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GLOBAL POLICYREGARDING HUMAN RIGHTSAND MODERN SLAVERY
JUNE 2022

GLOBAL POLICYREGARDING HUMAN RIGHTSAND MODERN SLAVERY
Take-Two Interactive Software, Inc. (“Take-Two”) is a leading developer, publisher, andmarketer of interactive entertainment for consumers around the globe. We develop
and publish products principally through our labels Rockstar Games, 2K, Private Divisionand Social Point.
1.

Our Commitment

In our business operations throughout the world, Take-Two is committed to conducting business fairly and ethically,
complying with all applicable laws and regulations, and promoting a work environment that values honesty, openness,integrity, and respect for others. Moreover, we promote respect for the fundamental freedoms articulated in the United
Nations’ Universal Declaration of Human Rights, and seek to combat the abuses of modern slavery such as forced andcompulsory labour and human trafficking that exist in both developed and developing economies across a multitude ofbusiness sectors.
We have no tolerance for human rights abuses, nor for any form of modern slavery, either in our organization, or in
our supply chains.

2.

Our Policies and Practices

To ensure that human rights are respected, and that modern slavery has no role in our business or supply chains,
we take the following actions:

Our Hiring and Employment Practicesn	Our employee recruitment processes globally are robust and in line with all applicable employment laws andregulations. We conduct “right to work” document checks and ensure all employees are 16 years of age or older.
n	Compensation and other rewards are in compliance with all applicable laws and regulations including minimum

wage and holiday entitlement laws. They are competitive with the relevant market, and are reviewed annually.
All employment is freely chosen, and employees are free to resign their positions at any time.
n	We offer a generous benefits package, with additional health and welfare options to support our employees’(and their families’) lifestyle choices.		

TAKE-TWO INTERACTIVE SOFTWARE, INC. n 110 W 44th Street n New York, NY 10036 n (646) 536-2842 n www.take2games.com

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GLOBAL POLICYREGARDING HUMAN RIGHTSAND MODERN SLAVERYJUNE 2022n	Employment at any of our locations around the world is dependent upon substantive ability, talent and work ethic,

not an individual’s race, color, religion, creed, sex or gender, age, national origin or ancestry, physical or mental
disability, pregnancy, sexual orientation, gender identity, marital status, veteran status, genetic information, or theircharacteristics protected by any applicable law. Our commitment to equal employment opportunity applies to all
aspects of the employment relationship, from recruitment and hiring through compensation, benefits, discipline
and termination.

Our Global Code of Business Conduct and Ethics
Our Global Code of Business Conduct and Ethics (the “Code”) reflects Take-Two’s core values and demonstrates
our commitment to conducting business fairly and ethically and promoting a work environment that values honesty,
openness, integrity, and respect for fundamental human rights. The Code applies to all directors, officers, employees,consultants, contractors and agents who do business on behalf of the Company, wherever located.
As our Code highlights, we are committed to ensuring that none of the products we develop, have manufactured orsell, including promotional materials, are made using child labor, prison labor, or are in violation of any law prohibiting
modern slavery or human trafficking.
We also have a supplier-facing Code of Business Conduct and Ethics (the “Supplier Code”) based on these sameprinciples. Suppliers, vendors, business partners, and other third parties we engage are held to the same standards as
are Take-Two’s own personnel.

The Code Reflects Our Culturen	The Code sets out our commitment to ethical business practices, and provides a guide to ethical decision-making.

It strictly prohibits any form of illegal discrimination or harassment in the Company, and encourages and promotes
equal opportunities for all employees.

The Code Mandates Reporting Any Knowledge or Suspicion of
Human Rights Abuses, Slavery, or any other Violation of Law or Our Coden	The Code requires employees to report any actual or suspected violations of applicable laws, regulations, andthe Code. It sets out a clear process, and several different options, for reporting any such violations, including
a telephone number of an independent third-party with whom employees—or anyone with knowledge of aviolation—can make a confidential report. The Code also designates certain senior individuals within the Internal
Audit and Legal departments to receive such reports.
n	The Code also makes clear that anyone who, in good faith, reports any actual or suspected violation of applicablelaw, regulation or the Code will not be subject to any disciplinary, retaliatory or adverse employment action ofany kind.

TAKE-TWO INTERACTIVE SOFTWARE, INC. n 110 W 44th Street n New York, NY 10036 n (646) 536-2842 n www.take2games.comPAGE 3 / 3
GLOBAL POLICYREGARDING HUMAN RIGHTSAND MODERN SLAVERY
JUNE 2022

We Regularly Train Our Employees and Certain ThirdParties to Promote Compliance with Our Coden	Upon joining Take-Two or any of our affiliates, our employees receive training regarding the requirements of ourCode, where to turn with any questions and for advice, and how to report any suspected violations, including
the option, where legally permissible, of using the confidential reporting hotline. We aim to refresh this training,frequently in person, biennially.
n	In addition, we provide training regarding our Supplier Code to certain of our consultants and third-party agentsand suppliers, to ensure their understanding of and compliance with its standards.

Best Practices in Our Supply Chains
We work with and rely on a number of suppliers to carry out our business activities.
Our supply chain is primarily comprised of disc replicators located in the United States, Mexico, Brazil, Ireland,Germany, Austria, China and Japan, printers, shipping and logistics providers, advertising agencies, and software
licensors. From time to time, we also contract with third parties to develop and manufacture promotional items that areused to market our games.		
n	As set out in our Code and Supplier Code, we seek to guard against any child labor, slave labor, prison labor,
modern slavery or human trafficking in any part of our business, including in our supply chains. We expect oursuppliers to uphold the same core values and standards that we set for ourselves.
n	Where appropriate, when contracting with third parties, we seek to obtain from those third parties, and from any

applicable subcontractors, a representation that they will respect human rights, and not use any child labor, slavelabor, prison labor, or engage in any modern slavery or human trafficking in the performance of their services.
n	Our key replicators and suppliers have adopted their own human rights policies denouncing modern slavery andhuman rights abuses of any kind in their operations or in those of their suppliers. They also commit to conducting
periodic internal and/or independent third-party audits and re-audits of their supply chains to ensure compliancewith robust labor, employment, health, and safety standards, and to determine areas for improvement.

TAKE-TWO INTERACTIVE SOFTWARE, INC. n 110 W 44th Street n New York, NY 10036 n (646) 536-2842 n www.take2games.com