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2022 Pearson Code of Conduct
2022 Pearson Code of Conduct
Conduct
A message from our CEO
Hi,
Andy
Andy Bird
Chief Executive
I. Using the Code and applying our values ............ 4 Appendix: policies & resources ............................. 32
B. Anti-retaliation.................................................................... 7
C. Compliance ......................................................................... 7
A. Our values
Our five values include all of us. That’s why we always start with we: we ask why, we ask what if, we earn trust,
we deliver quality, and we make our mark. These values describe what is important to all of us. They guide us to do
what is right for the world around us, helping us reach our shared purpose: to add life to a lifetime of learning.
• Review the Code regularly and acknowledge and commit Q: I’m a manager and I’m not clear what
to complying with it. I should do if someone comes to me with
a concern that involves a senior leader.
A. Asking questions
and speaking up Speaking up and anti-retaliation
Everyone has a responsibility to ask questions and raise www.PearsonEthics.com is a way to get answers to your
concerns when they believe that something might not questions and to report concerns by phone or online.
be right. We take concerns very seriously and have an It is operated by an independent company, available 24
explicit anti-retaliation policy. hours every day, and is multilingual. PearsonEthics.com
gives you the option to be anonymous as permitted by
If you have any questions or are concerned about law. If your local jurisdiction does not allow anonymous
something that seems to be in conflict with the law, reporting, the site will not permit you to make an
regulations, our Code, or our Company policies, you anonymous report.
have several options.
Here is how it works:
Start with your manager as a first step. Be as specific
and detailed as possible so they understand your
question or your concerns.
This system makes 11 easy to report an 1nc1dent about workplace You can check the status of your report or question using the
access number and password you created when you submitted the
issues like financial and aud1tmg concerns, harassment, theft,
ii. UK: 0800-098-84521 US:1-800-695-5897
report or question
substance abuse and unsafe conditions
Select your /ocat,on If you are dialing inlemat1onally choose your location from the list Access Number Password
1 Select one
below for the international number assigned to your country If your
country 1s not listed chck here for addrtional mstruct1ons
Where did the 1nc1denl occur?
2 Select one
Forgot your password?
~ Select your location
F:HIHIE
1§§@@1
"'"*
Please note this 1s not an emergency service Contact your local
authont1es 1f this 1s a life threatening issue
Click here to file a report online. Want to talk to someone? Follow these Click here to check on the report status.
instructions to call us.
If you want to check on the status of your question or report, provide additional information or documentation,
or communicate with the Ethics and Compliance Team make sure you create a username and password.
This is especially important if the report is submitted anonymously to enable communication while protecting identity.
Pearson will not share information about individual disciplinary actions. We follow the laws in every country that we
operate in that protect the rights of those that raise concerns or are involved in investigations.
B. Anti-retaliation C. Compliance
Retaliation of any sort in response to a report Violating laws, regulations, the Code, or company
is completely unacceptable and undermines the policies, or encouraging others to do so may expose
purpose of PearsonEthics.com. Moreover, it is often you to personal risk, including criminal exposure and
illegal, and exposes Pearson to liability. individual liability. It also exposes Pearson to potential
liability and puts our reputation at risk. Violations
If you think that you or someone you know will result in disciplinary action up to and including
has experienced retaliation as a result of reporting termination of employment. Certain actions may also
a breach of the Code or for participating in an result in legal proceedings. For any specific local policies
investigation, contact any of the teams mentioned regarding discipline and investigatory matters, you
in this section of the Code. For more information should check with your HR representative.
on speaking up at Pearson, please view our Raising
Concerns and Anti-Retaliation policy. For more View the “Appendix: policies & resources” at the end of this
Code for a complete list of policies, resources, and who
information about using PearsonEthics.com, please to contact for assistance.
refer to our Frequently Asked Questions guidance on
www.PearsonEthics.com.
A. Respect and integrity (Some limited and specific exceptions may apply where
local laws require divergence from Pearson’s policy. For
At Pearson, creating learning experiences that build more information, consult your HR Business Partner, Local
a more just and inclusive world isn’t something we Compliance Officer, Pearson Legal, or contact the Global
take lightly. It’s the responsibility of every one of our Diversity, Equity & Inclusion Team.)
employees and partners and is a journey that involves
us all.
2. Harassment-free workplace
Our standard
We believe we are at our best when we harness the
Pearson does not tolerate any form of harassment,
unique skills, perspectives, and backgrounds of every
bullying, or discriminatory behaviors including
employee to foster innovation and create the most
behaviors that are racist, anti-religious, anti-LGBT+,
effective solutions for learners around the world. We
and other biases that show prejudice toward a person’s
are committed to and promote an inclusive workplace,
gender, ethnicity, nationality, disabilities,
observe an equitable employment process, and do not
socio-economic status, and any other characteristic
tolerate any form of discrimination.
protected by law.
That’s why we’re building a culture of belonging for
These principles apply whether or not you are
everyone who works for and with us. We’re creating
at work. Therefore, you may be subject to discipline
more opportunities for diverse perspectives to be
for harassment, bullying, or discriminatory behaviors
heard and valued and creating more moments that
even outside of the workplace, including but not limited
are equitable and enriching. After all, it’s what we do
to activities online that damage Pearson’s reputation
inside Pearson that helps us create vibrant and inclusive
or cause concern for the well-being of learners
experiences for those we serve.
and employees.
1. Diversity, equity, inclusion, and
nondiscrimination Examples of harassment
Intimidation or bullying
Our standard
• Verbal abuse, threats, taunting, or other speech
We are committed to an inclusive workplace and
or action, including the display of images, that target
observe an equitable employment process. We do not
an individual’s characteristics that are protected under
tolerate any form of discrimination based in any way Pearson policies or applicable laws. Verbal abuse includes
on race, color, national origin, citizenship, religion or making derogatory, profane, or aggressive comments
religious affiliation, age, sex, gender identity and/or about a person.
expression, sexual orientation, marital or relationship
• Behavior that is intended to cause another employee
status, familial status, political affiliation, disability
to reasonably fear that they might be injured
(mental, sensory, intellectual, and physical), genetic or otherwise harmed.
information, veteran status, or any other characteristics
• The deliberate act on the part of one individual—often
or categories protected by specific Pearson employment
in a position of power—to target another individual
policies or applicable laws. Gender identity covers
in an attempt to control, humiliate, threaten and
all genders including those who identify as a man, intimidate them, or to sabotage their work, or efforts
woman, non-binary, or any other identity the individual for personal gain.
perceives themselves to be.
Harassment
We’re working to make every decision about who we
• Unwanted sexual advances or requests for sexual favors.
hire and how we promote equitable and free of bias.
This is a part of our commitment to providing equal • Unwelcome remarks, gestures, or physical contact.
opportunity in all aspects of employment, including • Sexual or offensive jokes, or comments (explicit
recruitment, hiring, training, compensation, benefits, or by innuendo).
terminations, educational assistance, social and • Making jokes or degrading references to someone’s
recreational programs, promotions, and transfers. sexual orientation, gender identity/expression, their
• Threatening to “out” people for their sexual orientation • Treat all colleagues professionally, respectfully, and in
including bi-identities, trans-identity, or hidden disabilities. a manner that is in the best interest of the team, and
organization as a whole.
• Using a threatening tone, making derogatory or abusive
comments, or ostracizing people. • All colleagues should be treated with respect when it comes
to their race, gender, ethnicity, religious beliefs, sexual
orientation, disability, or other personal characteristics, and
Q: You’re at a meeting and a transgender deserve a workplace environment that is safe, and where
Person of Color shared their name and they can be themselves.
preferred pronouns during a meeting and a • Managers should lead by example and demonstrate
participant continually refused to use their behaviors that celebrate diversity, equity, and inclusion,
and have a critical duty to speak up and out about
correct name and misgendered the person
harassment and behavior that is detrimental to our values,
throughout the meeting. What should I do? culture, or our employees.
• Make hiring and performance decisions based on A: The person may be subject to discipline
performance, qualifications, abilities, and potential. for behavior outside of work, including
Use objective, quantifiable standards as much as possible.
activities online that damage our reputation
• Respect colleagues’ privacy, dignity, and life outside work. such as discriminatory statements with
• Follow local Pearson policies regarding diversity, regard to anyone’s protected characteristics
equity, inclusion, and workplace conduct. such as race, color, national origin,
• Provide reasonable adjustments for the promotion citizenship, religion or religious affiliation,
and support of disabled colleagues. age, sex, gender identity, and/or expression,
• Follow the principles set out in the Pearson Global sexual orientation, marital or relationship
Content and Editorial Policy to create content that is status, familial status, political affiliation,
ethical and embeds our commitments to diversity, equity, disability (mental, sensory, intellectual and
and inclusion (see Content quality, ethical standards, and
physical), genetic information, veteran
inclusion on page 16).
status, or any other characteristics or
• Maintain a work environment that is professional and free
categories protected by specific Pearson
from harassment of any kind, including sexual harassment.
employment policies or applicable laws.
• Speak up about your concerns. Tell the person you are
upset by their actions or language, explain why, and ask
them to stop. If you are not comfortable doing this, report
your concerns to your manager, HR, Pearson Legal, to
Our responsibilities
To safeguard
• Understand your responsibility to safeguard and protect
learners. Where abuse is alleged or suspected, we may
have a legal duty to report it to relevant authorities.
To be responsible for our own work • Be honest and treat others with respect.
Our responsibilities
Do
Don’t
We should never engage in any practices that are • Share or receive any competitively sensitive information
anti-competitive or which limit competition through with competitors (for example, pricing, costs, commercial
illegal or unfair means. Competition and antitrust laws conditions, or other non-public confidential information,
generally prohibit collusion or agreements to restrict past or future, even on an occasional basis). This includes
competition with competitors whether direct indirect exchange through any Business Partner.
or through third parties. They also prohibit certain • Coordinate, directly or indirectly, with competitors or
types of restraints in relationships with distributors bidders to:
or Business Partners. Antitrust law can carry • Affect price or production/supply levels, terms of
criminal penalties for individuals as well as severe trade, dealing procedures or to share or partition
consequences for the Company, so we need to respond markets (even if this is to address a demand from a
extremely quickly in this kind of situation. governmental body).
• Any political party official and candidates We must always follow specific laws and procedures
for political office; designed to ensure that government contracts are
awarded fairly.
• Any member of a royal family who may lack
formal authority but who may otherwise be Inquiries from government agencies and authorities
influential, including by owning or managing
You may receive inquiries from regulators or
state-owned or controlled companies;
Public Officials. Before responding to a request for
• Any officer or employee of a government information, you should contact Global Government
department, board, commission, or Relations, your Local Compliance Officer, and Pearson
agency, including immigration and customs Legal, particularly if the request is not of an ordinary
employees, officers and employees of or routine administrative nature. In all cases, you are
entities owned or controlled by a government expected to respond to requests for information in an
(including any public schools or universities); honest and timely manner.
Don’t
To live our values, we must make sure that our Investments, Ownership or Control of Competitors.
dealings are conducted in an honest, transparent, Personal investments by you or anyone with whom
and neutral way. The best interests of Pearson come you have a Significant Relationship in companies
first, and we must avoid even the appearance of a that compete with Pearson, directly or indirectly,
conflict with our personal interests or gain. are not allowed unless they consist of small amounts
of stock (less than 1% of outstanding shares) in
A conflict of interest occurs when our personal publicly traded companies.
interests influence, potentially influence or are
perceived to influence our decision making. Conflicts Investments in Business Partners. You must disclose
of interest can harm our reputation, expose us to legal investments exceeding 1% of outstanding shares
actions, and affect our ability to retain or seek new in publicly traded companies, and ownership or control
business. There are three main types of conflicts of in privately held companies that you or anyone with
interest: actual conflicts of interest which is a real whom you have a Significant Relationship, have in
and existing conflict; potential conflicts of interest a Business Partner.
which is a situation that may result in a conflict; and
New business relationships
perceived conflicts of interest which is a situation
that may appear to be a conflict. Carefully weigh a potential new relationship that could
present a conflict of interest before entering into it.
You and our Business Partners are expected to
If necessary, seek advice from your manager, HR, Local
recognize when there are real, potential, or perceived
Compliance Officer, or the Global Compliance Office.
conflicts of interest.
Our responsibilities
Do
• Know who you are doing business with and make sure
that you complete due diligence on any in-scope third Q: What if I am threatened and forced
party. Confirm with your Local Compliance Officer to provide a cash payment to a Public Official
if you are unsure. to exit the country?
Don’t
A: Your safety is paramount. Make the
• Offer or accept bribes, or any other kind of improper payment if the failure to make the payment
payment including facilitation payments. Please refer to puts you or your family under threat of
the ABC Policy for further details on facilitation payments. harm. Report the situation as soon as
• Use a Business Partner to do anything that you are possible to your Local Compliance Officer.
not allowed to do yourself. Without exception, any such payment must
• Put yourself at risk if there is a threat to your personal be reflected accurately in the company’s
wellbeing, health, or safety if you do not make a payment books and records.
to an official. In this situation you should make the
payment and report it immediately to the Global Travel
manager, the VP of Corporate Security, and your Local
Compliance Officer.
Don’t
Our standard
Our Pearson Global Content and Editorial Policy
establishes the best practices and principles we should
all implement in our content. The four key principles of
the policy are:
3. To provide support for learning that is based on evidence also take the additional online learning module and attend
and facts. a workshop.
4. To create content that is ethical and adheres to legal • Consider how to embed awareness of and the promotion
requirements. of diversity and inclusion in our content.
These principles are fundamental to our success and • Be evidence-based when approaching controversial topics
while also respecting local laws.
our reputation as the world’s learning company. You
can find out more about these principles by reading the • Ensure that the authors and third-party vendors we work
Global Content and Editorial Policy and FAQs. with also read, receive training on, and understand the
standards we expect.
Our responsibilities
All new employees in relevant functions are provided
Do with a copy of the Global Content and Editorial Policy
and assigned the relevant online learning module to
• Always follow the principles set out in the Pearson Global
complete.
Content and Editorial Policy and understand your role
in ensuring our products and services are anti-bias If you have any questions about the Global Content
and aligned with our diversity, equity, and inclusion
and Editorial Policy or its application, you should
commitments.
speak to your manager or your local Policy Steering
• Employees and external content and editorial Business Committee representative. You can submit comments,
Partners should read and understand the Global Content queries, and concerns via the Global Content and
and Editorial Policy, undertake the introductory online
Editorial Policy feedback form which is available on
training module and learn how to apply it in your work.
the Hub. If you are not a Pearson employee but a
• If you work in a function (internally or externally) content or editorial Business Partner, please contact
that creates, develops, or reviews our content, you should your project lead.
• Be transparent about our privacy practices and how Employees must take care that their use of Pearson’s
individuals can contact us with questions or concerns, electronic systems and resources does not expose the
or requests related to their data within our systems. Company to the risk of security or confidentiality breaches,
legal claims, sabotage, viruses, or similar problems.
• Only share PI with those who have a legitimate need to
know and whose access is appropriately authorized.
Our responsibilities
Limited personal use is permitted as long as it is kept Do
to a minimum and has no adverse effect on productivity
and the work environment. • Always complete the Data Privacy Risk Assessment
in myLegal prior to entering into or renewing agreements
Our responsibilities with third parties.
• Report any suspicions you may have concerning theft, • Report any perceived infringement on Pearson’s copyrights
embezzlement, or misappropriation of any Pearson assets. to
Don’t Don’t
• Copy or use unlicensed or “pirated” software on Pearson’s • Distribute content outside of Pearson that does not
computers or other equipment. View, copy or store require a personal login to access. Follow the Pearson
pornography or obscene materials. Content Protection Policy for guidance. If this is not
possible, consult your manager to explore available
In accordance with our Acceptable Use Policy, all and acceptable alternatives.
users at Pearson are responsible for exercising good
judgment regarding appropriate use of information, E. Confidential information
electronic devices and network resources. For security, and intellectual property
network maintenance and compliance purposes,
authorized individuals within Pearson may monitor Our standard
equipment, systems, network traffic and email at any The unauthorized release of confidential information
time. can cause us to lose a critical competitive advantage,
cause reputational harm to Pearson and damage
In accordance with local laws, Pearson reserves the
our relationships with customers and others. Each
right to audit network and systems on a periodic basis
of us must be vigilant and safeguard our confidential
to ensure compliance. For more information about our
information as well as confidential information that
information security policies, please visit the Hub.
is entrusted to us by others.
A. Sustainability and
corporate responsibility
Our standard
For learners, employees, and suppliers, we will take Our commitment to human rights calls for us to:
a deliberate focus on access for all, with an emphasis
• Be familiar with the Pearson Human Rights Statement.
on groups who are under-represented, including
• Respect the human rights of all stakeholders, including
women, racial and ethnic minorities, low-income
learners, parents, employees and contractors, teachers
groups, and people with disabilities. Employees are
and other educators, customers, partners, suppliers,
encouraged to consider and take actions to support
and the broader community.
these and other underserved groups to better
access our products, including through balanced • Report any suspicion or evidence of human rights abuses
in our operations or in those of our business partners
representation in our content, and to be inclusive
to HR, your Local Compliance Officer, the Global
of employees and suppliers from all backgrounds.
Compliance Office, or the Global Sustainability team.
Our responsibilities
Do
C. Global trade
Our standard
We are committed to complying with applicable export
and import controls, money laundering regulations,
customs, and other relevant laws in the countries
in which we operate and do business. Each of us is
responsible for knowing the laws that apply to our
jobs and must seek expert advice if in doubt about the
legality of an action.
Our responsibilities
Do
Topic Contact/Resources
Conflicts of interest
Corporate responsibility
• Global Sustainability team (sustainability@pearson.com)
Includes sustainability, human rights, UK Modern
• www.PearsonEthics.com
Slavery Act, environmental stewardship.
Global content & editorial policy/content quality • Global Content and Editorial Team
Media inquiries
Includes communicating with the public • Contact media@pearson.com
and social media.
• www.pearson.com/report-piracy.html
• www.PearsonEthics.com
• www.PearsonEthics.com
• sanctionscompliance@pearson.com
The policies and resources listed below are available on the Global Compliance Office Site. Additional policies
and resources can be obtained by reaching out directly to a contact person within the relevant function.
Global Compliance Office policies and resources: Non Global Compliance Office policies and resources:
• Schedule of Authority
• Treasury Policy