Business ethics Our business ethics program permeates all our lines of business, corporate functions and operational groups. Our culture emphasizes legal and regulatory compliance, issue identification and escalation, and remediation. For us, adherence to law, accounting and ethical standards is a prerequisite to doing business and meeting stakeholder expectations. We recognize the importance of adhering to regulations and diligently accounting for the expectations of our stakeholders as part of our business strategy. Ensuring the reliability of our business and reducing reputational risk — across all dimensions — requires a steadfast commitment to ethical behavior. At TransUnion, we assert our enterprise commitment to business ethics in our Code of Business Conduct and related policies, all of which are available in the appendix of this report. Our culture emphasizes good judgment, highlighting potential areas of concern to management, and treating all TransUnion’s stakeholders in a transparent and fair manner. To accomplish this, we regularly discuss our corporate values, our ® focus on ethical behavior and what it means to use Information for Good . More concretely, all associates (including full-time and part-time) receive annual workplace ethics training and must attest to following our Code of Business Conduct and associated policies annually. We also maintain a robust Global Anti-Fraud Program comprised of an effective system of internal controls designed to prevent, detect and respond to internal fraud. The responsibility to mitigate internal fraud risk is collaboratively addressed by multiple stakeholders across our business — which includes identifying relevant internal fraud schemes, using standardized tools and trainings, partnering with pertinent departments, surveying the operating environment, documenting the mitigation measures, and developing plans to improve these measures. Reporting ethics issues ® Through our SpeakUp program, TransUnion associates are encouraged to report potential ethical issues through a variety of channels, including directly to their respective managers, a Code of Business Conduct Officer, or any member of the legal, compliance or human resources teams. TransUnion also maintains an ethics hotline for associates, affiliated partners and the general public to report (in a secure and anonymous manner) any suspected illegal, unethical or unsafe business conduct. Once an individual reports a concern through the hotline, the complaint is forwarded to the appropriate internal group to review and address. Regardless of the method used, associates who report an issue are protected from retaliation in any form. SECURITY, GOVERNANCE & COMPLIANCE TRANSUNION | 2021 SUSTAINABILITY REPORT 19
