CODE OF CONDUCTDO THE RIGHT THING

Code of Conduct

MESSAGE FROMSTEFANO DOMENICALI
Dear Colleagues
Welcome to the F1® Code of Conduct.
As Formula 1 continues to grow from strength to strength, each of you can beproud of the role you play in making this sport the incredible global event it is today.
Our Mission unites us as a team to deliver the world’s greatest sports andentertainment spectacle, with innovation, inclusivity, and sustainability at theheart of our future growth and value. Regardless of our role within the business,
we all need to put our skills and qualities into play because only together we canrealise our collective and individual potential in a constructive, honest, andtransparent way.
Every one of us has a clear responsibility to make the right decisions in the way
we behave, guided by our values. Doing what is right means we must act withintegrity to ensure we earn and retain the trust and respect of our colleagues,fans, business partners, and the communities in which we work.
We operate in challenging and complex environments across multiple borders
around the world and there could be serious consequences for both companies
and individuals if we do not act in a responsible, ethical, and lawful way.
The Code of Conduct has been developed to help ensure we do our work to thehighest standards. It protects not only the business and its global reputation,but each and every one of us as we go about our work. It is to be used as a daily
tool and to help you if you are faced with a difficult situation.

Stefano Domenicali, President and Chief Executive Officer

AS A UNITEDTEAM WE
ACHIEVE
GREAT THINGSTOGETHER.
OUR KEY TO
SUCCESS IS AN
ORGANISATIONTHAT VALUESPASSION,
INTEGRITYAND RESPECT.

Code of Conduct

CONTENTSSCOPE04OUR RESPONSIBILITIES05

ASKING FOR HELP AND REPORTING
CONCERNS

06

WHAT HAPPENS IF I BREACH THIS CODE? 07
MANAGING OUR RELATIONSHIPS

08

SOCIAL AND ENVIRONMENTALRESPONSIBILITY

16

Human Rights and Modern Slavery

17

Sustainability

18

Diversity and Inclusion

19

Harassment and Bullying

20

Health and Safety

21

Who are we dealing with?

09

Anti-Bribery and Corruption

10

Gifts and Hospitality

11

Data Privacy and Information Security

23

Anti-Money Laundering

12

Insider Trading

24

Sanctions13

Accurate Record Keeping

25

Anti-Trust

14

Asset protection and Fraud

26

Conflicts of Interest

15Intellectual Property Rights

27

HANDLING DATA AND ASSETS
WITH INTEGRITY

22

Code of Conduct

SCOPE
This Code has been adopted by each Formula 1® company andapplies to every officer and employee (including temporary
members of staff and secondees). We also expect those who
perform services for or on behalf of Formula 1 (such as
consultants, agents, introducers, contractors, suppliers andfreight service providers) to apply or adopt internal policies
that are consistent with this Code.

Formula 1 means every company in our group, being Delta Topco
Limited and its subsidiaries, including Formula One Management
Limited, Formula Motorsport Limited, Formula One WorldChampionship Limited, Formula One Marketing Limited, Formula One
Hospitality and Event Services Limited, Formula One Digital Media
Limited, Formula One Research, Engineering and Development
Limited, F1 Academy Limited and Las Vegas Grand Prix, Inc.

4

FURTHER INFORMATION:

See full and up to date list of
F1® Companies in the Policies
section of the Compliance Portal.

Code of Conduct

OUR RESPONSIBILITIESWe are all individually responsible for ensuring that we dothe right thing whilst at work. Wherever we are in the world,
we must conduct ourselves with integrity and comply withthe law and this Code.
Failure to comply with this Code will be treated seriously andmay result in disciplinary action (which could, in some cases,
include dismissal in accordance with our internal policies andemployment laws).

Situations that involve ethical issues, value judgments andpotential violations of laws are sometimes complex. This Codedoes not cover every situation, so should be read in conjunction
with all other F1® policies. If you are unsure how to proceed, ask
yourself the following questions:• Is it consistent with this Code?
• Would I feel comfortable explaining it to my colleagues,
friends and family?
• How would I feel if it was made public in the newspapers
or online?
If you are still not sure what thecorrect course of action is, always
talk to someone. See Asking for
Help and Reporting Concerns.

5Code of Conduct

ASKING FOR HELP AND
REPORTING CONCERNS
We are committed to open communication and encourage
you to ask for help if you are not sure what to do in adifficult situation.
We all have a responsibility to report any wrongdoing within thebusiness of which we may become aware. We must do this toprotect the business and each other.
You can seek advice from and report concerns to your manager,
or one of the Contacts below. If you would feel more comfortable
reporting your concern to someone independent, you cancontact the 24 hour confidential hotline service, “Speak Up”.

Calls to this hotline are handled promptly, discreetly and canbe made anonymously, if you prefer. All genuine concerns,
regardless of how they are reported, will be investigated anddealt with appropriately. Reports will be kept in confidence tothe greatest extent possible and will be balanced with therequirement to undertake a full and proper review.
Anyone raising a report or concern in good faith will not be
criticised or penalised in any way, even if it is shown afterinvestigation that they were mistaken. Any form of retaliation
against anyone who has raised a report or concern will not betolerated and will itself be treated as a serious disciplinary matter.

CONTACTS
Compliance
Sacha Woodward Hill		swoodwardhill@f1.com
Tatyana Dobson
tdobson@f1.com
HR
Adrienne Heeley
aheeley@f1.com
H&S
Adrienne Heeley
aheeley@f1.com
Speak Up
Available using the following
telephone numbers or via
web access:UK
0800-917-9782
United States(866) 222-1232
Web Accessliberty.tnwreports.com

6Code of Conduct

WHAT HAPPENS IF
I BREACH THIS CODE?
Breaches of this Code can result in severe consequences.
Both the business and individuals can be criminallyprosecuted and/or subject to other legal proceedings.

An external investigation into misconduct would be lengthy,
costly and could result in significant reputational damage even
if no action was taken following the investigation.

Individuals can be imprisoned (for up to 10 years in respect ofbribery) and face fines. The business could face unlimited fines
and significant reputational damage both of which would impact
the revenue of the business.
Any reported breach of this Codemay result in disciplinary
proceedings and dismissal.

7

MANAGING OUR RELATIONSHIPSDO THE RIGHT THING

Code of Conduct

MANAGING OUR RELATIONSHIPSWHO ARE WE DEALING WITH?
Our relationships can present a risk to our business. We could
be investigated and suffer significant reputational damage
if we are associated with people who do the wrong thing.
We therefore need to know who we are dealing with and how
they operate.
Due diligence is an ongoing process conducted when we enter
into new relationships, when contracts are renewed and at suchother times the Compliance Team advise. If you want to engage,
contract or renew arrangements with a business partner, pleasecontact the Compliance Team as soon possible so they can carryout the appropriate checks.

Q: I’m discussing terms with a regular supplier. Can I simply		 ask them for an updated quote, then make an order if the		 price is right? I know who they are as I have dealt with		 them for years.
A: Please contact the Compliance Team to check that due
		 diligence has been conducted on this supplier		 previously. If it has, the due diligence may need to be		 refreshed. If it has not, to proceed with the supplier		 could present a risk to the business. While your		 knowledge of the supplier relationship is relevant,		 there may be other issues of which you are unaware
		 without due diligence being performed.

Q: I have found an exciting new sponsor for Formula 1®.
		 They are keen to get the deal signed as soon as possible.
		 Can I arrange for a contract to be entered into immediately?
A: Not yet – please contact the Compliance Team to		 ensure that due diligence is performed and any
		 potential risks to the business are assessed before 				 contractual arrangements are entered into. If you
		 involve the Compliance Team early, due diligence		 should not slow the deal down.

9

FURTHER INFORMATION:

F1® Due Diligence Policy

Code of Conduct

MANAGING OUR RELATIONSHIPSANTI-BRIBERY AND CORRUPTION
Bribery is illegal in all countries in which we operate.
Wherever we are in the world we must never give, offer,promise, ask for or accept a bribe.
Formula 1® could be prosecuted for any bribe given, offered,promised, or accepted by anyone acting on our behalf or
performing services for us. We therefore need to be sure thatpeople who act for or represent us, operate in accordance withthis Code.
Engaging with Public Officials poses increased bribery risks.
We must therefore be particularly careful in our dealings with
Public Officials and their Related Persons (see definitions below).
A bribe can be anything of value including cash, commissions,gifts and hospitality, tickets to Grand Prix events (even a
Paddock pass), donations to charities or social funds, in-kindbenefits or favours.
A facilitation payment is a type of bribe. It is a small payment
made to a Public Official (defined below) in order to speed up aroutine procedure. Facilitation payments are illegal and prohibited.

Public Official includes:

FURTHER INFORMATION:(i) Any official, employee, agent or representative of any branchor level of government (executive, legislative or judicial andwhether national, state or local) or of any governmental
department or agency (including advisors to such agencies
and branches);

F1® Anti-Bribery and Corruption Policy(ii) Any director, officer or employee of state-owned orcontrolled companies (including their consultants, advisors,
agents and other representatives);(iii) Political parties, party officials and candidates for office;(iv) Officials and employees of public international organisations
such as the European Union or the United Nations (including
their consultants, advisors, agents and other representatives);(v) Individuals who exercise public functions for any publicagencies such as members of the police or fire services.

Formula 1 has adopted Anti-Bribery Principles which underpin
the way we do business and are incorporated into our contracts.

Related Person includes a spouse or civil partner, child,parent or sibling (whether by blood or by marriage) or otherfamily member or guest of a Public Official.

Q: Our freight handling agent has asked me if he can tip airport		 staff to ensure everything runs smoothly. Since this is just a tip
		 and is part of the local culture, can I tell our agent this is fine?

Q: I’ve hired a consultant to get the permits we need from a 		foreign government. The consultant now wants an additional$2,000 to “help keep things moving”. Should I be concerned?

A: No. Airport staff may be employees of state owned 				 entities, in which case they will be low level Public Officials.
		 It is never acceptable to tip a Public Official for fulfilling their		 role. Unless the payment is for an official fast track service
		 that is clearly advertised, available to all and the payment
		 goes to the government authority rather than the		 individual official, it is a facilitation payment.

A: Yes. Formula 1 could be liable for the improper actions ofother people, such as consultants. We must ensure thatthey never offer a bribe on our behalf. You need to findout exactly what the payment is for and advise the 		Compliance Team. Until you and the Compliance Team are
comfortable that the payment is for legitimate purposes,
it must not be made.

10

F1® Anti-Bribery Principles
F1® Public Officials and Related
Persons Policy

Code of Conduct

MANAGING OUR RELATIONSHIPSGIFTS AND HOSPITALITY
Gifts and hospitality are recognised as a normal part ofbusiness. However, we must think carefully about thecontext, value and timing of gifts and hospitality we receive
and offer.
This is because a gift or hospitality could be used (or perceived
to be used) as a bribe to influence a person when making an
official or business decision.
We must remember:• All gifts and hospitality must be reasonable, transparent
and for a genuine business purpose.
• Never allow a gift or hospitality to influence our businessdealings.
• Never accept a gift or hospitality if there may be an 		
expectation of something in return.
• Never give or accept cash or cash equivalents (such as
gift cards, gift vouchers or any product or service discounts
that are not agreed for all staff).
• Never offer or receive anything that could damage the 		
reputation of Formula 1®.
• Frequent or lavish gifts or hospitality are inappropriate.
If you are unsure, ask yourself the following questions:• Am I in the middle of a business decision?
• Is there a clear business justification for offering or
receiving the gift or hospitality?
• Have my colleagues been offered a similar gift/hospitality
or am I singled out?
• Would I feel comfortable if this was reported to mymanager or in the press?

All gifts and hospitality offered and received are subject tothe reporting and approvals procedures in the F1® Gifts andHospitality Policy.
Special rules apply when giving or receiving gifts and hospitality
to or from Public Officials and Related Persons (see page 10 for
definitions). These rules are set out in the F1® Public Officials andRelated Persons Policy. If you have questions about these rules orremain unsure, please consult with the Compliance Team.
Q: One of our sponsors has given me a £25 gift card, which		 can only be used in certain shops. What should I do?
A: You must not accept a gift card, certificate or voucher,		 whatever its value, from any business partner because		 they are cash equivalents. You must decline the gift card
		 and explain to the sponsor that Formula 1’s Gifts and		 Hospitality Policy does not allow you to accept cash or		 cash equivalents. You should also promptly report the		 offer in the Gifts and Hospitality Register on the 				 Compliance Portal.
Q: I’ve been invited to dinner by a supplier who was involved
		 in a recent Grand Prix. She has asked me to join her and her		 team for dinner to celebrate the recent successful event.
		 Do I need to tell anyone?
A: You can accept this hospitality provided it is appropriate
		 in the circumstances. If the value of your dinner is over		 £100, then it must be recorded in the Gifts and Hospitality
		 Register and you should get prior approval from the 				 Compliance Team. See the F1® Gift and Hospitality
		 Policy for further guidance.

11

FURTHER INFORMATION:

F1® Gifts and Hospitality Policy
F1® Public Officials and Related
Persons Policy

Code of Conduct

MANAGING OUR RELATIONSHIPSANTI-MONEY LAUNDERING AND
TERRORIST FINANCING
Money laundering is an illegal process where the funds from
criminal activity are hidden or “cleaned” in legitimate
business dealings, or where funds from legitimate businessare used to support criminal activity (including terrorism).

Our due diligence procedure is designed to spot any potential
issues such as money laundering but if you notice any of thefollowing in relation to someone we are working with,contact the Compliance Team:We operate with many people worldwide and it is possible thata person may want to use our business in these illegal ways.
It would be an offence if we accept or transfer the proceeds ofcrime or become involved in an arrangement that facilitatesmoney laundering or terrorist financing. To manage this risk
we conduct due diligence to ensure that we always know who
we are doing business with and where funds are coming from(see Who Are We Dealing With?).

• Large up-front payments that we have not asked for;

FURTHER INFORMATION:

F1® Anti-Money Laundering Policy• A bank account held in a name that does not match theperson/company we’re working with;• A bank account located in a country that has no connection
to the person/company we are working with;• It is unclear who owns the company;• Any payment/financial requests that seem unusual.
If you have any suspicions orconcerns regarding a company,
individual or the source of funds you
must contact the Compliance Team(see Asking for Help and Reporting
Concerns).

12

Code of Conduct

MANAGING OUR RELATIONSHIPSSANCTIONSAs a global business we must ensure that our activities are
not in breach of international sanctions or trade restrictions.
International sanctions and trade restrictions can apply toterritories, entities and individuals. They can restrict how we dobusiness and who we do business with. They are complex andare constantly changing.
As we are a UK business owned by a US company, we mustcomply not only with UK sanctions, but also US sanctions(in some circumstances), as well as the sanctions regimesof other countries in which we operate. We could facesignificant financial penalties for breaching, circumventing or
facilitating a breach of sanctions and implicated individuals
could face imprisonment.

Q: We are creating a new product to be offered for sale online
		 globally. Do I need to think about sanctions?

FURTHER INFORMATION:

F1® Due Diligence Policy

A: Yes. We are not allowed to sell (online or otherwise) into		 certain territories which are subject to broad sanctions
		 regimes. You should contact the Compliance Team who		 will advise which territories we are allowed to sell into		 and how to proceed practically.

You must contact the ComplianceTeam if your commercial discussions
involve any of the following
territories: Iran, Cuba, North Korea,
Syria, Venezuela, Russia, Belarus,
Crimea and the non-Ukrainian
government controlled areas of theDonetsk, Kherson, Luhansk andZaporizhzhia oblasts.

13

Code of Conduct

MANAGING OUR RELATIONSHIPSANTI-TRUSTFormula 1® is committed to fair competition and free trade incompliance with applicable anti-trust laws (also known ascompetition laws).

Within your role you may come across the following potential
risk areas and in such cases you should consult theCompliance Team:

This means we all have a responsibility to ensure that we donot become involved in anti-competitive behaviour – i.e.
arrangements that could restrict the open market, exclude
others from competing and/or result in artificial or fixed prices.

• Exclusive agreements of a long duration (more than 3 years);• Any commitment to give a party preferential treatment
relating to renewal or extension of the contract (e.g. firstrefusal, right to match, an option to extend);• Arrangements that run indefinitely until one party cancels(so called ‘evergreen contracts’);• Suggestions to share confidential information (e.g. between
F1® and other sporting organisations) or to facilitate
exchange of information between competing suppliers withwhom F1® deals;• Suggestions to influence bidding processes;• Agreeing with others either to favour or to boycott aparticular supplier.
You must seek permission from theCompliance Team before joining or
attending any industry/sector forum
or discussion group and always seek
agendas for such meetings inadvance which must be provided to
the Compliance Team.

14

Code of Conduct

MANAGING OUR RELATIONSHIPS

CONFLICTS OF INTEREST
We must always act in the best interests of Formula 1® andavoid any conflict of interest. This means avoiding situations
where personal, family or financial interests conflict, or could
be perceived to conflict, with those of Formula 1.
If you believe a conflict may exist, you must disclose the details
to your manager who, in consultation with the Compliance
Team, will advise on what action, if any, needs to be taken. In
most cases, the conflict will be resolved by removing you fromthe situation.
Examples of situations that could cause a conflict of interest
include:• Diverting a business opportunity from Formula 1 to yourself
or to another company;• Having a personal connection or financial interest in a 		company that works with Formula 1;• Serving as a director of another business that does businesswith Formula 1;• Being a leader in an organisation that conflicts with
Formula 1’s interests;• Managing your own business or taking a second job.

Q: I’m aware of a job vacancy at Formula 1 and think my		 brother would be perfect for the role. Can he apply for it?
A: Yes, but only if you are not involved in the recruitment
		 process and the role does not report into you. If you will		 work in the same team, you must disclose this potential
		 conflict of interest to your manager, the Compliance Team		 and the person managing the recruitment process.

Q: I’m reviewing bids from several companies for the supply of		 Formula 1 uniforms. My wife works for the company that		 has made the best offer. My decision has not been affected
		 by the fact that my wife is involved so do I really need to		 disclose this?
A: Yes, you must disclose this to your manager and the		 Compliance Team should be consulted. You will need to		 step back from the selection process. Even if the bid from		 your wife’s company is the best and we decide to select		 that company, you cannot be involved in the process as		 you are not impartial.

Remember, if your ability to make the right decision on behalfof Formula 1 is affected by external factors, you may be
conflicted and should disclose the matter to your manager
or the Compliance Team (see Asking for Help and Reporting
Concerns).

15

FURTHER INFORMATION:

F1® Conflict of Interest Policy

SOCIAL AND ENVIRONMENTALRESPONSIBILITY

DO THE RIGHT THING

Code of Conduct

SOCIAL AND ENVIRONMENTAL RESPONSIBILITYHUMAN RIGHTS AND
MODERN SLAVERY
Human rights abuses and modern day slavery are widespread
across the globe and as an international business we may
come across such abuses.
We are committed to respecting human rights in our operations
globally and ensuring that we monitor the potential impacts of
our activities. In the UK we must report annually on the steps
we take to ensure slavery does not happen within our businessand supply chain.

Q: A merchandising manufacturer has given me a very
		 competitive quote for a range of Formula 1® clothing to sell
		 at races and online. I’m going to agree terms before
		 conducting due diligence, to make sure I don’t miss out.

FURTHER INFORMATION:

F1® Human Rights Statement
F1® Modern Slavery Statement

A: Always consider whether something is too good to be		 true. If the quote is well below market rate, the		 manufacturer may be cutting corners elsewhere in the		 supply chain such as not paying fair wages to factory
		 workers or engaging in slave or child labour. Due diligence		 must be conducted before you agree any terms, to ensure		 the manufacturer adheres to all relevant ethical trade		 legislation and F1® policies.

Q: I recently visited a new circuit that is under construction
		 and noticed employees of a local construction company 				 working around the clock to get things ready without taking
		 a break. They were not wearing any protective gear either.
		 The company is not a Formula 1 subcontractor so it is not		 for me to interfere, is it?
A: There are indications that workers’ rights are not being		 protected at the circuit and their safety is at risk. Even		 though the company is not a subcontractor of ours, it is		 part of the broader event operations and so you should
		 report your observations to the Compliance Team as		 soon as possible.

17

If, during your work, you believe thatan individual’s human rights may be
adversely affected, you must report
it to the Compliance Team as soon
as possible (see Asking for Help andReporting Concerns).

Code of Conduct

SOCIAL AND ENVIRONMENTAL RESPONSIBILITYSUSTAINABILITY
At Formula 1® we recognise the critical role we must play to
reduce the environmental impact of our operations globallyand to make the sport and all events more sustainable andinclusive. The F1® Sustainability Strategy underpins ourtarget to have a net zero carbon footprint by 2030 and our
mission statement includes innovation, inclusivity, andsustainability at the heart of our future growth and value.
The F1® Sustainability Policy Statement sets out a framework ofsustainable development objectives for Formula 1’s activities andoperations, consistent with the F1® Sustainability Strategy and incompliance with the international standard ISO 20121:2012,
and the United Nations’ sustainable development goals.
From our office-based operations, through to our production
activities and circuit-based work, each of us has a responsibility
to help deliver these objectives. We should each do this byconsidering how our day-to-day choices, decisions and actions
may contribute to, or influence Formula 1’s carbon footprint andsocial impact.

Q: How can I support F1’s 2030 Net Zero goal?
A: While travel and logistics are critical to the delivery of		 our events, they have a significant impact on our carbon
		 footprint. You can help to support our Net Zero goal by		 considering the following before making any travel or		 logistics requests:		 • Requirement: Can this task be fulfilled in another way,			 for example through local sourcing or digital delivery?
		 • Design: Has the item being transported been			 designed to be lightweight and to be packed
			 efficiently for travel?
		 • Mode: Have you considered lower carbon travel			 options, such as sea freight and/or the use of			regional hubs?
Q: What is my role in ensuring suppliers understand and		 deliver against Formula 1’s Sustainability Strategy?
A: The procurement team is a critical partner in making our		 potential and current suppliers aware of Formula		 1’s Supplier Sustainability Code of Conduct. By engaging
		 procurement early in any tenders or sourcing 				 requirements, we can incorporate both environment and		 social considerations.
Q: How can I get involved?
A: We all have a role in delivering our Sustainability Strategy.
		 To get involved:		 • Consider establishing sustainability goals for you			 and your teams as part of the annual Formula 1®
			 review process on Workday.
		 • Share your thoughts and ideas with the sustainability
			 team at sustainability@f1.com

18

FURTHER INFORMATION:

F1® Sustainability Policy Statement
F1® Sustainability Strategy

Code of Conduct

SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

DIVERSITY AND INCLUSION
Formula 1® is committed to fostering a culture of diversity
and inclusion, where different perspectives are respected andembraced, and employees are valued for their contribution
and empowered to reach their full potential.
We believe that with a diverse organisation, we will attract andretain people from wide-ranging backgrounds, drawing on thebest talent, knowledge and experience.

We are all responsible for ensuring that we are inclusive ofothers in the workplace and creating an environment that is
free from prejudice. Formula 1 takes a zero-tolerance approachto discrimination of any kind. We must never discriminate on thebasis of age, disability, gender reassignment, marriage and civil
partnership, pregnancy and maternity, race, religion or belief,sex or sexual orientation.

FURTHER INFORMATION:

F1® Equal Opportunities Policy

If you see or are aware of any
behaviour that you consider to bediscriminatory, you must report it toHR (see Asking for Help andReporting Concerns)

19Code of Conduct

SOCIAL AND ENVIRONMENTAL RESPONSIBILITYHARASSMENT AND BULLYING
Formula 1® does not tolerate harassment or bullying of any
kind. We are committed to ensuring that our work
environment is collaborative, open, tolerant and respectful.

Behaviour that is acceptable to one person may not be toanother. It is our responsibility to be aware of how our own
behaviour may be received by others.

Harassment and bullying can take many forms and includes
behaviour that is belittling, humiliating, hostile or intimidating.
It can be behaviour that is based on a personal characteristic
such as age, gender, race, religion or disability.

We must be respectful at all times and report behaviour that is
unacceptable.

FURTHER INFORMATION:

F1® Harassment and
Bullying Policy
F1® Dignity at Work Policy

If you feel you or anyone else in thebusiness is being mistreated contact
HR (see Asking for Help andReporting Concerns).

20

Code of Conduct

SOCIAL AND ENVIRONMENTAL RESPONSIBILITYHEALTH AND SAFETY
We are all responsible for making Formula 1® a safe place towork (whether in one of our offices, at a circuit or travellingas part of our job) and for reporting immediately anythingthat appears unsafe.
We all need to follow the F1® Health and Safety Policy and weshould ensure our contractors do too. Therefore, we need to be
confident that people acting for us have the right experienceand competence to fulfil their work, including having appropriate
safety records and standards.
A number of us travel regularly as part of our job - we must
do so responsibly and safely. At each event we have adesignated safety advisor whose details are set out in thetravel documents.

Q: My senior colleague engages a contractor to erect electronic		 signs at the races each year. I’ve been surprised at how 				 amateurish the contractor seems to be. The equipment
		 used to hoist the signs seems very basic and I’m worried a		 sign will be dropped. I’m not an expert though and don’t		 want to interfere. Should I raise it?

FURTHER INFORMATION:

F1® Health and Safety Policy
F1® Alcohol and Drugs Policy
F1® Alcohol and Drugs Screening Policy

A: Yes, if you have any concerns regarding safety always
		 speak up (see Asking for Help and Reporting Concerns)
		 and how to proceed practically.

Remember to be vigilant and to lookout for your colleagues.
Remember to be vigilant and tolook out for your colleagues. For
further guidance or advice pleasecontact the H&S advisor or HR(see Asking for Help and Reporting
Concerns).

21

HANDLING DATA ANDASSETS WITH INTEGRITY

DO THE RIGHT THING

Code of Conduct

HANDLING DATA AND ASSETS WITH INTEGRITYDATA PRIVACY AND
INFORMATION SECURITY
As part of our business activities, Formula 1® handles
confidential information and the personal and special category
data of individuals, including our employees and customers.
We have a duty to protect the privacy of those individuals by
ensuring that their data is kept confidential, secure and nolonger than is necessary. We must ensure we respect individuals’
rights relating to their data, such as the right of access.
Personal data is information that identifies an individual,such as a person’s name or email address.
Special category data is more private to the individual andincludes racial or ethnic origin, political opinions, religious beliefs,
trade union activities, physical or mental health, sexual life ordetails of criminal offences.

Q: A supplier has asked me to provide a customer list on a
		 USB stick. They need this urgently. The information
		 requested only relates to a limited number of customers so		 I could get this to the supplier in 5 minutes. Can I do this		 just this once?

FURTHER INFORMATION:

F1® Data Privacy Policy

A: Personal or special category data must never be		 transferred onto a USB stick - all transfers must be made		 through secure channels. You need to contact the		 Compliance Team in order to determine if this request is		 appropriate. If it is, the Compliance Team in consultation
		 with IT, will identify a safe way to provide this information.
		 See the F1® Data Privacy Policy.

If you handle personal or special
category data in your role, you musthave first read and understood the
F1® Data Privacy Policy.
If you are aware of a breach of data
privacy you have a responsibility toreport it to the Compliance Team assoon as possible.

23

Code of Conduct

HANDLING DATA AND ASSETS WITH INTEGRITY

INSIDER TRADING
If you are in possession of inside information of a company you
must not buy, sell or otherwise deal in that company’s shares.
Inside information is information that has not been made public
and may be share price sensitive – in other words, it may affect theprice of shares or related investments or influence a reasonable
investor’s decision to buy or sell shares or related investments.

Q: My sister wants to buy FWONK shares. I know I have		 inside information but I never talk to her about my work,		 so is this OK?

Inside information could be used to gain an unfair advantage inthe stock market and this is known as “insider trading” which
is a criminal offence in the UK, US and many other countries.

A: You must be sure that there is no information you have		 ever disclosed to your sister which could be viewed as		 inside information. You should ask your sister not to		 buy shares until you have discussed the situation with		 the Compliance Team, who will refer your query to		 Liberty Media for advice.

In the course of our work, we may become aware of inside
information about Formula 1®, Liberty Media or any othercompany we do business with. Such information should only be
discussed with other employees (and in certain circumstances,advisers) on a limited, “need to know” basis and must not beshared beyond this.

Q: I’ve come across some information about one of our		 business partners, a listed company, that I don’t think has
		 been announced yet. Can I suggest to my friends that they		 buy shares in that company?

From time to time you may be notified of a “black out” period
during which you must not deal in the shares of Liberty (including
any company within the corporate structure). This includes
Liberty’s Formula One Group shares which trade on NASDAQ
under the stock symbols FWONA, FWONK and FWONB.

A: No. Not only would this violate your confidentiality 				 obligations to Formula 1, but you could be charged with
		 illegal insider trading or other securities law violations.

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FURTHER INFORMATION:

Liberty Media Insider Trading Policy

Code of Conduct

HANDLING DATA AND ASSETS WITH INTEGRITYACCURATE RECORD KEEPING
We all have a responsibility to maintain full, accurate andhonest records of our business activities (including all
payments made or received, gifts or hospitality,
contributions to charities or social funds, conflicts ofinterest and due diligence).
We must never falsify our reports, records or expense claims,
or disguise the true nature or purpose of the relevantbusiness activity.
Q: I need to submit my expenses. I took some business partners
		 for dinner but have lost the receipt. Can I substitute my		 personal receipts of similar value to reclaim my expenses?
A: No. You cannot use a receipt that was for another		 expense. To do so would be to provide false and		 dishonest information. You should keep receipts for all
		 expenses incurred and only claim for expenses that you		 know are true and accurate.

SEC Filings and Public Disclosures
Formula 1® is committed to ensuring that any filing with theUnited States Securities and Exchange Commission (the “SEC”),
as well as other public disclosures by or on our behalf, are timely
and understandable and are fair, accurate and complete in allmaterial respects.
Formula 1 is subject to extensive and complex accounting
requirements. All of our books, records, accounts and financial
statements must be maintained in reasonable detail, must
appropriately reflect the business’ transactions and conform
both to applicable legal requirements and to Formula 1’s system
of internal controls.
You must never take any action intended to influence Formula 1’s
auditors in an improper manner or to influence the conduct ofan audit of Formula 1’s financial statements.
If you are involved in Formula 1’s disclosure process, you must
understand and comply with Formula 1’s disclosure controls
and procedures, including internal controls over financial
reporting (in each case to the extent relevant to yourresponsibilities), so that the reports and other documents filedwith the SEC will comply in all material respects with applicablesecurities laws and SEC rules. If you have authority regarding
those SEC filings or other public communications concerning
Formula 1’s business, results of operations, financial conditionor prospects you must consult with other Formula 1 employees
and take other appropriate steps to assure, to the extent
possible, that such disclosures are made in a timely fashion and,
when made, are accurate and complete in all material respects.

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If you are unsure about how torecord a transaction or haveconcerns about record-keeping or
accounting, you should contact theCompliance Team (see Asking for
Help and Reporting Concerns).

Code of Conduct

HANDLING DATA AND ASSETS WITH INTEGRITYASSET PROTECTION AND FRAUD
We all use and have access to Formula 1® property as part ofour jobs and have a responsibility to protect it.

Misuse of property can take many forms; examples include:

Formula 1 property includes the computers and mobile phones
we use for business purposes, office equipment as well as
intangible items such as intellectual property, computer systems
and confidential information.

• Sending Formula 1 documentation to your personal email
address;

We must protect Formula 1 property and ensure it is not
misused for personal gain or illegal purposes.

• Stealing supplies or equipment;• Misusing corporate credit cards, computers, mobile phones
and devices;• Submitting falsified expense claims;• Using company information without authority;• Retaining any benefit from a client or supplier that belongs
to Formula 1.
If you are aware of or suspect
any misuse of Formula 1®
property you must report it to
the Compliance Team.

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Code of Conduct

HANDLING DATA AND ASSETS WITH INTEGRITYINTELLECTUAL
PROPERTY RIGHTS
Formula 1® owns extensive rights in and to the Formula 1 brand,
including the rights to commercially exploit it worldwide.
Our Intellectual Property (“IP”) includes trade marks suchas word marks, logos, and event titles, and other IP such as
domain names, results and timing data, official type face, still
images; statistics; audio and visual content, official artwork,
and written content. Some examples of these are shown below.
Our IP is a valuable asset and critical to our business activities.
We offer our promoters, F1® event title partners, global
partners, suppliers, broadcasters and licensees the rights to use
our IP and associate themselves with our brand. We take theprotection of our brand and IP seriously by ensuring theirproper use and by preventing unauthorised use by third parties.

As a rule, our IP cannot be used by third parties without aspecific licence from us. However certain word marks canbe used editorially and by fans without requiring a licenceor permission.
Formula 1 is also committed to respecting the intellectual
property of others. Unauthorised use of third parties’
intellectual property can expose Formula 1 and individuals
within the organisation to legal action, damages, and fines.
We should only use it when we have secured the rights to do
so. If in doubt, please contact the Formula 1 Trademarks team.

FIA FORMULA ONE
WORLD CHAMPIONSHIP™

FURTHER INFORMATION:

F1® Social Media Policy
F1® Guidelines for the use of
trademarks and IP rights:
F1® Guidelines | Official Formula 1®
WebsiteIf you become aware that
Formula 1’s IP is being usedcommercially by anyone withoutauthorisation, please informthe Formula 1® Trademarks andCompliance teams.
Trademarks teamtrademarks@f1.com
Compliance teamcompliance@f1.com

FORMULA 1
BRITISHG AND PRIX

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Code of Conduct

DO THE RIGHT THING