Code of Business Conduct - Putting our business principles into action and delivering - TransUnion Investor Relations
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Code of Business Conduct Putting our business principles into action and delivering Information for Good® 2023 Version 3.3
© 2023 TransUnion LLC All Rights Reserved No part of this publication may be reproduced or distributed in any form or by any means, electronic or otherwise, now known or hereafter developed, including, but not limited to, the Internet, without the explicit prior written consent from TransUnion LLC. Requests for permission to reproduce or distribute any part of, or all of, this publication should be mailed to: Legal Department TransUnion 555 West Adams Chicago, Illinois 60661 The “tu” logo, TransUnion, and other trademarks, service marks, and logos (the “Trademarks”) used in this publication are registered or unregistered Trademarks of TransUnion LLC or their respective owners. Trademarks may not be used for any purpose whatsoever without the express written permission of the Trademark owner. transunion.com
Code of Business Conduct
Putting our business principles
into action and delivering
Information for Good®
3
Table of contents
Message from Chris ...........................................................................................................7
Our values and beliefs .......................................................................................................9
The beliefs that help us win....................................................................................................10
We’re all responsible...............................................................................................................11
Compliance with our Code of Business Conduct ....................................................................12
Waivers ..................................................................................................................................12
Reporting known or suspected violations ...............................................................................12
Tips and guidelines .................................................................................................................13
Our customers and consumers ......................................................................................15
Business relationships and customers ....................................................................................15
Government business ............................................................................................................15
Confidential information, assets, data breach and use of systems..........................................15
Information privacy ...............................................................................................................16
Our company and stakeholders.......................................................................................19
Antitrust, competition laws, fair dealing and fair lending ........................................................19
Bribes, inducements, kickbacks and payoffs...........................................................................20
Anti-corruption laws.............................................................................................................20
Gifts, entertainment and meals .............................................................................................20
Anti-money laundering laws...................................................................................................21
Conflicts of interest and business opportunities....................................................................22
Insider trading.......................................................................................................................22
Investor communication and bookkeeping, record keeping and documentation......................23
External communications .......................................................................................................24
Interacting with auditors and investigators ............................................................................24
Our people......................................................................................................................27
Workplace..............................................................................................................................27
Diversity and inclusion ...........................................................................................................27
Our community................................................................................................................29
Human and labor rights..........................................................................................................29
Community relations .............................................................................................................29
Corporate social responsibility ..............................................................................................29
Getting help ....................................................................................................................31
The TransUnion Helpline .........................................................................................................31
5
6 | Code of Business Conduct Return to Table of Contents
Message from Chris
Our Code of Business Conduct ensures all associates, officers and board
members have the guidance to act in a manner consistent with our values.
We are committed to ethical and law-abiding decision-making and behaviors,
and steadfast in our efforts to embody Information for Good®. The Code
is the standard by which we operate with each other, our consumers,
customers, vendors and business partners; it underpins our brand promise.
Everyone at TransUnion is required to affirm the Code annually. This act
of compliance is necessary to create awareness, but we need to go beyond
compliance to conviction. Our actions should reflect the behaviors and
expectations captured in the Code. It’s vital that we’re well-informed,
review the Code on a frequent basis, and rededicate ourselves to acting
in accordance with our values and beliefs. This results in a team committed to
ethical and law-abiding conduct with integrity in every aspect of our business.
Thank you for your personal commitment to keep TransUnion and our
stakeholders at the forefront of your decisions so that we may all have
continued success.
Sincerely,
Chris Cartwright
President and CEO
TransUnion
78 | Code of Business Conduct Return to Table of Contents
Our values and beliefs
The Code of Business Conduct is the cornerstone for how we work. The Code
reflects our belief in doing business the right way — the affirmation of Information
for Good®. We believe in operating with the highest ethical standards in everything
we do. We treat information responsibly. This is the foundation of every decision we
make, and the way we interact with each other, consumers, our customers, vendors
and business partners.
Several years ago, TransUnion undertook an extensive effort to understand from
associates what they believed was most important to the company. The resulting
list of qualities led to the values and beliefs we operate under today.
At TransUnion, we value:
Integrity People
We act with honesty, trust and We recognize each of us is
respect in all our interactions essential to our success.
and everything we do.
Customers Innovation
We earn trust and build We aspire to deliver
lasting relationships by tomorrow’s solutions today.
delivering what we promise.The beliefs that help us win
I own it I act decisively
& get things done
We hold ourselves We make timely, informed
and others accountable. and clear decisions. We
We own our successes and move with speed and agility
to get things done and
learn from our failures.
deliver results.
I think like I innovate
a customer and inspire
We put ourselves in our customer’s We bring new ideas to our work and
shoes so we can anticipate their inspire others to do the same. We’re
needs and be ready with solutions. a catalyst for change and willing to
Their goals are our goals. act on our ideas to move the company
forward and upward.
I make a
difference I say what
and so do you I need to say
We embrace our diversity and We engage in and
recognize the value and contribution
embrace candid, direct
of each individual. We’re part of a team
and understand how our own work communication, as well as
contributes to our wins and losses. honest and healthy debate.
10 | Code of Business Conduct Return to Table of Contents• Answer associates’ questions about TransUnion
We’re all responsible policies and, when in doubt about the right course of
action, seek advice and guidance from your manager.
TransUnion’s Code of Business Conduct applies to all
associates, officers and board members of TransUnion • Never condone any conduct or activity that may
and its subsidiaries (noting that compliance with this raise questions about TransUnion’s honesty, integrity
Code is subject to other governing documents and or compliance with legal standards.
agreements of TransUnion). We expect consultants, • Encourage everyone in our organization to voice
contractors and others temporarily working for concerns when they come up.
TransUnion to follow the principles outlined in this • Report Code violations you’re aware of to your
document during the time they perform work for us. manager, Human Resources Representative,
Legal Department, or the Helpline. If you have
Being a TransUnion associate means that you: knowledge of misconduct, you may be held
• Uphold the highest standards of ethical conduct. responsible for failing to take appropriate
This means being professional and respectful when action.
performing your TransUnion responsibilities. You • Implement appropriate disciplinary procedures after
should be honest in every business communication. a confirmed code violation occurs with oversight
You shouldn’t endorse or participate in activities from Human Resources.
that may embarrass TransUnion or lead to negative
publicity about us or our customers.
• Read, understand and follow all TransUnion
policies which include not only this Code of Did you
Business Conduct but all policies, procedures
and standards that apply to your TransUnion
know?
responsibilities. As a condition of employment,
each year you’re required to formally attest
to your compliance with this Code.
The Board of Directors of
• Conduct business in full compliance with
the letter and spirit of all laws, rules, regulatory
TransUnion periodically reviews
orders and court orders that apply to TransUnion. our Code of Business Conduct.
This includes confirming our
In addition, if you’re a manager, managers are providing the
that means you’re expected to: appropriate “tone at the top”
• Know the Code and promote a culture of ethical to encourage compliance
business conduct.
with this Code, TransUnion
• Support your staff in locating all TransUnion policies policies and legal standards.
and confirm they read and understand them.
Our legal standards require you to TransUnion policies include this
conduct business in full compliance Code of Business Conduct, as well
with the letter and spirit of all laws, as various policies, procedures and
rules, regulations and court orders that standards adopted at the enterprise
apply to TransUnion. and business unit levels.
These legal standards may be reflected You can find all Compliance policies
in TransUnion policies, information on the Compliance web page of
described to you by your manager, or TransUnion’s intranet website.
information discussed with you by our
You can also ask your manager or
Legal Department.
a Human Resources manager for
copies of applicable policies.
11Compliance with our
Code of Business Conduct
If you have questions about your job You’re expected to use good judgment and abide
by this Code of Business Conduct and all company
responsibilities, laws or applicable policies and procedures.
TransUnion policies, discuss them If you violate this Code or any company policies
with your manager. and procedures by, among other things, failing to
report a known or suspected violation, by withholding
information relating to a violation, or authorizing or
If you feel uncomfortable talking with knowingly allowing a subordinate to be in violation:
your manager, you should call the • You may expose yourself and TransUnion to civil,
TransUnion Helpline. criminal or financial liability.
• You could harm TransUnion’s reputation and
competitive position.
• You may be subject to disciplinary action,
up to and including possible termination
and/or criminal prosecution.
Waivers
Only the Board of Directors or the Audit and
Remember, you’ll receive Compliance Committee of the Board of Directors
annual training on the may provide you a waiver of this Code. All such
Code as well as other waivers must be promptly disclosed publicly as
required by law or applicable stock exchange
policies. You’re required regulation. For all others, only TransUnion’s Chief
to acknowledge you Legal Officer may approve a waiver.
read, understand and will
comply with the Code. Reporting known
or suspected violations
Associates must promptly report any possible non-
compliance with this Code. In addition, they must
promptly report:
• Any questionable accounting, internal
accounting controls or auditing matters
• Any possible non-compliance with applicable
legal and regulatory requirements
• Any alleged retaliation against associates and
other persons who make a good faith report
under this Code
Reports may be made in any of the manners
described below. For additional guidance, you can
read the Board of Directors’ Whistleblower Policy.
12 | Code of Business Conduct Return to Table of ContentsTips and guidelines
When faced with a situation where you have a concern, You may report or inquire
keep these steps in mind:
about suspected violations
1. Make sure you have all the facts. To the best of
your knowledge, you must provide as much detail in confidence and without
and factual information as possible. fear of retaliation.
2. Understand exactly what you’re being asked to do.
Does it seem right? Or does it seem unethical or Your anonymity will be
improper? Use your judgment and common sense. protected to the fullest extent
3. Clarify your responsibility and role. Are your possible if you contact the
co-workers and colleagues informed? Is there
shared responsibility? It may help to get others TransUnion Helpline.
involved and discuss the problem.
4. Discuss the problem with your manager.
TransUnion will not permit
This is basic for all situations. It’s your manager’s retaliation of any kind against
responsibility to help solve problems. If for some you for asking questions or
reason your manager is not helpful, you should
contact the TransUnion Helpline. reporting, in good faith,
5. Seek help from other TransUnion resources. If possible violations of this
you feel you cannot discuss the matter with your Code of Business Conduct.
manager, discuss it with your Human Resources
representative or someone from TransUnion’s
Legal Department. They’ll make sure you obtain
the guidance you need. Ignoring the issue is not
an acceptable option.
1314 | Code of Business Conduct Return to Table of Contents
Our customers and consumers
Our values and beliefs are at the core of how we work together, and honoring them
is critical in maintaining our business commitments and are an important part of
TransUnion’s success. We do what we say we’ll do. We provide services that we believe
meet – or exceed — the expectations of consumers and our customers.
Business relationships Confidential information,
and customers assets, data breach and
It’s important to preserve our values and beliefs use of systems
when selecting where and with whom we do
business. This includes our customers and all Protecting information is our top priority, and
third parties who help us meet the needs of those everyone at TransUnion has a responsibility to
customers, as well as consumers. We want to work protect the privacy and security of our assets.
with individuals and companies that share our Information is a key asset to our business and
commitment to ethical business conduct. competitive position.
We comply with all the terms and conditions of our You’re not authorized to access TransUnion’s
agreements with our customers, vendors, suppliers, confidential information, sensitive company
agents and other third parties. We expect them to information, or personal information relating
do the same. to associates, customers or consumers if it
doesn’t relate to your employment duties. You
If you become aware there’s been or is about to be
should never share proprietary information about
a violation of any agreement entered into by or with
TransUnion, our customers, consumers or any
TransUnion, you should immediately notify your
other third-parties with anyone outside or within
manager. In turn, your manager must then advise
TransUnion who is not authorized to receive that
the TransUnion Legal Department
information, including spouses, friends, business
associates, customers and vendors.
Government business You may only use TransUnion’s computer network,
email system, materials, ideas, products, services
Special rules and obligations apply to business and property for purposes directly related
arrangements with governmental authorities or to our business. You’re required to keep all
agencies. passwords associated with that equipment and
Government authorities or agencies include our computer systems confidential at all times
government sources, state-owned banks, and in accordance with our Information
telecommunication providers or other types Security program.
of service providers. Your use must also comply with applicable
You shouldn’t make an offer or respond to a TransUnion policies and legal standards. Assets,
proposal to do business with a governmental including data in the possession of TransUnion,
authority or agency unless your manager has must never be used, removed, transferred or
authorized and received prior approval of the borrowed unless your manager and Information
transaction from TransUnion’s Legal Department. Security, Legal or Compliance have approved it
and it’s compliant with TransUnion policies.Your use of TransUnion’s computer systems is at You’re strictly prohibited from:
the sole discretion of TransUnion. You should secure • Providing personal information about another
and protect all computers and telecommunications individual to a person without a legitimate
equipment like cell phones, wireless email devices purpose and proper authorization to receive it
and laptops assigned to you.
• Obtaining or modifying a consumer report or
You must follow all TransUnion policies, security information from that report in violation of
measures and internal controls for computer applicable laws or TransUnion policy
and communication systems, including portable
• Aiding any person to obtain or modify consumer
electronic devices, laptops, telephones, and other
information, products or services offered by
storage devices provided by TransUnion or used in
TransUnion unless in compliance with applicable
connection with its business.
laws and TransUnion policies and procedures
Can I? Send myself company files to Did you
my personal email account so I can know?
review them later?
No. The use of personal email
TransUnion often monitors
accounts for sending and receiving computer systems, including
TransUnion business emails is email and voicemail, to ensure
prohibited. See the Information compliance with TransUnion
Security Department Policy and their policies.
intranet page to learn more.
For additional information,
refer to the TransUnion Policy
and Agreement Forms found
Information privacy on The Hub.
TransUnion is committed to complying with
applicable privacy and data protection laws because
protecting the privacy of personal information is the
right thing to do.
Failure to properly protect the privacy and security
of personal information may affect TransUnion’s What if? I learn about a potential data
performance, value and reputation. It may also
damage our consumer and business relationships issue, like improper use or access of
and result in legal liability. consumer data. What should I do?
You must comply with TransUnion policies,
procedures and legal standards when handling
consumer personal information. Contact You must immediately notify your
TransUnion’s Compliance Department if you’re not manager. He or she will then notify The
sure how to handle data protection and privacy
Data Incident Response Team. To learn
matters.
more about reporting a data issue, read
Compliance Policy Statement LRC 245 –
Enterprise Issue Management.
16 | Code of Business Conduct Return to Table of ContentsProtecting TransUnion is everyone’s
job. If you have concerns about an
issue at TU, such as data security,
privacy, employee safety, ethical
behavior or any other risk, Speak up!
Questions about the Issue
Management Program can be emailed
to SpeakUp@transunion.com.
If you wish to remain anonymous, you
may use the TransUnion Helpline to
report the incident, see list of phone
numbers in Getting Help section.
You can report
ethics concerns
anonymously via
the web helpline.
1718 | Code of Business Conduct Return to Table of Contents
Our company and stakeholders
Our values and beliefs not only guide our actions with customers and consumers,
they are core in how we manage our company and deliver value to our stakeholders.
As a successful business, we all have an interest in protecting the company. We
strive for financial success by growing our business and making a reasonable profit.
We implement controls to manage our risks and create reliable records. And we
maintain open communication with our investors and keep them apprised of all
material developments.
Antitrust, competition laws, In addition, we are firmly committed to ensuring
our financial institution customers are confident in
fair dealing and fair lending their ability to make lending decisions based on the
information provided by TransUnion. TransUnion’s
products and services are used by creditors subject to
TransUnion seeks to outperform our competition
fair lending laws. These laws protect individuals from
fairly and honestly. It’s our responsibility to
discrimination in the lending process.
understand our customers’ requirements
and satisfy them by offering quality services
at competitive terms and prices. You must not:
Competition and antitrust laws regulate dealings • Discuss or enter into any understanding with
with competitors, customers, distributors and competitors concerning prices, production limits,
other third parties. All TransUnion team members products, services, customers or territories.
must understand how competition and antitrust • Discuss or enter into any understanding with
laws affect their daily work. You must fully and competitors regarding the boycotting of certain
consistently comply with applicable competition customers, industries, competitors or suppliers.
and antitrust laws.
• Use trade secret or proprietary information of
These laws prohibit agreements with a competitor to another company to win customers.
set any terms of sale (such as prices, discounts and
credit terms) and limit the information TransUnion • Induce past or present employees of other
can share with competitors. Because of these risks, companies to share proprietary information with you.
you’re prohibited from discussing competitive • Make disparaging comments about the products,
matters with any competitors without prior services or actions of any of TransUnion’s
authorization from TransUnion’s Legal Department. competitors.
What is Antitrust?
Antitrust generally refers to laws Violations of these laws can carry stiff
established to protect trade and criminal penalties as well as civil fines.
commerce from unlawful restraint
For more information about antitrust and
and monopolies or unfair business
competition laws, read the TransUnion
practices.
publication Guide to Antitrust and
Such laws exist to preserve a fair Competitive Laws that’s available on
and competitive economy. TransUnion’s intranet website.
19Did you
What is bribery?
know?
Bribery is the offer, promise,
giving, demanding or acceptance
If you wish to enter into an of an advantage as an inducement
activity with any competitor, for an action which is illegal,
you must obtain your unethical, a breach of trust,
manager’s approval and the
or improper performance
approval of TransUnion’s Legal
of a function or activity.
Department in advance.
It’s our policy to treat all consumers fairly
based on legitimate business factors necessary
Bribes, inducements,
to evaluate creditworthiness, without regard
to protected characteristics. In the United
kickbacks and payoffs
States, fair lending laws define these protected All associates, board members, officers, third parties,
characteristics as race or color, religion, national representatives or agents of TransUnion must
origin, sex, marital status, age, income derived conduct business on its behalf honestly and without
from any public assistance program, or exercise of the use of bribery, inducement or corrupt practices
a consumer’s rights under law. in order to gain an unfair advantage. TransUnion has
It’s illegal for creditors, using any information a zero tolerance policy toward these practices and
obtained, to discriminate against an applicant is committed to only the highest levels of openness,
based on protected characteristics in all aspects integrity and accountability.
of a credit transaction.
Anti-corruption laws
TransUnion must comply with all anti-bribery and anti-
corruption laws of the countries and nations in which
we operate. When acting for or on behalf of TransUnion,
What are Fair you must not:
Lending Laws? • Make, promise, offer or deliver any donation, gift,
favor, payment, contribution or other gratuity
to an official or employee of any government or
Fair Lending Laws are federal governmental agency, or any person seeking public
office.
laws protecting consumers
• Make any indirect payments to organizations
from unfair, discriminatory and associated with such employee, official or person.
predatory lending practices. For example, you cannot make indirect payments
through attorney fees, sales commissions, political
Fair Lending Laws prohibit committees or parties, or consultant fees.
discrimination against an You’re permitted to make legally-required payments,
such as fees for licenses, permits or other official
individual or group of people expenses required by law or regulation to do business.
based upon one or more However, prior to authorizing any such payment, you
protected characteristics. should confirm with your manager that the payment
has been approved by the TransUnion Accounting
Department.
You should contact your local Legal Department for
guidance if you’re unsure whether you might be dealing
with a government official, or have any other questions
on complying with anti-bribery laws. Always speak up
and report any suspected bribery activity.Gifts, entertainment and meals
You may give to or accept gifts or entertainment
from customers or vendors only if they’re ordinary,
reasonable and of limited value, and consistent with
TU policy.
Such gifts or entertainment must not violate any legal
standards or generally accepted ethical standards,
including the standards of the recipient’s organization You may support your selected political
You may be a guest or host for customary business parties or candidates for public office
functions such as meals, provided they’re for a valid
business purpose and reasonable in cost. with your own funds, as long as you
You can find additional information in Compliance don’t imply your action is on behalf of
Policy Statement LRC 226 – Gifts, Entertainment and TransUnion.
Contributions.
You may not make a political contribution
with TransUnion’s funds or request
Anti-money laundering laws reimbursement from TransUnion for
TransUnion is committed to fully complying with all a political contribution unless your
anti-money laundering laws and regulations. Money manager has approved the contribution
laundering involves hiding the origin of unlawfully and received prior approval from
gained money, such as through drug transactions,
bribery, terrorism or fraud. TransUnion conducts TransUnion’s Legal Department.
business only with reputable customers, suppliers
and others involved in legitimate business activities,
with funds derived from legitimate sources. Steps for Refer to Compliance Policy Statement
compliance include: LRC 231—Political and Lobbying
• Knowing your business partners: Where Activity for additional information.
appropriate or required, conduct integrity
assessments or ensure the party has been
reviewed and approved to do business with
TransUnion, and be generally familiar with their
business practices
• Monitoring financial activity: Observe and record
transactions consistent with all established
policies and procedures
• Keeping complete records: Keep current,
complete and accurate records of all business
transactions
• Reporting any suspicious activity: Immediately
alert TransUnion’s Legal Department of any
suspicious activity
• Cooperating fully with legal and regulatory
authorities charged with enforcing anti-money
laundering laws
21Working with a relative or someone with whom you
Conflicts of interest and have a personal relationship may cause a conflict
of interest. TransUnion may need to limit these
business opportunities circumstances, therefore you must disclose to your
manager any relationship you have with another
A conflict of interest arises when your private
associate, contractor or consultant of TransUnion so
interest interferes (or appears to interfere) in
that TransUnion may review the matter.
any way with the interests of TransUnion or your
objectivity and effectiveness as a TransUnion team Whether a conflict of interest exists isn’t
member. Because it impairs your ability to make always clear. When in doubt, you should discuss
objective judgments, any conflict of interest — the particular situation with your manager or
or even something that appears to be a conflict TransUnion’s Legal Department.
of interest — should always be avoided. However,
if the conflict cannot be avoided, you must disclose
and have it approved by your manager and the Did you
TransUnion Human Resources Department.
In particular, you should not:
know?
• Use TransUnion’s property, information or your
position for personal gain. An example is entering
into any investment or business opportunity
for yourself, family, friends or any business You can find additional
controlled by you, your family or friends, which
you know about through your job at TransUnion.
information about conflicts
of interest in the Conflicts
• Compete with TransUnion directly or indirectly
for business opportunities, unless you’ve of Interest Legal Policy on
disclosed the opportunity to your manager and TransUnion’s intranet website.
TransUnion’s Legal Department. You must also
have been specifically advised by TransUnion’s
Legal Department that TransUnion will not pursue
that particular opportunity.
Insider trading
What is a conflict You must never trade in securities of TransUnion
of interest? or of one of its business partners or customers
based on material, non-public information learned
through your position with TransUnion.
This occurs when your private U.S. securities laws prohibit trading on the basis
interest interferes (or appears of material non-public information. If you have
access to material non-public information about
to interfere) with interests of a company, including TransUnion, regardless of
TransUnion, or otherwise affects its source, you’re not permitted to use or share
your objectivity or effectiveness that information for your personal benefit. All
non-public information about TransUnion, its
as a TransUnion team member. customers, suppliers, or joint venture parties
should be considered confidential information.
Trading in securities of these entities while in
possession of material non-public information,
You must report the existence or discovery of as well as being the source of that information for
any circumstances that constitute a conflict of others who trade, may constitute illegal insider
interest or could create a potential conflict of trading. Additional information regarding avoiding
interest, including any financial or other business insider trading is available in Legal Department
relationship, transaction, arrangement, or other Policy Statement LRC 247 – Insider Trading.
interest or activity with any of TransUnion’s suppliers,
customers, competitors or other persons.
22 | Code of Business Conduct Return to Table of ContentsInvestor communication and
bookkeeping, record keeping The integrity of our business
requires we have accurate
and documentation information in order to make
We’re committed to providing investors with full, responsible business decisions.
fair, accurate, timely and understandable disclosure.
Therefore, the records, data and information owned, For example, our accounting
used and managed by TransUnion must be truthful,
accurate and complete. You’re responsible for the is based upon whether the
integrity of the information, reports and records under supporting documents are
your control. It’s essential the integrity, accuracy and
reliability of TransUnion’s books, records and financial truthful, accurate and complete.
statements be maintained to comply with all legal,
accounting, tax and other regulatory requirements.
Associates, who prepare, maintain or have custody of
TransUnion’s records and reports must ensure these Did you know?
documents:
Examples of unacceptable practices include:
• Accurately and fairly reflect, in reasonable detail,
• Backdating entries or transactions
the assets and transactions of TransUnion
• Reporting revenue or expenses without
• Are protected from loss or destruction supporting documentation
• Are retained for specified periods of time • Entering into unrecorded, special
in accordance with TransUnion’s document or “off the books” transactions
retention policy
• Are maintained in confidence Important
All our books and records must: If you discover any inaccurate records, reports
• Be maintained in reasonable detail
or documents — even if you didn’t create the item
— you must immediately inform your manager
• Appropriately reflect our transactions or the TransUnion Helpline.
• Conform to applicable legal standards
You’re responsible for the integrity of all records You must obtain all necessary approvals before you or
and documents you create or maintain as part someone under your supervision disburses or transfers
of your job responsibilities. any TransUnion funds or property.
You must always manage business records according to
our record retention policy and applicable legal standards.
You should not:
In the event you’re made aware of litigation or a
• Misrepresent facts in any TransUnion governmental investigation and you have business records
business document in your possession that may relate to that litigation or
• Falsify any financial or other records investigation, you must advise your manager. He or she
should then consult with TransUnion’s Legal Department
• Bypass our system of internal controls
to determine the proper handling of those records.
23• Route all communication regarding business
Did you operations, results, plans, or prospects in relation
to our business, competitors, customers, or
know? suppliers through the proper channels. Do not
discuss these with any person associated with the
media, any investment banking firm, any financial
analyst, or regulator, unless that discussion
Business records and has been pre-approved by TransUnion’s Legal
communications often become Department.
public. You should avoid • Review and comply with Communications Policy
LRC 248 – Public Communications and
exaggeration, derogatory Compliance with Regulation FD.
remarks, guesswork, and “joking”
or “surly” characterizations of
people, events and companies Interacting with auditors
in any communication. This and investigators
applies to email, voicemail, All interactions with auditors and investigators
instant messaging, internal should be coordinated with management and the
memos, formal reports and Legal and Compliance Department. It’s important
even personal notebooks and to provide complete and accurate information when
communicating with:
calendars. So remember, keep
• Any auditors or investigators — internal
your documents factual. or external
• Any governmental agency or official
There are laws that provide for severe criminal and
External communications civil penalties for anyone who tries to improperly
influence, obstruct or impede a governmental agency
Since TransUnion is a global leader, you may be in the performance of their official duties. Personnel
asked to comment as a representative of TransUnion of government agencies may include auditors,
on industry initiatives, consumer matters or other employees, agents or investigators doing work on
economic concerns. It’s critical our communications behalf of such agencies.
with external audiences are managed in a On a periodic basis, you may be called upon to
coordinated way to ensure our messages are provide information for governmental or regulatory
accurate, consistent and timely. In addition, as a filings. This responsibility will include certifying the
publicly traded company, TransUnion is prohibited information you or your associates have provided is
from selectively disclosing material non-public complete and accurate.
information. If called upon to provide this information, you’re
You should: expected to respond in a timely manner. Required
• Refer all media inquiries directly to TransUnion’s disclosure in the filings must be full, fair, accurate,
Public Relations team. timely and understandable.
• Have your manager, Corporate Communications
and Legal pre-approve any articles, speeches or
other materials you want to submit to the media
or present at an industry or customer conference For information about rules when
or governmental hearing.
engaging in online activities and social
• Not disclose actions or activities relating to our
business operations outside of TransUnion unless media, refer to Compliance Policy
that disclosure has been pre-approved by your Statement LRC 185 - Online Activities
manager, Corporate Communications and Legal.
and Social Media.
This includes communications made via
social media.
24 | Code of Business Conduct Return to Table of ContentsEngaging with
social media:
• Don’t post confidential
information about our
company.
• Don’t post confidential
information about our
consumers, customers,
co-workers, business
partners or vendors.
• Do not present yourself
as a spokesperson for
TransUnion.
• Clearly state any opinions
you’ve expressed are
your own.
• Be mindful of TransUnion’s
corporate values and non-
discrimination policies.
Whether intentional or
otherwise, your words
reflect on TransUnion.
2526 | Code of Business Conduct Return to Table of Contents
Our people
Our values and beliefs — designed by our people — have a clear application to our
workplace and how we treat one another every day. Each represents the way we hope
associates address their work product and their work environment, taking ownership
and pride in what they do.
Workplace Diversity and inclusion
At TransUnion, we have a shared responsibility in We see diversity as a source of strength and know that
maintaining a safe, professional, productive, healthy and it’s essential to our mission, innovation, and growth.
inclusive working environment. We believe that our ability At TransUnion, we know that diversity helps us win.
to attract and retain talented associates positions us for TransUnion is a place where everyone can be themselves,
success. That’s why we’re an equal opportunity employer, and we enrich both our work and each other’s lives by
seek a diverse employee base, and provide appropriate sharing our unique experiences and perspectives.
compensation opportunities and performance standards We are an equal opportunity employer and are committed
that reflect our best efforts. We value the contributions to treating all our employees and job applicants equally.
of all associates and do our part to foster the best We promote equality and conduct business according
working environment. to principles of social justice, respect and freedom of
TransUnion associates should: expression. All supervisors and managers are responsible
• Treat everyone with respect and dignity, for ensuring that policies of equal opportunity are applied
being sensitive to the diverse beliefs and at all times and that all procedures and practices are free
backgrounds of others. of discrimination. We appoint, train, develop and promote
employees on the basis of merit and ability alone.
• Express yourself in a positive, polite and
non-confrontational manner in both words We are committed to an inclusive workplace environment
and gestures, and maintain appropriate dress free from acts of discrimination and harassment, and we
and hygiene standards. strive to make all employment decisions based on job-
• Comply with and support all management related qualifications without regard to race, color, sex,
directives, and business unit and department age, disability, medical condition, physical appearance,
goals and objectives in the performance of your job. marital status, national origin, ancestry, alienage or
However, if you believe in good faith a directive, goal citizenship status, pregnancy, ethnicity, religion/creed,
or objective is in violation of this Code, you should disability, genetic information, gender (including gender
call the TransUnion Helpline as soon as possible. identity or gender expression, or status as a transgender
person), sexual orientation, military or veteran status,
• Not tolerate harassment, bullying, discrimination
marital or familial status, status as a victim of domestic
or violence.
violence, stalking or sex offenses, or any other category
• Not damage or misappropriate the property of protected by applicable law (“protected characteristics”).
TransUnion or our associates, customers or guests.
• Read and adhere to this Code and all TransUnion
policies relating to your job duties.
• Promptly report any conduct that is unlawful, TransUnion is committed to
abusive, an actual or potential health or safety
hazard or in violation of this Code a positive work environment.
Any behavior in conflict with maintaining
a safe, healthy, non-discriminatory, non-
For additional guidance, you can read
violent, alcohol-free, drug-free, crime-
the TransUnion Harassment Policy free environment will not be tolerated.
and Workplace Violence Policy in
TransUnion’s handbook.28 | Code of Business Conduct Return to Table of Contents
Our community
Finally, our values and beliefs carry out into our community. We encourage employee
involvement in community programs and socially responsible activities. We are
sensitive to culture and needs of all local communities in which we have a presence.
We support efforts that promote education and economic well-being in communities
where we work.
Human and Community Corporate social
labor rights relations responsibility
We’re committed to respecting At TransUnion, being a good For us it’s clear that it’s not
and preserving human rights, corporate citizen means giving enough to be a good investment,
not only for our associates but back to the communities where we are committed to being a
for the communities in which we operate. Our Community good corporate citizen. We
we operate. In our Human and Program, called GoodWorks@TU, encourage you to read our annual
Labor Rights Policy, we adopt focuses on the ways in which we Corporate Social Responsibility
international human, labor and believe we can most meaningfully report (transunion.com/csr)
development standards as the give back. We encourage you to for information on the work
baseline for how we operate read our annual Corporate Social TransUnion is doing to support
our business. Furthermore, we Responsibility report (transunion. communities all over the world.
underscore this commitment com/csr) for information on
with regular trainings for the work TransUnion is doing in
associates on relevant human communities all over the world.
and labor rights issue areas.
TransUnion as a company funds activities, you’re encouraged to
and supports a variety of community- participate and make a difference.
based activities that make a difference
TransUnion recognizes participating in
in people’s lives. One example is its
these types of volunteer programs and
participation in programs that promote
activities enriches the lives of associates.
financial literacy, empowering people to
TransUnion provides paid time off to
make smart financial choices.
eligible associates who participate in a
TransUnion also periodically sponsors qualifying volunteer program or activity.
regionally focused volunteer opport- Charitable matching gift programs are
unities throughout the year. Whatever also available in select regions.
way you choose to volunteer, either
through a company-sponsored event See Accounting SOP 703 – Charitable
or as an individual in neighborhood Contributions for further information.30 | Code of Business Conduct Return to Table of Contents
Getting help
Often, the right thing to do is obvious. At other times, a situation may seem complex or
unusual and we may be unsure about how to proceed. If you have a concern, please
speak up immediately. Not only do we have a duty to do so, it allows us to quickly gain
clarity and avoid potential problems. If something has gone wrong, it gives us an
opportunity to investigate and correct it.
The TransUnion Helpline • Trinidad & Tobago: 1-833-224-0172
Non-TransUnion personnel staff the helpline 24 hours • UK 0800 915 1571 or
day, 7 days a week. They’ll document your issue and +44 (0) 800 915 1571 if dialing from outside the UK
forward it to TransUnion Global Compliance for
investigation and resolution.
1.Step 1: An automated voice in English will indicate the
phone line is owned by ComplianceLine (Safecall in
the UK). You may also file a report through the web
2.Step 2: Remain on the line and a live operator will at https://transunion.webline.sai360.net.
answer.
3. Step 3: If you need a translator – please request one.
The access codes by country are: Should you wish to contact TransUnion’s
Legal Department, Information Security
• U.S. & Canada: 844-691-8137
Department or Human Resources
• U.S. Virgin Islands: 844-691-8137 Department regarding a Code of Business
Conduct matter and you don’t know who
• Brazil: 0-800-900-0197 to call, please contact the TransUnion
• Chile: 800-914-037 Helpline.
• Colombia: 01-800-518-9496
Leave your name, contact information and
• Costa Rica: 0800-542-5564 the department you’d like to speak with.
• Dominican Republic: 1-849-936-1370
A representative from that department
• El Salvador: 503-2113-8404 will be in touch with you as soon as
• Germany: 08001803962 possible.
• Guatemala (Claro): +502-2458-1826
• Honduras: 800-2791-9423
• Hong Kong: 800 906 155
• India: 000-800-9191-223
• Ireland: 0800 915 1571
• Kenya: 0-800-221-003
• Mexico: 800-681-5387
• Namibia: 264-83-380-0154
• New Zealand: 0800-448-204
• Nicaragua: 001-800-226-0584
• Philippines: 1800-1-322-0447
• South Africa: 080-098-1995© 2023 TransUnion. All Rights Reserved | 21-F96482
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