The RE Code of Ethics and Business Conduct, updated in 2009 to improve the clarity of its provisions and to ensure it reflects best practice, is disseminated to every employee as a guide to our corporate and individual conduct. Encompassing topics such as fair competition, anti-bribery and human rights, it encourages open and principled behaviour.

Good corporate governance is fundamental to our success as a business and we take it extremely seriously.

Objectives

We support and comply with the provisions and principles of governance set out in the UK Combined Code on Corporate Governance (the UK Code) and the Dutch Corporate Governance Code (the Dutch Code). We maintain standards of corporate governance and disclosure as applicable to companies listed on the stock exchanges of the United Kingdom, the Netherlands and the United States.

Results

One of our key objectives in recent years has been to increase training and awareness of our Code of Ethics and Business Conduct among our employees. The Reed Elsevier Code of Ethics and Business Conduct, disseminated to every employee, is a guide to our corporate and individual behaviour. Encompassing topics like human rights, anti-bribery, acceptance of gifts and entertainment, company political involvement, safety, and fair competition, it encourages open and principled behaviour. The Code has been translated into ten languages, including Chinese, French, German, Japanese, Polish, Portuguese, Russian, and Spanish. In 2009, Ethisphere ranked the Code as being in the top 3% of the 37 media industry codes they reviewed, and in the top 9% when benchmarked against their broader database.

In 2009, we set an objective of reaching 80% of staff trained on the Code of Ethics and Business Conduct. By year end, 80% of current employees had completed online Code training, with 63% of all US employees completing second round Code training.  In addition, we offered advanced ethics courses to relevant staff, including on anti-harassment completed by 2,400 employees, fair competition completed by 4,500 employees, and data privacy and security completed by nearly 12,000 US employees.

Ethical business

We offer employees advanced ethics training. For example, because LexisNexis’ risk information services involve access to consumer data, we offer the course 'Data Privacy and Security', completed by approximately 12,000 LexisNexis US employees in 2009. In addition, the course 'Competing Fairly, An Introduction to Antitrust and Competition Laws', reached 4,500 employees in the US, UK, Netherlands and across Asia Pacific, and 2,400 US managers completed anti-harassment training.

UN Global Compact

The United Nations Global Compact (UNGC) links businesses around the world with UN agencies, labour and civil society in support of ten principles encompassing human rights, labour, the environment, and anti-corruption. Since becoming a signatory, Reed Elsevier continually works to further UNGC principles within the company and beyond. We are a member of the steering group of the UNGC UK Network and chair the communications working group. In 2009, we hosted Georg Kell, Executive Director of the UNGC, at our head office in London who provided an overview of 2009 UNGC objectives for employees, UK Network members and observers, and other guests. We hosted online seminars for UK Network members on how to communicate about the UNGC; reviewed Communication on Progress reports – which all signatories must complete on an annual basis – as part of the UK Network’s peer review process; pursued our commitment to the UNGC CEO Water Mandate and Caring for Climate; and joined the UNGC Advisory Group on Supply Chain Sustainability, which aims to produce guidance for UNGC participants on sustainable supply chain practice.

Tax contribution

We believe paying tax is an important way to make a contribution to the communities in which we work. In 2009, our income tax contribution for our combined businesses was more than £200 million and, in addition, we collected an even greater amount of employment-related, sales, VAT and other taxes. We believe taxes are an important way in which large companies contribute to the communities in which they do business. We are considered a responsible corporate taxpayer which complies fully with the law by fiscal authorities, while ensuring an appropriate balance between our responsibility to shareholders and society.

2010 Objectives

• Code of Ethics and Business Conduct course completion by 90% of all employees
• Data Privacy and Security course completion by 60% of all employees
• Anti-bribery training for 80% of relevant employees in higher risk roles and geographies