Code of Conduct

PEARSON Code of Business Conduct

I. People

  • We believe our company should include a range of people from different backgrounds and different points of view. So when we hire someone to come to work in Pearson, we choose the best candidate without regard for gender, age, race, national origin, religion, disability or sexual preference. We apply that same standard when choosing suppliers, partners and anyone else we do business with.
  • People working with us can expect adequate pay for doing their job and special rewards for extraordinary work. They can also expect training; feedback; a safe, amenable place to work, freedom from bullying or favouritism and respect for their privacy, dignity and life outside work.
  • We do our best to communicate honestly and openly with everyone who has an interest in our company, including colleagues, suppliers, customers and shareholders.

II. The company

  • We aim to avoid conflicts between the company’s interests and our own individual interests.
  • In our personal capacities, we don’t compete with any activity or business of the company, directly or indirectly, or use the knowledge gained here to help anyone else compete with the company.
  • We don’t make personal investments that might affect our business judgment. For instance, we don’t have personal interests in companies that compete with or do business with Pearson unless we have disclosed this interest to Pearson’s board or management, and they have approved it. (This doesn’t include owning small amounts of stock in publicly-traded companies.)
  • We don’t do business on behalf of Pearson with a company from which we or a family member may benefit.
  • We don’t work with suppliers or any third parties in ways that might affect our performance or our judgment about Pearson’s business.
  • We treat company property as if it were our own, but we remember it’s not. We make sure it’s taken care of and that it is not used for personal purposes except in special, authorized circumstances.
  • We’re very careful with company plans and information we get to know in the course of our work, and we don’t disclose that kind of material to people outside or inside the company unless it’s necessary and we’re authorised to do so.
  • When we receive a press inquiry about the company’s business, we refer it to the communications department. We do not ever respond ourselves unless asked to by management or the communications department.
  • We take scrupulous care to maintain books and records that fairly reflect our business transactions as they occur. We don’t conceal or confuse our records in any way. We don’t make false or misleading entries. We follow all our control and financial policies.

III. Suppliers, associates and other partners

  • We view our suppliers as partners, and we expect them to make a fair return when they do business with us. We try to treat them equally, based on objective criteria such as price and quality and on intangible criteria such as their integrity and reliability.
  • We don’t accept gifts or gratuities from current or would-be suppliers or other parties interested in doing business with us or having our favour for personal or commercial reasons. Likewise, we don’t give money or gifts to gain influence for ourselves or for Pearson. Gifts or entertainment of small value may be given or accepted in circumstances where they can be reciprocated and where they don’t compromise us or the company
  • We respect all patents, trademarks, copyrights, proprietary information or trade secrets, as well as the confidentiality of anyone with whom we do business.

IV. Customers

  • The most important thing we can do for our customers is to offer products and services that are consistently superior.
  • When customers ask a question or make a request or a complaint, we start with the presumption that whatever they say is correct. Our response is always quick, generous, friendly, and it resolves the situation. We never blame problems on the customer or someone else, and we always keep our sense of humour
  • When we advertise or solicit business, we are truthful in every detail.

V. Governments and laws

  • We comply with the laws and regulations of any country in which we do business, and we don’t seek or give influence in exchange for promises, gifts or any other inducements, no matter what the local business practice may be.
  • We comply with securities laws and don’t trade in Pearson’s shares or other quoted companies owned and controlled by Pearson except during declared open periods. We never use company information that hasn’t been made public for our own or others’ benefit.
  • Our company is not partisan. We do make donations to a range of education or free speech related causes, but we do not make any donations that are considered large enough to be material to the individual or organization involved. We don’t make any donations without first referring them to our government relations office to ensure that they conform to these principles.
  • We always try to compete fairly and honestly, observing all applicable anti trust and competition laws.

VI. Our responsibility to society

  • Much of our business involves keeping faith with the public: as an education publisher with a responsibility to serve the purpose of learning; as a newspaper publisher dedicated to giving an unbiased account of events; as a company that protects the editorial independence of authors and editors everywhere. This public trust partly defines our company, and we will uphold it at all costs.
  • We try to give both time and money to the communities of interest in which we do business through our charities and sponsorship donations and through encouraging and enabling colleagues to volunteer their time to causes they support.
  • We oppose illegal or inhumane labour practices and expect our partners and suppliers to do the same.
  • We support universal human rights, including equal employment, safe workplaces, freedom of speech and of association, cultural, economic and social well-being.
  • We try to make it integral to our business decisions to operate in a way that is sensitive to the environment and minimize the impact of our products on the environment.
  • We expect our suppliers and associates to adhere to these legal and social responsibilities in order to do business with us.

Spreading the word about the PEARSON CODE of BUSINESS CONDUCT

I. Making sure the code is widely understood

  • Everyone working for Pearson will receive a copy, either electronically or on paper. It will be part of a new employee’s information package and it will be available on our corporate website and intranet as well as the websites and intranets of each of our operating companies.
  • All senior managers will be responsible for discussing it within their businesses and reporting back to the Pearson CEO on how they’ve done it and what the response has been.
  • If there is anything about any of these principles you don’t understand, if you can’t figure out how to apply them, or if you just want further guidance, ask one of the following people for help:
    Apart from your direct manager, try your operating company human resources director or legal counsel. All the senior management in your business can help you as well. If you want to talk to somebody at Pearson head office, you can call Gary Rinck, the Group Legal Counsel (+44 (0) 207010 2210) or Robert Harris, Head of Group Control (+212 641 2454). You can also contact Marjorie Scardino, Pearson’s chief executive (marjorie.scardino@pearson.com) or any other director, or anyone you trust in a position of authority.
  • We will see that all our major suppliers receive a copy of this code and that they understand it, and our legal department and Internal Auditors will ensure that our agreements with them comply with this code.

II. Making sure we comply with the code

  • In signing on to be part of Pearson, you become responsible for complying with this code and with any policies that we adopt to accompany it.
  • Violations of this code damage the name and reputation of Pearson and of our businesses and so affect us all.
  • If you think someone is acting in a way inconsistent with Pearson’s practice, you should report it to your operating company legal counsel immediately. If you feel uncomfortable with this route, we have a free, confidential telephone line you can call to report your concerns. From the USA call 1 866 278 4172, outside the USA call 00 800 7327 7667.
  • When you call this number you can remain anonymous, but if you want to leave your name and details that may be helpful. It’s your choice. Only the Pearson Group Legal Counsel (based at 80 Strand, London) has access to calls made to this free phone number. He is responsible for following up all calls, and our Internal Auditors will verify that he has.
  • Either the operating company legal counsel or the Pearson counsel will investigate reports of violations to this code, using whatever internal or external resources they require. These investigations will be confidential and the results reported to the operating company board and appropriate senior management, including the board of Pearson.
  • We will take whatever actions are necessary to prevent or stop business practices or behaviour which breach this code, possibly without regard for whether or not any harm has been done.
  • No action will be taken against any employee reporting actual or suspected wrong doing. No one’s opportunity for promotion, pay increases or any of the other benefits that the company provides will be restricted in any way because they have reported an actual or potential breach.
  • With this pledge of impunity comes responsibility. It is a serious matter to accuse someone of unethical conduct. This right and obligation should not be used for personal reasons or undertaken without good evidence.
  • Corporate governance rules require that we monitor and certify whether we’ve complied with this code of conduct. In our case, this code embodies behaviour that is integral with our culture and our way of doing business, so just having managers sign a statement that we’ve complied with it won’t tell us much. Instead, each year Pearson’s CEO will send everyone in the company an e-mail strictly about the code, highlighting some areas, making sure everyone is paying attention to it and understands it; and each of you will have to reply. Just one line is necessary if all is well and you’re feeling sure you and your colleagues are on the beam. If you need some explanations, or have some worries, write more. Our Director for People will monitor all these and make sure they allow us to be confident that we’ve all embraced this code as our way of doing business.
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