Business Ethics and Integrity

Our leaders set the tone from the top and our expectations are reinforced through our governance structure and key policies, standards and procedures that guide behavior across the organization.

Our Code of Business Ethics (COBE) serves as a blueprint for all our actions. Accessible in 11 different languages, it lays out clear expectations for ethical behavior within our own team and in our dealings with others. All employees are required to complete our annual COBE Training and Affirmation, with noncompliance resulting in disciplinary action, up to and including termination. Additional ethics training may also be required based on risk profiles, job roles and geographic locations.

The COBE is also a key focus of our leadership, with the CEO closely monitoring the annual COBE training campaign and the Board of Directors receiving annual updates on completion rates. The company also maintains a Code of Business Conduct and Ethics for Directors, which guides Board members on areas of ethical risk.

In 2023, we made several additions to the COBE, including new sections on close personal relationships, international sanctions and communications systems, and a Q&A on divisional independence and objectivity. We also made timely updates to other key ethics policies, including our Acceptable Use Policy; Anti-Bribery and Corruption, Economic Sanctions, Anti-Money Laundering and Other Financial Crimes Policy; Digital Communications Policy; Gifts and Entertainment Policy; and others.

We continue to update our policies, training and other procedures in response to new and evolving issues. For example, we have added a new training module on artificial intelligence (AI) to the 2024 COBE Training and Affirmation and have updated the COBE 2024 Policy to include a Q&A on the use of social media and AI.

We strive to create a “speak-up culture” within the company, encouraging our people to raise issues and voice concerns regarding unethical conduct. To facilitate this, we offer multiple reporting avenues, including our EthicsPoint Helpline, which is available 24/7 and offers comprehensive, confidential reporting on workplace fraud, abuse and other forms of misconduct. The helpline is audited each year by a neutral third party. The Audit Committee of the Board of Directors receives an annual ethics update.

We do not tolerate retaliation against anyone who in good faith seeks advice, raises a concern or reports a suspected violation of the COBE or any other company policies.

We are committed to working against corruption consistent with Principle 10 of the United Nations Global Compact, as well as the United States Foreign Corrupt Practices Act, the United Kingdom Bribery Act of 2010, and other applicable laws. Senior management clearly articulates such as through our COBE, that S&P Global does not offer or accept bribes or kickbacks in any form, either directly or through third parties.

Our Financial Crimes Compliance Policy broadly prohibits bribery and corruption of any kind. It is the policy of S&P Global that all employees, agents, representatives, officers, directors and temporary staff are prohibited from giving or receiving anything of value – directly or indirectly – to or from any person, including government officials, customers or third parties, if it is intended or could reasonably appear as intended to obtain or retain business, gain a business advantage, influence a business decision or influence official action.

We maintain appropriate internal controls and mandatory reporting requirements in support of anti-bribery and corruption compliance. All vendors are required to comply with our Vendor Code of Conduct, which, among other things, strictly prohibits bribery and corruption in any form.

S&P Global has taken steps to ensure that relevant policies and procedures have been communicated throughout the organization, including through periodic training focused on anti-bribery and corruption and broader financial crimes compliance risk.

During the reporting period, we are not aware of any material allegations of violations or violations of anti-corruption laws by S&P Global.

S&P Global’s commitment to high standards of ethics and integrity extends to how we meet our tax obligations. Our approach includes compliance with the tax laws in every jurisdiction where we operate, as well as adherence to our Global Tax Policy, which was adopted in 2021. Our international team of experienced and qualified tax professionals, with the support of global third-party tax advisors, enables us to operate within a comprehensive tax control framework and to properly identify and manage tax risks and compliance obligations.

Where the tax law is subject to multiple interpretations or uncertainties, we balance the company’s duties of compliance and payment of appropriate taxes with its commitment to efficient operations. We emphasize strong internal controls and transparency with investors and tax authorities and provide disclosure of tax information in periodic financial reports.