About the Compliance Hotline

What is the Compliance Hotline?

The IHS Markit Compliance Hotline provides IHS Markit employees and other individuals with a confidential and anonymous (where allowed by local law) reporting system to submit concerns and complaints regarding accounting, auditing and internal control matters, misconduct in the workplace, and violations of the IHS Markit Business Code of Conduct, company policy and the law. You can also use the Compliance Hotline to ask questions about ethics, compliance, and the Code.

Why do we need a system like the Compliance Hotline?
  • We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
  • Publicly traded companies are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee.
  • An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

How can I submit a report?

The Compliance Hotline allows for reporting through a secure web-based reporting tool online or by calling the toll-free phone number listed on the Compliance Hotline page.

What should I report?

The Compliance Hotline has been established to allow employees and other individuals to report misconduct – including concerns regarding accounting, auditing, internal controls and financial reporting – on a confidential and anonymous basis, where allowed by local law. Although the issues that may be reported to the Compliance Hotline vary by country because of country-specific laws, some common concerns that should be reported to the hotline include, but are not limited to:

  • Accounting discrepancies, misrepresentations and omissions
  • Violations of applicable securities laws
  • Discrimination and harassment
  • Fraud
  • Embezzlement
  • Bribery and kickbacks
  • Corporate theft, vandalism, and espionage
  • Cybersecurity violations

In certain countries, IHS Markit may only accept reports through the Compliance Hotline that relate to specified matters such as financial, accounting, auditing, or bribery matters. If your concern pertains to a matter that, under local law, may not be accepted by IHS Markit through the Compliance Hotline system, you will need to speak to your manager, human resources, or other established reporting channel.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

If you observe or credibly hear about behavior that you believe violates our Business Code of Conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other members of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. The Compliance Hotline has been established to allow you to report misconduct on a confidential and anonymous basis, where allowed by local law.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

The information you submit will be treated confidentially and communicated on a need-to-know basis to the extent permitted by applicable law. The reported information will be stored in the Compliance Hotline database hosted and operated by NAVEX Global. Unless otherwise required by law, the information you report will only be accessed and used by individuals who are authorized by IHS Markit and have a legitimate business need to access the information. These people may include IHS Markit employees in human resources, legal, compliance, finance, IT, audit and/or other appropriate departments and functions, external IHS Markit advisors retained to assist in investigating the report, and/or technical staff at NAVEX Global. Under certain circumstances, we may be required to report or disclose information to others, such as law enforcement. Please note that if you raise a concern about someone or otherwise identify them through the Compliance Hotline, the laws in certain jurisdictions may require us to inform them about the fact that a report has been made. However, to the extent reasonably possible, we will not reveal your name or identity. Individuals identified in a Compliance Hotline report may also have a right under applicable law to access the personal information pertaining to them. This right of access will, however, not include information relating to third parties and will not include the identity of the person who has made the report.

Is the Compliance Hotline available in more than one language?

Yes, by calling the toll-free Compliance Hotline phone number, reports or questions can be taken in a variety of languages. Please bear in mind that, in the case of less-widely spoken languages, there may be a delay and you may be asked to wait or we may have to call you back.

Reporting Security & Confidentiality

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous, if anonymous reporting is permitted under local law.

I am concerned that the information I provide through the Compliance Hotline will ultimately reveal my identity. How can you assure me that will not happen?

The Compliance Hotline is designed to protect your anonymity where anonymous reporting is permitted under local law. If you are reporting anonymously and wish to maintain your anonymity, take care to not reveal your identity by accident through the information you provide. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free Compliance Hotline confidential and anonymous?

You may submit a Compliance Hotline report by phone, which is confidential and anonymous where permitted under local law. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the Compliance Hotline system.

What if I want to be identified with my report?

There is a section in the report for identifying yourself.

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

We all have an obligation to promptly speak up when we see others failing to act with integrity or violating the law or company policy. This isn’t always easy or comfortable, but we expect you to help us maintain an ethical culture by reporting any concerns.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report, contact your manager, or contact human resources, as appropriate. We ask that you provide information that, to the best of your knowledge, is correct and factual. You will not be subject to retaliation from IHS Markit for any report of a suspected legal or compliance violation that is made in good faith, even if it later turns out to be incorrect.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Compliance Hotline is designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report through the Compliance Hotline, you receive a unique username and are asked to choose a password. You can return to the Compliance Hotline again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in a timely fashion to answer company questions.

Are these follow-ups on reports as secure as the first one?

Yes. All Compliance Hotline communications are as secure as the initial report.

Can I still file a report if I don’t have access to the Internet?

You can file a Compliance Hotline report from any computer that has access to the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call the Compliance Hotline toll-free telephone number, which is available in a variety of languages, 24 hours a day, 365 days a year.