Good governance allows us to ensure our approach to and implementation of corporate responsibility initiatives is effective and consistent with our stated objectives, our values and culture.
Our Board recognises the importance of maintaining high standards of corporate governance, which underpins our ability to deliver consistent financial performance, and value to our stakeholders, aligned with RELX’s culture of integrity. The Board has oversight responsibility of RELX’s corporate governance and their role and function is explained fully in the Corporate governance section. The Audit Committee of the Board regularly reviews ethics issues. In addition, the Chief Legal Officer (CLO) and Company Secretary is responsible for ethics issues as a member of the RELX executive committee. The Chief Compliance Officer and Corporate General Counsel reports to the CLO and presents to the Board annually on the status of our ethics policies and implementation.
Governing policies set out our stance on key issues and are publicly available here. These include the RELX Code of Ethics and Business Conduct, the Code of Ethics for Senior Financial Officers, the Supplier Code of Conduct, Tax Principles, Privacy Principles, Inclusion and Diversity Policy, Health and Safety Policy, Editorial Policy, Quality First Principles and Product Donation Policy.
Helping our people pursue the highest standards of integrity
Doing the Right Thing is more than a phrase at RELX, it embodies principles that represent RELX’s culture of integrity. It includes ensuring respect for one another, incorporating ethics in all our actions; growing our business with integrity; holding ourselves and each other accountable; and taking time to ask questions and report concerns.
Doing the Right Thing is underpinned by clear actions for employees, among them, being honest in our dealings with others; respecting the law, our policies and colleagues; and courageously speaking out for what is right. RELX in turn provides relevant training and resources; enables a culture where people can feel comfortable speaking up and experience no retaliation when they do; and ensures concerns are listened to and acted on in a fair and timely manner.
The pillars of our compliance activities include conducting periodic compliance risk assessments; implementing effective policies, procedures, training and communications; overseeing misconduct reporting channels, investigations processes and remediation efforts; and monitoring and auditing internal controls. We engage in a legal and compliance risk assessment twice a year to identify the top legal and compliance risks to the Company. The RELX Operating and Governance Principles further describe the process, policies and controls to manage risk.
Our Code of Ethics and Business Conduct (the Code) sets the standards of behaviour for all RELX employees and is reviewed regularly. Among other topics, the Code addresses fair competition, anti-bribery, conflicts of interest, employment practices, data protection and appropriate use of company property and information. It also encourages reporting of violations – with an anonymous reporting option where legally permissible.
We offer several reporting channels to report Code-related concerns, including an Integrity Line, available to employees, suppliers, and other reporting persons. The Integrity Line is managed by an independent third party and accessible by telephone or online 24 hours a day, 365 days a year. The Integrity Line also includes an Ask A Question feature which allows employees to seek ethical advice before taking action. Reports of violations of the Code or related policies are promptly investigated, with careful tracking and monitoring of violations and related mitigation and remediation efforts.
We maintain a comprehensive set of other compliance policies and procedures in support of the Code and our risk areas are reviewed and updated periodically to ensure they remain current and effective. We formally audit the compliance programme, including the Code, every three years. Our policies, including our anti-bribery policies, also comprise part of our adequate procedures for compliance with applicable laws. Full and part-time employees receive mandatory training on the Code – both as new hires and regularly throughout their employment – on topics such as maintaining a respectful workplace, preventing bribery and anti-competitive activity, and protecting personal and company data. Mandatory periodic training covers key Code topics and is supplemented by advanced in-person training for those in higher-risk roles or regions. Temporary staff and apprentices are also assigned training.
We engage in policy discussions that matter to our business and our customers. Strategic decisions about policy are made at senior levels of the company to help advocate particular policies and/or to share our expertise. We strive to help policymakers around the world understand our business, innovations and contributions to the public interest.
RELX employees may engage in direct advocacy. We also engage through trade associations, policy organisations and third parties.
Lobbying activities done on behalf of RELX Inc. are managed by the RELX Government Affairs team, and, in coordination with our legal teams, are vetted, tracked and reported as required by law.
Consistent with our commitment to fostering a culture of integrity including through good governance, RELX has a supplemental policy and training for our employees that specifically relate to engagement with government officials and agencies.
The Code and a related supplemental policy also address corporate political contributions, which are strictly prohibited except in the US, where such contributions and activities are permitted in certain states within allowable limits, if they comply with stringent reporting and disclosure regulations. Corporate political contributions require senior level review and approval. Corporate contributions are reported as required by law. Contributions are made on a bipartisan basis and no funds are donated for presidential campaigns or any other federal-level campaigns.
We remained diligent through the year in our ongoing efforts to comply with applicable bribery and sanctions laws and mitigate risks in these areas. Our anti-bribery and sanctions programmes include detailed, risk-based internal policies and procedures on topics such as doing business with government officials, gift and entertainment limits, gift registers, and complex sanctions requirements. Relationships with third parties and acquisition targets are evaluated for risk using one or more of the following methods, including questionnaires, references, detailed electronic searches, and Know Your Customer screening tools.
We monitor and assess the implementation of our anti-bribery and sanctions programmes by continually reviewing and updating our policies and procedures; conducting periodic programmatic risk assessments; and conducting quality reviews and internal monitoring and audits of the operational aspects of the programmes.
We engage with our employees about compliance through digital communications and other media, including videos and animation. To raise awareness during Compliance Week 2023 we held challenges and quizzes, and recognised outstanding employee contributions to our culture of integrity with Integrity Hall of Fame inductions.
Our Code of Ethics and Business Conduct supports the principles of the United Nations Global Compact (UNGC) and stresses our commitment to human rights. In accordance with the UN’s Guiding Principles on Business and Human Rights, we consider where and how we operate to avoid human trafficking and modern slavery in our direct operations and our supply chain.
As stated in our Modern Slavery Act Statement, we stand against all forms of slavery and human trafficking. We do not tolerate it in any part of our business, including our supply chain. As a UNGC signatory we uphold its Ten Principles related to human rights, fair and non-discriminatory labour practices, the environment, and anti-corruption. Our policies are also informed by the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the Women’s Empowerment Principles. We have consulted widely on a RELX Human Rights Policy which we will launch in 2024.
Data privacy
Data is integral to the solutions we provide that further our unique contributions as a business, including protecting consumers from the risk of fraud; allowing secure online transactions; improving access to financial, healthcare and government benefits; and delivering high quality medical care.
Recognising concerns and sensitivities around personal data, our commitment to data privacy remained a critical RELX priority in 2023 and continues to be supported by strong governance, transparency and accountability. Dedicated privacy teams implemented requirements for compliance with personal data protection regulations around the globe. In the United States, RELX continued to advocate for clear national privacy laws that protect consumers, bolster consumer trust and allow businesses to invest in data driven activities that serve the public interest. Certain US RELX companies have self-certified their participation in the Data Privacy Framework programme.
We proactively take into account privacy concerns in developing and offering our solutions. Our Privacy Principles guide our approach to the responsible collection and use of personal data and are supplemented by internal privacy policies and guidance that are updated by our privacy offices to respond to new requirements, best practices and expectations.
We undertake activities and training that deepen employee awareness about data privacy. For Data Privacy Day 2023, we organised internal panel discussions focused on privacy, AI and trust. We also celebrated the winners of the annual RELX Privacy Principles Champions Competition, which recognises the achievements of employees in protecting personal data and implementing our Privacy Principles.
Cyber security
We observed Cyber Security Awareness Month with both central and business specific initiatives aimed at improving security understanding for employees. The theme for 2023 was Get Your Cyber Priorities Straight. Events included a new Cyber Security Escape Room Challenge; educational sessions on AI and Security, webinars on cyber security for all ages, and avoiding traps on social media. We also launched our bespoke video advice series, RELX Cyber Security Experts Say. In the year, 100% of employees were included in monthly phishing simulation exercises. During 2023, we continued to enhance our security efforts with additional infrastructure monitoring capabilities both internally and through third parties.
In addition to more than 1,000 questionnaires and audits by our customers annually, we also engage third parties to perform independent audits on certain of our products and services. These audits help build trust and assurance in our target markets, especially where sensitive personal information is involved. For example, we have completed SOC 2 audits on our Risk US datacenters and our Lexis+ product, in addition, our UK Risk products have been ISO 27001 certified. 84% of our product revenue in Risk is covered by a third-party audit.
Pensions and investments
The Statement of Investment Principles for our UK pension scheme demonstrates that the Trustee recognises that consideration of financially material factors, including ESG and climate risk, is relevant at different stages of the investment process. As long-term investors, the Trustee embeds consideration of such factors in its investment decision-making as they can have a material impact on risk and return. The Trustee has produced a Responsible Investment Policy which has been shared with all investment managers. Throughout the year, the Trustee Board received presentations from corporate responsibility (CR) experts and the Responsible Investment Sub-Group met on a number of occasions. Furthermore, the Trustee submitted its first Taskforce on Climate-Related Financial Disclosures (TCFD) report in the year.
CR issues are also relevant to the investment decisions made by RE Venture Partners, RELX’s corporate venture arm. REV continues to invest in ethical AI, sustainable food technology and the creation of inclusive content for language learning.
A responsible taxpayer
Taxation is an important issue for us as well as our stakeholders, including our shareholders, governments, customers, suppliers, employees and the global communities in which we operate. We are transparent about our approach to tax.
We provide details about our tax principles and global tax contribution – broken down by regions and categories – along with our tax risk control framework. There are also case studies showing how RELX has made a positive contribution in tax-related areas to benefit society as a whole. RELX is a signatory to the B Team’s Responsible Tax Principles. The B Team is a group of business leaders committed to sustainability, equality and accountability. Globally, in 2023, RELX paid £619m in corporate taxes, but also paid and collected much more in payroll taxes and indirect taxes.