At Experian, our purpose is to give our customers the power to assess, predict and to plan so you may achieve your goals and navigate your world with confidence. To do so, we need to take a long-term view. Listening and responding to stakeholder issues or concerns is critical to achieving this and to delivering on our brand promise. We strive to maintain open and constructive relationships with a wide range of stakeholders including regulators, lawmakers, clients, investors, civil society and community groups to help us operate as a responsible and sustainable business. This helps inform our business strategy and build sound relationships in the markets where we operate. The engagement with policymakers and other stakeholders is overseen by senior management and involves various functions at Group, regional and country levels, and members of senior management also engage with policymakers regularly.
On a day-to-day basis, our Government Affairs, Legal and Compliance functions are responsible for identifying changes to regulation, ensuring that we comply with all requirements, and helping to manage relationships with policymakers. Responsibility for our public policy engagement rests with the Head of Government Affairs for the UK & Ireland and EMEA and Head of Compliance.
Our UK & Ireland Executive Committee has oversight of Experian’s approach to government and regulatory relations. The Executive Committee is comprised of the leadership of the business who have a wealth of experience in geopolitical matters.
We have strict governance procedures in place across the Group, and expect high standards of conduct and behaviour from all our staff, directors and contractors in dealing with political stakeholders. This is outlined in our code of conduct which is accessible to all employees. All our staff also complete a range of training on joining Experian and recertify many of these yearly to highlight the importance of observing and delivering high standards of conduct and behaviour. Modules include training of bribery and corruption and data protection.
We are committed to ethical behaviour, integrity and responsibility in all our activities. Our internal policies and procedures for public policy activities are designed to meet these values and the laws, norms and stakeholder expectations for integrity and ethical behaviour across our markets. This also ensures that our public policy activities are carried out consistently across our Group and third parties acting on our behalf.
We engage with relevant authorities to play our part in supporting the effective functioning of the data environment and financial services ecosystem. We are committed to complying with all legislation, rules and other regulatory requirements applicable to our businesses in the jurisdictions within which we operate. Our compliance with legal and regulatory frameworks across our markets ensures that the Group meets its obligations. In turn, this supports the resilience and effective functioning of the Group and the broader consumer and financial economy. As an organisation, we are committed to ethical behaviour, integrity and responsibility in our engagement with policymakers. Upholding ethical standards is a priority for the Experian Group and is set out in further detail on page 34 of our Annual Report.
Our active engagement with governments, regulators and policymakers enables us to share insights and technical expertise on key public policy issues. This engagement supports the development of best practice and the adoption of consistent approaches across our markets. We are committed to engaging with governments and regulators in a transparent way, and do so through a variety of channels, including through ongoing dialogue, submission of responses to formal consultations and by joining and participating in industry working groups. In 2017, we engaged with policymakers at all levels on topics such as the General Data Protection Regulation (GDPR), consumer credit policy changes, consumer law changes and financial services regulatory changes.
We are currently engaging with government, regulators and policymakers regarding the future of Credit Information and the opportunities presented by Artificial Intelligence and Machine Learning. As part of this engagement we have produced two documents that set out our views in these areas.
Our Credit Information white paper describes our vision for the future of credit information. Our aim is to create a future-proof credit ecosystem that’s personalised, fair, transparent, understandable and that has the consumer at its heart. You can find the document here.
In our Artificial Intelligence and Machine Learning white paper we set out why Experian believes that Artificial Intelligence and Machine Learning can bring very important benefits to a more inclusive financial services sector. They can deliver more insightful decisions by lenders, more insights and control for consumers, a better interaction with vulnerable consumers, and more people accessing affordable credit than ever before. You can find the document here.
We periodically respond to consultations on matters that impact our business and the markets in which we operate. Below, we publish our consultation responses on regulations impacting our business (or executive summaries for those containing commercially sensitive information) on a quarterly basis. Individual country responses specific to that country are not necessarily included. Copies of our responses are also often made available by the relevant authority on their website. Experian plc has signed up to the EU transparency register which is operated jointly by the European Parliament and the European Commission and discloses our key interests related to EU policy-making (e.g. GDPR, Payment Services Directive II, Retail Financial Services, ePrivacy, Consumer Credit Directive). As with all other signatories, it also includes an estimate of the annual cost of activities covered by the register which is a demonstration of our political spend.
Experian Responded to the Consultation on Breathing Space – the response is commercially sensitive however we are able to share that we support the initiative and are continuing to work with HM Treasury to understand the best method of reflecting a period of breathing space on a consumers credit file.
Experian responded to the consultation on the Centre for Data Ethics and Innovation – the response is commercially sensitive, however we are able to share that we support the creation of the Centre and believes it can play a key role in educating the public on the positive uses of data and in helping business and regulators work together to achieve common goals and standards. The UK has made great strides and we hope the Centre recognises the positives that have come from the increasing use of data, Artificial Intelligence and Machine Learning.
Experian supports the creation of the Geospatial Commission and the release of more Government held geospatial data. We believe that the Commission has a key role to play in explaining to a wider audience that geospatial data is not new and unknown data, but rather it is something that has been used for decades. View our response here.
Experian responded to the Gambling Commission consultation on proposals to strengthen age and identity verification for online gambling – Experian believes that technology has been proven to adequately, and quickly, verify customer’s details prior to accessing any age restricted products. Therefore, operators of age restricted games should validate identity and age prior to accessing any games.
Digital Competition Expert Panel: the response is commercially sensitive however, we are able to share that Experian believes that digital markets have led to increased innovation and competition which benefits consumers and that technologies such as AI and Machine Learning can be beneficial to both consumers and competition.
Pensions Dashboard: we are able to share that Experian supports the creation of the Pensions Dashboard and welcome the Government’s proposed approach to governing its creation and use.
Centre for Data Ethics and Innovation Bias in Algorithmic Decision Making: the response is commercially sensitive, however we are able to share that Experian recognises that the public may have concerns about the way algorithms are used and believe that transparency is key when seeking to engage with people.
Corporate Transparency and Register Reform: the response is commercially sensitive, however, we are able to share that Experian supports the Governments proposals for greater checks on the identity of company directors and the information stored in Companies House should be as accurate and up to date as possible.
Smart Data Consultation: the response is commercially sensitive however, Experian welcomes the work the Government is undertaking to harness the potential of smart data and urge them to focus on the important issue of data literacy and provide help to those who lack digital skills to ensure that no group in society is left behind.
Ofgem Consumer Vulnerability Strategy 2025: we are not able to share our response but can share that it relates to data processes and how these can be used to help the industry support consumers with vulnerabilities.
Digital Identity Consultation: we are not able to share our response but can share that we are supportive of the Government’s proposals and how the Government can help those ‘thin file’ consumers by digitising their own data assets.
Experian’s engagement with policymakers is conducted directly by its staff and through industry associations. We retain the services of a public affairs consultancy (Pagefield) to represent Experian’s interests alongside our UK & Ireland Government Affairs team. All representation of Experian to policy makers or expenditure on public affairs related activity is subject to prior approval and sign off by the Head of Government and Public Affairs. Experian requires parties acting alongside and for our Government and Public Affairs team to adhere to the same requirements of good ethical and transparent practice in their activities.
We recognise the need to deal with policymakers and politically-exposed persons in an appropriate and transparent way given the influence they may have over laws and regulations of material interest to Experian. As such, we have policies in place to guide staff on how to engage with such parties and staff are required to undergo training, to ensure that our engagement with policymakers is ethical and responsible.
Experian does not employ the services of serving politicians for advocacy or political engagement on behalf of the organisation. Experian operates in a regulated sector and its senior staff and individuals in roles of significant influence are subject to scrutiny and approval by the FCA.
Experian are members of a small number of trade associations relating to our public policy work. Our current memberships are listed below:
Association of Consumer Credit Information Supplier (https://accis.eu/).
As noted in the 2018 Annual Report (page 100), Experian did not make any political donations during the year ended 31 March 2018.
Experian implements a full revolving door policy which prevents against the occurrence of conflicts of interest from ex-Governmental employees. Clauses are added into employment contracts which seek to mitigate against any conflict of interest from occurring. This is managed via the Human Resources department. Experian currently does not employ ex-politicians within its Government Affairs function.
Experian commits to uphold Responsible Political Activities (RPA) Guidelines in our public policy activities: Responsibility in political activities is based on values of integrity, legitimacy, materiality, accountability and oversight, consistency and transparency.
Integrity: Experian is committed to ethical behaviour, integrity and responsibility in its political activities. Our policies and procedures for political activities are designed to meet these values and the laws, norms and stakeholder expectations for integrity and ethical behaviour.
Legitimacy: Experian’s political activities meet legitimate business objectives, serve the interests of the company and comply with laws. Stakeholders view the company as having a valid voice, expertise and contribution to make to the political process and that Experian’s political activities address their material interests and the company’s impact on society.
Accountability and oversight: The Board of Experian is accountable to shareholders and other stakeholders for the company’s political activities. The Board sets the guiding principles and scope for political activities, agrees the objectives and strategy, provides direction and guidance to management and receives reports on the implementation of the policies and procedures for political activities.
Consistency: Experian carries out its political activities consistent with its values, guiding principles, policies and procedures. Experian ensures that its political activities are carried out consistently across its corporate group and third parties acting on its behalf.
Transparency: Experian aims to be open about the guiding principles, objectives, policies and procedures of its political activities and reports regularly to stakeholders on activities, performance and expenditures (subject to contractual constraint). Material information is comprehensively made public where possible and aims to be easily accessible.