy – homson Reuters has zerotolerance for acts or threats of violence, intimidation and hostilitytowards another employee, a customer or a member of thepublic. o the extent permitted by law, this prohibition extendsto activities outside of work which adversely affect the reputationor business interests of homson Reuters or the safety of itsworkers.

o person may possess a weapon of any kind or other dangerousor hazardous device or substance in the workplace, in homsonReuters leased or owned facilities, at homson Reuterssponsored functions or otherwise on company business unlesslegally authorized to do so and only with the prior writtenapproval of the Global ead of ecurity.

Pohbd codc xampl – he following is a non-exclusivelist of prohibited behaviors:

• ngaging in behavior that injures another person, or isdesigned to or is likely to injure another person;

• Making or sending harassing or threatening statementsverbally and/or in writing, directly or through a third-party;

• ngaging in aggressive, threatening or hostile behavior;• ngaging in behavior that damages employer property or the

property of another or is designed to or is likely to damage suchproperty;

• ngaging in stalking or unauthorized surveillance of anotherperson; and

• Committing or threatening to commit violent acts.

hese behaviors are prohibited whether made in person orthrough telephone calls, e-mails, text messages, letters orthrough any form of electronic or other communication;

f you feel that you or another person is being threatened orsubjected to violence, or if you encounter suspicious activity, youmust make this known immediately to any of the following:

• upervisor or any other member of management;

• epartment/operations manager;

• uman Resources manager or Business Partner;

• homson Reuters Global ecurity epartment.

i h of a lf-hag mgcy, mmdalyofy local polc o amblac ad h l-maagm.

omestic and personal issues that have potential to enter intothe workplace (i.e. orders of protection, restraining orders,etc.) should be reported to the employee’s uman Resourcesrepresentative and Global ecurity.

he full text of the Workplace Violence Prevention Policy can befound on the homson Reuters intranet.

Y WRPLC VLCW R CMM RG L Y R MPLY.




Q: s there somewhere cango for help or counselingrelated to alcohol ordrugs?

: f you are experiencinga difcult personalproblem, such asalcoholism or drug abuse(or even somethingunrelated - such asmarital or family distress),we encourage you to use

the mployee ssistanceProgram or LifeWorks.

ny information that youmay share with them iscondential. f you arelocated in a country thatdoes not have an mployeessistance Program orLifeWorks, you should feelfree to contact your umanResources representative

for information aboutsimilar services that may be

available in your location.

lcohol and drugs can impair your ability to work effectivelyand can endanger you and those around you. homson Reutersprohibits the possession, use, purchase, sale, attempted sale,distribution or manufacturing of illegal drugs in the workplace,including non-prescription controlled substances, as well as theabuse/misuse of alcohol and illegal and prescription drugs, whileconducting homson Reuters business on or off our premises.

You should not report for work impaired by alcohol. nlessspecically authorized by homson Reuters, you may notpossess or use alcohol while on homson Reuters premises. fyou are at a homson Reuters-sponsored or customer-sponsoredfunction, use good judgment when consuming alcohol. f youhave any doubt about your ability to drive, you shouldn’t. nstead,you should make other arrangements such as calling a taxi or carservice or asking a colleague for a ride.

mployees who violate this policy will be subject to disciplinaryaction, up to and including termination. s involvement withcertain drugs is illegal, violations of this policy could also subjectyou to arrest and prosecution by law enforcement agencies.

Where allowable by law, homson Reuters reserves the right totake appropriate steps to investigate compliance, including butnot limited to drug and/or alcohol testing by qualied medical

professionals and searches in the workplace.

RG LCL’ LLGL RG, M LCL R B PRCRPRG WL CCG M RR B.




Q: ’m looking for a summaryof a law that understandis applicable to mybusiness. Who should contact for information?

: You should initially calla homson Reuterslawyer who supports yourbusiness to see how he orshe can assist you.

Q: We just received a draftcontract from a company

that we’re hoping to dobusiness with, and ’m

not sure if the terms are“standard.” Who should contact to discuss mylegal questions?

: You should contact ahomson Reuters lawyeror contract administratorwho supports yourbusiness.

s a global organization, we are subject to numerous laws, rulesand regulations. While we don’t expect you to be a legal expert,you are expected to understand and comply with laws, rules andregulations applicable to your job or position. You should alsoknow when to seek advice from your manager or a homsonReuters lawyer who supports your business. ny violation oflaws, rules or regulations applicable to us could jeopardize ourreputation. raud, dishonesty or criminal conduct will not betolerated.

s is appropriate for your job responsibilities and position, youshould:

• Learn about laws, rules and regulations that affect what you doat homson Reuters;

• ake mandatory compliance training;

• ttend periodic training and seek to keep informed about anyrelevant legal or regulatory developments; and

• Consult with a homson Reuters lawyer who supports yourbusiness if you have any questions about the applicability,existence or interpretation of any law, rule or regulation.

Comply wh applcabl ad co, xpo coolad boyco – rade restrictions and boycotts may restrictour ability to do business with particular countries, entities orindividuals. Certain countries maintain lists of these restrictedcountries, entities and individuals. n some instances, speciclicenses or authorizations must be received before we exportcertain products, software or technologies to specied countries,entities or individuals. n short, you should know your customersand others with whom we do business. f you are ever unsurecontact a lawyer that supports your business.

Comply wh omal law ad glao ha applyo thomo r – You have a responsibility to conduct ouroperations in a manner that complies with environmental lawsand regulations, and which minimizes any adverse effect on theenvironment. We follow policies, guidelines and managementsystems to ensure pollution prevention, resource efciency andresponsible sourcing. f your job involves contact with regulatedand/or hazardous materials or if you’re involved in decisionsabout them, you should understand how those materials can besafely handled and act accordingly. f you have any questions,you should immediately contact your manager, umanResources and/or the nvironmental ealth and afety group.

Local com – We must recognize the interests of the placesin which we do business. n addition to obeying laws andregulations, you should also respect the local customs of hostcountries (but not if doing so would violate applicable laws,regulations or this Code).

rpog – f you nd yourself in a position that you believemay violate a law, regulation, this Code or another homsonReuters policy, you should report the violation or what youbelieve or suspect is a possible violation. You can report yourconcerns to a manager, your uman Resources departmentor a homson Reuters lawyer who supports your business.lternatively, you can choose to report condentially andanonymously, as discussed in the section of this Code “Questionsand ow to Report Concerns and Violations.”

CMPLC W LW, RL RGLW CMPLY W LW, RL RGL PPLCBL

YR JB R P.




number of our ofcers, directors and employees have accessto nonpublic information about homson Reuters or othercompanies that is not known by people outside of homsonReuters. o ofcer, director or employee of homson Reuters orany of its businesses may trade in, or encourage another personto trade in, homson Reuters securities while in possessionof material nonpublic information. rading based on materialnonpublic information is a violation of the law and can result insevere penalties. Material nonpublic information is akin to insideinformation.

aal fomao – “Material” information is any informationdirectly or indirectly relating to the business, affairs or securitiesof homson Reuters that would, if generally available,reasonably be expected to:

• Result in a signicant change in, or a signicant effect on, themarket price or value of any homson Reuters securities; or

• ave a signicant inuence on a reasonable investor’sinvestment decisions.

nopblc fomao – “onpublic” information is informationthat is not generally known or available to the investing publicthrough a press release, website posting, securities ling,distribution to shareholders, widely reported media coverageor other ofcial public homson Reuters communications. obe clear, just because “nonpublic” information is the subjectof rumors posts in blogs or other types of social media or “talkon the street,” even if accurate, it is not considered “public”disclosure by our company.

t doesn’t matter how you learned about material nonpublicinformation – if you’re aware of it, you have a duty to avoidproting from it, or avoiding a loss because of it, and a duty notto disclose it to others.

Commo xampl – he most common example of “materialnonpublic information” about homson Reuters is informationabout our earnings or nancial performance that has not yetbeen publicly disclosed. Material nonpublic information can beeither positive or negative. ther examples of material nonpublicinformation may include:

• signicant change in our business operations, projections or

strategic plans;• potential merger, acquisition or restructuring;

• potential sale of signicant assets or subsidiaries;

• he gain or loss of a major supplier, customer or contract;

• he introduction of a new signicant product or service, orupcoming signicant product or service developments;

• signicant pricing change in our products or services;

• declaration of a stock split, a public or private securitiesoffering by our company or a change in our dividend policies oramounts;

• change in senior management or our Board of irectors;

• Major changes in accounting methods; or

• n actual or threatened signicant lawsuit or materialgovernment/regulatory investigation.

f you are not sure whether information is material or nonpublic(or whether information is still material or nonpublic), consultwith a homson Reuters lawyer who supports your businessfor guidance before engaging in any transaction in homsonReuters securities.

Do’ p fomao o oh – You should be careful notto knowingly or unintentionally disclose material nonpublicinformation about homson Reuters to other persons, suchas relatives or friends, who may trade on the basis of theinformation or disclose the information to others. ecurities lawsand regulations also prohibit trades made on the basis of these“tips.”

n addition, you should avoid trading in puts and calls relatingto homson Reuters securities as these are, in effect, a bet onthe short-term movement of those securities and may create anappearance that you are trading based on material nonpublicinformation.

CR LW RRG’ R , R CRG R PR R , M

RR CR Y P MRL PBLC RM.




Q: s part of my job, ’verecently learned alot about one of ourcustomers, whose stockis publicly traded. orexample, found out thatthe customer’s revenuesfor last year are muchhigher than what thepublic is expecting to beannounced. Can buysome of their stock atthis time?

: o. sing materialnonpublic information tobuy or sell securities isa violation of this Codeand insider trading lawsor regulations. f youcommit insider trading,you could lose your joband possibly face nesand/or jail time.

f you have material information about a customer, supplier orother company with which homson Reuters does businessor is negotiating a signicant transaction or agreement that isnot known to the investing public, you should not buy or sellsecurities of that company until the information has becomepublic or is no longer material.

n addition to the restrictions discussed in this section, homsonReuters has designated certain persons as “homson Reutersnsiders” because of their position in homson Reuters or theiractual or potential access to material nancial information.“homson Reuters nsiders” are subject to additional restrictionsin terms of their ability to buy, sell or trade homson Reuterssecurities. he homson Reuters General Counsel will notify youif you are a “homson Reuters nsider.”

or more information on insider trading, you should consult thefull text of our insider trading policy, available on our nternet.

CR LW RRG’ R , R CRG R PR R , M

RR CR Y P MRL PBLC RM.




Q: We came across someinteresting informationin a public database.Can we include it in oneof our products withoutobtaining a permission orconsent?

: he information mightstill be subject tointellectual propertyprotection. You shouldconsult with a homsonReuters lawyer whosupports your business,as the answer will likelydepend on the facts andcircumstances.

Q: What is a “moral right”?

: Moral rights are relatedto intellectual propertyand include the rightof attribution and theright to the integrity ofa work that is created.he waiver in this Code isdesigned to ensure that

all intellectual propertyrights related to workscreated by you duringyour employment belongto homson Reuters.

ur brand identity and intellectual property are among our mostvaluable assets and are essential to maintaining our competitiveadvantages. hese include the homson Reuters name, logo,copyrights, patents, trademarks, service marks, trade secrets,processes, innovations, content, software and moral rights. tis extremely important that we protect these assets and honorthose of third parties.

illcal popy of thomo r

• homson Reuters owns intellectual property that you createwhile you are a homson Reuters employee (provided it isrelated to homson Reuters business interests), or usinghomson Reuters resources. Publications, documentation,

software, creative materials and other works of authorshipare some of the types of materials that you may create in thecourse of your employment at homson Reuters, and thesebelong exclusively to the company.

» rom time to time, you may also create, discover or developmethods, processes, systems or other patentable inventionswhile performing your homson Reuters job responsibilitiesor utilizing information or resources available to you inconnection with your employment at homson Reuters orotherwise during your employment. ince we may want toprotect some of your inventions with patents, it’s importantthat you promptly disclose them to homson Reuters.nventions also include improvements, designs, ideas,technologies, programs and other works.

» o the extent permitted by law, you agree that all suchintellectual property, whether or not patentable orprotectable by copyright, trademark or trade secret, is ownedby homson Reuters. f applicable law or regulation considersyou the owner of the intellectual property, then you agree totransfer or assign ownership to homson Reuters.

» ll moral rights that you may have under applicable law orregulations in or related to works and other matter, and allintellectual property that you create or make in the courseof employment with homson Reuters, or which is relatedto homson Reuters business interests, are irrevocably

waived by you in favor of homson Reuters. Where permittedby applicable law, intellectual property created for us bycontractors or agents is the property of homson Reuters asa work-for-hire or, alternatively, by assignment.

• You should report any unauthorized use of homson Reuterscopyrights, patents, trademarks, service marks or otherintellectual property to your manager or a homson Reuterslawyer who supports your business.

• You should put copyright notices on all homson Reutersmaterials, information, products, services and other documentsor products intended for public distribution or circulation.

Illcal popy of hd pa – You should get written

permission to use a third party’s copyrights, patents, trademarksservice marks or other intellectual property. f you want or needto use intellectual property that belongs to someone else, wemay need to obtain a license to use the property or purchase theoutright ownership of the property.

You should neither make copies of, nor publish any copyright-protected materials until we have obtained written permissionfrom the holder and determined that copying or publishing islegally permitted.

You should neither copy nor distribute a third party’s softwareor related documentation without ensuring that the licensingagreement permits copying or distribution and does not impairhomson Reuters rights, as with open source software.

ome homson Reuters businesses have groups or departmentsthat oversee our compliance in using rights held by third parties.f you are uncertain whom to contact, please consult with ahomson Reuters lawyer who supports your business.

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Q: ’ve been looking over a

new customer contractand ’m not certain if have authority to sign and also don’t understandsome of the provisions.Who should contact?

: You should contact yourcontroller (or controller-type ofcer) or contractsdepartment/administrator to

determine if you can sign,or contact a homsonReuters lawyer whosupports your businessfor advice and help ininterpreting the contractor provision in question.

homson Reuters contracts and agreements govern ourbusiness relationships. Because the laws and regulationsgoverning contracts and agreements are numerous andcomplicated, policies and procedures are in place to ensurethat any contract or agreement entered into by and on behalfof homson Reuters has the appropriate level of review andapproval.

s a result, if you enter into contracts or agreements onhomson Reuters behalf, you must have proper authorization,including legal review where required by policy, prior tothe execution of any contract or agreement. he ourcingdepartment should be consulted for third party vendor andsupplier contracts and agreements.

You may not enter into unauthorized “side letters” withcustomers, suppliers or vendors. hese are undisclosedand unapproved letters, e-mails, faxes or verbal assurancesthat deviate from standard contract terms and conditions.nauthorized side letters may bind homson Reuters to dosomething that it is unable to do, and may expose homsonReuters to unwanted liability. While it’s not possible to describeevery type of unauthorized and undisclosed side letter, someexamples include communications that contain:

• “arly outs,” or the ability for a customer to terminate thecontract before it expires;

• Guarantees or contingencies that the customer will achievecertain performance measures or milestones;

• ny statement that contradicts terms in the contract, notablypayment terms;

• Commitments for products or services that homson Reuters isunable or unwilling to provide or perform; or

• ffers of free or discounted products or services.

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We give and receive gifts, meals, services and entertainment,subject to specic guidelines. We base our decisions to purchaseproducts and services from vendors, suppliers, consultants andothers on criteria such as quality, price and reliability and weexpect that our customers will buy our products and serviceson the same basis. Giving or receiving gifts and entertainmentcan potentially affect objectivity and judgment and may breachbribery and corruption laws and regulations in extreme cases.

Accpabl gf, mal, c ad am – Gifts,meals, services and entertainment are acceptable and complywith this Code if they:

• re relatively infrequent and not excessive in value for someoneof your position;

• Comply with applicable laws and regulations and areconsistent with customary business practices or courtesies;

• Will not place the recipient under any obligation to the personwho gave the gift;

• o not include cash;

• Would not embarrass homson Reuters, the person receivingthe gift or the person giving the gift, if publicly disclosed; and

• re never given to, or received from, any government ofcialunless you’ve received prior approval from a homson Reuterslawyer who supports your business. Be mindful that some ofhomson Reuters customers work for public institutions anduniversities and may be considered government employees.

Because it’s not possible to dene “not excessive” in a way thatcovers all possible cases, we rely on your good faith judgmentin these situations. f you have any doubts, you should consultwith your manager, your uman Resources representative or ahomson Reuters lawyer who supports your business.

n all cases, you should keep in mind that our customers oftenhave their own policies and guidelines and you should not

offer gifts, meals, services or entertainment which you know orsuspect would violate those policies or guidelines. Please alsoremember that some of our businesses have more restrictive giftpolicies and you should comply with the most restrictive policyapplicable to you.

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exampl of gf – he following are some examples of giftsthat you usually can accept or give:

• Promotional items with a company or brand logo;

• Prizes randomly received in rafes or contests at industryconferences;

• ickets to a local sporting or cultural event;

• Meals and entertainment of reasonable value when business isbeing conducted;

• Modest expressions of gratitude or gifts acknowledgingpersonal events, such as weddings and births; and

• mall gifts of nominal value customarily given on certainholidays.

f codao – sking yourself the following questionsmay help you in deciding whether to accept or give a gift:

• What’s the intention behind the gift?

• Would you feel uncomfortable or embarrassed if your co-

workers in a similar position or job level found out about the

gift?

• s the gift being presented to you or given by you at the ofce,or away from the workplace so others won’t know about it?

• f you’re giving a gift, does the person to whom you’re planningto give the gift have a policy that would prohibit it? When indoubt, check.

• oes it seem right? f not, don’t take it, don’t give it, or ask forguidance in advance.

n some countries, returning or refusing a gift would be offensivef this occurs, you should accept the gift on behalf of homsonReuters and consult with an appropriate manager about how thegift should be treated.

f you would like to give or receive any gift, meals, services or

entertainment that do not meet the guidelines discussed above,or if you have any questions, you should consult in advance witha homson Reuters lawyer who supports your business. ormore information, see the nti-Bribery and Corruption Policyand the Guidelines on Providing Gifts, ravel and ntertainmenton our intranet.

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Q: supplier has invitedme out for golf and thento dinner and drinks at arestaurant. Can accepthis offer?

: Yes, if the invitation isa common business

courtesy, is not excessiveand is intended toimprove or strengthenthe relationship.

Q: o all governmentagencies have the same

rules and regulationsregarding gifts?

: o. Rules andregulations differ amongfederal, state andprovincial governmentagencies in different

countries. Consult with ahomson Reuters lawyerwho supports yourbusiness if you have anyquestions.





Q: We have hired a localagent to assist us insecuring a governmentcontract. We wouldnever make an improper

payment to thegovernment employeeshandling the transaction,but we don’t know whatour agent might do.Could the agent’s actionsget homson Reuters introuble?

: Yes. f we pay anindividual or company

who in turn providessome or all ofthat payment to agovernment ofcial,homson Reuters could

be liable. When workingwith agents and otherintermediaries, it isimportant to conductdue diligence on theirbackground and tosecure contractualrepresentations fromthem that no improperpayments will be madeon behalf of homson

Reuters. You shouldconsult with a homsonReuters lawyer whosupports your businesswhen working with

agents and otherintermediaries.

Q: While crossing theborder into a foreigncountry for an importantproject, the customsofcial says thatmy laptop must beexamined for securityreasons. he process willtake 4 days, unless pay

a $100 cash “expeditingfee.” Can pay this?

: o. While this couldpossibly qualify as afacilitation payment,and therefore be legalunder some laws orregulations, it is againsthomson Reuters policyto make such a payment.When in doubt seekexpress approval from ahomson Reuters lawyerwho supports yourbusiness.

Bb ad mpop paym ad gf – ur policies, aswell as the laws and regulations of most countries where wedo business, forbid you from making or participating in makingany payments designed to cause or improperly inuence thedecisions of an individual, a company or a governmental ofcialto act in a way that gives homson Reuters or you an improperadvantage. imilarly, you cannot solicit, encourage or actuallyreceive any bribe or other payment, contribution, gift or favorthat could inuence your or another’s decision. While what’sviewed as a bribe in one country may be acceptable in another,you’re expected to comply with this Code. Bribes and otherimproper payments and gifts can take many forms, including,but not limited to:

• irect cash payments;

• ickbacks;

• nexplained rebates or discounts;

• nvoices for some disguised expense or;

• xcessive goods and services for personal use.

Faclao paym – “acilitation payments” (smallpayments made to government ofcials or afliated personsto secure routine actions such as processing visas or othergovernment papers, obtaining non-discretionary permits,providing phone or power service, and similar activities) arepermitted under some laws or regulations. Many countries,however, do not have such an exception in their anti-corruptionlaws or regulations. homson Reuters prohibits facilitationpayments by its employees and representatives. f you are facedwith a request for such a payment, you should refuse.

f you believe that it is necessary to make the payment in orderto achieve legitimate homson Reuters business goals, and youare unsure if the payment is permitted under applicable laws orregulations or this Code contact a homson Reuters lawyer whosupports your business. Making such a payment without doingso is a violation of homson Reuters policy and could subject youto disciplinary action up to and including termination.

or more information, see the nti-Bribery and Corruption Policyand the Guidelines on Providing Gifts, ravel and ntertainmenton our intranet.

GVG R RCVG G,RM R PYM’ RCLY R RCLY M R PYM

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Q: ’m planning to attendan industry conferenceand anticipate that willmeet my “equivalent” ata principal competitor.’ve heard through thegrapevine that we areboth planning to bid ona new service contract

for another corporation.Can speak to him?

: Maybe, although notabout that bid or anycompetitively sensitiveinformation like pricing.You should rst speakto a homson Reuterslawyer who supports

your business before youinitiate any conversationswith a competitor thatmay pertain to things likepricing and costs. venan informal discussion ata conference (includinga one way ow ofinformation from one

competitor to another,where the other actsupon that information)can be a potentialantitrust or competitionlaw or regulationviolation.

We believe in fair and open competition, and our successdepends in part on our ability to offer competitively pricedquality products and services. While we compete vigorously,we comply with applicable antitrust and competition laws andregulations wherever we do business.

iacg wh compo – ntitrust or competition lawsand regulations are extremely complex and cover a broadrange of conduct that may be declared illegal. Most antitrust orcompetition laws and regulations prohibit making agreementswith competitors or customers to limit or restrict competition, or

sharing information with competitors or customers that wouldlimit or restrict competition. his means that we never discuss,agree with or recommend to competitors to:

• ix prices;

• hare information about pricing, prot margins, costs, saleterms, credit terms, customers, promotions, discounts,marketing or strategic plans or other competitively sensitiveinformation;

• ivide up sales opportunities or territories;

• ot solicit each other’s customers;

• ot sell a particular product or service;

• ot sell products or services to, or solicit certain customers;• Rig a competitive bidding process; or

• Boycott a particular supplier or vendor.

f a competitor wants to discuss a subject that you think mightcause antitrust concerns, you should tell him or her that you can’ttalk about the topic. f the discussion continues, you should bringit to a close. f you attend a conference, trade show, associationevent or meeting and have informal contact with a competitor,it is always a good idea to limit informal contact to the extentpossible and keep a written summary of any discussions thatmay have taken place. he standards for conspiracy to violateantitrust laws and regulations are extremely broad and an

unlawful agreement can be found where competitors never metor exchanged words, but did something like share competitiveinformation (even just receiving such information, i.e., a one-wayow of information could qualify). ntitrust violations do nothave to be proven by written agreements and violations canbe inferred from an individual’s or organization’s actions. t’s agood idea to use extreme care when talking with competitors orpotential competitors.

s lgal gdac fo ca yp of agm adpacc – o conduct our business, we need to negotiate

agreements with our customers, suppliers and distributors.owever, these agreements can sometimes raise antitrustissues as well. n particular, you should seek legal advice from ahomson Reuters lawyer who supports your business before:

• sing customer pricing or licensing terms in order to drive outor unduly hinder competition (e.g., change of pricing, or likelyto, or deep discounting);

• elling any products or services below cost;

• Conditioning the sale of a product, service or discount upon acustomer taking other products;

• ntering into an exclusive dealing agreement, a ‘lock-in’agreement or an agreement with non-compete or reciprocity

provisions; or• reating customers, suppliers or distributors inequitably

(e.g., inequitable pricing and/or access to products or services)where such inequity might have an adverse effecton competition.

Because antitrust or competition laws and regulations are socomplex, are subject to many exceptions and qualications andvary signicantly from country to country, you should familiarizeyourself with applicable Competition Law guidelines found onour intranet and consult with a homson Reuters lawyer whosupports your business in advance of any planned actions thatmight be considered anti competitive.

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ag o podc ad c – We also deal fairly withour customers, suppliers, competitors and security holders.While comparative marketing and advertising are generallyacceptable, you should not unfairly disparage or criticizecompetitors’ products or services. While we strive to exceedcustomers’ expectations, we will only make honest and factualclaims about the availability, suitability, quality and performancecapabilities of our products, services and businesses.

ahg fomao abo compo – o continue to besuccessful, homson Reuters must understand its competitors.herefore, legitimate intelligence gathering (which is conductedin accordance with our competitive intelligence guidelines) is animportant part of doing business. owever, you shouldn’t obtaininformation about our competitors through unlawful or unethicapractices. f you receive or are offered data or information abouta competitor under questionable circumstances, you shouldn’tdistribute it. ither you or your manager should consult witha homson Reuters lawyer who supports your business. Youshould not misrepresent your identity or the business that youwork for in order to gain access to a competitor’s product orservice. You should not breach contractual terms or third parties’intellectual property rights, or entice a customer or other thirdparty to do so in order to obtain competitive intelligence. Priorto seeking or using any competitive intelligence, understand ourCompetitive ntelligence Guidelines (available on our intranet). fyou have any questions about the application of these guidelinescontact a homson Reuters lawyer that supports your business.

R CMP, R CMPV LLGCCMP L RLY W R GR CMPV

LLGC LGMLY.

Q: have a personalaccess for a thirdparty service from mylast employer and itstill works, can let mycolleagues use it?

: ot only should younot be sharing your or password withthird parties but youalso can not use anyservices or condentialinformation from yourpast employment forhomson Reuterspurposes. se of anythird party services

requires proper licensingand you must complyat all times withthe applicable thirdparty’s contractual andintellectual propertyrights.




homson Reuters strives to impose discipline for each Codeviolation that ts the nature and particular facts of the violation. failure by any employee or representative to comply with lawsor regulations governing homson Reuters business, this Codeor any other homson Reuters policy or requirement may resultin disciplinary action up to, and including, termination, and ifwarranted, legal proceedings.

Please remember that some homson Reuters businesses andunits have their own disciplinary actions policies that are distinctand separate from this Code. f there is any conict between thisCode and any supplemental policies or laws and regulationsapplicable to your job, you should comply with the mostrestrictive requirement.

CPLRY C R CVLVLG C C V CQC.




his Code is intended to serve as a guide for your own actionsand decisions and for those of your co-workers. f you believe thatyou or someone you know is in violation of the policies stated inthis Code, you have an obligation to report your concerns in atimely manner. here are several reporting options. You may usewhatever method of communication with which you feel mostcomfortable. he important thing is that you get the guidancethat you need, report what you know and get your questionsanswered.

slf pog – You are encouraged to identify yourself toassist us in addressing your concern or reporting an actual orpotential violation. n many instances, your immediate resourceis your direct manager or supervisor, your uman Resourcesrepresentative or a homson Reuters lawyer who supports yourbusiness. hese people may have the information that you needor may be able to refer the matter to an appropriate source. orwork environment-related complaints, such as harassment anddiscrimination, we encourage you to contact your manager oruman Resources representative.

Codal ad aoymo pog – We have alsoestablished another communication channel that you can usewhen you have specic concerns or when you want to report anactual or potential violation condentially and/or anonymously.or example, there may be times when you prefer not to goto your manager or supervisor, or you may want to report aconcern about your manager’s or supervisor’s conduct. homsonReuters employees may report violations and submit complaintsand obtain information, advice and suggestions condentiallyand anonymously by phone or e-mail. Condentiality will bemaintained to the fullest extent possible and information willonly be shared on a “need-to-know” basis, consistent with theneed to conduct an adequate review.

• Phone. We have established telephone numbers (the homsonReuters Business Conduct and thics otline) for employeesto call: Please see the section “elpful Contact nformation.”he otline is not equipped with caller-, recorders or otherdevices that can identify or trace the number from which youare calling.

• -mail. You may contact the otline by e-mail [email protected]. lthough e-mail from your ofceor home computer is not anonymous, you can request that youridentity be kept condential.

• Web. You may also report online using a web form. he reportprocessing and escalation to the appropriate homson Reuterscontact is the same as when you call on the otline. Whenyou submit a report online, you may also choose to remainanonymous. ee the otline page on our intranet for moreinformation.

Please be aware that local laws, rules or regulations may limitor prohibit the reporting of concerns to the otline unlessthe concerns pertain to accounting, auditing, fraud or similarmatters. f you’re an employee in a country subject to thesespecial otline reporting procedures and have concerns orquestions that do not pertain to accounting, auditing, fraudor similar matters (i.e., work environment-related issues), youshould contact your manager or supervisor, your local umanResources representative or a homson Reuters lawyer whosupports your business. homson Reuters will advise you if youwork in a country that is subject to special otline reportingprocedures.

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tam of po ad compla – Whether you contactyour manager, supervisor, uman Resources, a homsonReuters lawyer who supports your business or the otline, youcan expect:

• Your question, report or complaint will be taken seriously;

• nformation will be gathered in response to your questions orconcerns;

• Your question, report or complaint will be forwarded toappropriate homson Reuters management for follow-up;

• Condentiality will be maintained to the fullest extent possible,consistent with the need to conduct an adequate review;

• Complaints and concerns relating to accounting, internalaccounting controls or fraud related matters will be reviewedunder the homson Reuters udit Committee’s directionand oversight by the homson Reuters General Counsel andthe Corporate Compliance and udit department and/orsuch other persons as the udit Committee determines to beappropriate;

• You are obliged to cooperate with investigations relating toactual or alleged violations and complaints and must always betruthful and forthcoming in the course of these investigations;and

• Prompt and appropriate corrective and disciplinary action willbe taken when and as warranted.

ro of po ad compla ad gao – heCorporate Compliance and udit department will maintain alog of all reports and complaints related to accounting, internalaccounting controls and fraud related matters, tracking theirreceipt, investigation and resolution and will prepare a periodicsummary of reports and complaints for the udit Committee.nformation regarding other reports and complaints aremaintained by uman Resources and Legal/Compliance asappropriate.

ralao pohbd – We will not discharge, demoteor suspend you if you provide information or assist in aninvestigation regarding conduct that you reasonably believe isunethical or that constitutes a violation of law, this Code or ourother policies. his commitment includes you giving informationin connection with an authorized investigation. owever, wereserve the right to discipline you if you make an accusationwithout a reasonable, good faith belief in the truth and accuracyof the information or if you knowingly provide or make falseinformation or accusations. “Good faith” does not mean thatyou have to be right — but it does mean that you believe you areproviding truthful information. f you believe that you have beenunfairly or unlawfully retaliated against, you should immediatelynotify your manager or supervisor, your uman Resourcesdepartment, a homson Reuters lawyer who supports yourbusiness or the otline.

Pmpo of occ – f someone makes a report orcomplaint against you, you will be presumed innocent unless theinvestigation reveals a violation has occurred.

Dcplay poc – s noted previously, a violation of law,this Code or our other policies may result in disciplinary action upto, and including, termination and/or legal proceedings.

Coopao wh a gao – mployees who aresubject to, or interviewed in connection with, an investigation areobligated to cooperate. ailure to cooperate with an investigationincludes, but is not limited to: knowingly providing false ormisleading information, refusing to be available for contactduring the investigation and knowingly withholding or deletinginformation pertinent to the investigation. ailure to cooperatemay result in disciplinary action up to, and including, terminationand/or legal proceedings.

Wa – Waivers of this Code may be granted only by thehomson Reuters General Counsel’s ofce. owever, any waiverof this Code for homson Reuters executive ofcers or directorsmay only be made by the homson Reuters Board of irectorsor a Board committee and will be disclosed by homson Reutersto the extent required by law, regulation or stock exchangerequirement.

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Hma roc rpa, thomo rLawy ad Commcao rpa

f you do not know how to contact your local uman Resourcesrepresentative, a homson Reuters lawyer who supports yourbusiness or your local Communications representative, you cannd contact information on our intranet.

B Codc ad ehc Hol

-mail: [email protected]

elephone: + (1) 877.373.8837 (outside of the nited tates andCanada, precede with your country access number todial toll free).

Web: www.compliance-hotline.com/homsonReuters.jsp

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-Mail: [email protected]

ifomao ad it sym scy

[email protected]

“ecurity Matters” site can be found on the intranet.

rcod aagm

[email protected]

LPL CC RM




: Primary acknowledgment should take place electronically on our intranet. Please use a paper acknowledgement only if youdo not have access to a computer. f a paper acknowledgment is necessary, submit it to your uman Resources representative or linemanager.

RM CWLGM

acknowledge that have received and read the homsonReuters Code of Business Conduct and thics and understandmy obligations to comply with the policies, principles and valuesoutlined in this Code.

understand that my agreement to comply with this Code doesnot constitute a contract of employment.

ame (printed):

Business unit:

homson Reuters mployee :

ignature:

ate:



his Code serves as a reference to you. homson Reutersreserves the right to modify, suspend or revoke this Code and anyand all policies, procedures, and programs in whole or in part, atany time, with or without notice. homson Reuters also reservesthe right to interpret this Code and these policies in its solediscretion as it deems appropriate.

either this Code nor any statements made by any employee

of homson Reuters, whether oral or written, confer any rights,privileges or benets on any employee, create an entitlement tocontinued employment at homson Reuters, establish conditionsof employment, or create an express or implied employmentcontract of any kind between employees and homson Reuters.

n addition, all employees should understand that this Code doesnot modify their employment relationship, whether at will orgoverned by a written contract.

he version of this Code that appears online atwww.thomsonreuters.com may be more current and up-to-dateand supersedes any paper copies or previous versions shouldthere be any discrepancy between paper copies, previous

versions and what is posted online.tHOsOn reuters

www.thomsonreuters.com

LGL C

Documents

Thomson Reuters Code of Business Conduct English 20080423c