Code of Ethics

Current as at March 2024

1. Introduction

Iress Limited and all companies within its group (together “Iress”) is committed to:

1. complying with its legal obligations and also to acting ethically and responsibly;
2. conducting its business in a way that is open and accountable to shareholders and the wider marketplace; and
3. creating a safe and non-discriminatory workplace.

Iress expects its suppliers to share these values and to adhere to the matters set out within this Code of Conduct, as amended and updated from time to time (Code). Suppliers are also expected to ensure that the rest of their supply chain, including sub-contractors, adheres to this Code. Suppliers are expected to comply with the word and spirit of the Code.

2. Applicability

This Code applies to all suppliers engaged by Iress, being any third party organisation which provides goods or services to Iress (Suppliers).

3. Compliance with laws

Suppliers will comply with the content and spirit of all applicable laws and regulations in relation to their dealings with Iress. Suppliers will ensure that similar compliance takes place throughout their supply chain.

4. Employment

As a minimum, our Suppliers should:-,

• treat all employees fairly, regardless of gender, age, race, sexual orientation, disability, religion, union membership, marital or pregnancy status, and provide them with equal opportunities and have in place appropriate policies to prohibit discrimination;
• promote a safe, diverse and inclusive workplace;
• provide a safe work environment, in compliance with all applicable laws and regulations, promoting the health and safety of its workforce and have suitable policies and procedures in place to support this;
• respect the right of employees to associate or not associate with any group in accordance with relevant laws and regulations and not to discriminate against employees as a result of their decision;
• ensure that child labour is not used and comply with any local laws relating to the minimum age of employment;
• ensure that working hours comply with relevant laws and regulations; and
• ensure that wages meet legally mandated minimums required by local laws.

5. Modern Slavery

All work carried out for our Suppliers must be voluntary. Our Suppliers must ensure that there is no forced labour, slavery or human trafficking in their supply chains or in any part of their business and have appropriate controls and checks in place to monitor this.

6. Anti-Bribery

Suppliers are referred to Iress’ Anti-Bribery and Corruption Policy: Anti bribery & corruption policy. Iress will not tolerate any form of bribery or corruption. Suppliers are expected to comply with all relevant laws and regulations and to ensure that their staff understand and comply with their obligations in this regard.

7. Anti-facilitation of Tax Evasion

Suppliers should not engage in any UK tax evasion offences or a foreign tax evasion offences pursuant to the Criminal Finances Act 2017. Our Suppliers must ensure that they put in place reasonable prevention procedures to prevent such offences by associated persons (including their employees and subcontractors).

8. Environment

Suppliers shall make all efforts to ensure that their operations do not have an undue impact on the environment. Suppliers shall strive to reduce their energy and water consumption and to limit waste produced. Suppliers should dispose of their waste responsibly and make an effort to recycle various waste streams through appropriate collection facilities. Suppliers should choose environmentally responsible products and environmentally responsible service providers where possible.

9. Privacy

Iress has a policy setting out how it complies with privacy legislation: Global data protection policy (as such policy and link may be updated from time to time). Suppliers are expected to adopt a similar approach and to implement systems and procedures to ensure that they comply with all relevant laws and regulations.

9. Compliance

Suppliers should retain documentary evidence to support their compliance with this Code and should provide this to Iress upon request. If Suppliers consider that they cannot comply with this Code, they should contact their business contact at Iress immediately. Iress reserves the right to cease carrying out business with entities which do not comply with the Code.