LSE is a UK market operator and therefore subject to the Markets in Financial Instruments Directive (MiFID II) and Regulation (MiFIR), together with the associated rules and guidance issued by ESMA and the FCA, and the Companies Act 2006 (the Act) (together the Applicable Legislation).
Under Applicable Legislation, LSE is required to comply with a number of provisions which impact the composition and governance of the Board including that directors perform their duties independently and objectively
In line with Applicable Legislation, this policy provides guidelines on identifying and managing conflicts of interest and assists directors and prospective directors with the procedures to be followed in the event that an actual or potential conflict of interest is identified. This policy shall apply to directors and prospective directors.
This policy details (i) the general duties owed by directors to LSE, (ii) a non-exhaustive list of situations where a conflict of interest may arise, (iii) the directors’ duty to promptly disclose any circumstance that may result or has resulted in a conflict of interest and (iv) the consequences of non- compliance with the policy.
As a leading international exchange group, we at London Stock Exchange Group (LSEG), appreciate our responsibility for setting an example in ethical business practice.
In response to the UK Bribery Act (which entered into force on 1 July 2011), we have made every effort to review our practices, identify potential risks, and raise awareness of the Act amongst our employees and stakeholders in Italy, Sri Lanka and the UK.
The LSEG Anti Corruption Policy makes clear the specific responsibilities of all of our employees and business partners and we require all our employees, partners, agents, suppliers and customers to comply with the new regulation.
Involvement in the activities covered by the Bribery Act by any of our suppliers, customers, partners and agents can lead to termination of all the relevant agreements and relationships with our Group.
In light of the increased and broadly defined offences described in the UK Bribery Act, the LSEG has made a concerted effort to raise employees’, suppliers’, customers’, partners’ awareness of the continued responsibilities to comply with the new broader regulation.
LSEG has a zero tolerance policy regarding bribery that is fully backed throughout the business and by the Board of Directors and the Executive Committee.
We remain committed to ensuring that all of our operations continue to comply with the UK Bribery Act and that our policy implementation procedures are constantly monitored and updated.