Ethics Policy

GlobalData plc, its divisions and businesses (“the Group”) have implemented a Group-wide Ethics Policy and Code of Conduct to highlight the requirement for high standards of business ethics that are critical in our business.

This policy sets out the principles and values that the Group will support and be guided by in the conduct of its business. This policy applies to all employees, and anyone conducting business on behalf of the Group. The Group commits to conducting itself, and expects all employees to conduct themselves, in an honest, ethical manner in all dealings on its behalf and to behave professionally and with integrity and fairness at all times. The Group applies these same standards to all dealings with customers, suppliers, stakeholders, and public officials. These standards also apply to associates or intermediaries of any party involved in company business activities. The Group’s policy is that businesses should compete enthusiastically and fairly in the marketplace and must comply with the relevant competition laws of each country in which it operates.

Bribery

No employee may offer, seek, pay or accept a bribe, or other such advantage that may be construed as a bribe, in any form. Any approach from an external party soliciting a bribe or other advantage must be reported to the Company Secretary. Corporate hospitality may only be offered to or accepted from a third party if it is modest in value and in compliance with any applicable law. Company contributions to political parties, organizations or their representatives that are related, either directly or indirectly, to the Group’s business dealings are prohibited. All Group employees must maintain the confidentiality of price sensitive and commercial information and not use such information for their personal gain. Reporting of business performance should be undertaken in such a way that reflects the businesses’ true performance and the risks and opportunities that business may face.

Whistleblowing

The Group recognizes that it is important that all employees feel confident that they may freely and confidentially voice genuine concerns relating to possible business malpractice or breaches in ethical behavior to the appropriate management level. You are encouraged to make your disclosure to your team leader/manager, or if this matter concerns your team leader/manager, then HR, divisional senior manager or the Company Secretary. However, if you believe it is inappropriate to make your disclosure to an employee of the Company you may speak to the senior independent non-executive director. In such circumstances the Group will respect the confidential nature of any communication and ensure the protection of any individuals acting in good faith from harassment or victimization.

Insider Trading

Insider trading or insider dealing means personally buying or selling stock of any company while in possession of information about the company that is not available to the public and that could affect the share price of that company. Examples include, but are not limited to:

• A pending merger or acquisition
• A major lawsuit or claim
• An earnings announcement
• Significant product development

Insider trading is illegal, as is disclosing inside information to a friend, relative or colleague to enable that person to buy or sell shares on the basis of the information. Our people should not recommend or suggest the purchase or sale of GlobalData shares or the shares of any other company that they have inside information about. If in doubt, always ask the Company Secretary for further guidance.

Annual Declaration

In order to ensure that the Code of Ethics has been adhered to and to facilitate good business practice and corporate governance, an annual declaration is required to be completed by certain senior employees within the Group. The declaration asks employees to disclose any information relevant to this policy or relevant to other matters encapsulated by corporate governance. Completed declarations are required to be submitted to the Company Secretary who will review the information provided to ensure that employees and the Group are not exposed to any potential ethical issues. Information provided in the declarations will not be published and will be held by the Company Secretary.

The Board of Directors of GlobalData plc is ultimately responsible for this Policy. The Group’s executive management are responsible for ensuring that the Policy is enacted through integration into the Group’s normal management systems; divisional and business unit management are responsible for implementing and communicating this policy within their own divisions and business units. This policy will be reviewed on a regular basis and is published on the Group’s website.