CODE OF CONDUCTThis Code of Conduct describes the standards of conduct expected of everyone atBuzzFeed. This Code applies to everyone at BuzzFeed throughout the world, including
board members and all employees in all positions. Each BuzzFeed affiliate, worldwide,
has adopted this Code, and imposes it directly on its own employees (“BuzzFeed,” asused in the Code, means each BuzzFeed affiliate employer). Because this Codeaddresses minimum business standards, it also applies to third parties that perform workfor BuzzFeed, including contractors, consultants, partners and agents, in relation to theirwork for BuzzFeed.
BUZZFEED’S MISSION AND HOW THIS CODE OF CONDUCT APPLIES TO OURMISSION
BuzzFeed’s mission is to impact culture at massive scale by spreading truth, joy andcreativity. BuzzFeed was born on the Internet, and is committed to making it a force forgood. We strive to create content that has a positive impact on people’s actual lives andthe world. We measure our long­ term success by our scale multiplied by that impact.
Equally important is that we balance the ideals of growth with integrity. We engage inethical and intentional decision-making to honor the commitments made to ourcommunity. At the end of the day, we want to be proud of the work we do and how we
do it.
This Code sets forth the principles and responsibilities that guide how we fulfill ourmission. We follow the spirit of this Code as well as the actual words. This Code does notand cannot cover every possible ethical issue that may arise in our work. Instead, thepurpose of this Code is to clearly articulate that we care about acting ethically and withintegrity in the course of performing our work. BuzzFeed insists on a culture of inclusion,
where all will feel comfortable openly asking questions and raising concerns about any
ethical or other issues that arise.
BuzzFeed is committed to providing a safe and reliable means for BuzzFeed employees
and others to report concerns they may have about conduct at BuzzFeed. The guidelines
below explain how to raise concerns confidentially, anonymously (where appropriate)
and without fear of retaliation. If you are not comfortable discussing the concern withyour manager or HR Business Partner, you are encouraged to use the Company’s
ethics helpline, hosted by a third-party provider, where you can report your concern:
Ethics Helpline URL: buzzfeed.allvoices.co.

GUIDING PRINCIPLES
We are transparent and honest. We conduct all aspects of our business activities withintegrity and according to the highest ethical standards. We communicate in an honest
and transparent way and avoid making misleading communications or creating false
impressions. If we make mistakes, we acknowledge and correct them.
We treat others fairly, respectfully and with dignity. We foster a respectful work
environment free of any form of discrimination, harassment and intimidation, and whereeveryone can bring their whole self to work. We provide equal opportunity in all aspectsof employment. We respect diversity and we value differences. As expressed in ourAnti-Harassment Policy, we do not tolerate discrimination, harassment, violence, orthreatening behavior of any kind.
We are responsible and law abiding. This includes following the national and local laws,rules and regulations where we do business. If we are unfamiliar with the legal andregulatory standards that govern our jobs, we ask for help and learn them. If we becomeaware of wrongdoing, we follow the procedures for reporting wrongdoing described laterin this Code.
RESPONSIBILITIES TO BUZZFEED
We follow BuzzFeed’s policies and procedures. We are responsible for following
BuzzFeed’s policies and procedures as they relate to our jobs. If we become aware ofviolations, we follow the procedures for reporting them described later in this Code. If weare unfamiliar with the policies and procedures that govern our jobs, we ask for help andlearn them. We ask everyone to read and follow the applicable Employee Handbook fortheir jurisdiction.
We avoid actual conflicts of interest or even the appearance of conflicts of interest.
We have a responsibility to make business decisions strictly on the basis of BuzzFeed’s
best interests without regard to our personal interests. A conflict of interest occurs when
our personal interests, activities, investments, or associations interfere with, or evenappear to interfere with, BuzzFeed’s interests. We disclose any relationships,investments, associations or activities that may create any actual, potential, or perceived
conflict of interest as soon as we become aware of such conflict. Additional information
about conflicts of interest, including ways to recognize and raise them, is contained in our
Conflicts of Interest Policy, Related Party Transactions Policy and Gift and Entertainment
Policy.

CODE OF CONDUCT2

We are loyal to BuzzFeed. We do not compete with BuzzFeed or use BuzzFeed
property, information or business relationships for personal gain. Opportunities thatbelong to BuzzFeed, similarly, may not be diverted for employees’ personal gain.
We protect BuzzFeed’s sensitive and confidential information. Everyone covered bythis Code is expected to safeguard BuzzFeed’s confidential, personal, sensitive andproprietary information, including information related to employees, partners and otherthird parties, and anyone else with whom we do business. We do not disclose
information collected by BuzzFeed without proper authorization and only use suchinformation for legitimate business purposes and in accordance with applicable laws andgoverning contracts. Such confidentiality obligations continue beyond the end ofemployment. We do not speak on behalf of BuzzFeed unless authorized to do so. Before
we speak on behalf of BuzzFeed, we obtain authorization from BuzzFeed’sCommunications Department. Additional information about communications about theCompany is in our Corporate Communications Policy.
We maintain accurate and complete business and financial records. BuzzFeed createsand maintains transparent, reliable and complete financial and business records thatcomply with applicable requirements and generally accepted accounting practices andBuzzFeed’s policies. Employees are responsible for reporting concerns regarding
accounting, internal accounting controls or auditing matters in accordance with theCompany’s Employee Concern and Complaint Procedures for Accounting Matters Policy.
This Policy also provides for an option to report concerns or complaints about
questionable accounting matters directly to the Audit Committee of our Board ofDirectors.
We protect and properly use BuzzFeed’s assets and resources. Theft, carelessness,and waste have a direct impact on our profitability. We treat BuzzFeed’s finances,equipment, resources and facilities with care and use these resources for legitimate
business purposes, and exercise good judgment when using BuzzFeed’s tools andequipment for reasonable personal use. Additional information about appropriate use ofBuzzFeed resources is contained in our Delegation of Authority Policy and Travel andExpense Policy. In addition, use BuzzFeed’s information systems in a responsible mannerconsistent with the BuzzFeed Employee Handbook.
RESPONSIBILITIES TO THE BROADER COMMUNITY
We engage in fair business dealings. We do not take unfair advantage of anyone
through manipulation, concealment, abuse of privileged information, misrepresentation,or any other unfair dealing.

CODE OF CONDUCT

3

We do not engage in bribery or corruption. It is never acceptable to offer, permit or takebribes to advance our business, regardless of local norms or customs. As noted in
BuzzFeed’s Anti-Corruption Policy, we do not offer or give anything of value for animproper or corrupt purpose, nor do we ask others to do so on our behalf. We ask
BuzzFeed’s Legal Team if we have questions about whether anything we are doing could
be viewed as bribery or corruption.
We comply with antitrust and competition laws around the world. We do not discuss orexchange competitively sensitive information with competitors, nor do we participate inother anti-competitive conduct, such as agreeing with competitors on geographic
markets, customers or pricing. Additional information may be found in our Fair
Competition Policy. When interacting with a competitor, we ask BuzzFeed’s Legal Team if
we have questions about whether our actions are proper and in compliance with the law.
We comply with trade regulations. We comply with import and export laws and act inaccordance with U.S. economic sanctions and embargoes that prohibit or restrict tradewith certain countries or individuals (as well as with local import and export laws in otherplaces where we do business). We consult the Sanctions Policy or with BuzzFeed’s Legal
Team if we have any questions about compliance with trade regulations.
We respect copyrights and trademarks. We respect laws and regulatory restrictions
related to using, copying, displaying or distributing copyrighted written material andsoftware without the prior written permission of the copyright owner. Some examples ofcopyrighted materials may include: newspapers, books, magazines, photos, art, music,film, software or databases. In addition, we do not infringe on the trademarks, logos andbrand names that BuzzFeed does not own. We ask BuzzFeed’s Legal Team if we haveany questions about compliance with intellectual property laws.
We do not engage in insider trading. We do not buy or sell BuzzFeed stock when inpossession of material non-public information, or share such information with others,
including friends or family. We consult with our Securities Trading Policy or with
BuzzFeed’s Legal Team if we have any questions about trading in BuzzFeed securities.
We provide full, fair, accurate and timely disclosures of our financial position.
BuzzFeed’s employees, including its senior financial officers, (1) engage in honest andethical conduct, including with respect to the ethical handling of actual or apparent
conflicts of interest between personal and professional relationships; (2) provide
information that is full, fair, accurate, timely, and understandable in our public filings withand other submissions to the U.S. Securities and Exchange Commission or that areotherwise required to be disclosed by issuers; and (3) comply with applicable

CODE OF CONDUCT4

government rules and regulations, including but not limited to those having to do with thehandling of violations of this Code or other suspected fraudulent actions which may
affect the public filings or disclosures made by BuzzFeed or any significant deficiencies
in BuzzFeed’s internal controls that could affect the ability to properly record, process orsummarize financial data.
SPEAKING UP
BuzzFeed is committed to an environment where open, honest communications are theexpectation, not the exception. We speak up about violations stated in this Code ofConduct, as well as ask for guidance related to policies and procedure.
We use our best judgment and ask questions. If unsure whether something violates alaw, this Code or a BuzzFeed policy, we contact an appropriate BuzzFeed manager, or
BuzzFeed’s Legal Team or People Team for help.
We report violations and concerns. If we become aware of anything that may be anactual or possible violation of a law, this Code or a BuzzFeed policy, we promptly report
our concerns via our reporting processes, outlined below and/or in the Employee
Concern and Complaint Procedures for Accounting Matters Policy. Failure to report aviolation or possible violation may itself be considered a violation of this Code, other
BuzzFeed policies or applicable law.
WAYS TO RAISE QUESTIONS OR REPORT CONCERNS
BuzzFeed is committed to providing a safe and reliable means for BuzzFeed employees
and others to report concerns they may have about conduct at BuzzFeed. The guidelines
below explain how to raise concerns confidentially, anonymously (as appropriate) andwithout fear of retaliation.
■ Discuss the situation with a manager■ Discuss with a representative in Legal or a Human Resources Business Partner.
■ Report the concern to BuzzFeed’s Chief Legal Officer or Chief People Officer.
In addition you may report concerns or complaints about Accounting Matters directly to
the Audit Committee in care of our Corporate Secretary. You can contact them throughemail at corporatesecretarysoffice@buzzfeed.com or by mail in an envelope labeled withsomething like “To be opened by the Audit Committee only” sent to: Corporate Secretary,
BuzzFeed, Inc., 229 W 43rd St, New York, NY 10036.

CODE OF CONDUCT5

In situations where you do not feel comfortable reporting your concerns directly tosomeone, you are encouraged to use the ethics helpline, hosted by a third party
provider, which allows for you to raise complaints anonymously.
Ethics Helpline URL: buzzfeed.allvoices.coAdditionally, the New York State Division of Human Rights maintains a toll-free hotlinethat provides counseling and accepts complaints regarding workplace sexualharassment. This hotline can be reached at 1-800-427-2773.
ADDRESSING QUESTIONS AND REPORTED CONCERNS
BuzzFeed takes all reports of a violation or a possible violation seriously. The specificaction taken in any particular case will depend on the nature and gravity of the conduct
reported and the results of any investigation. BuzzFeed will keep reports confidential tothe extent that it is consistent with our ability to conduct a full and fair investigation andto comply with our legal obligations.
We do not retaliate for raising concerns, reporting violations or participating in aninvestigation. BuzzFeed takes its culture very seriously. Employees will not be penalized
or retaliated against in any way with regard to their employment, nor harassed orthreatened for reporting such concerns. BuzzFeed considers retaliation a violation of thisCode and will respond accordingly. Speaking up about retaliation enables BuzzFeed tohonor our values. If a complaint of retaliation is verified, appropriate disciplinary action
will be taken, up to and including termination of employment or any other working
relationship that the accused may have with BuzzFeed.
If you have a good faith belief that you have been subject to retaliation (such as but
not limited to: harassment, suspension, demotion), report it promptly by one of themethods described above.
We discipline behavior that is inconsistent with this Code. Anyone who violates a law,
this Code, or other BuzzFeed policies or procedures may be disciplined based on thenature and severity of the violation, up to and including termination of employment
and/or their business relationship with BuzzFeed. Certain violations of this Code may beviolations of the law, which may result in civil or criminal penalties, and BuzzFeed will
cooperate fully with the appropriate authorities in these situations.
WAIVERSCODE OF CONDUCT

6

We apply the Code consistently and only waive behavior inconsistent with this Codein limited circumstances. Any waivers of this Code will be granted only in limited
circumstances and only to the extent such waiver does not violate any applicable law,rule or regulation and provided that any such waiver is appropriately disclosed. Waivers
for a director or an officer (within the meaning of Rule 16a-1(f) promulgated under theSecurities Exchange Act of 1934, as amended), must be approved by Nominating,Corporate Governance, and Corporate Responsibility Committee. Any other waivers may
be approved by BuzzFeed’s Chief Legal Officer.
QUESTIONS | compliance@buzzfeed.com

Amended by the Board of Directors on February 8, 2024

CODE OF CONDUCT7