	Questionnaire

	Marjorie's note

	View Code of Business Conduct

	Download Code of Business Conduct (PDF)

	Reporting breaches of the Code

	Contacts

	People Development Network

Code of Business Conduct

Pearson

Pearson Code of Conduct

1. 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 orientation. 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 with 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.

2. 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.

3. 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.

4. Customers

The most important thing we can do for our customers is to offer products and services that are consistently superior.
When customers ask questions or make requests or complaints, 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.

5. 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 shares of 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.

6. Our responsibility to society

Much of our business involves keeping faith with the public: as an education publisher and service provider with a responsibility to serve the purpose of learning; as a newspaper and information 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 to 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 CONDUCT:

1. 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 packs and it will be available on our corporate website and intranet as well as the websites and intranets of each of our operating companies. www.pearsontopearson.com www.pearson.com
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:

marjorie.scardino@pearson.com

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 try to ensure that our agreements with them comply with this code.

2. 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 doing that, we have a free, confidential telephone line/website which you can use to report your concerns. Please click the following URL to access this service: www.PearsonEthics.com

When you make a report, you can remain anonymous, but if you want to include your name and details that may be helpful. It's your choice. The Pearson Group Legal Counsel and the Head of Group Internal Audit have access to reports made via the confidential telephone line/website and are jointly responsible for following up on all reported incidents.

Either the operating company legal counsel or the Pearson Group Legal Counsel/Head of Group Internal Audit 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.

We're serious about this Code, and so we monitor our compliance with it closely and have a process of certifying that we've complied. This code embodies behaviour that is integral to 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 sends everyone in the company an e-mail strictly about the code, making sure everyone is paying attention to it and understands it; and asking each of you to reply. If you need some explanations, or have some worries, you can indicate so through your response and it will be followed up. 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.

Contact Information:

Group Internal Audit -susan.rudolph@pearson.com Government Relations -jeff.taylor@pearson.com Legal -robert.dancy@pearsoned.com Communications - http://www.pearson.com/media/press_office.htm

Now that you have read the Code of Conduct, click here to complete the questionnaire.