Modern Slavery and Human Trafficking Statement for the Financial Year 2019-2020

Introduction

S&P Global Ltd. and its subsidiaries and affiliates (collectively "S&P Global") is committed to ensuring that we – and our suppliers – operate in compliance with all applicable laws as well as in accordance with the highest standards of ethical behavior, as outlined in the S&P Global Business Code of Conduct. S&P Global supports and respects the protection of internationally recognized human rights and endeavors to make sure that we are not complicit in human rights abuses. Accordingly, we do not tolerate modern slavery or human trafficking in our organization or supply chain.

Our business

S&P Global is a world leader in critical information, analytics and expertise in forging solutions for the major industries and markets that drive economies worldwide. The company delivers next-generation information, technology, data science, analytics and solutions to customers in business, finance and government, improving their operational efficiency and providing deep insights that lead to well-informed, confident decisions. S&P Global has more than 50,000 key business and government customers, including 80 percent of the Fortune Global 500 and the world's leading financial institutions.

Organizational structure

S&P Global Ltd. is a UK tax domiciled company incorporated in Bermuda, headquartered in London, with approximately 15,000 employees in 32 countries worldwide. More information about our offices can be found on our website at https://ihsmarkit.com/about/locations.html.

Our supply chain

S&P Global's supply chain largely consists of professional services providers such as consultants, accountants, law firms, contractors, software services, and data and content providers. S&P Global also uses suppliers of IT, office equipment, facilities management, print production and publication distribution services.

Given the nature of S&P Global's business, we believe there is minimal risk of practices that support, facilitate or are complicit with modern slavery, within either S&P Global or our supply chain. Nevertheless, we require that all vendors with whom we have a master services agreement agree to perform at the highest level of business and professional ethics, and to ensure that they and their subcontractors comply with all applicable anti-slavery and human trafficking laws, including but not limited to the UK Modern Slavery Act. We have also embedded these expectations in our purchase order forms and new vendor onboarding forms.

S&P Global policies on slavery and human trafficking

S&P Global's zero tolerance approach to modern slavery and human trafficking is confirmed in many of our corporate policies and procedures, including our Business Code of Conduct, our Third Party/Vendor Code of Conduct and our Human Rights and Labor Practices policy. These documents articulate our commitment to respecting and promoting fundamental human rights, which we view as a key component of responsible corporate citizenship. In addition to supporting the fundamental principles contained in the United Nations Universal Declaration of Human Rights, we are committed to working with suppliers to help uphold ethical human rights standards.

Due diligence and further steps

S&P Global has determined that the majority of its suppliers operate in areas considered to be at a low risk of supporting or being complicit in forced labor or human trafficking.

S&P Global has implemented procedures to assess the risk of new vendors at onboarding and we require suppliers to affirm their commitment to eradicating modern slavery and human trafficking. We will undertake in the next financial year to:

• Ensure clear and effective communication with new and existing vendors regarding our commitment to compliance with the Modern Slavery Act and our zero-tolerance approach towards forced labor;
• Continue risk assessments of and, as necessary, additional engagement with suppliers;
• Continue to promote an environment that encourages reporting concerns and protects whistleblowers.

Training

To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, all employees have been made aware of this statement and reminders will be issued on an annual basis.

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This statement is made pursuant to section 54(1) of the Modern Slavery Act of 2015 and constitutes the slavery and human trafficking statement for the financial year ending 30 November 2020 for S&P Global Ltd. and its subsidiaries to which the Act applies. Signed on the Board's behalf by:

Lance Uggla
Chairman and CEO