Standards of Business Conduct

We are charting a new course as Yahoo. It’s on all of us to know what we stand for as a
Company and to do what’s right, every time.
Our Standards of Business Conduct (“SBC” or “Standards”) ensure that what we do is done withintegrity, respect, and accountability. Each of us is obligated to know and to adhere to theseStandards; to seek help when we encounter uncertainty about what they require in a particular
circumstance; and to report concerns about anyone’s failure to live up to them.
These standards are a reflection of the culture we are building as Yahoo. We are owners,
creators, maximizers, and energizers, and we always do what’s right.

Integrity
Trust is our most fundamental asset. It is also the most fragile -- something that takes years
to build but that can be lost in a moment. That’s why each of us is responsible for conducting
ourselves and our business in a way that earns -- and maintains -- the trust of our customers,
partners, and coworkers, as well as those charged with enforcing the laws and regulations
that govern how we do business.

Privacy, Information Security and Data Governance, Intellectual Property,
Obligations to Prior Employers, and the Protection of Company andPartner Resources
Ensuring that we adhere to our privacy, data security, and intellectual property policies; theobligations that we have undertaken to other companies; and the laws and regulations
governing our collection, retention, and use of data is crucial to the integrity of our brands.

User Privacy
Our privacy policies inform our users about what information is collected from them, how thisinformation is used, and how they can limit the collection and use of their data. We must
respect these choices and protect user data.
This means that you may not access, use, or share user information without a proper businessreason. It also means that you are obligated to ensure that our contractors and partners respect
our user’s choices and protect their data. Accordingly, you should ensure that any agreementswith contractors or partners address and protect our user’s data and that you reach out to thePrivacy team, your Legal POC, the Paranoids or the Ethics and Compliance Office (“ECO”) if you
2have any questions or if you are aware of or suspect unauthorized access to, disclosure of, orloss of user data.

Employee Privacy
To protect applicable privacy rights; to eliminate the opportunity for pretexting, unfair labor
practices and other misconduct, and to ensure that we maintain an ethics and complianceprogram in which issues can be raised anonymously and without fear of retaliation, we restrict
access to current and former employees’ personal information and communications. If you
have a business need to access such information or communications, please reference theAccessing Current or Former Employee Records Policy on The Street. Nothing in this section
prohibits employees from discussing terms and conditions of employment and/or engaging inconcerted activity protected by law.

Information Security and Data GovernanceOur business depends on protecting our own proprietary, non-public, and confidential
information, as well as the information others share with us. This information may include, forexample, business plans, trade secrets, financial results, consumer credit card data, andprivileged and/or restricted information such as internal reports, policies, and procedures.
It is your responsibility to keep track of the information that has been entrusted to you and toprevent its loss, misuse or theft, and to comply with our Acceptable Use Policy and Information
Security Policy.
You may not disclose non-public financial information to the public or third parties without priorapproval from Yahoo’s Controller; you must ensure that a non-disclosure agreement is in place
before you share such proprietary and confidential information with any third party; even within
the Company you should only share such information only on a need to know basis; and you
must ensure that your use of third party data is consistent with our policies and any obligations
we have undertaken in regard to such data.
Your obligation to safeguard this information continues even after your employment at theCompany has ended.
If you have questions about whether information is proprietary, non-public or confidential orwhether a particular use of information is appropriate, please contact
datagovernance@yahooinc.com. Nothing in this section prohibits employees from discussing
terms and conditions of employment and/or engaging in concerted activity protected by law.

Intellectual Property
Our intellectual property is a valuable asset and must be protected by everyone. Similarly, youmust respect the proprietary rights of others by complying with all applicable laws andagreements, including those with business providers, competitors, and customers.

3You must not acquire the intellectual property of others through unlawful or inappropriate
means. Unless you obtain either the prior consent of the owner or a determination from ourIntellectual Property Team that such use is otherwise permissible, you may not copy, use, orshare third-party copyrighted materials.
If you have questions about intellectual property, please contact the Intellectual Property Team.

Obligations to Prior Employers
If you are subject to any intellectual property, non-competition, non-solicitation or non-disclosure
obligations to a prior employer that potentially impact your work on behalf of Yahoo, you arerequired to disclose the existence of any such obligations to HR and ECO.

Protecting Company and Partner Resources
You are required to protect the Company’s property, as well as property belonging to customers,
business providers, and co-workers. All Company resources must be used appropriately, andnever for personal gain. Company property cannot be taken, sold, loaned, given away, orotherwise disposed of, regardless of its condition or value, without specific authorization.
To ensure a safe work environment and the integrity of the company’s facilities, you must takeall appropriate precautions to protect Yahoo’s systems and premises. Do not leave visitors
unescorted or sensitive areas unattended or unlocked. When on company property andconducting company business, wear your identification badge and request identification fromothers you do not recognize. You must report all suspicious activity to Security.
Our communications and information systems, including all company computers and mobile
devices, are critical to the Company’s daily operation. You must protect company informationfrom accidental or unauthorized disclosure. You must protect the security of user IDs andpasswords for all company systems and devices. You must also comply with all Company
policies relating to the use of computer hardware and software on company systems, and theacquisition, use, and disposition of data on company systems.
You may not use company systems to engage in activities that are illegal, violate our policies, orthat could result in liability or reputational harm for the Company, its partners or its employees.
Some examples of improper uses of company systems include:●●●

Pornographic, obscene, offensive, harassing or discriminatory content;
Unauthorized mass email distributions; andSolicitations on behalf of political campaigns or third-party commercial ventures.

You may make limited personal use of company systems, so long as it does not interfere withyour work responsibilities or otherwise violate these Standards or any other Yahoo policies. You
may not send non-public proprietary and confidential company information to personal email
unless you are authorized to do so by a supervisor and comply with company policies regarding
encryption. If you have questions about the acceptable use of company resources, please referto the Company’s Acceptable Use Policy or contact the Paranoids.

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Our resources include the various benefits plans and programs that we provide employees. You
must use these plans and programs honestly. You are not permitted to misrepresent any fact
regarding your health status, covered members, beneficiaries, or any other facts, including
reasons for absence, for any purpose. If you have questions about our benefits plans andprograms, please contact the Benefits Team via HRAnswers.

Avoiding Conflicts of Interest
You are responsible for ensuring that the decisions you are empowered to make on behalf of
the Company are not influenced by your personal interests. You are also responsible foravoiding the appearance of conflicts of interest, which can be just as corrosive to our culture
as actual conflicts. Each of us is responsible for reporting any potential or actual conflict ofinterest to ECO as soon as we become aware of it -- whether it is our conflict or someone
else’s.
The areas in which conflicts most often arise are:●●●●

Relationships with friends, relatives, and co-workers
Outside activities and investments;
Inventions
Accepting gifts, entertainment and other business courtesies

Note that a conflict of interest exists whenever an employee’s personal interests areinconsistent with the Company’s interests; this list is not, therefore, exclusive. If you have aquestion or concern about whether a particular situation presents a conflict of interest,
contact ECO. Nothing in this section prohibits employees from discussing terms andconditions of employment and/or engaging in concerted activity protected by law.

Relationships with Friends, Relatives, Coworkers, and Partners
Certain types of personal relationships can create actual or apparent conflicts of interest bothinternally at Yahoo and in our interactions with external entities. You should never use yourposition at the Company to advance your personal interests or those of a friend or relative at theexpense of the Company’s interests.
Internally, you may not supervise – directly or indirectly – someone with whom you share aclose personal relationship, such as anyone in your family or household, or someone with whom
you have or had a romantic relationship or other close personal relationship that might leadothers to question your impartiality. If your work responsibilities for Yahoo require you tointeract with someone with whom you have a close personal relationship (even if no supervisory
relationship exists), you must disclose the relationship to ECO.
Externally, you may not participate in the selection process for, have discretionary authority
involving Yahoo’s business with, or supervise Yahoo’s relationship with, a company that does
business with Yahoo if it employs someone with whom you have such a close personal5relationship or is a company with which you have a business relationship. Exceptions to thisrestriction are limited and require the approval of ECO.
If a family member, romantic partner, or person with whom you have a close personal
relationship is employed by an entity that does business with Yahoo, you cannot interact withthat individual regarding business between Yahoo and the outside entity.
Likewise, hiring or engaging the services of a business owned by or affiliated with anotherYahoo employee or the employee’s family member presents a potential conflict of interest.

Outside Activities and Investments
Outside employment, advisory or board service, or investment activity presents an actual
conflict of interest if it:
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Is undertaken for a company or organization that makes or sells products or services
that compete with Yahoo (this includes products or services that Yahoo is developing orplanning to offer);
Risks the disclosure or use of Yahoo’s intellectual property or its confidential, proprietaryor non-public information;
Arises from your role in Yahoo’s business relationship with the outside company ororganization;
Involves transacting any business in a company’s securities or derivatives of thosesecurities if you conduct or supervise Yahoo business with that company; orInterferes with your work for Yahoo, including the use of the time you are scheduled to
be working on behalf of Yahoo or your use of Yahoo resources.

Other outside activities and investments present potential conflicts of interest, including:
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Investments in more than 2% of the total outstanding shares of a publicly traded
company;
Investments in private companies that are current or potential competitors or partners ofYahoo;
Serving as an advisor to a venture capital fund’s portfolio companies or advising on thefund’s investment activities;
Serving as a member of another company or entity’s board of directors or advisoryboard;
Performing the same type of work that you perform for Yahoo;
Speaking and teaching engagements; andHolding political office.

You are responsible for disclosing to and obtaining approval for any such activity or investment
from ECO. ECO will assess the actual or potential conflict of interest and work with you andyour supervisor to ensure that the conflict is either avoided altogether or adequately mitigated.

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Even when your outside activity is approved, you may not use your position at Yahoo to solicit
resources for or assistance with the activity.
Unless you receive the prior written approval of your supervisor and Human Resources, you may
not engage in any outside employment or self-employment or perform any commercially-related
services—with or without compensation—while absent from work on any company-approved
leave of absence, absence due to sickness or disability, Family Medical Leave or comparable
leave provided for by applicable law.

Political Activities and Contributions
We encourage participation in the political process. However, each of us is personallyresponsible for complying fully with all laws and regulations relating to interactions withgovernment officials, including laws governing campaign finance, government ethics andlobbying. Note that all lobbying activities on behalf of the Company must be authorized by the
Public Policy Team. The consequences for non-compliance can be severe -- for both you andthe Company.
If you are appearing before a government body or engaging in contact with a public official
outside of your ordinary work duties regarding a business in which Yahoo is engaged or abusiness issue in which Yahoo has an interest, you should make it clear that you are notrepresenting Yahoo, and you should advise the Public Policy team in advance.
Your personal political contributions and activities must be kept separate from the company. If
you make political contributions, you may not refer in any way to your employment or use thecompany’s assets, including its name, in connection with your contributions, unless required to
do so by law.
You may not make payments of corporate contributions, whether monetary or non-monetary
assets, to any domestic or foreign political party, candidate, campaign or public official unlessthat contribution is permitted under applicable laws inside and outside the U.S., and approved inadvance by ECO and the Public Policy team. In addition, you may never reimburse anyone forany political contribution.
Yahoo and its subsidiaries administer Political Action Committees (PACs) that accept
contributions from employees who wish to support Yahoo’s goals through the political process.
Your personal contributions to these PACs are entirely voluntary.
Before you seek any elected or appointed public office, including a local position, such as schoolboard member, you must obtain the approval of ECO and your supervisor.

Insider Trading
Insider trading occurs when a person trades in a company’s securities using material inside
information—that is, information that is not publicly available and that could reasonably affect a
person’s decision about whether to buy or sell the securities. It also occurs when a person gives

7

material inside information to someone else who trades on it. Insider trading is a serious
violation of the law and can result in severe civil or criminal penalties, including imprisonment.
As a Yahoo employee, you may become aware of material inside information about Yahoo,
Apollo Global Management or other companies with which Yahoo does business. You mustnever use material inside information (even if you acquired it as a “tip” from others) to trade inYahoo’s or any other company’s securities. This prohibition also includes trading in derivative
securities, such as calls and puts, and engaging in short selling or other hedging transactions. In
addition, you may not provide material inside information to any other person, including
members of your family or your friends, or assist any other person in buying, selling or entering
into any other transaction using material inside information.
The rules that relate to insider trading are complex. If you are not sure whether these restrictions
apply to you, you should consult ECO before making any decision to buy, sell or trade in asecurity, or before you disclose any information to another person. As a general rule, non-public
information concerning a company’s business, financial prospects, regulatory or legal matters,
significant cybersecurity incidents, or management issues, is often considered “material.”
You must not engage in any financial transaction that permits you to benefit from thedevaluation of Yahoo’s stocks, bonds or other securities, including, but not limited to, shortselling or buying “put” options on Yahoo stock.
In addition, you may not participate in financial transactions in the stock or other securities ofbusiness providers or prospective business providers, including “friends and family” deals or
initial public offerings (IPOs), if these opportunities may influence, or appear to influence, yourbusiness judgment on behalf of Yahoo.

Business Opportunities You Discover Through Your WorkBusiness opportunities that you discover through your work at the Company -- whether they
involve ideas for new businesses or technologies, sales opportunities or something else -belong to the Company unless the Company agrees otherwise. If you have a question about
whether a business opportunity belongs to the Company, contact ECO, which will work withappropriate stakeholders to provide you clarity -- something that benefits both you and Yahoo.

Inventions
Developing or helping to develop outside inventions that relate to the Company’s existing or
anticipated products and services, that relate to your position with the Company or that aredeveloped using Company resources may create a conflict of interest.
Note that the Confidentiality and Invention Assignment Agreement that all employees sign aspart of on-boarding at the Company assigns to the Company all inventions created by
employees during their employment, other than those inventions that are both (a) unrelated to
the Company’s current or anticipated business or research and (b) created by employees
entirely on their own time and without any use of the Company's facilities or resources. The
Agreement also provides that if an employee incorporates prior work into an invention created8during his employment with the Company, the Company is granted a perpetual, non-exclusive,
irrevocable, and royalty-free license to use the prior work in conjunction with the invention. If
you have a question about whether an invention creates a potential conflict or intellectual
property ownership issue, contact ECO or the Intellectual Property Team.

Integrity in the Marketplace
Yahoo’s relationships with customers, suppliers, and society are critical to our success. Each of
us must ensure the integrity of these relationships.

Relationships with Customers: Selling with Integrity
You may never deceive customers, and you must fully, clearly, and directly inform our customersof the terms and conditions of our products and services:
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All advertising and sales materials must be truthful and accurate. All claims must be
substantiated in advance with a factual basis and backup. No advertising or sales
materials should be released without Legal Department approval.
When advertising the price of Yahoo’s products and services, the customer must be
clearly informed of all fees and any other terms that are material to the customer’s
decision to do business with us.
All rules regarding sales and promotions must be followed without exception.
You should promote Yahoo’s products and services by focusing on their strength, quality,
reputation, and where appropriate, through fair and accurate comparisons with ourcompetitors. You should not disparage competitors, or make misleading or inaccuratecomparisons with competitors’ products and services.
You must report to ECO any loopholes or flaws in promotions or offers that allow
customers or the Company to be harmed.

Bribery, Anti-corruption and Government Ethics
We win and award business fairly. And we maintain strict policies against bribery andcorruption, which apply to all of us regardless of the countries in which we work or what thecustoms might be in those countries.
This means that you are never permitted to offer or pay a bribe to anyone and that you may
never accept a bribe from anyone. If you are ever offered a bribe, you must report it to ECO
immediately.
This also means that you must adhere to our established deal processes, including themulti-level controls we have implemented through the Global Authority Matrix, to ensure proper
review of deals as well as any charitable donations of money, advertising inventory or other
Company property.

9Dealing with government agencies and officials, including state-owned companies and theiremployees, presents unique risks. Accordingly, you must obtain ECO approval before:●●●

Offering or giving, directly or indirectly, any gifts, entertainment, meals, or anything elseof value to any government official, whether they are based inside or outside of theUnited States.;
Conducting any business with a government official on behalf of Yahoo (for example,
entering into a commercial relationship with a governmental agency or government- orstate-owned enterprise);
Hiring, entering into a joint venture or partnership with a government official, agent,
representative, consultant, or other party involved in paying or conducting business witha government official.

You may never make payments to any third party that you suspect may be passed on to
government officials or otherwise used to improperly influence anyone’s decision making toobtain business or other benefits for Yahoo. Whenever you retain any agents or consultants inconnection with our global business, you must ensure that there are adequate controls toensure that funds provided to those agents are not used to make improper payments.
Under anti-corruption laws, Yahoo is required to keep accurate books and records of its
business activities, particularly in its dealings with governments, state-owned enterprises, andpersonnel of these organizations. You must not omit, mask, falsify, or mis-state information inthese records, which include orders, invoices, and expense reports.
You must also ensure that any agents or consultants hired to represent Yahoo properly
document all transactions and maintain accurate records regarding all payments, including
amounts, recipients, and purpose of payments.
Please consult the ECO page on The Street for further Guidance on Doing Business with
Government and State-Owned Enterprises and Guidance on Government Ethics, Anti-Corruption,
Political Contributions, Lobbying, and Commercial Anti-Bribery. Contact ECO if you have any
questions.
Sidebar: Q: Who counts as a “government official?” A: Legal definitions of “government
official” can vary. For the purpose of complying with company policy, you should takethe broadest possible view of who is a government official. This includes all elected andappointed officials and any employee of any government entity, at any level, including
national, state, provincial, local, or municipal level. It also includes officials andemployees associated with quasi-governmental entities and state-owned companies. If
you’re in doubt as to whether someone should be treated as a government official,
contact the Legal Department for assistance.

Gifts and Entertainment
Gifts and entertainment can be part of promoting a successful working relationship with ourbusiness partners and customers. However, if you fail to follow the rules relating to gifts and10

entertainment, it can damage our relationships, harm our reputation, and expose the company
to legal risk under commercial bribery and other laws.
No gift or entertainment can be exchanged if (a) it might create the appearance of undue
influence, unfairness or impropriety, (b) it is intended to improperly influence another person’sbusiness judgment, or (c) you are participating in, conducting or directly supervising a formal
Yahoo procurement process.
If you receive or want to offer a gift or entertainment that is outside of Code standards, youmust contact ECO for guidance.
Moreover, you may never use your own funds to circumvent Yahoo’s rules regarding gifts andentertainment, and you must ensure that all gifts and entertainment are accurately reflected inYahoo’s books and records, including expense reports. Yahoo’s rules regarding gifts andentertainment can apply to your family and individuals with whom you have a close personal
relationship when those individuals receive gifts and entertainment because of your position atYahoo.

Gifts
A gift is anything of value, including promotional trinkets, food, beverages, and event tickets, thatyou give or receive. To be permissible, a gift must be in compliance with all applicable laws and:●●●Unsolicited;
Not cash or usable as cash (including gift cards unless they have been approved by ECO
as part of an authorized Yahoo program); and;No more than $250 in value in a calendar year to the same individual, unless approved bya Director level supervisor and ECO.

Entertainment
Entertainment is any meal or event that you attend with a customer or business provider. If you
do not attend an event with a customer or business provider, the tickets to the event areconsidered a gift, not entertainment. To be permissible, entertainment must be in compliancewith all applicable laws and:●●●

Attended by both a Yahoo employee and a business provider’s employee, and be an
occasion where business is discussed;
No more than $250 in value per occasion, per person, unless approved by a Director levelsupervisor and ECO; andAt a venue and conducted in a manner that does not violate other provisions of the Codeor harm the Company’s reputation (e.g., attending an event at an adult entertainment
venue).

If you receive a gift, entertainment or business courtesy that is outside of Code standards, youmust contact ECO for guidance.

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Providing or Accepting Travel or Lodging
You must receive approval from ECO before offering or accepting travel or lodging to or from apartner, vendor or customer. The Travel Request Forms are located on The Street.

Relationships with Suppliers and Partners
You must use good judgment when selecting and maintaining relationships with all of Yahoo’s
suppliers and partners. Employees who select, supervise, and work with suppliers and partners
must:
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Use a selection process that is fair, lawful, does not improperly discriminate, andcomplies with all company policies;
Ensure that suppliers and partners are apprised of their obligation to abide by all
applicable Yahoo policies, including the Yahoo Supplier and Partner Codes of Conduct;
Put all agreements in writing and obtain all required approvals for agreements; andProtect any confidential information that suppliers or partners share with us.

Relationships with Competitors
We are committed to competing fairly and we will never seek to eliminate or reduce competition
through illegal agreements with competitors. To safeguard against this risk, you may not enter
into agreements with competitors without advance approval from the Legal Department. When
thinking about what companies could be competitors, take a broad view and err on the side ofcontacting the Legal Department prior to making any agreement.
You must avoid agreements that could violate antitrust and competition laws such as fixing
prices, dividing markets or products, rigging bids, or boycotting particular suppliers or
customers. Explicit agreements, informal “gentlemen’s agreements,” and even a “wink and anod” are against the law and can result in criminal penalties for Yahoo and you personally.
When interacting with competitors externally – including at trade association activities or in
informal settings – you should not discuss Yahoo’s pricing, terms, or marketing plans.

Acquiring Other Parties’ Non-Public Information
You cannot accept or use non-public information belonging to a third party (including
information from a former employer) unless the person disclosing the information is authorized
to do so, Yahoo has the owner’s written permission to receive it, and the information is provided
according to a written agreement that has been approved in advance by your supervisor and theLegal Department.
Sidebar: Q: A customer shared a competitor’s pricing in connection with a pending bid because
the customer wants to make it clear that there is a certain “price to beat.” Can I use thisinformation? (A) No. This information is almost certainly proprietary and the customer

12may not be authorized to share it with Yahoo. You should contact ECO, preserve theemail, and do not take further action until directed by ECO.
Sidebar: Q: A competitor’s pricing information was posted on a blog and marked “confidential.”
Can I use it? A: If you have reason to believe the blogger wasn’t authorized to post the
information and that it is non-public, you should contact ECO and receive guidance
before using it.

Gathering Information About Competitors
Gathering information about competitors is a common business practice, but you must always
do so with integrity. You must always accurately represent yourself and may never misrepresent
your identity when gathering information. You are also required to ensure that all consultants
and agents with whom you work on behalf of Yahoo do the same.
You may generally obtain information from public sources, industry gatherings, surveys andcompetitive research, but it is never acceptable to obtain or request non-public information fromany source, including the internet. It is never appropriate to engage in theft, espionage, or
breach of a competitor’s non-disclosure agreement. To the extent that information you receiveis clearly marked private or marked in such a way as to indicate it is private, you should not use
it and should contact ECO for guidance.

Your Obligations after Leaving Yahoo and Our Relationships
with Former EmployeesYour obligation to follow these Standards continues even after your employment at Yahoo ends:●●●

When leaving or retiring, you must return all Yahoo property, including all records andequipment. You can’t use or disclose Yahoo’s non-public information in any subsequent
employment, unless you receive written permission in advance from ECO.
You may not provide any Yahoo non-public information to former employees unlessproperly authorized. If a former employee solicits non-public information from you, youmust immediately notify ECO.
Except as authorized below, you may not rehire a former employee, engage a former
employee as an independent contractor or contingent worker, or purchase products orservices on Yahoo’s behalf from a former employee unless the former employee has
been separated from the company for six months.
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Our Chief People Officer may approve the rehire of a former employee or theengagement of a former employee as an independent contractor or contingent
worker within six months of that person’s separation.
ECO may approve the purchase of products or services on Yahoo’s behalf from aformer employee within six months of that person’s separation.

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Financial Integrity
Preparing, Disclosing, and Maintaining Accurate Records
We are committed to maintaining and providing truthful information that fully satisfies all legal
requirements. We do not tolerate the falsification or improper alteration of records.
You must create and maintain true and accurate records. If you identify any mistakes ordiscrepancies, no matter how small, you must take steps to resolve them immediately, and you
must promptly notify your supervisor.
You may never direct anyone to create or approve a false or misleading record, or intentionallytake any action that leads to the creation of a false or misleading record, such as withholding
information from someone who is preparing a record.
Company records must be retained according to applicable laws and Yahoo’s Records
Management Policy. You may never destroy, alter, or conceal any record if you have been
directed to retain it or if you know – or reasonably believe there is a possibility – of any litigationor any internal or external investigation concerning that record.
If you believe a record was intentionally falsified or created to be misleading, or if anyone directs
you to violate these Standards or any Company policy, you must immediately notify ECO.

Promoting Transparent and Complete Disclosure
We are committed to transparency in financial reporting to enhance investors’ understanding of
the company’s business and to facilitate informed investment decisions. All disclosures madein financial reports and in public communications must be full, fair, accurate, andunderstandable.
You may not selectively disclose (whether in one-on-one or small meetings) any material
information regarding Yahoo. You should be particularly careful not to disclose suchinformation if you make presentations to customers, business providers, investors, or other third
parties.
Yahoo uses auditors to ensure the accuracy of its reporting. You must cooperate with auditors
and provide them with complete, accurate and timely information, and you must neverimproperly influence or mislead any auditor.

Anti-Money Laundering
Money laundering is an attempt to hide or disguise the proceeds of criminal activity through aseries of otherwise legitimate business transactions. To prevent our products and services
from being used to facilitate money laundering, we have voluntarily implemented a Global
Anti-Money Laundering Policy under which we periodically assess our products and services
and implement safeguards where appropriate.
14External Communications
When communicating externally we must all take care to protect the company’s brand andreputation. Unless you receive prior approval from your supervisor, when presenting yourpersonal views in public or at professional, community, and other events, you may never suggest
you are speaking on behalf of the company.
External requests and inquiries must be directed to the appropriate organizations as follows:●●●

Corporate Communications is responsible for contact with the news media and inquiries
about community relations.
Human Resources handles inquiries regarding current and former employees, including
employment verification.
The Litigation and Law Enforcement Teams handle contacts from outside attorneys, law
enforcement, legislative bodies, and regulatory agencies. This includes responses tosubpoenas, court orders, and inquiries from law enforcement, including requests toaccess Yahoo facilities. You are never permitted to confirm or deny the existence, or
discuss the substance of, any subpoena, warrant or court order, and should immediately
refer any such inquiries or requests to the Law Enforcement Team. If you receive any
legal documents relating to Yahoo, you must immediately forward them to the Litigation
Team.

Yahoo generally does not make company-sponsored endorsements or provide testimonials.
Yahoo’s name may not be used, nor may any employee make any endorsement, without the
explicit approval of the Legal Department and Brand Management.
Sidebar: Q: If I am using my personal social media account on my personal time, do theStandards of Business Conduct really apply? A: The Standards still apply to yourpersonal use of social media. For example, if you post a racist comment or encourage
acts of violence on your social media pages, such behavior may constitute prohibited
misconduct. Likewise, the Federal Trade Commission’s Guides for Endorsements andTestimonials apply to your use of a personal account to review our products.
Sidebar: Q: Where can I get more information about the company’s policies on social media? A:
More information can be found in the Company’s Social Media Policy.

Personal Integrity: Misconduct Outside the Workplace
Every one of us is an ambassador of the brands, customer relationships, and culture we areworking to build. Misconduct -- even outside of work and off Yahoo premises -- can jeopardize
this work and impair your ability to do it. Accordingly, in order for the Company to determine
whether off the job conduct could impair work performance and unless prohibited by applicablelaw, you must promptly report to ECO any arrest, charge or conviction for:●●a felony (or equivalent under local law);a crime involving dishonesty, assault or battery;
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a drug-related offense;
an alcohol-related offense relating to conduct while on company property or business or
any offense which may affect your ability to perform your job or affect the company’sbusiness interests.

Respect
We are committed to treating customers, fellow employees and partners with respect. This is asound business practice. It’s also the right thing to do.

A Diverse, Inclusive, Safe, and Professional Workplace
We seek to attract, retain, and develop a highly qualified, dedicated, and diverse workforce. We
believe an inclusive, safe, and professional workplace is key to our ability to do this.

Diversity and Inclusion
We respect and comply with all laws providing equal opportunity to individuals without regard torace, color, ethnicity, religion, age, sex, gender, pregnancy, sexual orientation, gender identity andexpression, national origin, disability, medical condition, reproductive health decisions, marital
status, citizenship status, veteran status, military service status or any other protected category
under applicable law.
Our commitment to inclusiveness extends beyond our workplace. We seek to do business withdiverse suppliers and vendors. And we refuse to use facilities, sponsor events, or maintainmemberships at organizations that have exclusionary membership practices.
We are committed to a workplace free from illegal discrimination or harassment, including
sexual harassment or harassment based on any other legally protected category. That’s why
we’ve implemented a Harassment-Free Workplace Policy.
Unlawful harassment comes in many forms and includes conduct or language that creates ahostile or offensive work environment. It can be physical, verbal, or visual. For example, sexual
harassment may include inappropriate touching, unwelcome romantic advances, lewd gestures,or the display of obscene material. Other forms of harassment may include racist comments,
ethnic slurs, religious stereotypes, or homophobic jokes.
As a Yahoo employee, you must never engage in or tolerate such behavior. If you are subjected
to or observe unlawful harassment, you should report it to your supervisor (if appropriate),
Human Resources, Employee Relations or ECO. Supervisors who become aware of harassment
concerns must report the issue; supervisors who fail to report harassment concerns may besubject to disciplinary action, up to and including termination of employment.

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A Healthy, Safe, and Professional Workplace
We are committed to providing a healthy, safe, and professional workplace for all employees
and to ensuring that we are good stewards of the environment. Our Environmental, Health, andSafety, Security, HR, and ECO teams help ensure that we meet these commitments.
You must perform your job in a safe and environmentally responsible manner and in compliancewith Yahoo programs and the law. If you are a supervisor, you must implement and enforce allapplicable regulations and policies and ensure that your direct reports are trained on the safety
and environmental practices applicable to each of their jobs. You must investigate allenvironmental, health, and safety issues that come to your attention, and refer any issues ofpotential noncompliance to your manager and the Environment, Health, and Safety team.
Contact your supervisor immediately if:● You are involved in a work-related accident, including any incident that results in awork-related injury.
● You learn of a release (or threatened release) of any hazardous substance.
● You observe a violation of environmental, health, or safety law or guidelines.
● You identify any other environmental, health, or safety hazard.
Contact the Security and the Environment, Health, and Safety teams immediately if:● You learn of a release (or threatened release) of any hazardous substance.
● You are unable to contact your supervisor to report other environmental, health, orsafety concerns.
Contact the Security and the Environment, Health, and Safety teams immediately if:● You believe your supervisor has failed to take appropriate action to remedy a condition
that is unsafe or in violation of any law or environmental, health, or safety practice.
● A regulator visits your worksite or asks to schedule an inspection.
● You need advice on compliance with environmental, health, and safety law or Yahoo’s
guidelines, or on how to do your work in a way that is safe, healthy, and protective of theenvironment.
Contact the Environment, Health, and Safety team or ECO if you have suggestions foropportunities to improve our environmental, health, and safety management program.
We are committed to a work environment that is free from violence, or threatening, hostile, or
abusive or illegal behavior.
This means that you must never engage in violent or threatening behavior toward fellow
employees, customers, or business partners. Such behavior will result in immediate disciplinary
action, up to and including termination of employment and referral to law enforcement.
We maintain a weapons-free workplace. This means that you may not possess or use any
weapon or weapon component (e.g., ammunition) on company property, in a company vehicle,
or while conducting company business. Unless expressly permitted by local law, this includes
weapons stored in a locked personal vehicle on company property.

17You must immediately report any instance of violence, threats, hostile behavior, or weapon
possession on company property to Security and your supervisor. In cases of imminent danger,
you should immediately notify local law enforcement (e.g., 911 or other emergency service
number).
Domestic violence can also have an impact on workplace safety. If you are the victim ofdomestic violence, you should notify the police and the Security team about any person who
may be threatening your safety or the safety of your fellow employees. You can also contact the
Employee Assistance Program for help.
Substance abuse is incompatible with workplace health and safety.
You may not report to work under the influence of alcohol, an illegal drug, or any controlled
substance for which you do not have a prescription. If you are taking a prescription medicationthat may affect your perception or responsiveness, you must notify your supervisor and Human
Resources. Never operate a vehicle or machinery while in an impaired state.
You must not use or possess illegal drugs (including marijuana) or drug paraphernalia while oncompany property, in a company vehicle, or when on company time. You should not possess oruse controlled substances or prescription drugs that have not been prescribed for you by aphysician.
Consumption of alcohol while conducting Company business, on Company premises or at a
Company-related social function must be voluntary and in moderation. Have fun, but don’t
embarrass yourself -- or the Company.
A professional workplace is one in which we don’t tolerate unprofessional or illegal behavior. If
you have questions about whether something might cross a line -- whether it's a contest, an
event you’re planning or some iffy behavior -- contact ECO.

Recording and Monitoring at Work
To maintain a safe, healthy, and professional work environment, consistent with applicable law,
we monitor employee use of company property, including communications devices, computer
systems, networks (including Internet corporate email, and personal web-based email accessedfrom company devices or systems), and facilities. In cases involving safety or suspected
misconduct, the Company reserves the right to search and monitor, with or without notice, any
company property or personal property (including vehicles) on company premises. And to theextent that you use personal devices or accounts to conduct business on behalf of theCompany or to engage in conduct that is relevant to an investigation or legal proceeding, theCompany has the right to preserve, collect, use, and disclose information created or stored on
those assets or accounts.

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You may not record (photo, video, or audio) an employee, customer, partner, or competitor
without that individual’s knowledge and approval. This means informing participants if you aregoing to record a meeting.

Accountability
We are accountable to all of our stakeholders -- our users, partners, customers, suppliers,
employees, investors, and communities. We are committed to operating smartly andsustainability, to protecting fundamental rights and freedoms, and to ensuring compliance, notjust across our own business, but also throughout our supply chain and partner network. Thisrequires each of us to have an owner’s mindset.
We must ensure that we hold ourselves and each other accountable. We must also ensure that
all of our stakeholders know how to raise questions and report concerns; that anyone raising aquestion or reporting a concern is free to do so without fear of retaliation; and that everyone
understands both the importance of cooperating with investigations and the potential
consequences for violating these Standards.

Performance
We hold ourselves to a high standard of performance. This means striving for quality in your job
performance; continuously improving the skills, knowledge, and competencies required in yourrole; always giving your best effort; stopping to think before you act to ensure that your actions
are in the best interests of the Company and its stakeholders; complying with all Company
policies and procedures that impact your work; asking questions if you are uncertain whether or
how a policy or a policy impacts your work; fostering an environment that drives engagement
and in which talent, innovation, and teamwork flourish; and taking ownership of problems andsolutions.
If you are a people manager, these obligations include developing the people you have been
entrusted to manage; ensuring your team’s compliance with these Standards and other
Company policies and procedures; and taking ownership of your team’s performance.

Human Rights
We are committed to upholding the fundamental rights and freedoms of all people across ourbusiness in line with the United Nations Declaration of Human Rights, the United Nations
Guiding Principles on Business and Human Rights, and the United Nations Global Impact. We
do this by working through our Business and Human Rights Program to incorporate humanrights policies and practices across our business and supply chain, and to advocate for public
policies that help protect the human rights of our customers and communities.

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Technology Use and Human Rights
To avoid the use of our technology -- whether for unintended purposes or in ways that may
impact human rights -- we adhere to sanctions, export/import restrictions, and embargoes. We
also engage in a constant assessment of the potential human rights impacts of these solutions,our business relationships, and doing business in particular jurisdictions.

Supply Chain Management
We require our suppliers to adhere to our Partner and Supplier Code of Conduct.

International Relationships
We follow the law, wherever we do business. If you find that there is a conflict between
applicable law and these Standards or another Yahoo policy, you should comply with the law,and seek further guidance from ECO.

Export, Import, and Anti-Boycott Laws
Export and import laws regulate where we can physically and electronically transfer and receive
software, technology, information, and items from one country to another. These laws also
include embargoes and sanctions that restrict or prohibit business activities with certain
countries, organizations, entities, and the parties that these entities own or control. You areresponsible for complying with the export and import laws of the U.S. (regardless of where you
are located) as well as the export and import laws of other applicable countries. Violations canresult in civil and criminal penalties. These laws are subject to change. Check with ECO for thelatest restrictions.

Sidebar: Q: Which countries are embargoed? A: Currently, countries and locations that are
subject to embargoes include: Cuba, Iran, North Korea, Syria, and the Crimea region of
the Ukraine. This list is subject to change. Visit the export compliance section of the
ECO website for a current list.

Not all countries agree on sanctions and boycotts. From time to time, a country may prohibit
Yahoo from complying with another country’s sanctions and/or boycott laws. For example, US
laws prohibit or penalize compliance with the Arab League’s boycott of Israel, and EU laws
restrict compliance with certain extraterritorial US sanctions. You must contact the Legal
Department if a sanctions or boycott law appears to conflict with the laws of another country.

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Anti-boycott laws make it unlawful to comply with foreign boycotts or to supply information in
response to boycott-related activities. Receiving such a request may be reportable by law.
Contact ECO for guidance.
Sidebar: Q: In connection with an RFP, a potential customer asked if Yahoo does business with
Israel. What should I do? A: You must contact the Legal Department if you receive any
request relating to Yahoo’s relationships with Israel or blacklisted companies or arequest regarding anyone’s race, religion, gender, national origin or nationality.

Sidebar: Q: Which of these are subject to export controls?
●●●●sending goods or software from one country to anotherpermitting the download of software by someone in another country
exposing or allowing access by non-US persons to US technical information, regardlessof what country the exposure occurs intransporting technical data or software on your phone or laptop, or tools or equipment inyour luggage when traveling to another country
Export controls broadly apply to tangible and intangible transfers of items from one
country to another; they may apply to each of these circumstances. To learn more about
export rules or to obtain guidance about a particular transfer, go to the ECO page.

Who Must Adhere to these Standards?
Every employee, including the Company’s executive management team, as well as the membersof our Board, must know and are bound by these Standards. People managers have a special
responsibility to set the right example; they must also foster an open door culture in which every
employee is comfortable asking questions and raising concerns.

What If I Have a Standards-Related Question or Concern?
You have an array of resources that are ready to help should you have any concerns orquestions about how these Standards apply to a particular circumstance. ECO is available 24
hours a day, 7 days a week at 844.943.4554, yahooinc.com/yathooethics or
ECO@yahooinc.com. Alternatively, you can contact ECO by mail at Ethics and Compliance
Office, 22000 AOL Way Dulles, Virginia 20166.
You must immediately report any instance of violence, hostile behavior, or possession of
weapons on company property to Security. In cases of imminent danger, you should contact
911 or local law enforcement first, and then contact Security at 408.349.4357 (The Americas),+353.1.866.3911 (EMEA) or +91.80.3077.5050 (India/APAC).
You must report any concerns or questions you have about the accuracy or integrity of Yahoo’s
financial statements, reporting, accounting, internal accounting controls, or auditing matters toInternal Audit at accountingcomplaints@yahooinc.com or to ECO@yahooinc.com.

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No Retaliation
We do not tolerate retaliation against employees for submitting complaints or participating ininvestigations. If you believe that you or anyone else is the subject of retaliation for reporting
misconduct or participating in an investigation, you must report it to ECO.

Investigations
You must cooperate completely in any investigation, including providing access to personal
devices and accounts that you use for work-related purposes. You must be honest andforthcoming at all times, and you may never misrepresent, withhold, or selectively disclose facts
during an investigation. You can’t interfere with or obstruct an investigation conducted by theCompany or by any government agency.

Resources
In addition to the online, email, and mail contact options provided above, we have established an
SBC Regional Advisors program -- a group of lawyers and business professionals drawn fromour different businesses and the different markets in which we operate that provides local pointsof contact and lines of communication that help us improve how we spot, manage, and stayahead of ethics and compliance risks.
For a list of regional advisors and company policies, visit the ECO page on The Street. And you
should always feel free to contact the Ethics and Compliance Office directly at
ECO@yahooinc.com.

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