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PRIVACY AND LEGAL
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Privacy Policy Terms of Use UK Modern Slavery Act UK Tax Strategy Accommodation
Statement AAP/EEO Statement External Referral Award Program Terms and Conditions
Cookie Policy Supply Chain Code of Conduct Supplier Diversity Policy The Federal
Transparency in Coverage Rule
PRIVACY POLICY
Last Revised April 2022
INTRODUCTION
Thank you for visiting www.factset.com, the Website of FactSet Research Systems
Inc. and its affiliates (“FactSet,” “we” or “us”). FactSet is a provider of
integrated financial information and analytical applications to the global
investment community. To protect your privacy better, FactSet wants our
customers, suppliers, employees, applicants, and other relevant parties to know
how we collect personal data, the types of personal data we collect, and how we
use and share your personal data. By visiting this Website (the “Site”), or
providing your information to us, you are accepting the practices described in
this Privacy Policy. Note that this Privacy Policy only applies to personal data
we collect (1) on our Site, (2) through our client and supplier- facing
applications and tools, (3) from communications or applications you send us, (4)
when you interact with our advertising and applications on third party websites
and services, if they include links to this notice; and (5) through your
contractual relationship with us, as applicable. This Privacy Policy does not
apply to any other personal data.
INFORMATION WE COLLECT
Factset collects information that may be used to identify, describe, or link to
people who visit our Site or request information about our product or the
products of third parties. We collect and process personal data mainly from our
customers and suppliers while doing business with them and we collect and
receive personal data on this Site and through social networks. The personal
data we process is mainly business contact information from our clients and
suppliers and information you and our customers provide when using our products
or accessing our websites or other applications.
We also collect and collate information (including some personal data) from
third party suppliers and public sources. We mainly process the personal
information in order to provide our services to our customers, and to fulfill
our contractual obligations and improve our products and offerings. For more
information on our Processing activities, see Section 3 (Lawful Grounds for
Processing) and Section 4 (How We Use Your Personal Data).
A. PERSONAL DATA THAT WE COLLECT WHEN YOU USE THE SITE
We collect several types of information and personal data, including data:
* that relates to an identified or identifiable individual, such as name,
postal address, email address, telephone number, IP or MAC address, etc. and
related information, such as the contents of an email ("personal data");
* about your internet connection, the equipment you use to access our Site and
usage details (e.g., statistics) regarding our products (“usage
information”);
* about browsing history, search history, information regarding the consumers
interaction with a website, application, or advertisement; and
* inferences drawn from any of the information identified above, such as
information used to create a profile of consumer’s preferences.
We collect this information and personal data:
* directly from you and your employees when you or they provide it to us;
* automatically as you or your employees navigate through the Site or use our
products. Information and personal data collected automatically may include
usage information, IP addresses, and information and personal data collected
through cookies, collected information from your use of our Site, including
search queries, surveys and content clicks, web beacons, and other tracking
technologies;
* from public and third-party sources. Third party advertisers or their
advertising servers, or other third-party service providers may also place
cookies on your devices used to access our Site.
Do Not Track (“DNT”) is a privacy preference that users can set in their web
browsers. When a user turns on DNT, the browser sends a message to websites
requesting that they do not track the user. At this time, FactSet ignores these
signals. FactSet does not change its practices, described elsewhere in this
Privacy Policy, in response to Do Not Track browser settings or signals. For
information about DNT, visit www.allaboutdnt.org.
Third parties may collect personal information about your online activities over
time and across different websites, including your use of this Site. This
Privacy Policy does not apply to, and we are not responsible for, the practices
of third parties that collect your personal information.
B. PERSONAL DATA YOU PROVIDE TO US
You may provide personal data to Us through your use of our Site or services, or
when you apply for employment with us. The personal data we collect may include:
* personal data that you provide by conducting business with us, by filling in
forms on our Site, or at a trade show, or anywhere else we conduct business,
by subscribing to newsletters or other communications, or by corresponding
with us by phone, e-mail or otherwise using our contact details. This
includes personal data provided at the time of requesting information or
services, soliciting business, or performing a service. We may also ask you
for personal data when you enter a contract with us, or a contest or
promotion sponsored by us, and when you report a problem;
* identifiers, including name, address, unique identifiers, account name, and
job title;
* records and copies of your correspondence (including email addresses);
* your responses to surveys that we might ask you to complete for research
purposes;
* your search queries on the Site;
* personal data you provide during the contractual relationship for execution
of the supplier or customer contract;
* personal data you provide by using our incident management and project
management tools and applications;
* personal data you provide by communicating with our customer care teams for
error resolving issues, training and support;
* Your usage of our products and related tools and applications.
Typically, the personal data you give us may include name, business affiliation,
business address, telephone number, and email address, and any personal details
required to conduct business with you or to resolve any inquiries or complaints.
We will indicate to you when personal data is required to enter into a contract
with you (such as in anticipation of a services agreement) or to perform a
contract with you (such as to provide services at your request), and when
failure to provide any personal data may result in our inability to provide
requested services or products.
For job applicants, we may collect various types of personal data about you for
the purposes described in this Privacy Policy, including:
* Data about you: such as your forename, surname, gender, nationality, date of
birth, home contact details (e.g., address, telephone number, e-mail),
national ID number, immigration and eligibility to work data;
* Data about your employment history and qualifications: qualifications,
references, CV and application form, background checks and verification of
information from LinkedIn or similar social media profile;
* Data about your application: such as interview notes or assessment results;
and
* Legal and criminal records data: legal records data are processed only in
compliance with the applicable laws and in specific circumstances (e.g.,
background checks for senior roles or roles handling sensitive information).
You may give us the personal data described above during the recruitment
process, whether through the application forms on our online job portal, on the
telephone or at interviews. We partner with certain third party jobsites, such
as LinkedIn or JobCentre Plus, and may receive your personal data via these
organizations.
C. PERSONAL DATA WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
If you navigate through and interact with our Site and some of our products, we
may use automatic data collection technologies to collect certain usage
information about your equipment, browsing actions, and patterns. Automatic data
collection is carried out through the use of cookies and related technologies.
For more information, please see our Cookie Policy which can be accessed here.
D. PERSONAL DATA WE COLLECT FROM PUBLIC SOURCES AND THIRD PARTIES
In order to provide our content services to our customers, we rely on content
provided by third party suppliers, as well as content that is made available to
the public. Some of that content includes general information about names of
directors, registered board members, managers, fund managers and other official
persons of companies published on public accessible websites, letterheads,
prospects, annual financial statements, invitations to shareholder meetings etc.
During the job recruitment process, we may also receive personal data about you
from other third parties; for example, recruiters; references from a previous
employer; business partners; background check providers; as well as from
publicly available sources such as social media.
LAWFUL GROUNDS FOR PROCESSING
All processing and use of your personal data is justified by a "lawful ground"
for processing. In the majority of cases, processing will be justified on the
lawful ground that:
* the processing is necessary to perform a contract with you or take steps to
enter into a contract at your request, such as to negotiate a contract with
us, to fill an order, or to provide product information that you have
requested;
* the processing is necessary for us to comply with a relevant legal
obligation, such as keeping accounting records;
* the processing is in our legitimate interests, which are not overridden by
the interests and rights of the relevant individual whose personal data is
collected; and
* you have consented to the processing.
Where we rely on our legitimate interests to process personal data, those
interests are:
* to use supplier, customer and website user data to conduct and develop our
business activities and improve our services in order to grow our business
and profitability, while limiting the use of this personal data to purposes
that support the conduct and the development of our business and the
improvement of our services;
* to use third party supplier and publicly available content (which in some
instances includes personal data) in order to provide our content services to
customers for their business purposes, which may include, but not be limited
to taking investment decisions or compliance with applicable laws and
regulations such as insider trading regulations and anti-bribery legislation,
but which are for our customers to determine and explain in their privacy
notices.
HOW WE USE YOUR PERSONAL DATA
The following is an overview of our purposes for using your personal data.
Additional details on how we process your personal data may be provided to you
in a separate notice or contract.
We use the personal data we collect to:
* provide customer services, including products and services; to take, verify,
process, and deliver orders and returns; to process payments, technical
support, or other similar purposes; and to establish and maintain customer
accounts;
* address your inquiries associated with the information you provide to us;
* provide training and after-sales-support on our products and answer to and
perform change requests;
* organize and perform incident management processes;
* implement projects by working together with customers and their users as part
of the project team;
* communicate with customers and suppliers, including responding to requests
for assistance and to update them about the status of their orders by postal
mail, email, telephone, or text message;
* investigate, prevent or take action regarding unauthorized use of our
services, illegal activities, suspected fraud or situations involving
potential threats;
* provide you with underlying tools and applications helping to implement
projects and resolve incidents;
* discuss, carry out and implement change request and further developments of
our products;
* provide our content services to our customers and to report and administer
customers’ users’ usage of third-party information products (e.g., real-time
data from stock exchanges etc.);
* administer and manage performance of purchase or sales agreements with our
suppliers and customers;
* to enhance the experience for our users, we use notes relating to support
provided to specific employees, advisors or agents of customers in relation
to our products and services for their future use of our services;
* service your account;
* to the extent it is lawful to do so, market and promote our products
including through email or equivalent electronic means, to send news and
newsletters, special offers and promotions, or to otherwise contact customers
about products, services or information;
* process, evaluate and complete certain transactions involving the Site, and
more generally transactions involving FactSet's products and services;
* operate, evaluate, maintain, improve and develop the Site (including by
monitoring and analyzing trends, tracking user behavior, access to, and,
where lawful to do so, use of the Site for advertising and marketing);
* to the extent it is lawful to do so, engage with you about events,
promotions, the Site and FactSet's products and services and send you emails,
event notifications, invitations, newsletters, announcements, and other
communications regarding matters that may be of interest to you;
* facilitate your job application process;
* provide you with documentation or communications which you have requested, or
which is part of a product;
* correspond with users to resolve their queries or complaints;
* protect the security of the Site, FactSet confidential and proprietary
information (which may include personal data), and FactSet employees;
* manage, protect against and investigate fraud, risk exposure, claims and
other liabilities, including but not limited to violation of our contract
terms or laws or regulations;
* share your personal data with third parties in connection with potential or
actual sale of our company or any of our assets, or those of any affiliated
company, in which case personal data held by us about our users may be one of
the transferred assets.
FactSet will not sell or rent your personal data you provided to us to third
parties for their own use, but as further described in Section 5, we may provide
third parties with your personal data where there is a legal requirement to do
so or where we need a third party to fulfill our services.
SHARING AND DISCLOSURE OF YOUR PERSONAL DATA
When you have provided personal data to us, we may disclose personal data to
other companies that we have engaged to assist us in providing you goods or
services. This may include the following service providers:
* fulfillment houses;
* billing services;
* transaction managers;
* credit verification services;
* market researchers; and
* other third-party service providers.
We do not sell or rent personal data to third parties for their own use but may
provide certain usage information to advertisers to help provide you with
relevant advertising where we are allowed to do so. Usage information, as used
in this policy, is anonymized and aggregated data, which does not identify you
in the way Personal Data would.
We may also disclose any of your personal data or usage information to law
enforcement or other appropriate third parties in connection with criminal
investigations, investigation of fraud, infringement of intellectual property
rights, or other suspected illegal activities, as may be required by applicable
law, or, as we may deem necessary in our sole discretion, in order to protect
our legitimate legal and business interests.
We may also share your personal data in connection with the recruitment or
employment application process, including sharing that data with:
* other members of the FactSet group;
* recruiters;
* IT service providers;
* companies providing FactSet background check services; and
* payroll systems.
If your application for employment with FactSet is successful, you will be
provided with a separate notice during your on-boarding process, which will
provide you with additional information.
We reserve the right to disclose, share, or otherwise transfer personal data and
usage information in connection with a proposed or actual corporate merger,
acquisition, consolidation, the sale of a portion of our business or the sale of
substantially all of our assets, or other fundamental corporate change, whatever
form it may take. In the event that there is a change of ownership or control of
your personal data or usage information, we will post a prominent notice to that
effect on our Site.
TRANSFERRING PERSONAL DATA
FactSet is a global organization headquartered in the United States, and we may
need to transfer your personal data to third party suppliers and to our
affiliates for the purposes described above. If your personal data is subject to
the GDPR and is transferred outside the EU to other FactSet affiliates or to
third party service providers, we will take steps to ensure that your personal
data receives the same level of protection as if it remained within the EU,
including by entering into data transfer agreements using the European
Commission approved Standard Contractual Clauses, or by relying on certification
schemes. For transfers of personal data among FactSet affiliates we have put in
place European Commission-approved Standard Contractual Clauses and have entered
into an Intragroup data transfer agreement. You have a right to obtain details
of the mechanism under which your personal data is transferred outside of the
EU, although please note that we may need to redact copies of transfer
agreements for reasons of commercial confidentiality, provided that you can
retain access to the relevant safeguards.
With respect to the information you provide to us through the recruitment or
employment process, we may share and transfer your data with other members of
the FactSet Group located globally (including in countries outside EU/EEA, such
as the United States of America, India and the Philippines). FactSet has adopted
an Intra-Group Data Transfer Agreement to ensure your personal data receives an
adequate level of protection wherever it is processed within the FactSet group.
FactSet reserves the right to share any information that you provide which is
not deemed personal data or is not otherwise subject to contractual
restrictions.
RETENTION OF YOUR PERSONAL DATA
We keep personal data only for as long as required to fulfill the purposes for
which it was collected. In general, we retain personal data for a period of time
corresponding to a statute of limitation, for example to maintain an accurate
record of customer and supplier dealings. However, in some circumstances we may
retain personal data for other periods of time, for instance where we are
required to do so in accordance with legal, tax or accounting requirements, or
if required to do so by a legal process, legal authority, or other governmental
entity having authority to make the request, for so long as required in
accordance with our document retention policy.
With respect to personal data we obtain from job applicants through the
recruitment process, our general approach is to retain your application for a
period of 6 months or, where you consent to a longer period of retention, for up
to 2 years following the closure of the recruitment process for the role you
applied for. Otherwise, you should note that, in certain cases, legal or
regulatory obligations require us to retain specific records for a set period of
time. If you accept employment with FactSet, your personal data will be held on
the basis set out in our Employee Data Privacy Notice, which will be shared with
you following your hiring.
YOUR RIGHTS
You may have certain rights in connection with the personal data we collect from
you or that you provide to us. Depending on where you reside, these rights may
be specifically provided to you by statute. We will take steps in accordance
with applicable legislation to keep personal data accurate, complete, and up to
date.
Specifically, you may be entitled to exercise the below rights in connection
with your personal data:
* Request that FactSet disclose our collection and use of your personal data
during the past 12 months;
* Request that we provide your personal data to you in structured, commonly
used and machine-readable format;
* Request that we correct any inadequate, incomplete, or incorrect personal
data we hold;
* Request that we delete your personal data;
* Request that we restrict processing of your personal data;
* Object to processing or withdraw your consent for processing (including
profiling) based on legitimate interest lawful grounds, without affecting the
lawfulness of processing before withdrawal;
* Object to direct marketing (including profiling); or
* File a complaint with the applicable supervisory authority.
Additionally, job applicants specifically have the following rights with respect
to personal data:
* Withdraw your consent at any time; for example, if you are no longer happy
for us to retain your unsuccessful application for an extended period of up
to 2 years;
* Request that we restrict our processing of your personal data where:
* you contest the accuracy of the personal data until we have taken
sufficient steps to correct or verify its accuracy;
* where the processing is unlawful but you do not want us to erase the
personal data;
* where we no longer need your personal data for the purposes of the
processing, but you require such personal data for the establishment,
exercise, or defense of legal claims; or
* where you have objected to processing justified on legitimate interest
grounds (see below) pending verification as to whether FactSet has
compelling legitimate grounds to continue processing.
Note that we will not discriminate against you in any way if you choose to
exercise any of the above rights. Please contact us as indicated in the Contact
Us section below or using the email-address: dataprivacy@factset.com if you wish
to exercise any of your rights, or if you have any enquiries or complaints
regarding the processing of your personal data.
We may need to request additional information from you in order to respond to
your request to exercise any of the above rights. We will respond to your
verifiable request and to take action with respect to your request within 45
days. If we require additional time to disclose and or delete your personal
information as provided under applicable law, we will inform you within 45 days
of your request.
To the extent allowed under applicable law, FactSet may decline to comply with
certain data deletion requests in the event that your personal data is required
to:
* Complete the transaction for which the personal information was collected,
provide a good or service requested by you, or reasonably anticipated within
the context of a business’s ongoing business relationship with you, or
otherwise perform a contract between FactSet and you;
* Detect security incidents, protect against malicious deceptive, fraudulent,
or illegal activity; or prosecute those responsible for that activity;
* Debug to identify and repair errors that impair existing intended
functionality;
* Exercise free speech, ensure the right of another consumer to exercise his or
her right of free speech, or exercise another right provided for by law;
* Comply with applicable laws or legal obligations;
* Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics
and privacy laws, when our deletion of that information is likely to render
impossible or seriously impair the achievement to that research, if you have
provided informed consent;
* Enable solely internal uses that are reasonably aligned with your
expectations based on your relationship with us; or
* Otherwise use your personal information, internally, in a lawful manner that
is compatible with the context in which you provided information.
CHILDREN
This Site is not intended or directed to anyone under the age of 16 and we do
not provide services to anyone who we know to be under the age of 18, nor do we
collect any personal information from anyone who we know to be under the age of
18. If you are under the age of 16, you should use this Site only with the
involvement of a parent or guardian and should not submit any personal
information to us.
DATA SECURITY
FactSet takes reasonable precautions to protect personal data from loss, misuse,
unauthorized access, disclosure, altercation, and destruction. Unfortunately,
while we work hard to ensure the security of your personal data while it is on
our systems, no security measures are perfect, and data transmitted over the
Internet is not guaranteed to be 100% secure. We cannot and do not ensure or
warrant the security of any personal data you transmit, and you do so at your
own risk.
Where we have given you (or where you have chosen) a password which enables you
to access certain parts of our jobsites, you are responsible for keeping this
password confidential. We ask you not to share a password with anyone and you
are responsible for the confidentiality of the password related to your account.
LINKS TO OTHER WEBSITES
Our Sites may provide links to other websites for your convenience and
information. These websites may operate independently from FactSet. Linked
websites may have their own privacy notices or policies, which we strongly
suggest you review if you visit any linked websites. To the extent any linked
websites you visit are not owned or controlled by FactSet, we are not
responsible for the websites’ content, any use of the websites, or the privacy
practices of the websites.
CHANGES TO OUR PRIVACY NOTICE
This Privacy Notice may be amended from time to time. Please review it
periodically. Changes to this Notice will be identified by the date at the top
of this page.
HOW TO CONTACT US
If you have any questions or comments about this Privacy Notice, FactSet's
privacy practices or if you would like us to exercise any of your data subject
rights, please contact us as provided below:
Chief Compliance Officer
FactSet Research Systems Inc.
90 Park Avenue, 7th Floor
New York, NY 10016
USA
Email: dataprivacy@factset.com
Visit: factset.com/privacy
Privacy Policy
TERMS OF USE
The following terms and conditions govern your use of this website and all
content, services, and products available on or through the website (taken
together, the "Site"). The Site is owned and operated by FactSet Research
Systems Inc. and its affiliates (together, “FactSet”) as a service to its
clients and investors and may be used for informational purposes only. Access to
and use of the Site is subject to your acceptance without modification of all
the terms and conditions contained herein, and all other operating rules,
policies, and terms on this Site and any applicable written agreements with
FactSet (which, in the event of a conflict with this terms and conditions, shall
govern). If you do not agree to these terms, do not use the Site or download any
materials from it. If you do not agree to the terms, or if you cannot remain in
compliance with these terms, you may not access or use the Site. If you are
accepting these terms on behalf of a legal entity other than yourself as an
individual, including a business or a government body, you represent and warrant
that you have full legal authority to bind that entity to these terms.
FactSet may revise these terms at any time by updating this posting. You should
visit this page from time to time to review the then-current terms because they
are binding on you. Certain provisions of these terms may be superseded by
expressly designated legal notices or terms located on particular pages at this
Site.
ELIGIBILITY: You are not eligible to use the Site if doing so would violate any
law or regulation, including but not limited to export controls or restrictions.
This Site is not intended for use for individuals under the age of 18. You must
be over the age of 18 to register an account on the Site. By registering an
account, you represent that you meet this minimum age requirement. In any case,
you affirm that you are over the age of 16, as the Site and the services are not
intended for use by children under 16.
ACCOUNT RESPONSIBILITY: You are responsible for maintaining the security and
confidentiality of your account and password, and you are fully responsible for
all activities that occur under your account, whether by you or anyone else. You
may not create or use an account for anyone other than yourself. You must
immediately notify FactSet of any unauthorized uses of your account or any other
breaches of security. FactSet will not be liable for any acts or omissions by
you, including any damages of any kind incurred as a result of these acts or
omissions. FactSet will not be liable for any loss that you or any other third
party may incur as a result of someone else’s use of your account or password,
either with or without your knowledge. FactSet may hold you liable for any
losses incurred by FactSet or any other party due to someone else’s use of your
account or password.
LICENSE: As long as you are in compliance with these terms and other applicable
FactSet policies, we grant to you a limited, revocable, non-assignable,
non-transferrable, non-sublicenseable, non-exclusive license to use the Site,
and to access and receive services that are intended for public display or
access. Any rights not explicitly granted to you in these terms are strictly
withheld and reserved by FactSet.
You agree that: (1) you will not copy or distribute any part of the Site or
services in any medium without our prior written authorization, except as is
necessary to your normal use of the Site; (2) you will not alter or modify any
part of the Site other than is necessary to use the Site for its intended
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These terms were last updated April 2022.
Terms of Use
FACTSET'S UK MODERN SLAVERY ACT STATEMENT 2022
This statement is made pursuant to section 54(1) of the United Kingdom Modern
Slavery Act of 2015 and constitutes FactSet’s group slavery and human
trafficking statement for the financial year ending 31 August 2022.
INTRODUCTION FROM PHIL SNOW, CHIEF EXECUTIVE OFFICER
As a major software and solutions provider globally, we recognise that our
company must act responsibly and thus are committed to improving our practices
to combat slavery and human trafficking. Employees are expected to report
concerns, using the appropriate reporting channels, and management are expected
to act upon them. We are proud of the corporate social responsibility work we
carry out in our local communities. As we expand into new markets, we ensure
that corporate social responsibility is a key part of our business strategic
development plans.
ORGANISATION'S STRUCTURE AND BUSINESS
We are a major supplier of online-integrated financial and economic information
to the investment management and banking industries. FactSet Research Systems
Inc. is the parent company of all our global subsidiaries, including our
businesses in the United Kingdom (“FactSet”). FactSet has more than 11,000
employees worldwide in 38 office locations in 20 countries. In fiscal 2022, we
established the FactSet Charitable Foundation which is a non-profit, nonstock
corporation and is a separate legal entity from FactSet.
OUR SUPPLY CHAINS
FactSet is not in an industry with a high risk of modern slavery or human
trafficking. Our supply chains include suppliers based throughout the world that
provide a range of services and products, from third party data to IT
infrastructure and local food service. FactSet is committed to high professional
standards and ethics, and we expect the same from all our suppliers. All
suppliers are expected to comply with all local and national laws and
regulations.
OUR VALUES AND POLICIES
Part of our values and culture is that we are an inclusive community, working
together as a team and staying connected to our clients and each other. We are
committed to ensuring that there is no modern slavery or human trafficking in
our supply chains or in any part of our business. As such, we have implemented
our own FactSet Supply Chain Code of Conduct, available on our public website.
We expect all our global suppliers and their respective supply chains to uphold
similar standards of ethical conduct and to act in accordance with the FactSet
Supply Chain Code of Conduct. This demonstrates our support and commitment to
act ethically and with integrity in all our business relationships. We seek to
implement and enforce effective systems and controls to ensure slavery and human
trafficking is not taking place anywhere in our supply chains.
Our Human Rights Policy is available on our public website and demonstrates our
commitment to develop due diligence to identify and prevent human rights risks
to people in our business and value chain. Where we identify adverse human
rights impacts resulting from or caused by our business activities, we are
committed to provide for or cooperate in their fair and equitable remediation.
EMPLOYEES
Giving back to our communities is an integral part of our culture. FactSet
continues to invest in local communities through its Corporate Responsibility
program, uniting around our four Pillars of Service: Inspire Tomorrow’s
Engineers, Educate to Elevate, Protect Our Environment, and Alleviate Food
Insecurity. The program is led by a global team and supported by local Corporate
Responsibility (CR) Committees who engage colleagues in strategic service
projects to make a difference in our local communities. During fiscal 2022,
FactSet employees served community needs in partnership with 75 charity partners
around the world and volunteered over 17,000 hours of community service. Through
global campaigns with strategic nonprofit partners, FactSet employees achieved
far[1]ranging impacts including volunteering with organisations to help prepare
young people for future careers, hosting a variety of awareness talks, volunteer
events, and sustainability challenges and supporting local and global
communities in relation to hunger and food insecurity alleviation.
All FactSet and FactSet Charitable Foundation grants are made on the provision
that the charity does not discriminate by race, creed, gender, gender identity,
sexual orientation, age, religion, or national origin. We look forward to
supporting our communities with the newly formed FactSet Charitable Foundation
in the upcoming years.
Our annual Sustainability Report is available on our public website and details
how we manage our global business through our fair and transparent governance
processes and equip our staff to uphold the highest standards of ethics.
Our Code of Business Conduct and Ethics is available on our public website and
applies to all employees globally and embodies fundamental principles of ethical
and legal conduct to ensure we continue to be guided by our values. The Code of
Business Conduct and Ethics helps all employees navigate the highly complex,
regulated, and challenging global business environment in which we operate, and
ensures that our sense of integrity is at the forefront of each business
transaction. All employees are required to affirm and recertify their commitment
to the Code of Business Conduct and Ethics on an annual basis. Mandatory new
hire and compliance training programs educate our employees on how to conduct
business in compliance with applicable laws, regulations, and our Code of
Business Conduct and Ethics.
If employees have any concerns about any wrongdoing or breaches of law, these
can be raised through appropriate channels. In situations where employees prefer
to place an anonymous or confidential report, they are encouraged to use
FactSet’s Ethics Action Line which is accessible on our intranet site. Our
Whistleblower and Anti-Retaliation Policy supports the confidential, anonymous
submission of misconduct concerns, and prohibits retaliation against the
individual reporting the alleged misconduct.
NEXT STEPS
We will continue to review the effectiveness of the steps we have taken to
ensure that there is no slavery or human trafficking in our supply chains, and
assess emergent risks, if any arise, regarding slavery and human trafficking in
our supply chains.
This statement was approved by the board of FactSet Research Systems Inc.,
FactSet Europe Limited and FactSet
UK Limited.
Phil Snow
Chief Executive Officer
Date: April 21, 2023
UK Modern Slavery Act
UK TAX STRATEGY
Financial year ending August 31, 2023
FactSet Research Systems Inc. (the “Company” or “FactSet”) is a multinational
company headquartered in Norwalk, Connecticut, United States with operations
across 23 countries. FactSet was founded in 1978 and provides integrated
financial information and analytical applications for the global investment
community.
INTRODUCTION TO FACTSET’S UK TAX STRATEGY
FactSet has substantial local operations and presence in the UK. FactSet is
committed to conduct its tax affairs in accordance with the following
objectives:
* Act as a responsible global corporate tax citizen in compliance with
applicable tax law, regulations and reporting disclosure requirements;
* Maintain an open relationship with tax authorities based on collaboration and
integrity;
* Apply diligence and care in the management of processes and procedures by
which all tax related activities are undertaken;
* Encourage ethical and transparent business practices;
* Use available incentives and reliefs while ensuring that these reliefs are
not used for purposes which are knowingly contradictory to the intent of the
legislation.
RISK MANAGEMENT AND GOVERNANCE
FactSet believes that it is important to pay the correct amount of tax at the
right time, under all relevant laws and regulations. We are committed to provide
transparent and accessible information to tax administrators in order to
facilitate an understanding of our tax strategy and the underlying business
models. We operate an effective tax control framework to identify key tax risks
and to manage those risks through appropriately designed and operated controls,
polices and processes.
TAX STRATEGY AND STRATEGIC OBJECTIVES
Generally, FactSet’s tax strategy and strategic objectives are intended to
establish a clear and unequivocal approach to all aspects of tax reporting and
compliance.
Our strategy is focused on ensuring that taxes (and tax risks) are managed to
provide outcomes consistent with commercial reality and are within the
parameters of our strategic objectives. The strategy also requires that all tax
obligations are complied with in the UK and all other relevant jurisdictions.
With the tax landscape constantly changing, FactSet’s tax affairs and tax risk
management procedures are regularly reviewed to ensure that processes and
measures are up-to-date so that we are able to identify, assess, manage and
mitigate tax risk as well as remain aligned with FactSet’s business strategy and
governance framework.
LEVEL OF ACCEPTABLE TAX RISK
We aim for certainty on the tax positions we adopt, so diligent professional
care and judgment is employed to assess tax risks arising from our commercial
operations. We seek to reduce the level of tax risk arising from operations as
far as is practically reasonable through an ongoing commitment to improving
internal control effectiveness and by ensuring that all tax or tax-related
processes are allocated to appropriately qualified owners.
FactSet’s level of acceptable risk is low, and we structure our affairs based on
sound commercial principles and in accordance with company policy and relevant
tax legislation. FactSet will consider different tax outcomes when considering
how to undertake commercially motivated transactions, but does not participate
in aggressive tax planning for the purposes of tax avoidance or engage in tax
schemes that go against the intention of the legislative authority.
APPROACH TOWARDS DEALINGS WITH HM REVENUE & CUSTOMS (“HMRC”)
It is FactSet’s general policy to be transparent and proactive in all
interactions with HMRC.
We have an open, honest and positive working relationship with HMRC. We are
committed to prompt disclosure and transparency in all tax matters with HMRC. We
recognize that there will be areas of differing legal interpretations between
ourselves and HMRC and where this occurs we will engage in proactive discussion
to bring matters to as rapid a conclusion as possible.
UK Tax Strategy
ACCOMMODATION STATEMENT
FactSet endeavors to make https://www.factset.com/careers accessible to any and
all users. If you would like to contact us regarding the accessibility of our
website or need assistance completing the application process, please contact
Kristen Panichella, Global Director, Talent Acquisition at
Recruiting2@factset.com. This contact information is for accommodation requests
only and cannot be used to inquire about the status of applications.
FactSet is an equal opportunity employer. Qualified applicants will receive
consideration for employment without regard to race, color, religion, sex,
sexual orientation, gender identity, national origin, disability or protected
veteran status. For our EEO Policy Statement, please click here. If you’d like
more information on your EEO rights under the law, please click here. For the
EEO Commission, please click here.
Accommodation Statement
AAP/EEO STATEMENT
A NOTICE AND INVITATION TO ALL EMPLOYEES AND APPLICANTS
Philip Snow, Chief Executive Officer
AFFIRMATIVE ACTION AND EQUAL EMPLOYMENT OPPORTUNITY POLICY STATEMENT
FactSet Research Systems, Inc. has been and will continue to be an equal
opportunity employer. To assure full implementation of this equal employment
policy, we will take steps to assure that:
1. Persons are recruited, hired, assigned and promoted without regard to race,
national origin, religion, age, color, sex, sexual orientation, gender
identity, disability, or protected veteran status, or any other
characteristic protected by local, state, or federal laws, rules, or
regulations.
2. All other personnel actions, such as compensation, benefits, transfers,
layoffs and recall from layoffs, access to training, education, tuition
assistance and social recreation programs are administered without regard
to race, national origin, religion, age, color, sex, sexual orientation,
gender identity, disability, or protected veteran status, or any other
characteristic protected by local, state, or federal laws, rules, or
regulations.
3. Employees and applicants shall not be subjected to harassment, intimidation,
threats, coercion or discrimination because they have: (1) filed a
complaint; (2) assisted or participated in an investigation, compliance
review, hearing or any other activity related to the administration of any
federal, state or local law requiring equal employment opportunity; (3)
opposed any act or practice made unlawful by any federal, state or local law
requiring equal opportunity or (4) exercised any other right protected by
federal, state or local law requiring equal opportunity.
I have appointed Kristen A. Panichella to take on the responsibilities of EEO
Coordinator. The EEO Coordinator will be responsible for the day to day
implementation and monitoring of the Company’s Affirmative Action Plan. As
part of that responsibility, the EEO Coordinator will periodically analyze the
Company's personnel actions and their effects to ensure compliance with our
equal employment policy and administer the audit and reporting system.
If you, as one of our employees or as an applicant for employment, have any
questions about this policy or would like to view portions of the Affirmative
Action Plan, please contact Leonard F. Johnson during regular business hours.
This is also a reminder that employees may update their disability status at any
time by contacting Kristen A. Panichella.
I have reviewed and fully endorse our Affirmative Action and Equal Employment
Opportunity program. In closing, I ask the continued assistance and support of
all of the Company's personnel to attain our objective of equal employment
opportunity for all.
Sincerely,
Philip Snow
Chief Executive Officer
AAP/EEO Statement
EXTERNAL REFERRAL AWARD PROGRAM TERMS AND CONDITIONS
FactSet Research Systems Inc.’s External Referral Award Program (the “Program”)
offers a one-time referral award to unaffiliated persons to help FactSet attract
top talent at our offices located throughout the United States. To make a
referral or learn more about the Program, please visit our External Referral
Award Program webpage . Referrals are valid for 12 months from the date of
submittal.
Please read the below carefully. By submitting a resume via email, You (as
defined below) agree to the following terms and conditions:
External Referrer (“You” or “Your”):
* Must be an individual person (i.e. not a business entity) who is at least 18
years of age and a legal resident of the United States in which you reside
* Can’t be associated with or a consultant of a staffing or recruiting agency
* Can’t be a current FactSet employee
* Can’t refer yourself
Your Referral Candidate:
* Can’t be a previous employee or current or former contractor for FactSet
* Can’t be previously referred by a current FactSet employee
* Can’t have already applied for the same position at FactSet on their own
If our team feels that Your referred candidate appears to be a match to our job
requirements, we will reach out to them directly. The referred person must
acknowledge that You referred them and we will ask the Referral Candidate to
then apply directly on the Careers page of our website.
Payment Terms
If You are eligible to participate in the Program, FactSet shall pay You a
one-time referral award in the form of an electronic gift card from one of
FactSet’s preapproved retailers (“Award”) in the following (gross) amounts:
* For Associate, Senior Associate, Specialist and Senior Specialist positions:
$50 Award
* For Senior Manager/AVP Lead, Manager, SVP or VP positions: $100 Award
FactSet will process the Award approximately 8-10 weeks after the referred
employee is successfully hired and is actively employed by FactSet at the time
the Award is to be paid. You are solely responsible for any appropriate state
and federal taxes associated with the receipt of the Award.
In the event of a duplicate or competing submission of a referral candidate,
payment will be made for the first referral candidate received by FactSet. Any
Award payment is at FactSet’s sole discretion.
Recruiters and Placement Agencies
FactSet does not accept unsolicited resumes from recruiters or placement
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Additional Information
1. You may refer as many qualified referral candidates as You want, but the
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5. Please email referrals@factset.com with any questions.
External Referral Award Program Terms and Conditions
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Cookie Policy
FACTSET RESEARCH SYSTEMS INC. SUPPLY CHAIN CODE OF CONDUCT
At FactSet Research Systems Inc. (inclusive of all of its subsidiaries,
“FactSet”), we are guided by our values. All of our employees, officers and
directors commit to a Code of Business Conduct and Ethics that embodies our
fundamental principles of ethical and legal conduct. In keeping with our values,
we expect all of our global suppliers (“Suppliers”) and their respective supply
chains to uphold similar standards of ethics and conduct and to act in
accordance with this FactSet Supply Chain Code of Conduct (the “Code”).
This Code outlines the minimum standards that all of our Suppliers are expected
to adhere to. All Suppliers are expected to conduct their business activities in
full compliance with all applicable laws, rules and regulations. This Code is
not and should not be interpreted to circumvent or undermine any applicable
laws, rules, or regulations. Any Supplier who is unable to comply with this Code
should immediately notify FactSet. Failure to comply with this Code may result
in FactSet taking specific action, including but not limited to the
disqualification of future opportunities and the withdrawal of business.
FACTSET’S CORE SOURCING PRINCIPLES
We consider the following factors when selecting our Suppliers:
* High quality products and services that fit our business needs;
* Best value, meeting our financial requirements without compromising on
quality or customer service;
* Successful completion of our data security assessment and architecture
review;
* Legal compliance and contractual terms in line with FactSet’s standards and
all applicable laws and regulations; and
* Business practices consistent with applicable laws, rules and regulations,
this Code, and whenever practicable, FactSet’s environmental, social and
governance philosophies.
ETHICAL BUSINESS PRACTICES
FactSet seeks to excel while operating honestly and ethically, never through
taking unfair advantage of others. FactSet prohibits fraudulent or corrupt
business practices and any conduct of a suspicious, unethical, or illegal
nature. Suppliers shall ensure their senior management oversees, monitors, flows
down and implements policies, procedures, and guidelines to ensure compliance
with law and demonstrate a commitment to business ethics, social justice,
environmental and climate action, and strong corporate governance. FactSet
suppliers shall work to ensure accountability, transparency, fairness, and
responsibility for internal and external stakeholders and other affected or
interested parties.
Our Suppliers must be transparent in their business dealings and timely in
regulatory reporting. Suppliers may not engage in bribery, corruption,
embezzlement, extortion, or other illegitimate and unethical business practices.
Suppliers must comply with all applicable laws relating to anti-corruption and
anti-bribery. Suppliers must avoid unlawful agreements or arrangements with
their competitors and comply with applicable fair competition laws. FactSet will
not support, facilitate, or condone money laundering, tax evasion or any other
illegal conduct by Suppliers and will assist governmental authorities, where
appropriate, in preventing illegal activities involving FactSet.
HUMAN RIGHTS/WORKERS’ RIGHTS AND DIVERSITY
FactSet believes in the fundamental responsibility to respect international
human rights standards (see our Human Rights Policy). FactSet expects its
Suppliers to share its commitment to human rights and equal opportunity in the
workplace. Suppliers must commit to upholding the human rights of their workers
in accordance with this Code, the principles and guidelines of the International
Labor Organization and the United Nations, and in accordance with all applicable
laws and regulations.
Suppliers must ensure that all of their employees have chosen their employment
freely without duress. Their employees must work in safe, healthy and humane
working conditions. Employees must be provided with fair wages and benefits
relative to the market, and none of our Suppliers should expect their employees
to exceed fair working hours as designated by applicable local and international
law. Suppliers shall respect the right of freedom of association of their
employees and the right to collective bargaining.
All of our Suppliers must ensure that they do not have within any part of their
own operations or their supply-chain any form of child labor or human rights
violations. FactSet is committed to ensuring there is no modern slavery or human
trafficking in our supply chains or in any part of our business and FactSet will
not knowingly support or conduct business with any organization involved in
slavery or human trafficking (see our Modern Slavery Act Statement).
Suppliers must be committed to a workforce free of harassment and
discrimination. We expect our Suppliers to take diversity and inclusion in their
workplaces seriously and demonstrate a commitment to equality of opportunity for
individuals and groups, with no tolerance for discrimination or workplace
harassment. We urge our Suppliers to recruit, hire, develop, promote and
discipline employees without regard to race, sex, color, religion, gender,
gender identity or expression, sexual orientation, age, national origin,
citizenship, marital status, pregnancy, disability, or veteran status, providing
reasonable accommodations where necessary to ensure fairness and
non-discrimination.
ENVIRONMENT AND SUSTAINABILITY
FactSet recognizes its social responsibility to protect the environment and
operate its business sustainably. FactSet expects its Suppliers to adhere to
responsible environmental management and to operate their business in compliance
with applicable environmental laws and regulations. Suppliers should strive to
minimize negative environmental impact as far as is practical and possible. We
urge our Suppliers to target reductions in their carbon footprints, reduce their
levels of waste and where possible incorporate reduction, re-use and recycling
measures in their business operations.
THIRD PARTY INTELLECTUAL PROPERTY, PROPRIETARY AND PRIVACY RIGHTS
FactSet respects the intellectual property, proprietary and privacy rights of
third parties and expects its Suppliers to do the same. Any Supplier given
access to FactSet data, including confidential, sensitive, proprietary data or
personal information of FactSet employees, clients, business partners or others,
must carefully safeguard and protect that data from unauthorized disclosure.
When Suppliers are properly given the right to use such assets, they must use
them responsibly. Suppliers must respect the privacy of their customers,
employees, and other data subjects, and comply with all applicable privacy laws
and regulations.
MONITORING COMPLIANCE AND REPORTING CONCERNS
Suppliers are expected to self-monitor their compliance with this Code while
conducting business and to have appropriate internal controls and management
systems in place. FactSet may request reasonable audits or information to
confirm compliance with this Code by our Suppliers. If you are aware or
concerned that someone has violated this Code, please report your concern to our
Chief Compliance Officer at dataprivacy@factset.com or anonymously through the
FactSet Ethics Action Line at https://FactSetEthicsActionline.com. Reports will
be kept confidential to the fullest extent possible, consistent with law and the
need to conduct an adequate review. FactSet prohibits retaliation against any
individual or company for having made a complaint in good faith, regardless of
whether the complaint is ultimately substantiated.
Supply Chain Code of Conduct
FACTSET RESEARCH SYSTEMS INC.GLOBAL PROCUREMENT DIVERSITY POLICY
FactSet Research Systems Inc. and its subsidiaries (“FactSet” or the “Company”)
have adopted the following Global Procurement Diversity Policy (“Policy”).
I. FACTSET’S POLICY
FactSet is committed to developing mutually beneficial business relationships
with a variety of suppliers, including minority-owned, women-owned,
disability-owned, veteran-owned and/or LGBTQ+-owned business enterprises
(“Diverse Suppliers”). The primary goal of this policy and FactSet’s Supplier
Diversity Program is to provide greater access and opportunities to those
diverse suppliers that meet the Company’s procurement and contractual standards.
FactSet employees are encouraged to proactively identify and include Diverse
Suppliers in the procurement process. Those that are competitively priced, that
offer high-quality goods and services, and that satisfy our procurement and
contractual standards should be included in our sourcing and procurement
process. This policy reflects the Company’s desire to create an opportunity for
Diverse Suppliers to market their products and services to FactSet and to
encourage FactSet employees to offer opportunities to such suppliers.
II. APPLICATION OF THE POLICY
The Policy applies to all transactions to procure goods or services to which
FactSet is a party, regardless of whether they have been drafted by FactSet or a
third party, and provides socially- and economically-disadvantaged businesses
with an equitable opportunity to compete as a supplier in acquisitions of goods
and services conducted in bidding procedures, as referenced in the Global
Procurement and Contracting Policy, to the extent that the opportunity is
consistent with contract performance.
III. POLICY
1. FactSet encourages the use of Diverse Suppliers, including those with the
designations noted in “Definitions” (see Appendix), for product and service
purchases, provided that such suppliers demonstrate the ability to meet
FactSet’s Contract requirements.
2. Supplier Diversity. The Procurement function’s Supplier Diversity department
will work in conjunction with key stakeholders to promote the participation
of Diverse Suppliers in FactSet’s procurement process. Such coordinated
activities include, but are not limited to:
1. Attend, participate or support supplier events that to engage with and
encourage participation with Diverse Suppliers;
2. Educate Diverse Suppliers about the competitive bidding process and
opportunities for obtaining Contracts;
3. Promote consideration of Diverse Suppliers in the purchasing process;
4. Ensure organization has access to supplier diversity classifications for
competitive bidding process;
5. Work with key stakeholders to prioritize spend categories, develop and
publish diversity spend targets;
6. Seek out certified Diverse Suppliers that can provide competitive,
high-quality goods and services;
7. Communicate the value of supplier diversity both internally and externally
to all stakeholders; and
8. Report supplier diversity data/information as required and to the extent
permissible under applicable laws.
To ensure equity and fairness, the formal competitive bidding process, as
outlined in the Global Procurement and Contracting Policy, should include the
consideration of Diverse Suppliers. Requisitioner shall consult with an
appropriate Procurement representative to identify diverse supplier(s) for the
required spend category. Procurement representatives may consult Workday to
identify Diverse Suppliers with the noted diversity tags, as defined in the
“Key Terms and Definitions” (see Appendix).
IV. RELATED POLICIES AND PROCEDURES
Supply Chain Code of Conduct
Global Procurement and Contracting Policy
Code of Business Conduct and Ethics
V. GUIDANCE AND ASSISTANCE
For questions regarding Workday, the workflow, or the approval hierarchy,
contact the Senior Vice President of Finance, Procurement and Operations.
For questions regarding identification of diverse suppliers, contact the
Supplier Programs and Projects Manager.
For questions regarding applicability of Purchase Orders, Bilateral Contracts,
or the acceptability of vendor-provided purchase orders, Contracts, or terms,
contact any member of the Legal Department.
APPENDIX
KEY TERMS AND DEFINITIONS
Contract - A legally binding and enforceable agreement between two or more
parties stating the terms and conditions for an exchange of something of value
(e.g., money, goods, or services) between the parties. A contract can be
established by a written document, including email, letters, purchase orders and
order confirmations. A contract can also be established by an oral agreement or
a combination of oral agreements and written documents. A contract can also be
established by the conduct of the parties.
Diversity - Diversity encompasses the range of similarities and differences
everyone brings to the workplace, including but not limited to national
origin, language, race, color, disability, ethnicity, gender, age, religion,
sexual orientation, gender identity, socioeconomic status, veteran status, and
family structures.
Supplier Diversity - Supplier Diversity programs provide minority, women and
what has since been classified as under-utilized small business owners, an
opportunity to secure Contracts with government agencies, major companies, and
corporations as qualified-small business suppliers.
Minority Business Enterprise (MBE) - Minority group members are United States
citizens who self-identify as Asian-Indian, Asian-Pacific, Black, Hispanic, and
Native American. Ownership by minority individuals means the business is at
least 51 percent owned by such individuals or, in the case of a publicly-owned
business, at least 51% of the stock is owned by one or more such individuals
(i.e. the management and daily operations are controlled by those minority group
members).
Woman Business Enterprise (WBE) – At least 51 percent owned, controlled,
operated, and managed by a woman or women. This means one or more women must
have unrestricted control of the business, a demonstrated management of
day-to-day operations, and a proportionate investment of capital or expertise.
8(a) Economically Disadvantaged Small Business - Be at least 51 percent owned
and controlled by U.S. citizens who are economically and socially disadvantaged.
Have a personal net worth of $750 thousand or less, adjusted gross income of
$350 thousand or less, and assets totaling $6 million or less. Owner manages
day-to-day operations and also makes strategic policy of the business.
Veteran-Owned Business Enterprise (VBE) - At least 51 percent owned, controlled
operated, and managed by a veteran or veterans. The veteran or veterans must
have full control over the day-to-day management, decision-making, and strategic
policy of the business.
Veteran-Disability Owned Business Enterprise (V-DOBE) - At least 51 percent
owned, controlled, operated, and managed by a veteran, but disability was not
incurred during their time of service. The veteran or veterans must have full
control over the day-to-day management, decision-making, and strategic policy of
the business.
Service-Disabled Veteran-Owned Small Business (SDV-DOBE) - At least 51 percent
owned and controlled by one or more service-disabled veterans. One or more
service-disabled veterans manage day-to-day operations and make strategic policy
of the business. Eligible veterans must have sustained their disability during
their time of service.
Historically Underutilized Business Zone (HUBZone) - Be at least 51 percent
owned and controlled by U.S. citizens, a Community Development Corporation, an
agricultural cooperative, an Alaska Native corporation, a Native Hawaiian
organization, or an Indian tribe. Have its principal office located in a
HUBZone. have at least 35% of its employees living in a HUBZone.
Disabled-Owned Business Enterprise (DOBE) – At least 51 percent owned,
controlled, operated, and managed by a person or persons with a disability. The
person or persons must have full control over the day-to-day management,
decision-making, and strategic policy of the business.
LGBT Business Enterprise (LGBTBE) - At least 51 percent owned, operated,
managed, and controlled by an LGBT person or persons who are either U.S.
citizens or lawful permanent residents.
Requisition - A request to purchase goods or services. The Requisition must
include all data, specifications, and information necessary for the accurate
identification of the requested good or service, as well as the required
delivery date and location for delivery.
Requisitioner - Any FactSet employee who requests procurement of a good or
service via the requisition function in Workday.
Supplier Diversity Policy
THE FEDERAL TRANSPARENCY IN COVERAGE RULE
This link leads to the machine readable files that are made available in
response to the federal Transparency in Coverage Rule and includes negotiated
service rates and out-of-network allowed- amounts between health plans and
healthcare providers. The machine-readable files are formatted to allow
researchers, regulators, and application developers to more easily access and
analyze data.
http://www.ticmrf.com/13-3362547
The Federal Transparency in Coverage Rule
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