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POLICY FORREPORTING MISCONDUCTJUNE 2022

POLICY FORREPORTING MISCONDUCTViolations of Applicable Law, Regulation,or Company Policy Must be Reported

1.	All persons acting on behalf of Take-Two Interactive Software, Inc. and its wholly owned subsidiaries and affiliates(collectively, the “Company”) must act in compliance with all applicable laws, regulations, and the Global Code ofBusiness Conduct and Ethics (“Code”). Such persons, which include employees, consultants, agents, and others, mustalso promptly report any actual or suspected violations of applicable laws, regulations, the Code (including, in particular,violations involving fraud, embezzlement and kickbacks involving the Company), the Company’s accounting practices(including record-keeping, internal controls, auditing, and the Company’s disclosure practices) in accordance with theprocedures set forth below.
Violations may be reported in any of the following ways:		n	In person or by phone to your immediate supervisor, any member of the Legal Department,or any Human Resources Representative;		

n

In person or by phone to the Company’s Chief Legal Officer or the Head of Internal Audit;		

nIn person or by phone to any member of the Company’s Board of Directors;		

n	Online at take2.ethicspoint.com, or by calling the designated Ethics Point Hotline number listed in the table on

the following page. The telephone hotline is staffed 24 hours a day, seven days a week, by a communications
specialist employed by an outside company. You may report anonymously in countries where that is permitted
under local law. However, the Company encourages you to identify yourself to give the Company the best
opportunity to verify the report and to conduct a meaningful investigation into the matters raised.
A report of an actual or suspected violation should be as specific and detailed as possible to allow for proper andcomplete assessment and remediation. Confidentiality will be maintained to the fullest extent possible, consistent with
the need to conduct an adequate review and address any violations.
All complaints will be investigated promptly and with discretion. At the conclusion of an investigation, remedial and/or disciplinary action will be taken as appropriate.
Any supervisory personnel who receive a report must immediately advise the Company’s Chief Legal Officer by phone orin person, or if not possible or practicable, another member of the Legal Department. Complaints relating to Accounting
Matters will be reviewed with Audit Committee direction and oversight by the Chief Legal Officer, head of Internal Audit, orsuch other persons as the Audit Committee determines to be appropriate.

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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POLICY FORREPORTING MISCONDUCTJUNE 2022

No disciplinary, retaliatory or adverse action of any kind will be taken against any person who in good faith reports anactual or suspected violation of applicable law, regulation, or the Code, regardless of whether such violation is ultimately
determined to have occurred. No Company Employee or other Covered Individual may interfere or impede in another
employee’s making a report under this Policy, consistent with relevant law, including Section 806 of the Sarbanes-Oxley
Act or Section 922 of the Dodd-Frank Act.
Although the company encourages internal reporting of potential violations of law or regulation, nothing in thisPolicy, or in any other Company policy or pronouncement, should be construed to prevent you from reporting possible
violations of law or regulation to an appropriate governmental agency or governmental entity, making other disclosuresprotected under any whistleblower provisions provided by law or regulation, or requiring any pre-clearance from theCompany to make such a report or disclosure.

ETHICS POINT HOTLINELOCATION

TOLL-FREE NUMBER

Australia

1-800-76-9163

Canada1-866-404-7401

China

400-888-0493

Czech Republic

800-144-264

France0800-91-8607

Germany

0-800-225-5288, then when prompted, dial 866-404-7401

Hungary

06-800-011-11, then when prompted, dial 866-404-7401

India

000-117, then when prompted, dial 866-404-7401

Ireland

1-800-903-228Japan

00531-11-0445 (KDD)
0066-33-830675 (Softbank)0034-800-600326 (NTT)		

Netherlands

0800-022-9111, then when prompted, dial 866-404-7401

New Zealand

000-911, then when prompted, dial 866-404-7401

Serbia0-800-800825

Singapore

800-110-2216

South Korea

00308-13-3058

Spain

900-99-0011, then when prompted, dial 866-404-7401

Switzerland

0-800-890011, then when prompted, dial 866-404-7401

Taiwan00-801-102-880, then when prompted, dial 866-404-7401

United Kingdom

0808-234-0382

United States

1-866-404-7401

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