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Submission to CDP Reporting period: 2017 31 December 2018

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Page 1: Submission to CDP - London Stock Exchange Group › sites › default › files › content... · London Stock Exchange Group (LSE.L) is a diversified international market infrastructure

Submission to CDP

Reporting period: 201731 December 2018

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CDP Climate Change Questionnaire 2018

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C0 Introduction

Introduction

(C0.1) Give a general description and introduction to your organization. London Stock Exchange Group (LSE.L) is a diversified international market infrastructure and capital markets business sitting at the heart of the world's financial community. The Group can trace its history back to 1698.

The Group operates a broad range of international equity, bond and derivatives markets, including London Stock Exchange; Borsa Italiana; MTS, Europe's leading fixed income market; and Turquoise, a pan-European equities MTF. It is also home to one of the world’s leading growth markets for SMEs, AIM. Through its platforms, the Group offers international business and investors unrivalled access to Europe's capital markets.

Post trade and risk management services are a significant part of the Group’s business operations. In addition to majority ownership of multi-asset global CCP operator, LCH Group, LSEG operates CC&G, the Italian clearing house; Monte Titoli, the T2S-ready European settlement business; and globeSettle, the Group’s newly established CSD based in Luxembourg.

The Group is a global leader in indexing and analytic solutions. FTSE Russell offers thousands of indexes that measure and benchmark markets around the world. The Group also provides customers with an extensive range of real time and reference data products, including SEDOL, UnaVista, and RNS.

London Stock Exchange Group is a leading developer of high performance trading platforms and capital markets software for customers around the world. In addition to the Group’s own markets, over 35 other organisations and exchanges use the Group’s MillenniumIT trading, surveillance and post trade technology.

Headquartered in the United Kingdom, with significant operations in North America, Italy, France and Sri Lanka, the Group at the end of 2017 employed approximately 4,700 people.

Further information on London Stock Exchange Group can be found at www.lseg.com.

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(C0.2) State the start and end date of the year for which you are reporting data. Please complete the following table.

Start date End date Indicate if you are providing emissions data for past reporting years

From: 01/01/2017 To: 31/12/2017 Yes

(C0.3) Select the countries for which you will be supplying data. Please complete the following table:

Country

France; Italy; Russian Federation; Sri Lanka; United Kingdom of Great Britain and Northern Ireland; United States of America.

(C0.4) Select the currency used for all financial information disclosed throughout your response. Please complete the following table:

Currency

GBP

(C0.5) Select the option that describes the reporting boundary for which climate-related impacts on your business are being reported. Note that this option should align with your consolidation approach to your Scope 1 and Scope 2 greenhouse gas inventory. ● Operational control

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C1 Governance

Board oversight

(C1.1) Is there board-level oversight of climate-related issues within your organization? ● Yes

(C1.1a) Identify the position(s) of the individual(s) on the board with responsibility for climate-related issues. Please complete the following table.

Position of individual(s) Please explain

● Board/Executive board● Within the Board, the Group CEO is responsible for CR policy execution and compliance,

including climate-related issues.

● Chief Financial Officer (CFO) ● The Group CFO has responsibility for the environmental climate change programme of our CRstrategy, as stated in the Group CR policy available at www.lsveg.com.

● Chief Risk Officer (CRO) ● Environmental and climate-related issues are directly managed by the Group Chief Risk Officerin their capacity as the relevant sustainability strategy pillar lead. They are directly responsible forproviding strategic guidance for the development and implementation of the environmental actionplan covering all climate-related issues.

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(C1.1b) Provide further details on the board’s oversight of climate-related issues. Please complete the following table.

Frequency with which climate-related issues are a scheduled agenda item

Governance mechanisms into which climate-related issues are integrated

Please explain

● Scheduled - some meetings

● Reviewing and guiding strategy

● Monitoring implementation and performance of objectives

● Monitoring and overseeing progress against goals and targetsor addressing climate-related issues

LSEG's Environmental Policy is part of the Group Corporate Responsibility Committee, which is a matter reserved for the Board.

David Warren, interim CEO and Group CFO, reports to the Board on environmental matters.

The Board also reviews and approves on an annual basis both the Annual and the Corporate Sustainability reports, where climate-related targets and progress against them are disclosed.

Below board-level responsibility

(C1.2) Below board-level, provide the highest-level management position(s) or committee(s) with responsibility for climate-related issues. Please complete the following table.

Name of the position(s) and/or committee(s) Responsibility Frequency of reporting to the board on climate-related issues

● Chief Executive Officer (CEO)●

● Both assessing and managing climate-related risks andopportunities

● Quarterly

● Chief Financial Officer (CFO) ● Both assessing and managing climate-related risks andopportunities

● Quarterly

● Chief Risks Officer (CRO) ● Both assessing and managing climate-related risks andopportunities

● Quarterly

● Sustainability committee ● Both assessing and managing climate-related risks andopportunities

● Quarterly

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● Safety, Health, Environment and Quality committee ● Both assessing and managing climate-related risks andopportunities

● Quarterly

● Environment/Sustainability manager ● Both assessing and managing climate-related risks andopportunities

● Quarterly

● Facility manager ● Both assessing and managing climate-related risks andopportunities

● Quarterly

(C1.2a) Describe where in the organizational structure this/these position(s) and/or committees lie, what their associated responsibilities are, and how climate-related issues are monitored. The Group CEO is responsible for CR policy execution and compliance, including climate-related issues.

The CEO and Group CFO are responsible for environmental matters within the LSEG Board of Directors the Group Executive Committee. This is an executive role that connects management to Board oversight and encompasses oversight of both operational and business risks associated with climate-related issues.

The Chief Risk Officer is pillar lead for the Sustainability Strategy pillar overseeing environmental matters, and as such reports to the Group Sustainability Committee. This reflects the integration of ESG risks into LSEG Risk Management framework.

The Head of Group Property chairs the Environmental Management Committee, reporting to the Chief Risk Officer in their capacity as relevant sustainability strategy pillar lead. The Environmental Management Committee holds responsibilities for the oversight of climate-related risks and opportunities associated with our business operations. The Environmental Management Committee is comprised of key stakeholders across the Group who are responsible for environmental impacts i.e. Property/Facilities Managers, Procurement, Data Centre Managers, Business Travel and HR and covers all the Group's geographies.

Each financial year, the Environmental Management Committee submits an environmental action plan which incorporates environment and climate-related issues to the ExCo. This focuses on our current objectives, annual environmental targets, and other CR opportunities for the Group, including a critical evaluation of our successes and our competitive position.

The Environmental Management Committee is responsible for defining annual objectives, targets and programmes as well as delivering and reviewing performance across the Group including monitoring GHG emissions, identifying improvement opportunities and reporting.

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Employee incentives

(C1.3) Do you provide incentives for the management of climate-related issues, including the attainment of targets? ● Yes

(C1.3a) Provide further details on the incentives provided for the management of climate-related issues. Please complete the following table.

Who is entitled to benefit from these incentives?

Types of incentives Activity incentivized Comment

● Corporate executive team ● Monetary reward

● Emissions reduction target

The Group Head of Property has environmental objectives, which includes climate change and other environmental targets, as part of their annual business objectives, which are linked to the annual bonus programme. These objectives are cascaded to the Group Property team across our global regions. Specifically, we are seeking reduced carbon impact due to energy efficiency and enhanced business continuity capability due to adaptation measures. Group-wide Sustainability Targets include: Science-based target: 40% reduction of absolute global Scope 1 and 2 GHG emissions by 2030 from a 2016 baseline. Other targets include: 20% reduction in our CO2e emissions per FTE and £m Revenue by 2020, with a 5% reduction in 2018 relative to 2017; 20% by 2020 reductions in Data Centre and Office Energy Use, Water Consumption, Waste and Business Travel (Flights), and 2-5% 2017 reductions in each of these areas. Paper consumption has a 5% reduction target. There is also a 2018 behaviour change related target to increase video conferencing use by 5%.

● All employees ● Other non-monetary reward ● Behavior change related indicator All staff in the UK are provided the opportunity to

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offset their household or travel carbon footprint through a salary related donation to Pure, a carbon-offset charity. All donations are used to buy and cancel carbon credits from renewable energy and efficiency projects such as wind farm construction and forest preservation that meet the UK Government’s Quality Assurance Scheme for Carbon Offsetting and the high quality standards of the Kyoto Protocol.

● All employees ● Other non-monetary reward ● Behavior change related indicator In the UK, we operate a cycle-to-work scheme as a form of salary sacrifice which allows employees to reduce their gross salary in exchange for hiring a new bike and cycling accessories with savings of over 40%.

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C2 Risks and opportunities

Time horizons

(C2.1) Describe what your organization considers to be short-, medium- and long-term horizons. Please complete the following table:

Time horizon From (years) To (years) Comment

Short-term 1 3

Medium-term 3 5

Long-term 5 10

Management processes

(C2.2) Select the option that best describes how your organization's processes for identifying, assessing, and managing climate-related issues are integrated into your overall risk management. ● Integrated into multi-disciplinary company-wide risk identification, assessment, and management processes

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(C2.2a) Select the options that best describe your organization's frequency and time horizon for identifying, and assessing climate-related risks.

Frequency of monitoring How far into the future are risks considered? Comment

● Six-monthly or more frequently

● > 6 years

Our risk management approach considers transition risks (policy and legal, technology, market, reputation) and opportunities (resource efficiency, energy source, products/services, markets, resilience), and physical risks (both acute and chronic) related to climate change.

(C2.2b) Provide further details on your organization’s process(es) for identifying and assessing climate-related risks. Our risk management approach considers transition risks (policy and legal, technology, market, reputation) and opportunities (resource efficiency, energy source, products/services, markets, resilience), and physical risks (both acute and chronic) related to climate change. The political, economic, physical and social environment in which we operate is undergoing much change and the need for efficient, transparent and well regulated capital markets has never been greater. Understanding how climate change is, and potentially will, impact the operations of LSEG, our clients and suppliers is crucial to our business. The Executive Committee (ExCo) are accountable at both a company and asset level for risk identification, analysis, evaluation and mitigation which includes climate change risks and opportunities. We achieve this through:

● Company Level: Climate Change transition risks and opportunities are identified analysing our product portfolio across client segments and asset classes(Product/Services and markets), whereas the risks and opportunities associated with energy sources and business resilience are assessed taking into account all of our operations. Our Corporate Sustainability strategy is aligned with our business strategy across the Group. The Corporate Sustainability Committee and Environmental Management Committee are responsible for ensuring the business annually assesses and mitigates climate change risks where appropriate and that we maximize arising opportunities.

● Asset Level: LSEG has offices and data centres located around the world, and we assess risks and opportunities at the facility level to understand climaterelated risks including flooding, long-term temperature changes and extreme weather events. We assess our facilities ability to operate, staff access, safety and wellbeing and insurance premium impacts on both a short and long-term basis. We recognise that an effective monitoring and assessment programme must consider both the global perspective and specific local needs.

These processes for identifying and assessing climate-related risks include:

The Group leverages the expertise of FTSE Russell in the identification of climate risks and opportunities as part of their ESG assessment of global listed companies, including LSEG, and via their Green Revenues Data Model which measures climate risks and;

● The Group overall climate-related risk exposure is validated by the FTSE Russell assessment.

● LSEG closely liaises with ESG rating agencies to assess the materiality of climate related risks - both physical and transition - to its business model.

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● We also rely on our participation in the Centre for the Protection of National Infrastructure (CPNI) in the UK for the identification of the severity of physicalclimate risks that might adversely affect our technological infrastructure.

● Stakeholder engagement is a crucial part of the risk assessment process, especially as regulatory risks are concerned.

● LSEG is involved in a number of working groups on the development of green finance regulations.

● Market risks associated with the cost of energy are monitored by our Property Department.

● Market risks associated with the regulatory disclosure requirements for our listed companies are also closely monitored.

Within these processes, we define as "substantive" a financial impact that needs factoring into our business strategy and operations, requiring a change in our product portfolio, client target, and resource mix.

(C2.2c) Which of the following risk types are considered in your organization's climate-related risk assessments? Please complete the following table:

Risk type Relevance & inclusion Please explain

Current regulation

● Relevant, always included

We consider all financial disclosure regulations affecting our listed companies i.e.: Companies, Partnerships and Groups (Accounts and non-financial reporting) Regulations 2016 - transposition of the EU Directive 2014/95/EU on the disclosure of non-financial and diversity information (NFR Directive) and Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2013

Emerging regulation

● Relevant, always included Both the UK and the EU are looking to implement the TCFD recommendations in their regulatory frameworks. This can have impact on the disclosure obligations associated with climate risks and opportunities for our listed companies.

Technology ● Relevant, always included We consider all physical climate risks which could adversely affect LSEG business continuity and technological infrastructure.

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Legal ● Relevant, always included We estimate that litigation risks associated with climate-related issues in LSEG disclosures are limited, however incorporate these risks in our assessment.

Market ● Relevant, always included Market impacts from climate-related risks are linked to risks

arising from regulation and reputational risks - see above and below for more detail.

Reputation ● Relevant, always included Though admission to listing is not in LSE’s powers, we are aware

of the reputational risks for LSEG associated with public opinion reactions to the conduct and approach to climate risk disclosures of our listed companies and incorporate these risks in our assessments.

Acute physical ● Relevant, always included Acute physical climate risks adversely affecting LSEG business continuity and technological infrastructure (eg through floods) are considered in all of our climate-related risk assessments.

Chronic physical ● Relevant, always included Chronic physical risks (eg higher cooling costs for our data centers associated with rise in temperatures) are limited and mitigated through BAU activities, though always included in our climate-related risk assessments.

Upstream ● Relevant, always included Upstream risks include Technology, Acute physical and Chronic physical risks (please see above for details).

Downstream ● Relevant, always included This comprises “Current regulation”; “Emerging regulation” “Market”, “Reputation” (please see above for details).

(C2.2d) Describe your process(es) for managing climate-related risks and opportunities. Response options Our risk management approach considers transition risks (policy and legal, technology, market, reputation) and opportunities (resource efficiency, energy source, products/services, markets, resilience), and physical risks (both acute and chronic) related to climate change. Key external and internal factors are stress tested across our Group operations to assess the potential impact on the financial results, strategic plans and operational resilience. The risk function is centralised at the Group level with the exception of the CCPs where each clearing house has its own risk team in compliance with the EMIR requirements and CSDs which will be required to have their own risk teams under the forthcoming provisions of CSDR. The function supports the Risk

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Committee members by providing reports on the Group’s risk profile and timely escalation of exceptions. It also monitors compliance with rules and regulations and develops and maintains frameworks to facilitate the identification, assessment, reporting and monitoring of all the principal risks that could materially impact the reputation, financial position or operations of the Group. In June 2017, the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) released its reporting recommendations. LSEG signed the TCFD statement of support, affirming its commitment to support the recommendations, and sees them as an important step in driving improved global consistency in voluntary global reporting standards. As the Group, and FTSE Russell in particular, intends to play a critical role in enabling the flow of information envisioned by the TCFD, the recommendations were incorporated into FTSE Russell’s climate-related indicators and in the Group ESG Reporting Guidance. Product/services and markets risks and opportunities relating to climate change are prioritised with respect to the magnitude of impact and the Group’s ability to operationalise solutions into a business strategy. LSEG determines materiality and priority of risks and opportunities through engagement with national policy decisions that could impact our business both in the short and long-term. LSEG prioritises short term (0-3 years) climate change transition risks and opportunities that may affect our product portfolio and competitiveness with respect to peers, and physical risks that may affect the ability of our facilities to operate, and impact our insurance premiums. For longer-term risks (5+ years), we prioritise those risks that may affect the operations of companies listed on our exchanges, as well as physical risks to our facilities and ability to operate. The publication of FTSE Russell’s report “Investing the global green economy” in May 2018 is an example of research applied to climate change risks and opportunities relevant to our market. https://www.ftserussell.com/sites/default/files/ftse_russell_investing_in_the_global_green_economy_busting_common_myths_may_2018.pdf As part of the Risk Management Framework businesses are required to assess the risks associated with their activities. This includes risks involved with undertaking new activities or entering new territories; changes in market perception, legislation and regulation; business continuity / recovery strategies, and adapting to regulatory change. The risk framework is governed by a Board approved Enterprise-wide Risk Management Framework policy and Risk Appetite. Executive management are accountable at a company and asset level for risk identification (including climate change issues), analysis, evaluation, mitigation, monitoring and reporting in their area using a standardized risk library and within the framework established by the Board. Through this understanding of both internal and wider impact, we have identified the risks and opportunities arising from climate change, and where applicable are in the process of creating improvement programs to increase operational efficiency, reduce costs, and reduce our carbon impact, as well as create products and services which meet the needs of this changing business context. LSEG has offices and data centers located around the world, and we assess risks and opportunities at the facility level to understand climate related risks including flooding, long-term temperature changes and extreme weather events. We assess our facilities ability to operate, staff access, safety and wellbeing and insurance premium impacts on both a short and long-term basis. We recognize that an effective monitoring and assessment programme must consider both the global perspective and specific local needs. For example, our assessment and monitoring process identified that Data Centre energy use accounted for over 50% of the Group's ghg emissions. In May 2017 we switched the UK's energy to be sourced from 100% renewable sources, meaning data centre energy now accounts for less that 20% of Group emissions. Other initiatives include a cold aisle containment rollout across the portfolio

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Risk disclosure

(C2.3) Have you identified any inherent climate-related risks with the potential to have a substantive financial or strategic impact on your business? ● Yes

(C2.3a) Provide details of risks identified with the potential to have a substantive financial or strategic impact on your business. Please complete the following table.

Identifier Where in the value chain does the risk driver occur?

Risk type Primary climate-related risk driver

Type of financial impact driver

Company- specific description

Time horizon

● Risk1

● Customer

● Transition risk

Policy and legal: Enhanced emissions-reporting obligations

Policy and legal: Increased operating costs (e.g., higher compliance costs, increased insurance premiums)

Increased regulatory focus on climate change can lead to enhanced disclosure requirement for our listed companies, with higher transaction costs associated with the status of listed company (as opposed to privately held).

● Medium-term

Likelihood Magnitude of impact Potential financial impact

Explanation of financial impact

Management method Cost of management Comment

● Very likely

● Medium-low

50,000,000 The potential financial impact is based on the aggregated annual additional cost for our c.2500 listed companies of enhanced reporting

LSEG has provided guidance to listed companies to facilitate reporting and keep reporting costs low to mitigate the impacts of

60,000 LSEG plans to invest in capacity building initiatives for its issuers to further mitigate these risks.

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requirements (estimated at £20,000 per company).

this risk. - LSEG engages with potential policy creation in these areas i.e. UK Mandatory Carbon Reporting Regulations and the UK government consultation on energy efficiency to enable early action and mitigate potential arising costs. - LSEG is a signatory of the Paris Pledge for Climate Action, the CDSB Statement on fiduciary duty and climate change disclosure. In 2016 we engaged with the European Commission and the UK and Italian governments regarding the Non-Financial Reporting Directive and related Guidelines. In our consultation response, we acknowledge that so called ‘non-financial’ risks can turn into financial risks. We participated in the Commission-run industry workshops, organised bilateral meetings and joined the European Commission High Level Expert Group on sustainable finance. In June 2017, the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) released its reporting recommendations. LSEG

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signed the TCFD statement of support, affirming its commitment to support the recommendations. As the Group, and FTSE Russell in particular, intends to play a critical role in enabling the flow of information envisioned by the TCFD, the recommendations were incorporated into FTSE Russell’s climate-related indicators and in the Group ESG Reporting Guidance.

Identifier Where in the value chain does the risk driver occur?

Risk type Primary climate-related risk driver

Type of financial impact driver

Company- specific description

Time horizon

● Risk2

● Customer

● Transition risk

Market: Changing customer behavior

Market: Re-pricing of assets (e.g., fossil fuel reserves, land valuations, securities valuations)

A shift in t he co mp osition of t he ov erall ma rket c apit alization , with c om panie s op erati ng in low-c arb on in tensity sect ors in cre asing t heir ma rket capit alizatio n whilst com pani es fr om high c arb on in tensity sect ors gra dually red uce t heir ma rket c apitaliz ation .

Please see FTSE Russell’s report “Investing in the global green economy” in May 2018 is an example of research applied to climate change risks and opportunities relevant to our market. https://www.ftserussell.com/sites/default/files/ftse_russell_investing_in_the_global_green_economy_busting_common_myths_may_2018.pdf

● Medium-term

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Likelihood Magnitude of impact Potential financial impact

Explanation of financial impact

Management method Cost of management Comment

● Very likely ● Medium-low 1 The replacement of high-carbon intensity with low-carbon intensity market cap is likely to be neutral in financial impact.

LSEG closely monitors the transition to a low carbon economy on its markets through the FTSE Russell Green Revenue data model. The Group leverages the expertise of FTSE Russell in the identification of climate risks and opportunities as part of their ESG assessment of global listed companies, including LSEG. The Group overall climate-related risk exposure is validated by the FTSE Russell assessment. LSEG closely liaises with ESG rating agencies to assess the materiality of climate related risks - both physical and transition - to its business model. Stakeholder engagement is a crucial part of the risk assessment process, especially as regulatory risks are concerned. LSEG is involved in a number of working groups on the development of green finance regulations.

150,000 Our risk management approach considers transition risks (policy and legal, technology, market, reputation) and opportunities (resource efficiency, energy source, products/services, markets, resilience), and physical risks (both acute and chronic) related to climate change.

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Identifier Where in the value chain does the risk driver occur?

Risk type Primary climate-related risk driver

Type of financial impact driver

Company- specific description

Time horizon

● Risk3 ● Direct operations • Physical risk Chronic: Rising mean temperatures

Increased operating costs (e.g., inadequate water supply for hydroelectric plants or to cool nuclear and fossil fuel plants)

A shift in the composition of the overall market capitalization, with companies operating in low-carbon intensity sectors increasing their market capitalization whilst companies from high carbon intensity sectors gradually reduce their market capitalization. Data centres are critical to LSEG's business, with instant transactions, data and information core to operations. Increases in the average temperature will result in higher cooling requirements and costs. Likewise, decreases in average temperature will result in higher heating costs. Planning and analysis of future temperature impacts will enable stronger long-term design and investment, particularly ensuring the health, safety and wellbeing of staff and visitors at each of our locations. Other impacts could include dissatisfied occupants of buildings that are not fit for purpose, e.g. building occupiers

● Long-term

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experiencing flooding, inadequate drainage, lack of heating control and cooling, problems with air tightness, driving rain and winds. Existing buildings may not be well-adapted to the new climate, especially in hot summer conditions, leading to reduced value of existing buildings if they are not future climate-proofed. However, due to the long-term nature of the risk (>6 years), there will be adequate time to adapt our operations to take advantage of emerging technologies and mitigate this risk.

Likelihood Magnitude of impact Potential financial impact

Explanation of financial impact

Management method Cost of management Comment

● Likely ● Low 1 Due to the long-term nature of changes in average temperatures, the financial impact of this risk to LSEG is estimated to be £1 as all costs and changes would be assumed within BAU practices.

The LSEG Corporate Sustainability Committee and Environmental Management Committee are responsible for ensuring the Group monitors the latest news, research and reports regarding the physical impacts of climate change, and for assessing the materiality for LSEG’s operations and ensuring all operations are meeting the business needs of this

1 There is no current or expected incremental cost (£1) for applying LSEG’s Business Continuity Program to risks associated with climate change as this is already managed in BAU operations. There may be some direct costs from specialist advice on long term physical climate impacts, (less than 0.5% of operational spend). .

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changing environmental context. Where appropriate, this advice is adapted into our BAU Business Continuity Program. The Environmental Management Committee meets at least Quarterly, with specialist external advice also sought where appropriate. Actions that are helping mitigate this risk include over £9m in energy efficiency and carbon reduction initiatives in our data centres and offices - which are helping reduce water and energy consumption. In 2017, we moved all UK energy to be provided by 100% renewable sources. During 2017 we continued to implement cold-aisle containment in our data centres, as well as IT efficiency, lighting and other building process efficiencies in our offices. In 2017, 7 projects were either implemented, or had implementation commenced, with potential for 15480 tCO2e reduction. We have set science-based targets to further reduce our absolute GHG Emissions - our aim is a 40% reduction by 2030 vs a 2016 baseline. These

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methods will help us ensure we achieving a reduction in our carbon emissions now, reducing the business’ energy requirements and impact of long-term weather changes.

Opportunity disclosure

(C2.4) Have you identified any climate-related opportunities with the potential to have a substantive financial or strategic impact on your business? ● Yes

(C2.4a) Provide details of opportunities identified with the potential to have a substantive financial or strategic impact on your business. Please complete the following table.

Identifier Where in the value chain does the opportunity occur?

Opportunity type Primary climate-related opportunity driver

Type of financial impact driver

Company-specific description

Time horizon

● Opp1

● Customer

● Products and services Development and/or expansion of low emission goods and services

Increased revenue through demand for lower emissions products and services

LSEG has identified a number of product opportunities that integrate climate-related considerations: - Green Bond listings, trading and clearing - Green Infrastructure funds - Green equity listings and trading

● Current

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- Low-carbon and green revenue equity and fixed income indexes Current status of realizing these opportunities: - 78 Green Bonds outstanding in total on LSE in 2018 raising $24.5bn in 7 different currencies - 73 Green companies listed on LSE with a combined market cap of $7bn - 14 Renewable Infrastructure funds listed on LSE with an aggregate value of over $7bn, and over 30 ETFs tracking sustainability indexes - 100+ ESG indices calculated by FTSE Russell - Our data shows that approx. 3000 listed companies globally already generate some of their revenues from green products and services that enable transition to the low carbon economy. Please see LSEG’s Global Sustainable Investment Centre website (www.lseg.com/sustainable) for more details.

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Likelihood Magnitude of impact Potential financial impact

Explanation of financial impact

Strategy to realize opportunity

Cost to realize opportunity

Comment

● Virtually certain●

● Medium-low●

1 LSEG does not publicly report the financial performance of individual products or services, however the Group has seen or expects the following as LSEG’s suite of green is set to grow its contribution to the Group’s revenues over the medium term: - 30% growth in green bond issuance expected in 2018 - Strong growth set to continue over the next ten years

LSEG will increase R&D in the index business area, and promotional efforts in the capital markets business to realise these climate-related opportunities. For example, we have produced FTSE Russell’s report “Investing in the global green economy” as an example of research applied to climate change risks and opportunities relevant to our market. https://www.ftserussell.com/sites/default/files/ftse_russell_investing_in_the_global_green_economy_busting_common_myths_may_2018.pdf As part of our strategy to create a sustainable investment environment and be recognised as a global sustainability leader, during 2017 LSEG has developed guidance for listed companies on the voluntary disclosure of ESG information to investors, based on UN Sustainable Stock Exchanges initiative framework. In the short term, the Group will keep developing market leading products and services like FTSE4Good, which has

1 The Group continues to invest in services that enable investors to model and understand the transition to a low carbon economy. We expect to launch new services and tools in this area during 2018 which reflects substantial investment in growing our capabilities in this area. There is no incremental cost (£1) to LSEG to manage these opportunities, as additional resources and costs are offset by increasing revenues

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made a significant impact on the behaviour of companies (i.e., requiring GHG emission and other climate change targets as part of the inclusion criteria). The Group will keep developing products and services to provide investors with tools for benchmarking and tracking ESG-driven funds as well as continuing to develop a range of low carbon economy (LCE) services. For example, FTSE Russell provides its LCE data model, designed to measure the revenue exposure of public companies engaged in the transition to the green economy.

Identifier Where in the value chain does the opportunity occur?

Opportunity type Primary climate-related opportunity driver

Type of financial impact driver

Company-specific description

Time horizon

● Opp2

● Direct Operations

● Resilience

Participation in renewable energy programs and adoption of energy-efficiency measures

Increased reliability of supply chain and ability to operate under various conditions

It is significant for the Group that we ensure our operations and property estate are equipped to adapt to changes in climate and take advantage of the efficiency and savings that can be achieved through targeting our GHG emissions. This includes

● Medium-term

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issues such as energy efficiency and pricing through to the efficiency and physical security of our property estate. LSEG has prioritised issues like renewable energy, energy efficiency as well as virtualisation and consolidation of our data centre environments, which are building sustainability and strength into our business. Changes in temperature extremes may impact energy prices, as well as make it difficult for employees to travel between our global offices. However the internet and video conferencing are both powerful tools which are enabling many aspects of our business to be done virtually, allowing for reductions in employee travel. We are targeting a 2% reduction in travel during 2018.

Likelihood Magnitude of impact Potential financial impact

Explanation of financial impact

Strategy to realize opportunity

Cost to realize opportunity

Comment

● More likely than not●

● Low●

825000 The Group spends over £9m on annual energy consumption and business travel - a cost we have opportunity to

The LSEG Corporate Sustainability Committee and Environmental Management Committee are responsible for

9000000 In the last three years, LSEG has invested over £9m in energy efficiency and carbon reduction initiatives in our data

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reduce as we target energy reduction, and invest in the future of our property estate. A potential 5-10% reduction in energy and business travel costs through adapting our operations in preparation for climate change extremes would mean an £825k reduction in operational expenses - a small impact on operational expenditure.

ensuring the Group monitors the latest news, research and reports regarding the physical impacts of climate change and for assessing the materiality for LSEG’s operations. The Committees meet at least Quarterly, with specialist external advice also sought as appropriate. Examples of how we are managing the opportunities arising from long-term changes in temperature extremes include: - In the last three years, LSEG has invested over £9m in energy efficiency and carbon reduction initiatives. During 2017 we switched our UK energy supplies to be provided by 100% renewable sources, dramatically reducing our GHG emissions. During 2017 we continued to implement cold-aisle containment in our data centres, as well as IT efficiency, lighting and other building process efficiencies in our offices. In 2017, 7 projects were either implemented, or had implementation commenced, with potential for 15480 tCO2e reduction. We have set science-based targets to further reduce our

centres and offices. There are also direct costs from engaging with policy decisions, specialist advice on regulations, compliance, and management tools to gather data and measure progress against targets (less than 0.5% of total operational spend).

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absolute GHG Emissions - our aim is a 40% reduction by 2030 vs a 2016 baseline. LSEG reports progress against these targets and impacts of reduction initiatives to CDP, DJSI, FTSE4Good, Annual Reports and on our website.

Identifier Where in the value chain does the opportunity occur?

Opportunity type Primary climate-related opportunity driver

Type of financial impact driver

Company-specific description

Time horizon

● Opp3

● Customer

● Products and Services

Shift in consumer preferences

Better competitive position to reflect shifting consumer preferences, resulting in increased revenues

The political, economic, physical and social environment in which we operate is undergoing much change and the need for efficient, transparent and well regulated capital markets has perhaps never been greater. This macro-economic background highlights the importance of the role played by LSEG. This role includes the Group’s environmental, social and governance (ESG) responsibilities and how the organisation conducts itself as a ‘good’ corporate citizen. Sustainability is an integral part of the Group’s strategy and there are both risks and

● Short-term

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opportunities arising as a direct result of our engagement in this area. There are reputational opportunities for LSEG to attract and retain talent, as well as gain competitive advantage in the marketplace through integrating climate change factors into our business and risk management strategy. We also understand that a number of our clients are increasingly becoming invested in climate change initiatives and seek to work with companies like LSEG, who have similar goals and perspectives regarding climate change and the environment.

Likelihood Magnitude of impact Potential financial impact

Explanation of financial impact

Strategy to realize opportunity

Cost to realize opportunity

Comment

● More likely than not ●

● Low ●

825000 The Group spends over £9m on annual energy consumption and business travel - a cost we have opportunity to reduce as we target energy reduction, and invest in the future of our property estate. A potential 5-10% reduction in energy and business travel costs through

The LSEG Corporate Sustainability Committee and Environmental Management Committee are responsible for ensuring the Group monitors the latest news, research and reports regarding the physical impacts of climate change and for assessing the materiality for LSEG’s

9000000 In the last three years, LSEG has invested over £9m in energy efficiency and carbon reduction initiatives in our data centres and offices. There are also direct costs from engaging with policy decisions, specialist advice on regulations, compliance, and management tools to

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adapting our operations in preparation for climate change extremes would mean an £825k reduction in operational expenses - a small impact on operational expenditure.

operations. The Committees meet at least Quarterly, with specialist external advice also sought as appropriate. Examples of how we are managing the opportunities arising from long-term changes in temperature extremes include: - In the last three years, LSEG has invested over £9m in energy efficiency and carbon reduction initiatives. During 2017 we switched our UK energy supplies to be provided by 100% renewable sources, dramatically reducing our GHG emissions. During 2017 we continued to implement cold-aisle containment in our data centres, as well as IT efficiency, lighting and other building process efficiencies in our offices. In 2017, 7 projects were either implemented, or had implementation commenced, with potential for 15480 tCO2e reduction. We have set science-based targets to further reduce our absolute GHG Emissions - our aim is a 40% reduction by 2030 vs a 2016 baseline. LSEG reports progress against these targets and impacts of reduction initiatives to

gather data and measure progress against targets (less than 0.5% of total operational spend).

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CDP, DJSI, FTSE4Good, Annual Reports and on our website.

Business impact assessment

(C2.5) Describe where and how the identified risks and opportunities have impacted your business. Please complete the following table:

Area Impact Description

Products and services

● Impacted

LSEG has identified product opportunities that integrate climate-related considerations: - Green Bond listings, trading and clearing - Green Infrastructure funds - Green equity listings and trading - Low-carbon and green revenue equity and fixed income indexes These identified opportunities have significant potential to grow in the medium term.

Operations

● Impacted

The Group has made energy efficiency investments and climate adaptation investments to address climate risks. During 2017 we switched our UK energy supplies to be provided by 100% renewable sources, significantly reducing our GHG emissions. During 2017 we continued to implement cold-aisle containment in our data centres, as well as IT efficiency, lighting and other building process efficiencies in our offices. In 2017, 7 projects were either implemented, or had implementation commenced, with potential for 15480 tCO2e reduction. We have set science-based targets to further reduce our absolute GHG Emissions - our aim is a 40% reduction by 2030 vs a 2016 baseline.

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Financial planning assessment

(C2.6) Describe where and how the identified risks and opportunities have factored into your financial planning process. Please complete the following table:

Area Relevance Description

Revenues

● Impacted

The new climate related product and services are already generating revenues and the Group actively identifies opportunities to expand these in its financial planning processes.

Operating costs

● Impacted

Climate-related risks and opportunities are considered in planning for operating costs - particularly those arising from impacts to energy, water and business travel. The Group has in place clear management and planning processes to identify opportunities to reduce climate-related impacts and benefit from resulting cost savings i.e. energy or water efficiency. The management of an ISO14001 certified environmental management system also has costs that are factored into the annual budget and expenditure processes.

Capital expenditures/capital allocation

● Impacted

R&D investments in intellectual property in the index business are impacted by climate-related risks and opportunities.

Acquisitions and divestments

● Impacted

The Group expects to continue to identify, assess and execute organic and inorganic opportunities that enhance our existing business, or create new opportunities in complementary areas, including with respect to the Group's climate-related product offering as appropriate.

Access to capital

● Not Impacted

Climate-related isssues do not have any impact on LSEG's access to capital.

Assets

● Not Impacted

Climate-related issues do not have any impact on LSEG's financial planning processes related to Assets.

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Liabilities

● Not Impacted

Climate-related issues do not have any impact on LSEG's financial planning processes related to Liabilities.

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C3 Business strategy

Business strategy

(C3.1) Are climate-related issues integrated into your business strategy? ● Yes

(C3.1a) Does your organization use climate-related scenario analysis to inform your business strategy? ● No, but we anticipate doing so in the next two years

(C3.1c) Explain how climate-related issues are integrated into your business objectives and strategy. LSEG recognizes that we must use resources in ways that ensure the long-term sustainability and profitability of the business and have a positive impact on the environment. This is significant in ensuring our own operations are efficient, sustainable and responsible, as well as developing products and services that support these aims through companies listed on our markets. The Group has established Corporate Sustainability policies, with a specific focus on Environmental and Climate Change commitments. Our environmental approach is led by the Group Chief Risk Officer and Head of Group Property. This structure ensures a defined process to collect and report climate change information that impacts our strategy. LSEG has set emissions and energy reduction targets to reduce our environmental impacts and we have established robust data collection and reporting tools across our property portfolio. The Environmental Management Committee provides leadership and accountability, ensuring data is collated, that we make progress against our goals and that our approach is communicated and reported. The Group’s strategy is formed around both environmental impacts/risks and opportunities that present themselves as a result of climate change. The operational efficiency benefits of reducing and mitigating these physical climate change impacts through clear short and long-term targets have shaped our strategy. Regulatory and legislative reporting requirements have also influenced our approach i.e. UK mandatory GHG emissions reporting. We must also ensure that we are adapting and mitigating our operations against more significant, longer-term impacts of climate change such as extreme weather changes and events which we monitor. LSEG is a committed supporter of green financing and we see the transition to a low carbon economy as a major industrial trend. In addition to attracting and profiling green bond and equity listings through FTSE Russell we support institutional investors in defining climate factors and integrating them into benchmarks and portfolio analytics.

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The physical and regulatory impacts of climate change have influenced our short term strategy. As a result, we have set emissions and energy reduction targets (5% in 2018, vs 2017 and 20% by 2020, vs 2013) and report our GHG emissions and performance annually. In 2017 we set a science-based absolute emissions reduction target of 40% reduction in absolute Scope 1 and 2 emissions by 2030 vs 2016. We invested in data centre and office space consolidation and energy efficiency projects during the reporting period, and switched all UK energy to be provided from 100% renewable sources. As part of our strategy to create a sustainable investment environment and be recognised as a global sustainability leader, during 2016 LSEG developed guidance for listed companies on the voluntary disclosure of ESG information to investors, based on UN Sustainable Stock Exchanges initiative framework. In the short term, the Group will keep developing market leading products and services like FTSE4Good, which has made a significant impact on the behaviour of companies (i.e., requiring GHG emission and other climate change targets as part of the inclusion criteria). Our role means the core influence we bring to long term climate change impacts is through products and services that help drive the market transition to a low-carbon economy. The Group will keep developing products and services to provide investors with tools for benchmarking and tracking ESG-driven funds as well as continuing to develop a range of low carbon economy (LCE) services. For example FTSE Russell launched its LCE data model, designed to measure the revenue exposure of public companies engaged in the transition to the green economy. The publication of FTSE Russell’s report “Investing the global green economy” in May 2018 is an example of research applied to climate change risks and opportunities relevant to our market. https://www.ftserussell.com/sites/default/files/ftse_russell_investing_in_the_global_green_economy_busting_common_myths_may_2018.pdf In June 2017, the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) released its reporting recommendations. The Group signed the TCFD statement of support, affirming its commitment to support the recommendations and sees them as an important step in driving improved global consistency in voluntary global reporting standards. LSEG is ideally placed to help promote good practice across the industry. We joined the Sustainable Stock Exchanges initiative, backed by the United Nations. LSEG was the first global exchange group to become an official partner of the Climate Bonds initiative. In addition we are compliant with the ICMA’s Green Bonds Principles and we also signatories of the Paris Pledge for Action. Longer term climate change risks ensure we will actively monitor climate changes that could affect our operations, including direct impacts such as flooding and extreme weather, and indirect impacts such as increased average temperatures which could increase in cap and trade schemes, resulting in additional operating costs for our business and that of quoted companies. Engaging with ESG issues, investor-led principles such as the UN PRI and other initiatives i.e. the UN Sustainable Stock Exchange initiative have enabled the Group to gain early-mover strategic advantage over our competitors. LSE ranked first among large exchanges and eighth globally in a 2016 study by Aviva and Corporate Knights for the quality of ESG reporting disclosure (including carbon disclosure). FTSE Russell has pioneered the concept of ESG Indices globally with the FTSE4Good Index Series and has continually evolved its offering. The achievements of the Group are reflected in the top quartile ratings LSEG attains in the most high profile ESG assessments including FTSE ESG, MSCI ESG, Sustainalytics and the DJSI.

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The LSEG Global Sustainable Investment Centre was launched in 2016, and aims to integrate sustainable solutions deep into capital raising and investment - including the transition to a low-carbon economy driven by short and long-term physical and regulatory climate change impacts, . We are proud to have been one of the founding members of the Green Finance Initiative of the City of London in 2016. The GFI’s goals are to promote London’s status as a leading global centre for the provision of green and sustainable financial and professional services, to advocate for specific regulatory and policy developments and to provide public and market leadership on issues relating to market impediments and opportunities. A key decision based on physical impacts of climate change i.e. changes in long-term temperature extremes, was to set targets for in the areas of carbon emissions, energy efficiency, water, and waste. These targets are regularly reviewed, and in 2017 we set a science-based target of a 40% reduction in absolute emissions.

(C3.1g) Why does your organization not use climate-related scenario analysis to inform your business strategy? In the next two years we plan to carry out scenario analysis linking the implications of investments associated to different EIA scenarios to industry shifts. We expect the results of this scenario analysis to inform our future business strategy

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C4 Targets and performance

Targets

(C4.1) Did you have an emissions target that was active in the reporting year? ● Both absolute and intensity targets

(C4.1a) Provide details of your absolute emissions target(s) and progress made against those targets. Please complete the following table.

Target reference number

Scope % emissions in Scope % reduction from base year

Base year Start year Base year emissions covered by target (metric tons CO2e)

Abs 1

Scope 1 +2 (market-based)

100%

40%

2016

2017

22712

Target year Is this a science-based target? % achieved (emissions) Target status Please explain

2030 Yes, we consider this a science-based target, but this target has not been approved as science-based by the Science-Based Targets initiative

100% ● Underway ●

This target has been reviewed and approved by the Science Based Targets Initiative in 2017, however is awaiting formal approval status on completion of a Scope 3 target. We exceeded this long-term target in 2017 due primarily to a switch to 100% renewable energy for our managed UK energy sources, which include a significant percentage of our

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data centre footprint. Though this target was exceeded in the reporting year (41% reduction vs base year), we are maintaining it as a long-term absolute reduction target which will become more challenging to achieve as the business grows.

(C4.1b) Provide details of your emissions intensity target(s) and progress made against those target(s). Please complete the following table.

Target reference number

Scope % emissions in Scope % reduction from baseline year

Metric Base year Start year

Int 1

Scope 1+2 (location-based) +3 (upstream)

100%

20%

Metric tons CO2e per unit revenue

2013

2014

Normalized baseline year emissions covered by target (metric tons CO2e)

Target year Is this a science-based target?

% achieved (emissions)

Target status Please explain % change anticipated in absolute Scope 1+2 emissions

% change anticipated in absolute Scope 3 emissions

0.00003

2020 No, but we are reporting another target that is science-based

100% ● Underway ●

Target covers Total Group Emissions from Scope 1, 2 and 3 (including Air Travel, Rail Travel, Water and Waste). We exceeded this long-term target in 2017 due primarily to a switch to 100% renewable energy for our managed UK energy sources, together with other

-1 -1

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significant improvements in energy efficiency since 2013. This target was exceeded in the reporting year (-59% tCO2e per £m Revenue in 2017 vs base year), and is now being replaced by a long-term science-based absolute emissions reduction target. As a direct result of this target, we anticipated a small reduction in absolute emissions by 2020, however we are now anticipating significant reductions due to the additional setting of an absolute long-term science-based target.

Target reference number

Scope % emissions in Scope % reduction from baseline year

Metric Base year Start year

Int 2

Scope 1+2 (location-based) +3 (upstream)

100%

20%

Metric tons CO2e per unit FTE employee

2013

2014

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Normalized baseline year emissions covered by target (metric tons CO2e)

Target year Is this a science-based target?

% achieved (emissions)

Target status Please explain % change anticipated in absolute Scope 1+2 emissions

% change anticipated in absolute Scope 3 emissions

9.7

2020 No, but we are reporting another target that is science-based

100% ● Underway ●

Target covers Total Group Emissions from Scope 1, 2 and 3 (including Air Travel, Rail Travel, Water and Waste). We exceeded this long-term target in 2017 due primarily to a switch to 100% renewable energy for our managed UK energy sources, together with other significant improvements in energy efficiency since 2013. This target was exceeded in the reporting year (-56% tCO2e per FTE in 2017 vs base year), and is now being replaced by a long-term science-based absolute emissions reduction target. As a direct result of this target, we anticipated a small reduction in absolute emissions by 2020, however we are now anticipating significant reductions due to the additional setting of an

-1 -1

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absolute long-term science-based target.

Target reference number

Scope % emissions in Scope % reduction from baseline year

Metric Base year Start year

Int 3

Scope 1+2 (location-based) +3 (upstream)

100%

2%

Metric tons CO2e per unit revenue

2016

2016

Normalized baseline year emissions covered by target (metric tons CO2e)

Target year Is this a science-based target?

% achieved (emissions)

Target status Please explain % change anticipated in absolute Scope 1+2 emissions

% change anticipated in absolute Scope 3 emissions

0.0000191

2017 No, but we are reporting another target that is science-based

100% ● Underway ●

Target covers Total Group Emissions from Scope 1, 2 and 3 (including Air Travel, Rail Travel, Water and Waste). We exceeded this annual target in 2017 due primarily to a switch to 100% renewable energy for our managed UK energy sources, together with other energy and emissions reduction initiatives. This target was exceeded in the reporting year (-41% tCO2e per £m Revenue in 2017 vs 2016), and is has been upgraded to a 5% reduction target for

-41 -2

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2018. As a direct result of this target, we anticipated a small reduction in absolute emissions, however the switch to renewable energy resulted in a 41% reduction in absolute Scope 1 & 2 emissions vs 2016. We anticipated a small reduction in absolute Scope 3 emissions as a result of this target and achieved a 2% reduction in absolute Scope 3 emissions vs 2016.

Target reference number

Scope % emissions in Scope % reduction from baseline year

Metric Base year Start year

Int 4

Scope 1+2 (location-based) +3 (upstream)

100%

2%

Metric tons CO2e per unit FTE employee

2016

2016

Normalized baseline year emissions covered by target (metric tons CO2e)

Target year Is this a science-based target?

% achieved (emissions)

Target status Please explain % change anticipated in absolute Scope 1+2 emissions

% change anticipated in absolute Scope 3 emissions

6.91 2017 No, but we are reporting another target that is science-based

100% ● Underway ●

Target covers Total Group Emissions from Scope 1, 2 and 3 (including Air Travel, Rail Travel, Water and Waste).

-41 -2

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We exceeded this annual target in 2017 due primarily to a switch to 100% renewable energy for our managed UK energy sources, together with other energy and emissions reduction initiatives. This target was exceeded in the reporting year (-42% tCO2e per FTE in 2017 vs 2016), and is has been upgraded to a 5% reduction target for 2018. As a direct result of this target, we anticipated a small reduction in absolute emissions, however the switch to renewable energy resulted in a 41% reduction in absolute Scope 1 & 2 emissions vs 2016. We anticipated a small reduction in absolute Scope 3 emissions as a result of this target and achieved a 2% reduction in absolute Scope 3 emissions vs 2016.

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Other climate-related targets

(C4.2) Provide details of other key climate-related targets not already reported in question C4.1/a/b. Please complete the following table.

Target KPI – Metric numerator

KPI – Metric denominator (intensity targets only)

Base year Start year Target year KPI in baseline year

● Waste

metric tonnes total waste

Full Time Employee (FTE) 2016

2016

2017 0.21

KPI in target year % achieved in reporting year

Target Status Please explain Part of emissions target Is this target part of an overarching initiative?

0.17

100%

Underway LSEG continues to achieve 99% landfill avoidance, and total waste produced per FTE has reduced by 13%. This is largely driven by improvements in the waste management process in the UK including introduction of a baler and new food waste processes – adding to an innovative food waste solution in Italy.

Science-based targets initiative

Target KPI – Metric numerator

KPI – Metric denominator (intensity targets only)

Base year Start year Target year KPI in baseline year

● Air Travel

tCO2e from Air Travel

£m Revenue 2016

2016

2017 3.83

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KPI in target year % achieved in reporting year

Target Status Please explain Part of emissions target Is this target part of an overarching initiative?

3.61

100%

Underway LSEG continues to review and extend the use and availability of video conferencing (VC) facilities, and to encourage the use of VC in place of air travel. Train travel is the preferred option between a number of major European hubs. Over the last year, we significantly exceeded our target of a 10% increase in VC call hours (49%). Air travel per FTE also exceeded its 2% reduction target, achieving a 6% reduction per £m Revenue. In 2017, we changed part of our vehicle fleet to be electric (charged using 100% renewables), and are investigating options to switch the remaining fleet.

Science-based targets initiative

Emissions reduction initiatives

(C4.3) Did you have emissions reduction initiatives that were active within the reporting year? Note that this can include those in the planning and/or implementation phases. ● Yes

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(C4.3a) Identify the total number of projects at each stage of development, and for those in the implementation stages, the estimated CO2e savings. Please complete the following table:

Stage of development Number of projects Total estimated annual CO2e savings in metric tons CO2e (only for rows marked *)

Under investigation

15 824

To be implemented*

2 124

Implementation commenced*

3 156

Implemented*

4 15324

Not to be implemented

(C4.3b) Provide details on the initiatives implemented in the reporting year in the table below. Please complete the following table.

Activity type Description of activity Estimated annual CO2e savings (metric tons CO2e)

Scope Voluntary/ Mandatory

● Low-carbon energy purchase

100% Natural Renewable Energy Purchase

13854

● Scope 2 (market-based)

● Voluntary ●

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Annual monetary savings (unit currency, as specified in C0.4)

Investment required (unit currency, as specified in C0.4)

Payback period Estimated lifetime of the initiative Comment

0 15000 ● 1-3 years ●

● >30 years

In May 2017, we switched 64% of the Group's electricity to be sourced from 100% natural, renewable energy sources. This energy is backed by a Renewable Electricity Commitment Certificate and is expected to be a long term commitment.

Activity type Description of activity Estimated annual CO2e savings (metric tons CO2e)

Scope Voluntary/ Mandatory

● Energy Efficiency: Processes

Cooling technology

106

● Scope 1 ● Scope 2 (location-based) ● Scope 2 (market based) ● Scope 3

● Voluntary ●

Annual monetary savings (unit currency, as specified in C0.4)

Investment required (unit currency, as specified in C0.4)

Payback period Estimated lifetime of the initiative Comment

21500 160000 ● 4-10 years ●

● 6-10 years

Data centre cold aisle containment and equipment efficiency consolidation projects are resulting in greater utilisation of available space and reductions in energy and water consumption. 2017 saw the implementation of a similar scope of programme to 2016. Reductions were achieved in Scope 1 & 2 (energy, cooling and heating) and Scope 3 (water).

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Activity type Description of activity Estimated annual CO2e savings (metric tons CO2e)

Scope Voluntary/ Mandatory

● Energy Efficiency: Building Services

Lighting

24 ● Scope 2 (location-based) ● Scope 2 (market based)

● Voluntary ●

Annual monetary savings (unit currency, as specified in C0.4)

Investment required (unit currency, as specified in C0.4)

Payback period Estimated lifetime of the initiative Comment

4000 15000 ● 1-3 years ●

● 6-10 years

Swap out lighting for LED equivalents in office spaces. Reductions were achieved in Scope 2 energy.

Activity type Description of activity Estimated annual CO2e savings (metric tons CO2e)

Scope Voluntary/ Mandatory

● Energy Efficiency: Processes

Process optimization

1340

● Scope 2 (location-based) ● Scope 2 (market based)

● Voluntary ●

Annual monetary savings (unit currency, as specified in C0.4)

Investment required (unit currency, as specified in C0.4)

Payback period Estimated lifetime of the initiative Comment

201000 0 ● 1-3 years ●

● 6-10 years

Emissions reduction activities in 2017 included cold-aisle containment and LED lighting, as above, but also included server efficiency replacements in data centres, and office consolidation projects in our UK offices particularly. Changes to food waste management processes in Italy and the UK resulted in further Scope 3 reductions. Reductions were achieved in Scope 1 & 2 (energy, cooling and heating)

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and Scope 3 (water and waste). Investment in these reduction activities is now considered BAU, so no further investment is required.

(C4.3c) What methods do you use to drive investment in emissions reduction activities? Please complete the following table.

Method Comment

● Compliance with regulatory requirements/standards

LSEG are deriving further energy efficiency and GHG emissions reduction through participation in the UK CRC Energy Efficiency Scheme and the ESOS scheme, as well as the UK mandatory emissions reporting regulations.

● Employee engagement The small decisions we each make help us become more aware of our strategic role in building a sustainable economy and business, through investment and engagement. Because of this, we believe that the investment with the highest return for the environment is behavioural change. This year, we continued to engage staff through sustainability communications, regular reporting of performance against targets on our intranet and other initiatives.

● Financial optimization calculations LSEG have employed the services of energy efficiency specialists where appropriate to quantify, analyse and prioritise financial investment in building fabric, services and process efficiencies, including as part of the ESOS process. These projects will simultaneously reduce LSEG's GHG emissions and energy costs.

Low-carbon products

(C4.5) Do you classify any of your existing goods and/or services as low-carbon products or do they enable a third party to avoid GHG emissions? ● No

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C5 Emissions methodology

Base year emissions

(C5.1) Provide your base year and base year emissions (Scopes 1 and 2). Please complete the following table:

Scope Base year start Base year end Base year emissions (metric tons CO2e)

Comment

Scope 1

1/1/2016

12/31/2016

1583

Scope 2 (location-based)

1/1/2016 12/31/2016 23120

Scope 2 (market-based)

1/1/2016 12/31/2016 21738

Emissions methodology (C5.2) Select the name of the standard, protocol, or methodology you have used to collect activity data and calculate Scope 1 and Scope 2 emissions. ● Bilan Carbone

● Defra Voluntary 2017 Reporting Guidelines

● The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised Edition)

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C6 Emissions data

Scope 1 emissions data

(C6.1) What were your organization’s gross global Scope 1 emissions in metric tons CO2e?

Gross global Scope 1 emissions (metric tons CO2e) End-year of reporting period Comment

1918 2017

1583 2016 2016 figures have been updated on receipt of annual emissions factor guidance and actual data from suppliers.

1094 2015 2015 figures have been updated on receipt of annual emissions factor guidance and actual data from suppliers.

1294 2014 2014 figures have been updated on receipt of annual emissions factor guidance and actual data from suppliers.

Scope 2 emissions reporting

(C6.2) Describe your organization's approach to reporting Scope 2 emissions. Please complete the following table:

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Scope 2, location-based Scope 2, market-based Comment

● We are reporting a Scope 2, location-based figure

● We are reporting a Scope 2, market-based figure

Scope 2 emissions data

(C6.3) What were your organization's gross global Scope 2 emissions in metric tons CO2e? Please complete the following table:

Scope 2, location-based Scope 2, market-based (if applicable) End-year of reporting period Comment

21958

11749

23120 21738 2016 2016 figures have been updated on receipt of annual emissions factor guidance and actual data from suppliers.

24204 22809 2015 2015 figures have been updated on receipt of annual emissions factor guidance and actual data from suppliers.

24528 23259 2014 2014 figures have been updated on receipt of annual emissions factor guidance and actual data from suppliers.

Exclusions

(C6.4) Are there any sources (e.g. facilities, specific GHGs, activities, geographies, etc.) of Scope 1 and Scope 2 emissions that are within your selected reporting boundary which are not included in your disclosure? ● No

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Scope 3 emissions data

(C6.5) Account for your organization’s Scope 3 emissions, disclosing and explaining any exclusions. Please complete the following table:

Sources of Scope 3 emissions

Evaluation status Metric tons CO2e Emissions calculation methodology

Percentage of emissions calculated using data obtained from suppliers or value chain partners

Explanation

Purchased goods and services

● Relevant, not yet calculated

Purchased goods and services are likely to be relevant, however as an office based financial services firm we are reviewing available data and calculation methodologies to identify the most appropriate and meaningful method to calculate, disclose and manage these emissions.

Capital goods

● Relevant, not yet calculated

As an office based financial services firm, capital goods are likely to include IT hardware in our offices and data centres. We are reviewing available data and calculation methodologies to identify the most appropriate and meaningful method to calculate, disclose and manage these emissions.

Fuel-and-energy-related activities (not included in

● Relevant, calculated 915 Data is calculated using primary data from building metering and is cross-checked

95% Emissions calculated are for Transmission and distribution (T&D) losses (generation

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Scope 1 or 2)

against supplier invoices and externally verified. Extrapolation based on FTE headcount has been used where limited data available due to landlord data restrictions or slow availability of landlord data in serviced office space. Electricity is 5% extrapolated. T&D losses from electricity are calculated using 2017 or the latest available conversion factors and associated GWP from each of the following sources: United Kingdom: DEFRA UK Government GHG 2017 Conversion Factors: www.ukconversionfactorscarbonsmart.co.uk Global (non-extrapolated): GHG Protocol: http://www.ghgprotocol.org/calculation-tools/all-tools Extrapolated: DEFRA UK Government GHG 2017 Conversion Factors: www.ukconversionfactorscarbonsmart.co.uk

of electricity).

Upstream transportation and distribution

● Not relevant, explanation provided

As an office based financial services firm, our operations do not currently include any upstream transportation or distribution other than that which would be directly included in our purchased goods and services or capital goods and services.

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Waste generated in operations

● Relevant, calculated 198 Emissions from waste are calculated based on total waste (kg) including waste to energy, waste to landfill and waste recycled (including glass, paper, cardboard, plastics, food and drink, and mixed recycling). Emissions are calculated from primary supplier data in the UK and Italy and extrapolation based on FTE has been used where primary data is not available across the rest of the world. Waste is 75% extrapolated. Emissions from waste generated in operations are calculated using 2017 or the latest available conversion factors and associated GWP from each of the following sources: United Kingdom: DEFRA UK Government GHG 2017 Conversion Factors: www.ukconversionfactorscarbonsmart.co.uk Global (non-extrapolated): DEFRA UK GHG 2017 Government Conversion Factors (as no GHG protocol factor for waste): www.ukconversionfactorscarbonsmart.co.uk Extrapolated: DEFRA UK Government 2017 GHG Conversion Factors: www.ukconversionfactorscarbonsmart.co.uk

25 We currently measure and monitor all of our global waste streams and thus are able to calculate the emissions directly arising from this aspect of our operations in the UK and Italy. We are constantly working with suppliers to increase the availability of primary data rather than using extrapolation.

Business travel

● Relevant, calculated 7085 Emissions are 100% calculated based on air travel and rail travel miles supplied and

100 Air travel forms the most significant aspect of our business travel footprint.

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confirmed by our travel booking partner. Air Travel data calculated from mileage from travel bookings provider except Asia partner bookings which are based on Origin / Destination airport codes and Via Michelen mileage data. Rail travel is calculated using origin and destination city pairs, and Via Michelen mileage data. Emissions are calculated based on Distance i.e. International, Long Haul, Short Haul, Domestic and class i.e. Economy, Premium Economy, Business Class, First Class. Rail travel uses Eurostar/National Rail factors. All factors are from 2017 DEFRA UK Government GHG Conversion Factors. Source: Full Carbon Factors export from www.ukconversionfactorscarbonsmart.co.uk

Employee commuting

● Relevant, not yet calculated We are reviewing the potential of undertaking a travel plan for our global offices to understand our employee commuting footprint and any potential methods to influence or reduce this footprint. The central city location of most of our offices means the majority of our commuting footprint is likely to be public transport based.

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Upstream leased assets

● Not relevant, explanation provided

All upstream emissions from leased assets are already included within our reported Scope 1 and Scope 2 emissions.

Downstream transportation and distribution

● Not relevant, explanation provided

As an office based financial services firm, our operations do not currently include any downstream transportation or distribution.

Processing of sold products

● Not relevant, explanation provided

As an office based financial services firm, our operations do not currently include any sold physical products.

Use of sold products

● Not relevant, explanation provided

As an office based financial services firm, our operations do not currently include any sold physical products. All emissions from our services are calculated and included within our Scope 1 and 2 reported emissions.

End of life treatment of sold products

● Not relevant, explanation provided

As an office based financial services firm, our operations do not currently include any sold physical products.

Downstream leased assets

● Not relevant, explanation provided

All investments are currently under our operational control. We use the operational control method for our reporting scope, and all investment emissions as lessor of office space have been included in our Scope 1 and 2 reported emissions.

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Franchises

● Not relevant, explanation provided

We do not currently have any franchise operations.

Investments

● Not relevant, explanation provided

Other (upstream)

● Relevant, calculated 37 Water Emissions. Data is calculated using primary data from building metering in UK, Italy and Sri Lanka and is cross-checked against supplier invoices and externally verified. Extrapolation based on FTE headcount has been used where limited data available due to landlord data restrictions or slow availability of landlord data in serviced office space for the Rest of the World. Emissions from water are calculated based on municipal water consumption in tCO2e per litre. Water is 9.4% extrapolated. Emissions from water consumption are calculated using 2017 or the latest available conversion factors and associated GWP from each of the following sources: United Kingdom: DEFRA UK Government GHG 2017 Conversion Factors: www.ukconversionfactorscarbonsmart.co.uk Global (non-extrapolated): DEFRA UK GHG 2017 Government Conversion Factors (as no GHG protocol factor for water): www.ukconversionfactorscarbonsmart.co.uk Extrapolated:

90.6 We currently measure and monitor all of our global water consumption using primary supplier data wherever available and thus are able to calculate the emissions directly arising from this aspect of our operations in the UK, Italy, Sri Lanka. We are constantly working with suppliers to increase the availability of primary data rather than using extrapolation.

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DEFRA UK Government 2017 GHG Conversion Factors: www.ukconversionfactorscarbonsmart.co.uk

Other (downstream)

Emissions from biologically sequestered carbon

(C6.7) Are carbon dioxide emissions from biologically sequestered carbon relevant to your organization? ● No

Emissions intensities

(C6.10) Describe your gross global combined Scope 1 and 2 emissions for the reporting year in metric tons CO2e per unit currency total revenue and provide any additional intensity metrics that are appropriate to your business operations. Please complete the following table.

Intensity figure Metric numerator (Gross global combined Scope 1 and 2 emissions)

Metric denominator Metric denominator: Unit total

Scope 2 figure used % change from previous year

Direction of change Reason for change

0.000006993

13667

● unit total revenue

1954500000]

● Market-based

50.3

● Decreased

Revenue increased by 18% during the reporting period, while gross Scope 1 & 2 market-based emissions decreased by 41.4% due primarily to a combination of a

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switch to 100% renewable energy in the UK from 1 May 2017, emissions reduction activities (such as cold-aisle containment and other energy efficiency projects such as LED lighting replacement) and emissions factor changes. Therefore emissions per unit total revenue have decreased by 50.3%.

2.49 13667 ● full time equivalent (FTE) employee

5491 ● Market-based 51.1 ● Decreased FTE employees increased by 20% during the reporting period, while gross Scope 1 & 2 emissions decreased by 41.4% due primarily to a combination of a switch to 100% renewable energy in the UK from 1 May 2017, emissions reduction activities (such as cold-aisle containment and other energy efficiency projects such as LED lighting replacement) and emissions factor changes. Therefore emissions per FTE have decreased by 51.1%.

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0.147 13667 ● square meter 92907 ● Market-based 43.1 ● Decreased Floorspace increased by 2.9% during the reporting period, while gross Scope 1 & 2 emissions decreased by 41.4% due primarily to a combination of a switch to 100% renewable energy in the UK from 1 May 2017, emissions reduction activities (such as cold-aisle containment and other energy efficiency projects such as LED lighting replacement) and emissions factor changes. Therefore emissions per square meter have decreased by 43.1%.

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C7 Emissions breakdown

Scope 1 breakdown: GHGs

(C7.1) Does your organization have greenhouse gas emissions other than carbon dioxide? ● No

Scope 1 breakdown: country

(C7.2) Break down your total gross global Scope 1 emissions by country/region. Please complete the following table.

Country/Region Scope 1 emissions (metric tons CO2e)

United Kingdom of Great Britain and Northern Ireland 515

Italy 1248

Sri Lanka 131

United States of America 0

France 0

Russian Federation 0

Rest of the World 24.1

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Scope 1 breakdown: business breakdown

(C7.3) Indicate which gross global Scope 1 emissions breakdowns you are able to provide. ● By activity

(C7.3c) Break down your total gross global Scope 1 emissions by business activity. Please complete the following table.

Activity Scope 1 emissions (metric tons CO2e)

Natural Gas 1503

Diesel 232

LPG 31

Road Fuel 64

Fugitive Emissions 88

Scope 2 breakdown: country

(C7.5) Break down your total gross global Scope 2 emissions by country/region. Please complete the following table.

Country/Region Scope 2, location-based (metric tons CO2e)

Scope 2, market-based (metric tons CO2e)

Purchased and consumed electricity, heat, steam or cooling (MWh)

Purchased and consumed low-carbon electricity, heat, steam or cooling accounted in market-based approach (MWh)

United Kingdom of Great Britain and Northern Ireland

14918 6232

42433

24707

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Italy 3149 1626 9155 4427

Sri Lanka 2204 2204 4269

United States of America 56 56 236

France 25 25 532

Russian Federation 150 150 381

Rest of the World 1456 1456 4758

Scope 2 breakdown: business breakdowns

(C7.6) Indicate which gross global Scope 2 emissions breakdowns you are able to provide. ● By activity

(C7.6c) Break down your total gross global Scope 2 emissions by business activity. Please complete the following table.

Activity Scope 2, location-based (metric tons CO2e) Scope 2, market-based (metric tons CO2e)

Data Centre Purchased Electricity

12,454.00

6,139.00

Office Space Purchased Electricity 9,504.00 5,610.00

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Emissions performance

(C7.9) How do your gross global emissions (Scope 1 and 2 combined) for the reporting year compare to those of the previous reporting year? ● Decreased

(C7.9a) Identify the reasons for any change in your gross global emissions (Scope 1 and 2 combined), and for each of them specify how your emissions compare to the previous year. Please complete the following table:

Reason Change in emissions (metric tons CO2e)

Direction of change Emissions value (percentage) Please explain calculation

Change in renewable energy consumption

9,774.00

● Decreased

41.91

Scope 1 & 2 market-based emissions decreased by 41.4% in 2017 due primarily to a combination of a switch to 100% renewable energy in the UK from 1 May 2017. In 2016, emissions from the switched meters was 13854 tCO2e, whereas in 2017 following the switch emissions were 4080 tCO2e, a reduction of 9774 tCO2e or 70.55%. 2016 gross Scope 1 & 2 market-based emissions were 23321 tCO2e. The calculation for the emissions value % is therefore (9774/23321)*100 = 41.91%

Other emissions reduction activities

1,470.00 ● Decreased 6.3 Emissions reduction activities in 2017 included cold-aisle containment and server efficiency replacements in data centres, and office consolidation and LED lighting replacement in offices. It is estimated that these emissions reduction activities resulted in reductions of 1470 tCO2e. 2016 gross Scope 1 & 2 market-based

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emissions were 23321 tCO2e. The calculation for the emissions value % is therefore (1470/23321)*100 = 6.3%

Divestment

There have been no material divestments during the reporting period.

Acquisitions

There have been no material acquisitions during the reporting period.

Mergers

There have been no material mergers during the reporting period.

Change in output

1,599.00 ● Increased 6.86 During the reporting period, our Primary Markets saw 194 new companies listed. In Secondary Markets, UK cash equity average daily value traded increased by 4%, average daily number of equity trades in Italy increased by 6%. To support this growth, our data centre occupancy increased by 2.7%, and FTE employees increased by 19.8%. Scope 2 electricity consumption increased by 6.7% against 2016, or 1599 tCO2e if using 2016 emissions factors. Changes in Scope 1 emissions are outlined in 'Other' below. 2016 gross Scope 1 & 2 market-based emissions were 23321 tCO2e. The calculation for the emissions value % is (1599/23321)*100 = 6.86%.

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Change in methodology

1,974.00 ● Decreased 8.46 The Defra electricity emissions factor, which is used primarily across our UK sites, decreased by 14.68% in 2017 vs 2016. There was no material change in Scope 1 factors. The difference between 2017 electricity emissions with no emissions factor change, and with the 14.68% emissions factor reduction, is 1974 tCO2e. 2016 gross Scope 1 & 2 market-based emissions were 23321 tCO2e. The calculation for the emissions value % is (1974/23321)*100 = 8.46%.

Change in boundary

There have been no boundary changes during the reporting period.

Change in physical operating conditions

There have been no material changes in physical operating conditions during the reporting period.

Unidentified

Other

385 Increased 1.65 Scope 1 energy consumption from Natural Gas increased by 28% or 385 tCO2e using 2016 conversion factors, largely due to a landlord meter fault at a site in Italy which has now been resolved. 2016 gross Scope 1 & 2 market-based emissions were 23321 tCO2e. The calculation for the emissions value % is (385/23321)*100 = 1.65%.

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(C7.9b) Are your emissions performance calculations in C7.9 and C7.9a based on a location-based Scope 2 emissions figure or a market-based Scope 2 emissions figure? ● Market-based

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C8 Energy

Energy spend

(C8.1) What percentage of your total operational spend in the reporting year was on energy? ● More than 0% but less than or equal to 5%

Energy-related activities

(C8.2) Select which energy-related activities your organization has undertaken. Please complete the following table:

Activity Indicate whether your organization undertakes this energy-related activity

Consumption of fuel (excluding feedstocks)

• YES

Consumption of purchased or acquired electricity • YES

Consumption of purchased or acquired heat • NO

Consumption of purchased or acquired steam • NO

Consumption of purchased or acquired cooling • NO

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Generation of electricity, heat, steam, or cooling • YES

(C8.2a) Report your organization’s energy consumption totals (excluding feedstocks) in MWh. Please complete the following table:

Activity Heating value MWh from renewable sources MWh from non-renewable sources Total MWh

Consumption of fuel (excluding feedstock)

● HHV (higher heating value)

0

8,671.00

8,671.00

Consumption of purchased or acquired electricity

N/A

Consumption of purchased or acquired heat

N/A

Consumption of purchased or acquired steam

N/A

Consumption of purchased or acquired cooling

N/A

Consumption of self-generated non-fuel renewable energy

N/A

Total energy consumption

N/A 29,134.00 41,301.00 70,435.00

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(C8.2b) Select the applications of your organization’s consumption of fuel. Please complete the following table:

Fuel application Indicate whether your organization undertakes this fuel application

Consumption of fuel for the generation of electricity

• No

Consumption of fuel for the generation of steam

• No

Consumption of fuel for the generation of cooling

• No

Consumption of fuel for co-generation or tri-generation

• No

(C8.2c) State how much fuel in MWh your organization has consumed (excluding feedstocks) by fuel type. Please complete the following table.

Fuels Heating value Total MWh consumed by the organization

Natural Gas

● HHV

7,594.00

Diesel

● HHV

933.00

Liquefied Petroleum Gas (LPG)

● HHV

144.00

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(C8.2d) List the average emission factors of the fuels reported in C8.2c. Please complete the following table:

Fuel Emission factor Unit Emission factor source Comment

Diesel

2.63567 ● metric tons CO2e per liter

UK and Rest of World: 2017 UK Government GHG Conversion Factors for Company Reporting: Fuels, Diesel (Retail), litres (Gross CV) - 2.57843 Italy and Sri Lanka: GHG Protocol 2009-2015: Diesel (Retail) - 2.6753

Liquefied Petroleum Gas (LPG) 2.99048 ● metric tons CO2e per metric ton GHG Protocol 2009-2015: LPG -

Natural Gas 0.19792 ● metric tons CO2e per MWk UK and Rest of World: 2017 UK Government GHG Conversion Factors for Company Reporting: Fuels, Natural Gas, kWh (Gross CV) - 0.18416I Italy: GHG Protocol 2015: Natural Gas - 0.20215

(C8.2f) Provide details on the electricity, heat, steam, and/or cooling amounts that were accounted for at a low-carbon emission factor in the market-based Scope 2 figure reported in C6.3. Please complete the following table.

Basis for applying a low-carbon emission factor

Low-carbon technology type MWh consumed associated with low-carbon electricity, heat, steam or cooling

Emission factor (in units of metric tons CO2e per MWh)

Comment

● Energy attribute certificates, Guarantees of Origin

● Solar PV ● Concentrated solar power (CSP) ● Wind ● Hydropower

29,134.00

0

Renewable electricity in Italy is provided by 100% hydro. Renewable electricity in the UK is provided by 100% natural (Sun, Wind

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● Biomass (including biogas) ● Tidal

or Water) REGO backed electricity.

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C9 Additional metrics

Other climate-related metrics

(C9.1) Provide any additional climate-related metrics relevant to your business. Please complete the following table.

Description Metric value Metric numerator Metric denominator (intensity metric only)

% change from previous year

Direction of change Please explain

Waste

0.17 metric tonnes waste Full Time Employee (FTE)

12.7 Decreased LSEG continues to achieve 99% landfill avoidance, and total waste produced per FTE has reduced by 13%. This is largely driven by improvements in the waste management process in the UK including introduction of a baler and new food waste processes – adding to an innovative food waste solution in Italy.

Air Travel 3.61 tCO2e from Air Travel £m Revenue 5.9 Decreased LSEG continues to review and extend the use and availability of video conferencing (VC) facilities, and to encourage the use of VC in place of air travel. Train travel is the preferred

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option between a number of major European hubs. Over the last year, we significantly exceeded our target of a 10% increase in VC call hours (49%). Air travel per FTE also exceeded its 2% reduction target, achieving a 6% reduction per £m Revenue.

Paper Consumption 2065 Sheets of A4 Paper Full Time Employee (FTE) 1.6 Decreased In our second year of setting a paper reduction target, we achieved a 2% reduction in A4 sheets per FTE, building on a 29% reduction in 2016. A new print management system is being further rolled out, and an ongoing push towards paperless processes is expected to driver further reductions in 2018.

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C10 Verification

Verification

(C10.1) Indicate the verification/assurance status that applies to your reported emissions. Please complete the following table:

Scope Verification/assurance status

Scope 1

● Third-party verification or assurance process in place

Scope 2 (location-based or market-based)

● Third-party verification or assurance process in place

Scope 3

● Third-party verification or assurance process in place

(C10.1a) Provide further details of the verification/assurance undertaken for your Scope 1 and/or Scope 2 emissions and attach the relevant statements. Please complete the following table.

Scope Verification or assurance cycle in place

Status in the current reporting year

Type of verification or assurance

Attach the statement Page/section reference

Relevant standard Proportion of reported emissions verified (%)

● Scope 1

● Annual process

● Complete

● Limited assurance

Attach your document here.

Pages 1-4. ISO14064-3 100%

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● Scope 2 location based

● Annual process ● Complete ● Limited assurance Pages 1-4. ISO14064-3 100%

● Scope 2 market based

● Annual process ● Complete ● Limited assurance Pages 1-4. ISO14064-3 100%

(C10.1b) Provide further details of the verification/assurance undertaken for your Scope 3 emissions and attach the relevant statements. Please complete the following table.

Scope Verification or assurance cycle in place

Status in the current reporting year

Attach the statement Page/ section reference Relevant standard

● Scope 3- at least one applicable category

● Annual process

● Complete

Attach your document here.

Pages 1-4. Scope 3 emissions covered in this verification statement cover all Scope 3 emissions categories reported in this CDP disclosure.

● ISO14064-3

Other verified data

(C10.2) Do you verify any climate-related information reported in your CDP disclosure other than the emissions figures reported in C6.1, C6.3, and C6.5? ● No, but we are actively considering verifying within the next two years

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C11 Carbon pricing

Carbon pricing systems

(C11.1) Are any of your operations or activities regulated by a carbon pricing system (i.e. ETS, Cap & Trade or Carbon Tax)? ● No, and we do not anticipate being regulated in the next three years

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C12 Engagement

Value chain engagement

(C12.1) Do you engage with your value chain on climate-related issues? ● Yes, our suppliers

● Yes, our customers

(C12.1a) Provide details of your climate-related supplier engagement strategy. Please complete the following table.

Type of engagement Details of engagement

% of suppliers by number

% total procurement spend (direct and indirect)

% Scope 3 emissions as reported in C6.5

Rationale for the coverage of your engagement

Impact of engagement, including measures of success

Comment

● Compliance & onboarding

● Included climate change in supplier selection / management mechanism

● Climate change is integrated into supplier evaluation processes

● Collect climate change and carbon information at least annually from suppliers

7.50%

54.30%

100%

We engage our suppliers to understand their approach to environmental management including their carbon and climate change practices. We use this information to help inform and prioritise our supply chain selection, and to help understand our wider procurement impacts. We target strategic

The Group introduced a new Procurement Policy and Supplier Code of Conduct in October 2014. The figures supplied account for the suppliers who have confirmed commitment to comply with the code and what value of our third party cost base they represent (as a proportion of our 3rd party spend in 2017). Climate

We currently engage our suppliers to understand their approach to environmental management including their carbon and climate change practices. We use this information to help inform and prioritise our supply chain selection, and to help understand our wider procurement impacts.

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Information collection (understanding supplier behavior)

and high value suppliers as our main priority, due to the scope and scale of their environmental impacts and the level of engagement we have with them.

change and wider environmental considerations are incorporated into the Supplier Due Diligence Framework which was launched alongside the policy and requirements with a specific environmental impact are referred escalated to Group Property to ensure environmental considerations are addressed for new suppliers. Procurement continues to drive adoption and agreement to the Code. Approximately 7.5% (5% in 2015) of our total supply base has so far committed to comply with the Code, equivalent to more than 54% (50% in 2015) of our annual third party spend - these metrics are our primary measures of success of our engagement. We are continuing to target strategic and high value suppliers as our main priority.

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(C12.1b) Give details of your climate-related engagement strategy with your customers. Please complete the following table.

Type of engagement Details of engagement Size of engagement % Scope 3 emissions as reported in C6.5

Please explain the rationale for selecting this group of customers and scope of engagement

Impact of engagement, including measures of success

● Education/information sharing

● Run an engagement campaign to educate customers about the climate change impacts of (using) your products, goods, and/or services

100

0

The political, economic, physical and social environment in which we operate is undergoing much change and the need for efficient, transparent and well regulated capital markets has never been greater. Understanding how climate change is, and potentially will, impact the operations of LSEG, our clients and suppliers is crucial to our business. Until now the transition to a sustainable and “green” economy has been a loose concept rather than a defined, investable, industrial system. This lack of definition and data has led to the impression that it is of limited size; small cap dominated; lacking diversification and that investors give up performance in exchange for environmental benefits. However, analysis by FTSE Russell dispels these stereotypes. It finds a large investment opportunity, backed by global efforts to combat climate change and broader environmental challenges. The opportunity is diversified across company size,

On 9 February 2017, LSEG issued guidance through the Global Sustainable Investment Centre, setting out recommendations for good practice in ESG reporting. The global guide responds to demand from investors for a more consistent approach to ESG reporting, which is now a core part of the investment decision process. The Guidance is available online to both issuers and investors globally, and was sent to more than 2,700 companies that have securities listed on LSEG’s UK and Italian markets with a combined market capitalisation of more than US$7 trillion. We have engaged companies of all sizes listed on London Stock Exchange and Borsa Italiana, and FTSE Russell has consulted asset owners and asset managers to understand key ESG reporting challenges. The Guidance builds on market standards such as the Financial Stability Board’s Task Force on Climate related Financial Disclosures report and the UN Sustainable

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geography and sector and has delivered out performance of the global equity market. Our role means the core influence we bring to long term climate change impacts is through products and services that help drive the market transition to a low-carbon economy. LSEG is ideally placed to help promote good practice across the industry, and a core part of this is engagement with our customers.

Development Goals. The launch of the Guidance leverages the central role LSEG plays in capital markets and support improvements in reporting, dialogue and data flows along the investment chain. The launch event was attended by over 800 market participants globally, both in presence and remotely. Following the launch, the Guidance was integrated into London Stock Exchange’s Issuer Services portal (www2.londonstockexchangegroup.com/issuer-services) and presented at the first Italian Sustainability Day organised by Borsa Italiana. The full Guidance can be viewed at: www.lseg.com/esg.

Public policy engagement

(C12.3) Do you engage in activities that could either directly or indirectly influence public policy on climate-related issues through any of the following? ● Direct engagement with policy makers

● Trade associations

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(C12.3a) On what issues have you been engaging directly with policy makers? Please complete the following table.

Focus of legislation Corporate position Details of engagement Proposed legislative solution

● Mandatory carbon reporting

● Support with minor exceptions

EU’s Non-Financial Reporting Directive mandates large public-interest entities (listed companies, banks, insurance undertakings and other companies that are so designated by Member States) with more than 500 employees to disclose in their management report relevant and useful information on their policies, main risks and outcomes relating to various ESG factors. LSEG supported this EU Directive and its transposition into EU member states’ law (particularly in the UK and Italy). We have responded to the public consultation n, participated in workshop organised by the policymakers and engaged with the European Commission.

During this engagement, we stressed the importance of investor materiality, importance of investment grade data and compatibility with the global frameworks, the FSB TCFD in particular.

● Climate finance ● Support David Harris was appointed a member of the European Commission High-Level Expert Group on Sustainable Finance, and contributes to developing recommendations for a comprehensive EU strategy on sustainable finance as part of the Capital Markets Union. The Commission will draw on these recommendations to determine how to integrate sustainability considerations into the EU's rules for the financial sector. This marks an important step in the follow-up to the EU's 2030 Agenda for sustainable development as well as the Paris Agreement on climate change.

Investors need better access to quality ESG data, tools and sustainable investment opportunities: Companies should be encouraged to provide more detailed sub-segment revenue breakdown; particularly for environmentally or socially positive products. The EU can support global standard formation of reporting and standards, building on the work of the FSB TCFD, and preventing regional fragmentation including encouraging IOSCO to play a role. Mechanisms to support greater green bond issuance, including from the corporate sector, and investable opportunities for green infrastructure are also needed. Catalysing sustainable investments by European Asset Owners. More asset owners, particularly corporate pension schemes, should be encouraged to follow the leadership of peers in

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integrating ESG considerations and in increasing asset allocation to green and socially beneficial investments. This could be through further clarifying and strengthening the understanding of consultants, trustees and investment boards around fiduciary duty (building on, but going further than IORP2) and through a European equivalent of Article 173 to spur investors to report on ESG integration and portfolio climate exposures, and hence to create an enabling environment. Incorporation of within the prospectus is important and should be reflected in prospectus regulation. Retail investors also need support and the PRIPs directive could be further built on, as could the modernised Prospectus Directive so that relevant ESG considerations are fully reflected. Reduce regulatory barriers to long term sustainable investments by life insurance. This could include reducing the capital buffer requirements where assets relate to long term green or sustainable assets. Note that Solvency II also encourages investment in debt over equity due to the vastly differing capital charges. Where investments are in long term green infrastructure investments they could be treated preferentially.

(C12.3b) Are you on the board of any trade associations or do you provide funding beyond membership? ● Yes

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(C12.3c) Enter the details of those trade associations that are likely to take a position on climate change legislation. Please complete the following table.

Trade association Is your position on climate change consistent with theirs?

Please explain the trade association’s position

How have you influenced, or are you attempting to influence the position?

UKSIF (UK Sustainable Investment & Finance Association)

● Consistent

UKSIF advances its mission and delivers value for its members by: Acting as a voice for the sustainable and responsible finance industry in the UK, convening its members to understand, educate and influence governments, nongovernmental organisations, regulators, companies, professional advisers, the general public and other stakeholders. As the industry matures and access to and information about companies becomes easier to obtain, UKSIF’s role in support of dialogue with governments and regulators in the UK and potentially elsewhere has become a more significant part of its role. Their support for UK leadership in advancing sustainable development through investment and finance includes: Accelerating green finance and impact investing. In partnership with others, we support the creation of the UK Green Investment Bank and influencing corporate sustainability reporting requirements such as carbon emissions and regulatory approaches to social impact investment. Assisting members to develop their practices. Their analyst seminar programme catalyses debate on emerging environmental (including climate change), social and governance issues and assists our members to develop their practices. Other activities include the annual Extel SRI & Sustainability Survey, the UKSIF Annual Lecture and their support for the City of London’s Sustainable City Awards.

David Harris is LSEG's Group Head of Sustainability Business and is responsible for FTSE Russell’s ESG services, including FTSE4Good, ESG Ratings and FTSE Environmental Markets. David was elected to the UKSIF Board in 2009 and until September 2015 served as Vice Chair. At the September 2015 AGM David had completed his two terms and stood down. John Jarrett, Associate ESG Director, FTSE Russell was successfully elected in a contested election to replace David on the board. Beata Sivak, Senior Regulatory Strategy Manager, has been appointed a member of the Leadership committee, giving organisation a policy steer. LSEG influences the UKSIF position through these roles, as well as our role as members of a number of regional and global ESG/responsible investment trade bodies including US SIF, ASRIA, Japan SIF and EuroSIF. We are also members of the UN PRI.

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UN Sustainable Stock Exchanges Initiative ● Consistent The SSE Initiative aims to explore how exchanges can work together with investors, regulators and companies to enhance corporate transparency and ultimately performance on ESG issues and to encourage responsible long-term approaches to investment. Currently over 40 exchanges from around the world are partner exchanges to the SSE Initiative.

David Harris is a member of the UN SSE Consultative Group and chaired the Working Group that in 2015 developed the Model Guidance for Exchange on ESG disclosure. LSEG launched in 2017 an own Guidance for issuers on the integration of ESG into investor reporting and communication, based on the model guidance.

Climate Bonds Partnership Programme ● Consistent Climate Bonds Initiative is the only organisation in the world working solely to mobilize the largest capital market of all, the $100 trillion bond market, for climate change solutions

London Stock Exchange Group (LSEG) become the first global exchange to join the Climate Bonds Partnership Program.

Green Bond Principles ● Consistent The Green Bond Principles are coordinated by the ICMA.

LSEG is an official observer.

TCFD - Financial Stability Board Task Force on Climate-Related Financial Disclosures

● Consistent The Task Force on Climate-related Financial Disclosures (TCFD) will develop voluntary, consistent climate-related financial risk disclosures for use by companies in providing information to investors, lenders, insurers, and other stakeholders. The Task Force will consider the physical, liability and transition risks associated with climate change and what constitutes effective financial disclosures across industries. The work and recommendations of the Task Force will help firms understand what financial markets want from disclosure in order to measure and respond to climate change risks, and encourage firms to align their disclosures with investors’ needs.

LSEG took part in the Phase I consultation, responded to the subsequent “Recommendations” report, participated in various events serving to raise awareness and engaged in discussions with members of the Task Force. Mary Shapiro, Non-Executive Director to LSEG Board has been a secretary to the Task Force.

(C12.3f) What processes do you have in place to ensure that all of your direct and indirect activities that influence policy are consistent with your overall climate change strategy? LSEG has a transparent approach to lobbying. All our consultation papers are published on our website. We are also registered in the EU's Transparency Register.

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The 'Our Communities' strategic CR pillar coordinates activities across the Group, partnering with all business areas to ensure consistency of engagement and approach with both internal and external stakeholders. All Government Relations and policy initiatives involve the development of position papers which are submitted to the Corporate Responsibility Committee. CR Committee members provide their input whenever they see the topic has possible areas of overlap with sustainability and climate change issues to ensure these are consistent with the Group’s overall climate change strategy. In 2017, LSEG Group Head of Sustainable Business, David Harris, was appointed a member of the European Commission High-Level Expert Group on Sustainable Finance, aiming to deliver a long term EU strategy by Q1 2018. LSEG and specifically FTSE Russell plays a leading role in the most important ESG and sustainable investment initiatives globally and is a board or advisory council member for a number of them. These include UKSIF, US SIF, City of London Green Finance Initiative, US SIF, ASRIA, EuroSIF, RIIA, the UN backed PRI, and Luxflag. To increase awareness, FTSE Russell representatives regularly speak at conferences and in the media. FTSE Russell also works with a range of leading ESG partners and providers in delivering and supporting ESG services, including Impax Asset Management, CDP and Trucost.

Communications

(C12.4) Have you published information about your organization’s response to climate change and GHG emissions performance for this reporting year in places other than in your CDP response? If so, please attach the publication(s). Please complete the following table.

Publication Status Attach the document Content elements

● In mainstream reports

● Complete

Attach your document here.

● Governance ● Strategy ● Risks & Opportunities ● Emissions figures

● In voluntary sustainability report ● Complete ● Governance ● Strategy ● Risks & Opportunities ● Emission figures ● Emission targets ● Other metrics

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C14 Signoff

Signoff

(C14.1) Provide details for the person that has signed off (approved) your CDP climate change response.

Job title Corresponding job category

Board/Executive board

● Chief Financial Officer (CFO)

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Important Information Companies should not consider their CDP response a means of complying with any regulatory requirement to share financially sensitive non-public information with the market. CDP questionnaire copyright and licensed use

The copyright to CDP’s annual questionnaire/s is owned by CDP Worldwide, a registered charity number 1122330 and a company limited by guarantee, registered in England number 05013650. Any use of any part of the questionnaire, including the questions, must be licensed by CDP. Any unauthorized use is prohibited and CDP reserves the right to protect its copyright by all legal means necessary.

Terms for responding to Investors (2018 Climate Change) These terms apply if you are submitting a response to the CDP Climate Change Questionnaire 2018 to Investors. If you are also submitting a response to Supply Chain Members the Terms for responding to Supply Chain Members (2018 Climate Change), below, will also apply. 1.DEFINITIONS Billing Company: means the organization determined in accordance with the table at the end of these terms. CDP: means CDP Worldwide, a charitable company registered with the Charity Commission of England and Wales (registered charity no. 1122330 and a company number 05013650). References to “we”, “our” and “us” in these terms are references to CDP and the Billing Company. Deadline: means 31 July 2018. Fee: means the fee set out in the table at the end of these terms, which is exclusive of any applicable taxes. Personal Data: means data which relates to an individual who can be identified from the data, such as a person’s name and job title. Questionnaire: means the CDP Climate Change Questionnaire 2018. Responding Company: means the company responding to the Questionnaire. References to “you” and “your” in these terms are references to the Responding Company. 2.PARTIES The parties to these terms shall be CDP, the Billing Company (where the Billing Company is not CDP) and the Responding Company. 3.THESE TERMS These are the terms that apply when you submit a response to our Questionnaire to Investors. If you do not agree to these terms, please contact us at [email protected] to discuss them with us. 4.RESPONDING TO OUR QUESTIONNAIRE

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General. When responding to our Questionnaire, you will be given a choice as to whether your response can be made public or whether your response is non-public. We strongly encourage you to make your response public. Deadline for responding. You must submit your response to us using our online response system by the Deadline for your response to be eligible for scoring and inclusion in any reports. Public responses. If you agree that your response can be made public, we may use and make it available for all purposes that we decide (whether for a fee or otherwise), including, for example, making your responses available on our website, to our investor signatories and other third parties and scoring your response (including publishing your score). Non-public responses. If your response is non-public, we may use it only as follows: (a) make it available as soon as it is received by CDP to our investor signatories (as listed on our website) either directly or through Bloomberg terminals, for any use within their organizations but not for publication unless any data from your response has been anonymized or aggregated in such manner that it has the effect of being anonymized; (b) make it available as soon as it is received by CDP to our group companies and affiliates (for example, CDP North America, Inc), our country partners, research partners, report writers and scoring partners: (i) to score your response and to publish that score; and (ii) for any other use within their organizations but not for publication unless any data from your response has been anonymized or aggregated in such manner that it has the effect of being anonymized. Amending your response. You may amend a response that you have submitted at any time before the Deadline. After the Deadline has passed, your response can only be amended by our staff and we may charge a fee. Please note that any changes that you make to your response after the Deadline may not be reflected in any score or in any report. Scoring of responses. If you submit your response to us using our online response system by the Deadline your response will be scored. If you submit your response after the Deadline but on or before 1 October 2018 you can choose to request an ‘On-Demand’ score for a fee. Please email [email protected] for more information. 5.FEE Fee. We are a not-for-profit organization and charge certain companies an annual administrative fee to enable us to maintain the disclosure system. Unless you are exempt from paying the Fee, as set out below, if you are listed, incorporated or headquartered in a country that is listed in the next paragraph, you are required to pay the Fee plus any applicable taxes. The Fee is payable once regardless of how many responses (climate change, forests and water security) you submit in 2018. Please note that we may charge an additional fee if you want to change your response after you have submitted your response and you are seeking to make the change after the Deadline or if you submit your response after the Deadline and you would like it to be scored.

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Countries where the Fee applies. A Responding Company will be required to pay the Fee if it is listed, incorporated or headquartered in any one of the following countries: Argentina, Australia, Austria, Bahamas, Belgium, Bermuda, Brazil, Canada, Cayman Islands, Channel Islands, Chile, Colombia, Denmark, Finland, France, Germany, Hong Kong, Iceland, India, Indonesia, Ireland, Italy, Japan, Luxembourg, Malaysia, Mexico, Netherlands, New Zealand, Norway, Peru, Philippines, Portugal, Singapore, South Africa, South Korea, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, the UK or the USA. Exemptions from the Fee. A Responding Company is exempt from paying the Fee if: (a) it falls within one of CDP’s investor samples and it has not submitted a response to CDP in the last three years; or (b) it is responding only to CDP’s supply chain request. Please note we will decide in our absolute discretion as to whether the Fee is payable or not and we will notify you before you submit your response. A full list of companies in our investor samples is available on our website. Payment of the Fee. You must pay the Fee by credit or debit card or request an invoice via CDP’s online corporate dashboard, which must be paid within such time as set out in the invoice. Please note that you will not be able to submit your response unless you have paid the Fee, you have requested an invoice or you are exempt from paying the Fee. 6.RIGHTS IN THE RESPONSES Ownership. All intellectual property rights in your response will be owned by you or your licensors. License. You grant to us, or shall procure for us, a perpetual, irrevocable, non-exclusive, assignable, sub-licensable, royalty-free and global license to use your response and any copyright and data base rights in your response for the uses set out in these terms. 7.IMPORTANT REPRESENTATIONS You confirm that: (a) the person submitting the response to us is authorized by you to submit the response; (b) you have obtained all necessary consents and permissions to submit the response to us; and (c) the response that you submit: (i) does not infringe the rights of any third party (including privacy, publicity or intellectual property rights); (ii) does not defame any third party; and (iii) does not include any Personal Data. 8.LIABILITY We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors; for fraud or fraudulent misrepresentation.

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We are not liable for business losses. Subject to these terms, CDP and the Billing Company have no liability to you in any circumstances for any loss of revenue, loss of profit, loss of business, business interruption, loss of business opportunity, loss of goodwill, loss of reputation, loss of, damage to or corruption of data or software or any indirect or consequential loss or damage. Exclusion of liability. Subject to these terms, CDP and the Billing Company have no liability to you in any circumstances arising from the content or submission of your response to us, our use of your response and/or the use of your response by any third parties. Limitation of liability. Subject to these terms, CDP and the Billing Company’s total liability to you in all circumstances shall be limited to an amount equivalent to the Fee or to £625 if you are not required to pay the Fee. 9.GENERAL We may transfer our rights to someone else. We may transfer our rights and obligations under these terms to another organization. Nobody else has any rights under these terms. These terms are between you and us. No other person shall have any rights to enforce any of its terms. Entire agreement. These terms constitute the entire agreement between you and us unless you also choose to share your response with supply chain members, in which case you will also be subject to our Terms for responding to Supply Chain Members (2018 Climate Change). Variation. CDP (acting on its own behalf and the Billing Company’s behalf, if applicable) reserves the right to change these terms at any time. Such changes shall be effective immediately or such other time as CDP elects. In the event of any materially adverse changes, you may request to withdraw your response within 30 days of us notifying you of the change. If a court finds part of these terms illegal, the rest will continue in force. Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect. Governing law and jurisdiction. These terms are governed by English law and you and us both agree to the exclusive jurisdiction of the English courts to resolve any dispute or claim arising out of or in connection with these terms or their subject matter or formation. Language. If these terms are translated into any language other than English, the English language version will prevail. 10.AMOUNT OF FEE

Location of Responding Company Fee (exclusive of any applicable taxes)

Brazil

BRL 3,560

India

INR 67,000

Japan

JPY 97,500

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UK

GBP 625

Europe (excluding UK)

EUR 925

Rest of the world

USD 975

11.BILLING COMPANY

Billing Company Location of Responding Company

CDP Worldwide

Australia, Bahamas, Bermuda, Cayman Islands, Channel Islands, Hong Kong, Indonesia, Ireland, Malaysia, New Zealand, Philippines, Singapore, South Africa, South Korea, Taiwan, Thailand, Turkey, United Kingdom

CDP Worldwide (Europe) gGmbH

Austria, Belgium, Denmark, Finland, France, Germany, Iceland, Italy, Luxembourg, Netherlands, Norway, Portugal, Spain, Sweden, Switzerland

CDP North America, Inc

Canada, USA

Carbon Disclosure Project (Latin America)

Argentina, Brazil, Chile, Colombia, Mexico, Peru

Carbon Disclosure Project India

India

一般社団法人

CDP Worldwide-Japan

Japan

If the Responding Company is located in a territory that is not listed in the table above, the Billing Company shall be CDP Worldwide.

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Terms for responding to Supply Chain Members (2018 Climate Change) These terms apply if you are submitting a response to the CDP Climate Change Questionnaire 2018 to Supply Chain Members. If you are also submitting a response to Investors the Terms for responding to Investors (2018 Climate Change), above, will also apply. 1.DEFINITIONS CDP: means CDP Worldwide, a charitable company registered with the Charity Commission of England and Wales (registered charity no. 1122330 and a company number 05013650). References to “we”, “our” and “us” in these terms are references to CDP. Deadline: means 16 August 2018. Personal Data: means data which relates to an individual who can be identified by such data, such as a person’s name and job title. Questionnaire: means the CDP Climate Change Questionnaire 2018. Responding Company: means the company responding to the Questionnaire. References to “you” and “your” in these terms are references to the Responding Company. Supply Chain Member: means an organization that is requesting data from its suppliers. 2.PARTIES The parties to these terms shall be CDP and the Responding Company. 3.THESE TERMS These are the terms that apply when you submit a response to our Questionnaire to Supply Chain Members. If you do not agree to these terms, please contact us at [email protected] to discuss them with us. 4.RESPONDING TO OUR QUESTIONNAIRE General. When responding to our Questionnaire, you will be given a choice as to whether your response can be made public or whether your response is non-public. We strongly encourage you to make your response public, but in either case, we will not divulge the relationship between you and any Supply Chain Member that has asked you to respond other than to our group companies and affiliates (for example, CDP North America, Inc), our country partners, research partners, report writers and scoring partners, all of which are obliged to keep such relationship confidential. Deadline for responding. You must submit your response to us using our online response system by the Deadline for your response to be eligible for scoring and inclusion in any reports. Public responses. If you agree that your response can be made public, we may use and make it available for all purposes that we decide (whether for a fee or otherwise), including, for example, making your responses available on our website, to our investor signatories and other third parties and scoring your response (including publishing your score). Note that information you submit within the supplier climate module will be treated as non-public (see below for details). Non-public responses. If your response is non-public, we may use it only as follows:

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(a) make it available as soon as it is received by CDP to any Supply Chain Member that has asked you to respond to the Questionnaire for any use within their organization but not for publication unless any data from your response has been anonymized or aggregated in such manner that it has the effect of being anonymized; (b) make it available as soon as it is received by CDP to our group companies and affiliates, our country partners, research partners, report writers and scoring partners: (i) to score your response and to publish the score of any Responding Company that receives an A grade; and (ii) for any other use within their organizations but not for publication unless any data from your response has been anonymized or aggregated in such manner that it has the effect of being anonymized. Supplier climate module. Information you submit in response to the supplier climate module (questions SC1, SC2, SC3 and SC4 of the Questionnaire) will be treated as non-public even if you choose to make your response public. Questions SC1.1, SC2.1, SC2.2a, SC3.1a and SC4.2e ask you to select a Supply Chain Member using a drop-down menu in our online response system, and only the Supply Chain Member you select for each row will have access to the information in it. For all other questions in the supplier climate module the information you submit will be accessible to any Supply Chain Member that has asked you to respond to the Questionnaire. All information you submit in the supplier climate module will be accessible to CDP and to our group companies and affiliates, our country partners, research partners, report writers and scoring partners, all of which are obliged to keep such information confidential. Amending your response. You may amend a response that you have submitted at any time before the Deadline. After the Deadline has passed, your response can only be amended by our staff and we may charge a fee. Please note that any changes that you make to your response after the Deadline may not be reflected in any score or in any report. Scoring of responses. If you submit your response to us in English using our online response system by the Deadline your response will be scored. If you submit your response in English after the Deadline but on or before 1 October 2018 you can choose to request an ‘On-Demand’ score for a fee. Please email [email protected] for more information or contact your local CDP office for information about scoring if you intend to submit your response in a language other than English. 5.RIGHTS IN THE RESPONSES Ownership. All intellectual property rights in your response will be owned by you or your licensors. License. You grant to us, or shall procure for us, a perpetual, irrevocable, non-exclusive, assignable, sub-licensable, royalty-free and global license to use your response and any copyright and data base rights in your response for the uses set out in these terms. 6.IMPORTANT REPRESENTATIONS You confirm that: (a) the person submitting the response to us is authorized by you to submit the response; (b) you have obtained all necessary consents and permissions to submit the response to us; and

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(c) the response that you submit: (i) does not infringe the rights of any third party (including privacy, publicity or intellectual property rights); (ii) does not defame any third party; and (iii) does not include any Personal Data. 7.LIABILITY We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors; for fraud or fraudulent misrepresentation. We are not liable for business losses. Subject to these terms, CDP has no liability to you in any circumstances for any loss of revenue, loss of profit, loss of business, business interruption, loss of business opportunity, loss of goodwill, loss of reputation, loss of, damage to or corruption of data or software or any indirect or consequential loss or damage. Exclusion of liability. Subject to these terms, CDP has no liability to you in any circumstances arising from the content or submission of your response to us, our use of your response and/or the use of your response by any third parties. Limitation of liability. Subject to these terms, CDP’s total liability to you in all circumstances shall be limited to £625. 8.GENERAL We may transfer our rights to someone else. We may transfer our rights and obligations under these terms to another organization. Nobody else has any rights under these terms. These terms are between you and us. No other person shall have any rights to enforce any of its terms. Entire agreement. These terms constitute the entire agreement between you and us, unless you also choose to share your response with investors in which case you will also be subject to our Terms for responding to Investors (2018 Climate Change). Variation. CDP reserves the right to change these terms at any time. Such changes shall be effective immediately or such other time as CDP elects. In the event of any materially adverse changes, you may request to withdraw your response within 30 days of us notifying you of the change. If a court finds part of these terms illegal, the rest will continue in force. Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect. Governing law and jurisdiction. These terms are governed by English law and you and us both agree to the exclusive jurisdiction of the English courts to resolve any dispute or claim arising out of or in connection with these terms or their subject matter or formation. Language. If these terms are translated into any language other than English, the English language version will prevail.

About CDP CDP is an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests.

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Voted number one climate research provider by investors and working with institutional investors with assets of US$100 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental impacts.

Over 6,300 companies with some 55% of global market capitalization disclosed environmental data through CDP in 2017. This is in addition to the over 500 cities and 100 states and regions who disclosed, making CDP’s platform one of the richest sources of information globally on how companies and governments are driving environmental change. CDP, formerly Carbon Disclosure Project, is a founding member of the We Mean Business Coalition. Please visit www.cdp.net or follow us @CDP to find out more.

What is the legal status of CDP?

CDP Worldwide (CDP) is a UK Registered Charity no. 1122330 and a company limited by guarantee registered in England no. 05013650. The charity has wholly owned subsidiaries in Germany and China and companies in Australia, Brazil and India over which it exercises control through majority Board representation. In the US, CDP North America, Inc. is an independently incorporated affiliate which has United States IRS 501(c)(3) charitable status. © 2018 CDP Worldwide