Trust Matters
Code of Business Conduct and Ethics
2025
Exhibit 99.7
Contents
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Using and protecting our confidential information and other data |
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Personal use of social media and other online communications |
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© 2025 Thomson Reuters |
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The Thomson Reuters Code of Business Conduct and Ethics (Code) applies to all employees, officers and directors of Thomson Reuters Corporation and our majority-owned or controlled subsidiaries, as well as to consultants, contractors, temporary employees. Any third parties or agents (such as business partners) acting on our behalf or performing services for us should be made aware of their obligation to comply with the Code.
A global code
With thousands of employees around the world, Thomson Reuters operates under a wide variety of laws and regulations. Regardless of where we operate, our values and trust principles will not change. This Code underscores those values and principles and helps guide how we engage with our customers, our business partners (such as vendors, suppliers, agents, etc.), our colleagues and the communities where we work and live. The Code is also a resource to check policies, guide decisions and help employees and others understand when and how to Seek Help.
The Code applies in every country we do business. If it ever conflicts with local laws and/or supplemental policies that apply to our job, we must comply with the most restrictive requirement. If any of us have questions about how the Code might apply, we should Seek Help.
Regulated entities
Regulated entities within Thomson Reuters may have their own policies and procedures that apply to staff acting on their behalf. These policies always take precedence over Thomson Reuters policies addressing the same topic. Seek Help for more information.
Reuters journalists Because of the nature of their jobs, Reuters journalists have policies that, in some cases, are more restrictive than the company’s general policies (such as those relating to personal political activity) and, in some cases, may be less restrictive (such as reporting on what a third party might view as confidential). Reuters journalists should review the Handbook of Journalism and Seek Help for more information. Our responsibilitiesAccountability for everyone |
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Waiver In the unusual circumstance that you believe you may need a waiver of a particular provision of the Code, you should contact the Chief Legal Officer of Thomson Reuters. Any waiver for executive officers or directors may be granted only by the Thomson Reuters Board of Directors or a Board committee and will be disclosed by Thomson Reuters to the extent required by law, regulation or stock exchange requirement. |
All Thomson Reuters employees have an obligation to hold themselves and each other to the policies and high ethical standards described in this Code. This means we are each expected to read and understand our obligations to comply with the Code, as well as any supplemental materials that
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might apply to us, and act accordingly. If you are unsure about any part of the Code or supplemental materials, or how to access them, then please Seek Help.
Disciplinary action, up to and including termination and/or legal proceedings, may result from any failure to comply with laws, rules or regulations that apply to each of us, our Code, or any other Thomson Reuters policy or requirement.
Responsibilities of leaders and managers Leaders and managers at Thomson Reuters are expected to hold themselves to the same high standards that they demand of their teams. Leaders play an essential role in building a culture of transparency, open communication and trust that extends from colleagues to customers to external business partners. To help achieve this, leaders should: • Listen and take action when team members raise concerns — whether big or small |
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Managers We hold managers (which include supervisors) to an even higher standard and require them to raise or address any inappropriate conduct they learn of in the workplace, even if they are aware of it indirectly or have not received a specific complaint about the behavior. |
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applicable department will maintain records of any such reports or complaints, tracking their receipt, investigation, and resolution.
Fair process and disciplinary action
All reasonable efforts will be made to determine the relevant facts behind any reported violation and bring the investigation to a timely conclusion. If you become involved in an investigation, you are obligated to cooperate.
Failing to cooperate with an investigation may result in disciplinary action, up to and including termination and/or legal proceedings. Failure to cooperate includes:
The Trust Principles
In observing this Code, we must remember that the Thomson Reuters Trust Principles guide the conduct of every individual within the organization. These principles are not just a set of guidelines; they are an invaluable asset that defines Thomson Reuters, unifying our content and providing the bedrock for the trusted answers sought by our customers. The Trust Principles are:
The Trust Principles on TR.com
The Trust Principles on the Intranet
Purpose
Our company purpose is to Inform the Way Forward, reflecting our commitment to serving professionals, advancing critical institutions and building trust through our products and our actions.
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Purpose, in our context, extends beyond profit-making; it unites our commercial value and societal impact, shaping our core reason for existence and influencing every aspect of our business. This guiding principle informs our strategy, inspires our team, engages our customers and community, and is deeply embedded in our culture.
Our products and business play a central role in how we Inform the Way Forward by empowering the most informed professionals worldwide. Collaborating with our customers, we elevate knowledge, act with courage and integrity, and champion justice, truth, and transparency—values that underpin progress and create value.
Inform the Way Forward on TR.com
Inform the Way Forward on the intranet
Values
Our values serve as guiding principles that shape our culture and define our ways of working at Thomson Reuters. They drive decision-making and consistent behaviors, giving clarity for how we work, think and collaborate to deliver value to our customers
We put customers' goals, needs and challenges ahead of our own. We constantly innovate to ensure our customers help their clients succeed. We prioritize investments that drive customer value.
We are relentless about ensuring our solutions are superior to our competitors. We accomplish more by being tenacious, agile and resourceful.
The best ideas win at TR. We listen and challenge each other - offering alternative viewpoints with facts, candor and clarity. We have the courage to disrupt the market and ourselves.
We iterate in days - not weeks or months. We are willing to risk fast failure, and we quickly learn from our mistakes. We are decisive and commit to decisions, turning them into action.
We value our global team of talented people who are great at what they do, and even better working together. We have very high expectations for performance while also caring for each other. We face all challenges with humility, accountability and ownership.
Our Culture on the Intranet: Purpose | Trust Principles | Values
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Providing equal opportunities
We are trusted to. . .
. . .promote equal employment and provide reasonable accommodations for qualified individuals.
We are committed to complying with applicable laws, rules and regulations governing nondiscrimination wherever we do business and providing equal employment opportunities with regard to hiring, compensation, promotion, classification, training, apprenticeship, referral for employment and other terms of employment for all persons without regard to the classifications listed in the Anti-discrimination section of this Code.
We also make reasonable accommodations for qualified individuals with disabilities and for colleagues with sincerely held religious beliefs. For these purposes, a “reasonable accommodation” is a modification or adjustment to job duties or the work environment that enables an employee to perform the essential functions of the job while not putting undue hardship on Thomson Reuters.
Contact your manager or Human Resources if you believe you require an accommodation to perform the essential functions of your position, need a religious accommodation or have questions.
Human Resources Global Policies
Connecting the dots I’m considering two job candidates who have similar qualifications on paper. One has a physical disability that may hamper the ability to get around the office. Am I allowed to factor this trait into my evaluation of the candidates? You should not assume that a disability will limit someone’s ability to perform his or her job. However, if you reasonably believe the disability would legitimately affect the individual’s ability to perform the essential functions of the job, you should contact human resources to discuss whether reasonable accommodations could be made. |
Embracing inclusion and belonging
We are trusted to. . .
. . .foster an inclusive workplace and a workforce that reflects the wide range of customers and communities we serve.
Why it matters:
We work best in partnership. When our workforce has an extensive range of skills, expertise and experiences, it enhances our abilities as colleagues to partner with each other and with our customers. The more perspectives we can provide, the more potential there is for innovation. The more that all employees feel valued and free to reach their full potential, the more trust can develop
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among all of us. In short, a commitment to inclusion and belonging not only honors our values but also fuels our competitive edge in the global marketplace.
How we deliver:
We foster an inclusive workplace where all colleagues are valued and have the opportunity to reach their full potential.
We embrace a range of perspectives, experiences and styles. We know this drives innovation and delivers a competitive advantage.
Fostering a respectful workplace
We are trusted to. . .
. . .actively foster a work environment where everyone is treated with dignity and respect.
Why it matters:
When discrimination, harassment and bullying are allowed to take root in a workplace, they inhibit communication and damage productivity. We cannot properly share ideas and concerns or work together as a team if any member of our team or partnership feels targeted or unsafe. Additionally, these types of acts may leave us vulnerable (as individuals and as a company) to fines, lawsuits and civil or even criminal proceedings.
By putting a premium on fairness, equality, respect and dignity and not allowing discrimination, harassment and bullying, everyone who enters our workplaces should feel protected and empowered to achieve their full potential.
How we deliver:
Anti-discrimination |
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We do not tolerate discrimination. This means we do not allow unequal treatment on the basis of: |
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• Race, color or ethnicity |
• Age |
• Disability |
• Religion |
• Gender identity or expression |
• Veteran Status |
• Sex or gender • Pregnancy • Sexual orientation |
• Marital status • National origin • Citizenship status |
• Any other classification protected by applicable laws or regulations |
Harassment and bullying
We also do not tolerate harassment of any kind at our workplaces, including sexual harassment and bullying. We support dignity in the workplace without regard for whether the person engaging in the
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Keeping workplaces safe, secure and healthy
We are trusted to. . .
. . .ensure a work environment where health, safety and security are paramount.
Why it matters:
A safe and healthy workplace not only protects us from harm but also builds trust, prevents costly accidents and enhances the company’s reputation as a responsible corporate citizen.
How we deliver:
Health and safety
To conduct business operations and activities in a manner that prevents injury and ill-health for employees, customers, visitors and contractors, protects the environment, conserves natural resources and positions us as a responsible neighbor, we:
Security
We do our part to ensure the security of our workplaces by:
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Threats, workplace violence and weapons
We do not tolerate acts or threats of violence, intimidation or hostility in our workplace, whether directed at colleagues, vendors, suppliers, customers, or visitors. We also do not allow:
This may extend to activities outside of work if they adversely affect the company’s reputation or interests or the safety of our employees.
If you feel someone is being threatened or subjected to violence, are concerned that someone may cause harm to him or herself or see something suspicious, move out of harm’s way, call the local police, follow the instructions of emergency authorities and call Global Security and Human Resources. If there is a life-threatening emergency, contact the local police or emergency services first, then Global Security and Human Resources.
Security Incident Report Form
Global Security
Workplace Violence Prevention Policy
Environmental, Health and Safety Policy
Connecting the dots I have a domestic issue at home that affects my personal safety. Do I need to disclose it at work? If you have a domestic or personal issue that may apply to or affect safety in the workplace (e.g., an order of protection or a restraining order), you should report it to Human Resources and Global Security. That is the best way to help ensure not only your safety but also that of your colleagues. Also see the Workplace Violence Prevention Policy. |
Drugs and alcohol
Drugs and alcohol can be a danger to everyone in the workplace. Thomson Reuters does not allow the possession, use, purchase, sale, attempted sale, distribution, manufacturing or being under the influence of illegal drugs in its workplaces.
We also do not allow the abuse or misuse of alcohol, prescription drugs or other impairing substances in the workplace, whether your workplace is in the office or remote working, or when conducting company business. This means we:
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Employees in violation will be subject to disciplinary action, up to and including termination. Violations also could lead to arrest and prosecution by law enforcement if such violations involve illicit drugs or other illegal activities.
Where permissible by law, Thomson Reuters reserves the right to take appropriate steps to investigate compliance with the Code and other applicable policies, including but not limited to drug and/or alcohol testing by qualified medical professionals and searches in the workplace.
If you believe someone in the workplace may have an issue with substance abuse or may be impaired, contact your manager or Human Resources.
Connecting the dots If I have a problem with substance abuse, does the company offer any help? Thomson Reuters offers a number of employee programs that may provide assistance. Please ask Human Resources about available services in your location. |
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Recognizing and avoiding conflicts of interest
We are trusted to. . .
. . .act in the best interests of Thomson Reuters and avoid situations that even appear to compromise our judgment.
Why it matters:
A conflict of interest may arise whenever our personal interests as individuals interfere, or appear to interfere, with the interests of the company. Conflicts of interest also can arise if we take actions or have interests that may make it difficult for us to do our jobs objectively and effectively.
If broken, the bonds of trust that we have developed over time with customers and partners can be difficult to rebuild. By knowing how to recognize and disclose or avoid potential conflicts, we protect our reputation and our ability to do business effectively.
How we deliver:
We avoid real or perceived conflicts of interest, at all times, by doing the following:
Keep in mind that not all conflicts are prohibited. Some conflicts of interest are permissible if they are disclosed and approved. Below are some of the more common areas where conflicts arise.
Corporate opportunities
We may not take for ourselves any opportunity that was created or discovered through the use of company property, information or other resources or through our position at the company. This means we:
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interfere or conflict with your role at TR or our work with a partner or customer. This means that while working for Thomson Reuters, we each:
Practicing law on behalf of Thomson Reuters
Thomson Reuters employs many individuals with law degrees who also may be licensed to practice law. It is important to remember that only lawyers in the General Counsel’s Office (GCO) or those who are working at the direction and under the supervision of the GCO, may practice law or provide legal advice on behalf of Thomson Reuters. This means that while working at Thomson Reuters, employees who do not meet the above criteria may not, among other things:
If you are unsure if you meet the criteria to practice law on behalf of Thomson Reuters, please contact ECHelp@thomsonreuters.com.
Organizational conflicts of interest
When dealing with the government, we avoid situations that might give Thomson Reuters an unfair competitive advantage or that could affect our ability to perform work objectively as individuals.
This means we:
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We are trusted to. . .
. . .compete vigorously, fairly and openly.
Why it matters:
Anti-competitive practices harm customers and distort markets. These practices severely damage our relationships with customers and partners by eroding their foundational trust. Competition and antitrust laws prohibit making agreements with competitors, customers, suppliers or other third parties that limit competition. Even though competition laws are complex and dynamic, we are expected to know the law in this area. If we fail to act lawfully, we can hurt the company’s reputation and leave Thomson Reuters and ourselves open to the potential of substantial fines and even criminal prosecution.
How we deliver:
Fair dealing
We treat our competitors, customers, suppliers, partners and security holders with fairness and respect. This means we:
• Comply with the letter and spirit of applicable laws • Recommend only products, services and solutions that we believe are the proper fit for each customer’s needs • Remain transparent and forthright in all contracting • Award contracts based on merit and clearly defined benchmarks • Provide accurate and timely documentation • Deliver on what we promise • Are honest and accurate in advertising and marketing claims, avoiding exaggeration, misrepresentation, and ambiguity • Take special care when making comparative claims and do not disparage or unfairly criticize a competitor’s products or services • Do not gather competitive intelligence in unlawful or unethical ways (see Competitive Intelligence in the Code) |
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Seek advice before you act We often negotiate agreements with customers, suppliers and distributors. To avoid antitrust issues, seek advice from the General Counsel’s Office before you: • Use customer pricing (such as deep discounts) or licensing terms to keep out or unduly hinder competitors • Sell anything below cost • Tie the sale of any product, service or discount to another product • Enter an exclusive dealing or lock-in agreement • Treat customers, suppliers or distributors inequitably for the same products • Restrict a distributor in terms of whom they can sell to and at what price or agree to a similar restriction on Thomson Reuters where we resell third-party products or services • Impose any non-compete or other similar restriction, or accept a similar restriction on Thomson Reuters |
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Competition and antitrust
We abide by all competition and antitrust laws that apply to us, avoiding situations that could put us at risk of even appearing to violate these laws. This means we do not engage in discussions with competitors to:
Because competition and antitrust laws are so complex and there are some exceptions and variations from country to country, you should consult ECHelp@thomsonreuters.com before taking any action that might be considered anti-competitive. For more information, see CompetitiveIntelligence Policy, Competition Guidelines, Creating Better Documents, Competing FairlySummary Flyer and other related resources.
Connecting the dots. . . I attended a conference recently, and an employee of a competitor struck up a conversation with me about a new product they just launched. She didn’t say anything about pricing or profits, but I felt uncomfortable. What should I do in this situation? If you feel uncomfortable about any conversation with a competitor, it’s best to exit that conversation as quickly and as gracefully as possible. Remember, even if the employee didn’t reveal pricing or other sensitive information, she may have said something that could appear to violate antitrust laws to someone listening. Contact the General Counsel’s Office if you need more clarification or want to confirm that nothing happened that could be or could appear to be a violation. |
We are trusted to. . .
. . .act as responsible citizens in the global marketplace, relying on our performance and innovation, not on bribes or other corrupt practices, to earn business.
Why it matters:
Bribes, corruption and illegal payments all have a deeply damaging impact on our society. They can harm economies, destabilize governments and undermine public trust. These types of actions can result in Thomson Reuters being prohibited from bidding on contracts. In addition, they can result in both personal and company fines and even imprisonment. As a team of thousands of professionals working around the world, we have both the power and the obligation to fight bribery and corruption wherever we encounter it. By embracing this responsibility with the business partners with whom we engage on a daily basis, we continue to bolster the reputation of Thomson Reuters. We also protect the communities where we work and help level the playing field, as we should win on the merits of our performance as individuals and as a company.
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How we deliver:
Anti-bribery and anti-corruption
We do not tolerate bribery or corruption in any form. This applies to both the public and private sectors. We take reasonable steps to ensure Thomson Reuters business partners, including vendors and other third parties do not engage in illegal or unethical actions when acting on our behalf. We expect all Thomson Reuters business partners to meet these standards, understanding that we can be held liable for their actions, which — good or bad — reflect on the company. This means we:
• If we are offered a bribe, asked for a bribe or asked to make a facilitation payment Report it to our manager and ECHelp@thomsonreuters.com • Do not offer or accept bribes or kickbacks • Do not make facilitation or “grease” payments, even if they are legal in the country where requested • Offer or accept only reasonable hospitality and business expenses • Record all payments and receipts honestly and accurately • Carry out a level of due diligence appropriate to the risk before we engage business partners • Communicate our Anti-Bribery & Anti-Corruption Policy to business partners at the outset of our business relationship and as appropriate thereafter • Watch out for red flags, including vague descriptions of payments or services, payment requests in exchange for approvals or signs of over-invoicing or false invoicing • Mitigate or terminate business as relationships as appropriate if we learn that a business partner may have violated our standards |
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The many forms of bribery Bribes can take the form of anything of value being offered or given in exchange for, or as a reward for, favorable treatment. There are many business interactions that can go from legitimate to corrupt when motivated by an intention to obtain favorable treatment, including providing or accepting: • Cash or cash equivalents • Facilitation payments • Unreasonable gifts, entertainment or hospitality • Unexplained or excessive rebates, discounts or commissions • Loans • Invoices for disguised expenses • Excessive goods or services for personal use • Free use of Thomson Reuters services or facilities • Favors (such as the hiring of a relative) • Charitable donations • Job offers or promises of future employment, or paid or unpaid internships |
Anti-Bribery & Anti-Corruption Policy
Government Contracting Policies
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Identifying government officials Dealing with government officials poses a particularly high risk due to the strict rules and regulations that often apply to giving anything of value to a government official. Some government officials are easy to identify, but others may not be. Government officials can include: |
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• Elected officials • Law enforcement officers • Customs officials • Inspectors |
• Employees of government facilities • Employees of state-owned or controlled entities, such as some oil firms, public utilities, and universities and media companies • Military personnel and support teams |
Connecting the dots What is a facilitation or “grease” payment? A facilitation or “grease” payment is a small payment made to a government official to secure what should be a routine action, such as processing a visa, issuing a permit or providing a utility service. This does not include official payments, such as those where a government agency has a published fee schedule for a service equally available to anyone and provides a receipt. Thomson Reuters prohibits its employees and representatives from making facilitation payments, even if it is legal in the country where the payment is taking place. Seek Help if you have any questions about facilitation payments. If you must make a payment to protect your liberty or safety, notify your manager as soon as possible and know that such extraordinary events will not be treated as policy violations. |
Gifts and entertainment
We use our best judgment in the giving and receiving of gifts to avoid even the appearance of improper influence. This means we:
Anti-Bribery & Anti-Corruption Policy
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Determining what is “not excessive in value” requires your good faith judgment. It may change depending on the situation. |
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Acceptable gifts and entertainment generally include: • Promotional items with company logos • Routine tickets to a local sporting or cultural event • Gifts of nominal value that are customarily given on national holidays • Prizes randomly given or received through raffles, contests or industry events • Meals and entertainment of reasonable value when business is being conducted |
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Unacceptable gifts and entertainment generally include: • Cash • Certain cash equivalents (e.g., gift cards) • Luxury goods • Events, trips or meals where there is no clear business purpose being conducted • Anything of value given to or received from a government official |
If you aren’t sure whether you should offer or accept a gift, ask yourself:
If you have questions about whether any gift, meal, service or entertainment would be acceptable under the Code, contact your manager or ECHelp@thomsonreuters.com.
Connecting the dots We engaged a local agent with good connections to help us secure a government contract. He wants to give a bottle of expensive liquor to the government official who signed off on the contract and insists that it’s customary to do so. Could we get in trouble for that? Yes, Thomson Reuters can be held responsible for the actions of the agents we hire. You must tell the agent from the start not to give gifts to a public official. More importantly, before engaging such a person, it’s important to conduct due diligence on the agent and get a contractual assurance that no improper payments will be made on behalf of Thomson Reuters. |
Sanctions, embargoes and export controls
Sanctions and export controls can be complex and ever changing. As a company known for its information and resources to enable our partners to navigate difficult legal questions, it is imperative we understand and abide by these laws and regulations. That is why we are committed to following sanctions and export compliance requirements applicable to us. This means we:
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Trade Controls Handbook and Policies
Connecting the dots Recently, one of my customers asked whether some employees in their organization who work in a sanctioned country could subscribe to one of our online software products. Can we add them as subscribers since we wouldn’t be exporting a physical product? Most likely not. Export controls cover software as well as hardware and equipment. It also appears your customer may be representing individuals or entities from that sanctioned country Seek Help before taking any action. |
Anti-money laundering
Money laundering is the process by which funds generated through criminal activity (such as terrorism, drug dealing or fraud) are processed through commercial transactions in order to hide the source of the proceeds, avoid reporting requirements or evade taxes. We follow all anti-money-laundering and anti-terrorist financing laws that are applicable to us and do not condone or facilitate money laundering. This means we:
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We are trusted to. . .
. . .ethically and responsibly design, develop, deploy and use artificial intelligence (AI) solutions, whether internally, in partnership with a third party or in the service of a customer.
Why it matters:
Thomson Reuters is committed to inform the way forward by embracing the many opportunities AI presents while recognizing the unique challenges and risks. As the landscape of AI evolves, it will challenge our ways of thinking and our ways of working. What must not change is our commitment to our Trust Principles and our Data and AI Ethics Principles.
How we deliver:
Data and AI Ethics Principles
We will responsibly deploy artificial intelligence solutions governed by our Data and AI Ethics Principles to promote trustworthiness in our continuous design, development, and deployment of AI and our use of data, as follows:
We believe these Data and AI Ethics Principles will provide our colleagues and partners with the right foundations to build reliable and trustworthy AI for our customers and ensure the responsible use of
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AI solutions internally. The Data and AI Ethics Principles will evolve as the related industries continue to grow and develop.
When designing, developing, deploying or using AI solutions, it is your responsibility to follow our AI principles, policies, and guidelines. For more information, visit Data and Model Governance, Data & Model Governance Policies & Standards and All Things AI. |
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Reuters Reuters uses AI in several ways to improve its news reporting and delivery. AI Guidance for Reuters Journalists AI Journalism Handbook entry AI @ Reuters |
We are trusted to. . .
. . .protect all intellectual property against misuse, whether it belongs to Thomson Reuters or to someone else.
Why it matters:
Intellectual property is the lifeblood of our business. From the systems and databases we create to empower our customers with information, to the news stories we write, to the processes we use in our workplaces, intellectual property is vital to our company’s identity. Knowing how important it is to us and to others, we have a special obligation to protect the intellectual property that we create and to defend all intellectual property against improper use. By doing so, we put our company, our colleagues and ourselves in the best position to innovate and win in the marketplace.
How we deliver:
We recognize when intellectual property should belong to Thomson Reuters and take all necessary action to protect it. This means we:
• Agree, to the extent permitted by law, that Thomson Reuters owns all intellectual property (and related rights) that we create during the course of our employment, whether we create them in the office, at home or elsewhere, if they are related to company business or created with company resources • Waive or assign to Thomson Reuters all moral rights we may have under applicable law to intellectual property that we create as employees |
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What are moral rights? Moral rights are rights relating to intellectual property, and they include the right to be recognized as the creator and the right to the integrity of any works created. The waiver or assignment in this Code is designed to ensure that Thomson Reuters can take any action concerning works created by you during your employment with Thomson Reuters. |
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Connecting the dots My team would like to use information held in a public database for an upcoming project. Is this allowed under Thomson Reuters policy? Even if it appears to be accessible by the public, some information still may be subject to intellectual property protection. Contact the General Counsel’s Office for guidance. |
Intellectual property of others
We respect the intellectual property of third parties, including competitors, and do not use it in any way that would violate the law or our values. This means we:
• When necessary, get written permission to use or copy a third party’s copyrights, patents, trademarks or other intellectual property, obtain licenses or, if the circumstances require it, purchase the intellectual property outright • Ensure licensing agreements permit copying or distribution where necessary and do not impair the company’s rights before we copy or distribute third- party content, data, software or technologies • Ensure intellectual property belongs to and is assigned to Thomson Reuters when it is created for us by third parties or contractors, where allowable by law |
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What is intellectual property? Examples include: • The Thomson Reuters name and brand names that we use • Copyrights, patents, service marks • Innovations, Ideas, Processes • Trade secrets • Software • Designs • Images • Data |
Connecting the dots I was driving home from work the other day and came up with an idea to improve one of our products. Does it ultimately belong to me or to Thomson Reuters? This idea is the intellectual property of Thomson Reuters, as it likely was the result of knowledge, resources and opportunities obtained through your employment with the company. If you think it’s a viable idea, you should share it with your manager. |
Competitive intelligence
We live our values of performance and innovation by striving to better understand our competitors through extensive research and study. We obtain intelligence about our competitors only through lawful and ethical channels. In addition to following our rules on respecting the intellectual property rights of others, we ensure that we:
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Before seeking out or using any competitive intelligence, make sure you understand our Competitive Intelligence Policies and Guidelines. If you have any questions about how to apply these guidelines, contact the General Counsel’s Office.
Connecting the dots I recently joined Thomson Reuters from a competitor, and I have knowledge about some of this competitor’s processes. Some of this information is confidential, and some, I believe, is not. What can I use in my work or share with my Thomson Reuters colleagues? You must not keep or share documents— in any format— related to the competitor’s business that you possessed as an employee of that competitor. Even in the case of information you simply remember, if the information is confidential, you have a personal legal obligation to your former employer to protect it from disclosure, just as you would with Thomson Reuters confidential information if you left the company for a competitor. Sharing such information with Thomson Reuters could also put you and us at risk legally. For the information you recall that you believe is not confidential, it is best to contact the Enterprise Compliance team before revealing it to anyone. |
Protecting confidential information and data privacy
We are trusted to. . .
. . .safeguard and protect the confidentiality and privacy of information that we hold and prevent it from being improperly accessed, shared, or lost.
Why it matters:
Our competitive advantage is built on the secure and ethical management of data, including our own confidential data and sensitive data entrusted to us by others. Failure to handle data correctly can lead to market disadvantages, harm to consumers, legal consequences, and damaged business relationships.
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How we deliver:
Confidential information
Employees with access to nonpublic information about Thomson Reuters, our operations, customers or partners must treat such details as confidential. Disclosure is prohibited unless expressly authorized as required for legitimate business purposes.
Strictly Confidential and Confidential information includes some of our most valuable assets, such as the following examples: • Trade secrets • Pricing information • Nonpublic financial information and customer information • Legal documents and privileged communications |
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Reuters journalists should follow the policies and requirements of the Handbook of Journalism and seek guidance from their manager or the General Counsel’s Office. Handbook of Journalism |
Data Security Data Classification Standard
Information Security Policies & Standards
Important information security practices There are many ways to protect data effectively. For example: • Remember that public instant messaging services including, but not limited to, WhatsApp and Signal are unapproved for conducting TR business • Put sensitive documents in locked files or drawers • Use shredders or secure shred bins when discarding confidential information • Use password protection on computers, other devices, and sensitive documents • Use encryption when storing and transmitting confidential information • Take care when accessing information in areas where members of the public or other unauthorized persons, including other colleagues, might see it • Securely back up devices on a regular basis • Use caution when connecting to public Wi-Fi and comply with the Information Security Handbook Report damaged or lost laptops and other devices, security incidents, and personal data breaches immediately to security@thomsonreuters.com. |
Report data breaches! Any time we know or suspect that a breach of data security has occurred, whether accidental or intentional, we must report it immediately to security@thomsonreuters.com. Doing so promptly can mitigate the effects of the breach and help us take the right actions quickly to manage the incident, secure the data and reduce the risk of future breaches. |
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Data protection and privacy
Data protection and privacy are governed by rapidly evolving laws and regulations. Use the following references to stay informed, and consult the Privacy Office Legal Front Door for guidance on personal data collection, use, retention, and transfer. For more information visit: Privacy Office on the Intranet and the Information Security Handbook.
Using and protecting our confidential information and other data
We have established information security and privacy policies to safeguard confidential and personal data. Pursuant to the Thomson Reuters Privacy Program, employees are expected to:
Privacy Office Policies and Procedures
Information Security Handbook
Connecting the dots A customer recently told me he doesn’t want to receive marketing e-mails from Thomson Reuters. What should I do? You must action the customer's request as a marketing opt-out within 10 business days. See the Marketing Privacy Guidelines for more information. |
I received a request from an individual seeking access to the personal data we hold about them and asking us to correct and delete that data. What should I do? Ask the individual to fill out this webform for the most efficient processing: Data Subject Request Form. |
Insider trading
Some of us have access to material nonpublic information about Thomson Reuters, our customers, suppliers or other companies with which Thomson Reuters either does business or is negotiating a significant transaction or agreement. Misuse of material nonpublic information could result in violations of insider trading laws and carry severe penalties. We are careful to treat this “inside information” lawfully and ethically. This means we:
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If you are not sure whether certain information is considered material or nonpublic, consult the
General Counsel’s Office for guidance before engaging in any securities transactions.
Insider Trading Policy
Inside information Whether information is “material” and “nonpublic” depends on the facts and circumstances. Information is material if it would, if generally available, reasonably be expected to result in a significant change in, or have a significant effect on, the market price or value of any securities. Information also is material if it would have a significant influence on a reasonable investor’s investment decisions. Information is nonpublic if it is not generally known or available to the public through an official company communication, such as a press release, website posting, securities filing or distribution to shareholders or through widely reported media coverage. Examples of material nonpublic information may include: • Earnings results and any future financial forecasts or outlooks that have not been publicly disclosed • Significant changes in business operations or strategies • Significant potential acquisitions or sales • Cybersecurity or other technology-related risks and incidents, including vulnerabilities and breaches • Gains or losses of major suppliers or customers • Introductions or launches of new, significant products or services • Changes in senior management or our Board of Directors • Actual or threatened significant lawsuits or material government or regulatory investigation |
Insiders We have designated certain people as “Thomson Reuters Insiders” because of their position, managerial responsibilities, or access or potential access to material nonpublic information about the company. Thomson Reuters Insiders are subject to additional restrictions related to trading in securities of our company. |
Using information and communications systems responsibly
We are trusted to. . .
. . .respect company communications systems and use them appropriately so that they operate as efficiently and effectively as possible.
Why it matters:
Nearly all of the work Thomson Reuters does on a daily basis runs in some way through our information and communications systems. When we each take personal responsibility for using these systems properly, it protects the integrity of the data we store and transmit, and it ensures that we all have prompt access to the systems we need to help our company thrive. Likewise, improper use leaves us all vulnerable to hackers, data breaches, shutdowns and miscommunications, as well as legal repercussions.
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How we deliver:
We use company information and communications systems properly. This means we:
• Never use, download or redistribute personal, unauthorized or copyrighted software on work devices • Never share user IDs, passwords, access details, software, services or authentication devices (e.g., SecureID tokens) that are intended for individual use to gain access to a system • You must only use Thomson Reuters authorized collaboration tools and devices for official Thomson Reuters business |
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Monitoring and recording Where permitted by applicable law, Thomson Reuters reserves the right to monitor and record your use of information, communications, technology or infrastructure owned or supplied by Thomson Reuters. |
For more information see: Information Security Handbook, Data Loss Prevention Standard, Mobile Device Management Standard, and Mobile Device Use Policy
Connecting the dots Can I use my company e-mail address to send personal e-mails to my friends? Yes, as long as you limit this practice, follow our policies and guidelines, and do not let it interfere with your work. It’s important to remember when discussing personal matters on company systems that any message you send or receive through company communications systems and devices — including email, social media, and text or SMS messages — may be the property of Thomson Reuters and may be accessed by the company. |
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We are trusted to. . .
. . .use company assets properly and protect them against loss, theft, misuse, damage and waste.
Why it matters:
Thomson Reuters computers, phones, office supplies and facilities exist for the purpose of helping us all maximize our performance as individuals, as a team and as a business. By respecting these assets, we ensure they remain accessible and fully functional when our customers and colleagues need them. We also help make sure company time and resources are used on positive initiatives, not on fixing preventable problems.
How we deliver:
We use company assets for legitimate and authorized business purposes only. We consider misappropriation, carelessness or waste of assets to be a breach of our duty and the taking of assets from company property without permission to be theft. This means we:
Global Security
Information Security
IT Workstation Policy
Examples of assets of Thomson Reuters include: • Computers, printers, copiers, scanners and monitors • Phones, laptops, tablets and other mobile devices • Intellectual property, such as software codes, licenses, brand names, business plans and inventions • Buildings and other physical property • Office supplies and equipment • Customer, supplier or distributor lists and information • Memos, notes and other documents made by us or a third-party business partner |
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We are trusted to. . .
. . .maintain records that are in accordance with company accounting policies and legal requirements.
Why it matters:
We are a publicly listed company, and our global operations require us to comply with various securities and financial reporting obligations. When we take accountability for ensuring the financial records that we handle are accurate and complete, we protect the company’s reputation for integrity and uphold our commitment to trust. Reliable financial reporting allows shareholders to fairly assess our performance, provides management with information to allocate our resources most effectively and prevents violations.
How we deliver:
We produce accurate, fair and timely records for management, directors, shareholders, government regulators and others. This means we:
Disclosure Controls and Procedures
Connecting the dots A contractor has asked us to make a payment to a company for his services instead of to him personally. We previously engaged the contractor in his own name. Is this permissible? No. Payments to vendors and contractors must be supported by appropriate documentation. They also must be accurate and complete, which includes making payments to the same person or company that we engaged. |
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Tax payments and records
We have the responsibility to ensure that reasonable procedures are in place to prevent those acting on behalf of Thomson Reuters (including employees, agents, contractors, service providers, distributors and other associated persons) do not knowingly facilitate the evasion of taxes (for ourselves or those with whom we do business) anywhere in the world.
Tax evasion includes activities such as: failure to register as a taxpayer in a local jurisdiction, under-reporting of income, claiming non-allowable expenses, issuing invoices for services not received, backdating documents, deliberately mispricing assets or helping to move assets/funds knowing that tax will be evaded as a result.
Raising concerns
We have a responsibility to raise good faith concerns about questionable financial matters. The Audit Committee of the Thomson Reuters Board of Directors is committed to facilitating employee efforts to make these concerns known and has established procedures for how to treat complaints about accounting, internal controls, auditing matters and disclosure controls. This includes procedures for receiving, retaining and processing such complaints, as well as for submitting confidential and anonymous concerns.
In addition, it is unlawful to fraudulently influence, coerce, manipulate or mislead any independent public or certified accountant who is auditing our financial statements.
Learn more about reporting fraud in the Protocol for Internal Reporting and Investigation of a Fraud Allegations Policy. Anonymous reports may be submitted to the Ethics Hotline.
Reportable fraud Report to your manager or the Ethics Hotline, any type of fraud or dishonest activity that you have seen or suspect, including: • Questionable transactions with customers, agents, vendors or other consultants • Forgeries or other alterations of documents • Billings that are higher or lower than agreed-upon prices for products or services • Payments made for any reason other than described in a contract • Payments made through intermediaries that deviate from everyday business transactions • Transfers or deposits in the bank account of an individual instead of the company we contracted with • Embezzlement, theft or misappropriation of company or customer assets • Verbal arrangements with customers or unauthorized written agreements that are outside of an official contract • Any activity intended to unfairly influence commission payments |
Reportable auditing and accounting issues Promptly report to your manager or the Ethics Hotline, any complaints or concerns involving: • Fraud or deliberate errors in preparation, maintenance, or review of any Thomson Reuters financial statement or record • Deficiencies or noncompliance with internal accounting controls • Misrepresentation or false statements to or by a senior officer or accountant regarding financial audits or records • Deviations from full and fair reporting of the company’s financial condition |
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We are trusted to. . .
. . .properly maintain and dispose of electronic and physical records.
Why it matters:
As a largely information-based business, Thomson Reuters generates thousands of business records every day, in addition to financial records. These records must be created, stored and disposed of according to strict legal requirements. When we can access records in a timely fashion, we provide better service to our business partners and we avoid risks around audits, regulatory issues or litigation. At the same time, records kept past their disposal dates can create avoidable information security, privacy or legal risks.
How we deliver:
We care for, store, retrieve and dispose of our business records according to applicable records management policy. This means we:
• Consistently organize our filing, storage and retrieval of electronic and physical recorded information • Use the proper storage method specified by legal, fiscal, regulatory or operational requirements • Protect records from loss, damage or deletion • Retain all records related to any pending or threatened litigation or government investigation until otherwise directed by the General Counsel’s Office |
What is a record? A record is any recorded information (electronic or physical) made or received and retained by an organization in pursuance of legal obligations or value to the government or in the transaction of business. |
It may be a criminal offense to destroy or falsify documents or emails related to a legal proceeding. Contact ECHelp@thomsonreuters.com if you have legal questions about whether a document should be retained.
For more information on how long to maintain certain categories of records, see our Records & Information Governance.
Connecting the dots How long do I need to retain emails and other messaging? If an email is not part of a business record and has served its business purpose and there is no legal or regulatory obligation to retain it, it should be deleted. If an email is part of a business record or there is a legal or regulatory obligation to retain it, you should remove it from your work email account and store it in an appropriate manner for future reference by the company (e.g., in a cloud folder related to the record). If you are subject to a “legal hold,” you should always retain emails until you’ve been notified by the General Counsel’s Office that the hold has ended. |
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We are trusted to. . .
. . .sign contracts or agreements on behalf of Thomson Reuters only if we are authorized.
Why it matters:
Miscommunications or errors made in contracting can cause loss of business, delays, legal action, fines, and ultimately damage the trust we have built with our customers and business partners.
How we deliver:
We strive to deliver and receive the promises in our contracts and agreements. This means we:
• Consult the Procurement team (Global Services) for third-party vendor or supplier contracts and follow Procurement policies • Ensure that any contract or proposal is carefully reviewed and properly authorized and executed by the appropriate signatories and legal entities • Do not provide or agree to unapproved non-standard terms or unauthorized “side letters” to customers or business partners • Ensure complete, accurate documentation of contracts, related orders and customer status in applications to process customer accounts • Follow the rules that govern public procurement when providing products and services to governments and ensure compliance with the Government Contract Compliance Policy |
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Unauthorized side letters may bind us to something we cannot deliver or expose us to unwanted liability. They are undisclosed, unapproved letters, e-mails, notes or oral agreements that vary contract terms, and can include: • Early outs, or the ability for the customer to terminate before the contract expires • Guarantees that the customer will achieve certain milestones • Statements that directly contradict parts of the contract, including payment terms • Commitments for products or services Thomson Reuters is unable or unwilling to provide or perform • Offers of free or discounted products or services |
Global Services Policies
Connecting the dots I received a vendor invoice for an amount that exceeds my authority limit. Can I split the amount into two separate payments that I am authorized to approve? No. Splitting an invoice into separate payments in order to meet an authorization level is considered a circumvention of our internal controls. If the vendor payment amount exceeds your authorization level, the next-level approver in your management chain must approve the payment. |
Government contracting Government contracting laws and regulations can be complex and are often subject to change. The Thomson Reuters Government Contract Compliance Policy provides guidance on contracting with governments. For guidance specific to your location, consult the General Counsel’s Office to verify that you are complying with applicable laws, policies and standards. |
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We are trusted to. . .
. . .speak to the media, participate in public speaking events, or communicate on social media on behalf of Thomson Reuters only if we are authorized to do so.
Why it matters:
We are fully aware of the power of media and our responsibility to use it wisely. Our company’s stock price, reputation and ability to compete can be affected by the information we make public. By being aware of the risks and not appearing to speak on behalf of the company without authorization, we can help make sure the company consistently gets an accurate message across to its intended audience while also exercising our individual right to post on social media.
How we deliver:
If we receive requests for information from outside of the company, even seemingly simple ones, we refer them to colleagues authorized to act as company spokespersons, in collaboration with the Communications team. These spokespersons:
Public speaking and engaging with the media
If an employee, delivers a speech at a conference or event, participates in a panel discussion, or gives an interview in the media or provides any comment to a member of the press, they are assumed to be speaking on behalf of the company and must receive explicit approval from their manager and the Communications team.
If you are unexpectedly approached by the media – in person at a conference or under any other circumstances – you must consult the Communications team before agreeing to an interview. In
some instances, we may need to make it clear that these views do not represent those of Thomson Reuters and the Communications team can advise accordingly in such cases.
In our capacity as Thomson Reuters employees, we must have approval before engaging with journalists, media outlets, or blogs to create content for distribution in the media and on social media platforms, such as Twitter, LinkedIn, Facebook, and Instagram.
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Connecting the dots I saw an article online that had incorrect claims about a Thomson Reuters service. Can I correct it in a comment on the article if I make it clear that I’m speaking as myself and not as an official company spokesperson? This is managed by our company’s Communications team—please let them know so they can properly investigate the issue and address it if needed. In general, avoid posting any information about Thomson Reuters products, stock, strategies, customers or competitors, even if you’re trying to clear up confusion or false claims. |
As a leading provider of business information services, Thomson Reuters recognizes and encourages independent participation in social media and online communications if done so responsibly. This means we:
Be aware that some of us in certain jobs may need to comply with supplemental policies regarding social media. If you have any additional questions on personal or corporate social media use, please contact the Communications Team.
Data Loss Prevention (DLP) Standards Social
Media Guidelines
Connecting the dots I am active on social media and have several different accounts. Sometimes I want to post content that overlaps with the interests of Thomson Reuters. Am I allowed to? Before posting such content, it is important to make sure that it doesn’t reveal confidential or nonpublic information about the company, our customers, our colleagues or other people or companies that we do business with. You shouldn’t cite or reference customers or business associates without their approval. Also, if you are commenting on products and services we sell or those sold or offered by our competitors, you should be mindful of the Trust Principles and make it clear that you are employed by the company. In any event, you should make it clear that any opinions are your own and not those of Thomson Reuters. See the Social Media Guidelines, and if in doubt, talk to your manager or the Communications team. |
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We are trusted to. . .
. . .respect human rights and our environment and to hold our employees, customers, vendors, suppliers, and other business partners to the same high standard we demand of ourselves.
Why it matters:
Thomson Reuters works with thousands of professionals all over the world, and as members of the United Nations Global Compact, we are committed to creating positive change in the areas of human rights and environmental responsibility. We are aligned to the United Nations Guiding Principles on Business and Human Rights (UNGPs) and, as part of this obligation, we have established a Human Rights Policy that underscores our commitment and approach to human rights.
We are committed to respecting all internationally recognized human rights and treating all our colleagues with dignity and respect, and we expect our business partners to do the same. We are also committed to protecting and preserving the environment and seeking sustainable sourcing solutions. We know that our responsibilities are great, as are our opportunities, which is why we are committed to driving innovation and performance, proving to our partners, our employees and the world that we are leaders committed to long-term success.
For more information, visit Social Impact Institute, Thomson Reuters Foundation, and United Nations Global Compact Policy
How we deliver:
Human rights
We strive to protect human rights and worker rights wherever we do business. This means we:
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If you believe you’ve encountered a violation of our human rights standards, either within one of our workplaces or involving one of our business partners, contact your manager, Human Resources or report it through the Ethics Hotline.
Human Rights Policy
Supply Chain Ethical Code
Modern Slavery Act Transparency Statements
Responsible sourcing and the Supply Chain Ethical Code
We actively seek suppliers who share our ethical standards and commitment to environmentally sound and sustainable practices. This means we:
Supply Chain Ethical Code
Modern Slavery Act Transparency Statements
Environmental responsibility
We are committed to limiting our environmental impact. By managing our resources and seeking sustainable solutions, we can ensure a better future for all of us. This means we:
Contact Environmental, Health and Safety if you have any environmental safety concerns or if you have ideas on how to increase our sustainability and conservation efforts even more.
Environmental Health and Safety Policy
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We are trusted to. . .
. . .support the communities where we live and work by investing in people and projects that make a positive impact.
Why it matters:
Thomson Reuters operates on a global scale and relies on local relationships and resources for support. When we improve our communities, we can improve the lives of our current and future workforce, as well as the lives of our customers. By seeking worthy causes to support and inviting collaboration and open communication, we can help our communities grow and succeed with us.
How we deliver:
We collaborate with our colleagues and partners to support our communities and encourage charitable work. This means we:
If you have a community cause or event you think the company might be interested in supporting, contact the Social Impact Institute and view the MyGiving Program Guidelines.
We are trusted to. . .
. . .support and respect each other’s individual right to take part in political activities while keeping Thomson Reuters separate from any political activity.
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Why it matters:
The political process can be an effective way to create positive change in our world. However, rules regarding companies’ political donations are strict in most countries where Thomson Reuters operates. Therefore, we must make sure Thomson Reuters is not mistakenly connected to any political group or activity. This is especially important for our news operations, which our Trust Principles dictate we must remain free from political bias, both in appearance and in practice. Just as the Trust Principles apply to all Thomson Reuters employees and not journalists alone, so too does the obligation for all of us to ensure that the company is not improperly linked to any particular political group or activity.
How we deliver:
Although we encourage employees to responsibly participate in politics and civic matters as individuals, Thomson Reuters does not support any political party, candidate, group or religion (i.e., any “political cause”). This means the company:
Lobbying
At times, we may discuss with government officials various issues and topics that could impact our business, regulators and politicians. When these discussions focus on the possible impact of proposed laws, rules or regulations on our business, we adhere to the Trust Principles and obtain prior approval from ECHelp@thomsonreuters.com before taking an external position on potential legislation, policy, program or position of federal, state, provincial or local government. If we do take a position, we must follow all applicable lobbying laws, restrictions and regulations.
We will not provide anything of value, including gifts or campaign contributions, to a government official without prior approval from ECHelp@thomsonreuters.com or connect any item of value to an official act by a government official.
Independence from foreign government interests
In the United States, we are exempt from coverage of the Foreign Agents Registration Act (FARA) because we only engage in activities in support of Thomson Reuters commercial business, and do not directly promote the public or political interests of a foreign government or foreign political party. In no event will our corporate or individual political activities be directed by a foreign government or foreign political party. If we conduct activities of a political nature in the United States, those activities will be authorized only to the extent they further the bona fide commercial, industrial or financial operations of Thomson Reuters. We will therefore represent the interests of our non-U.S. citizen
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stakeholders only through authorized private and nonpolitical activities related to our commercial interests, or through other activities not serving predominantly any foreign interest.
Personal political activity
If we plan to campaign for or serve in political office as individuals, we are careful to separate ourselves from Thomson Reuters in these efforts. This means we:
• Abide by laws and regulations in those states and countries that limit political contributions by employees or their family members • Take special care to make it clear that our political activities and expressed political views are personal and not those of Thomson Reuters — especially if our business works with a governmental entity |
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Supplemental policies Be aware that some of us in certain jobs may have supplemental policies regarding lobbying and personal political activity. |
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This Code serves as a reference to you. Thomson Reuters reserves the right to modify, suspend or revoke this Code and any and all policies, procedures and programs in whole or in part, at any time, with or without notice. Thomson Reuters also reserves the right to interpret this Code and these policies in its sole discretion as it deems appropriate.
Neither this Code nor any statements made by any employee of Thomson Reuters, whether oral or written, confer any rights, privileges or benefits on any employee, create an entitlement to continued employment at Thomson Reuters, establish conditions of employment or create an express or implied employment contract of any kind between employees and Thomson Reuters. In addition, all employees should understand that this Code does not modify their employment relationship, whether at will or governed by a written contract.
The version of this Code that appears online at www.thomsonreuters.com may be more current and up-to-date and supersedes any paper copies or previous versions should there be any discrepancy between paper copies, previous versions and what is posted online.
Thomson Reuters
www.thomsonreuters.com
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