Appendix
2016 Impact Report

Bloomberg Impact Report 2016

GUIDING PRINCIPLES OF BLOOMBERG EDITORIAL•

It isn’t news if it isn’t true. Accuracy is the most important principle in journalism. There is no such thing as being first withnews if we’re wrong.

•

Show, don’t tell. Support statements and assertions with facts, figures and anecdotes. Write with nouns and verbs; be sparing
with adjectives and adverbs.

•

News is a surprise. What do we know today that we didn’t know yesterday? That question will offer guidance when deciding
which facts to highlight first. Why are we reporting this? Why are we reporting this now? No story is worth writing unless weanswer these questions for our readers.

•Names make news. People want to read and hear about people—the actors and the victims. The bigger the name, the bigger
the audience.

•

Not invented here. We immediately report news from other organizations and then seek to advance the story. We don’t accept
the frequent lapse in journalism that if we didn’t break the news, it didn’t happen, and we should never fail to acknowledge who
did break the news.

•

Follow the money. Explaining the role of money in all its forms— from capital flows to executive compensation to the cost of an
acquisition to election spending—reveals the meaning of the news. We then examine how that information relates toshareholders, bondholders and anyone else with money at stake.

•

One story for all. Write with a style and simplicity that a layman can understand and a professional can appreciate.

•

The more we prepare, the luckier we will be. We develop the necessary sources and knowledge in advance so we can deliver
our best judgment when news breaks. That is what readers, listeners and viewers need most at the moment their interest is
greatest.

•

We adhere to the Five Fs. We strive to be the most Factual word on any topic, the First to report the news and the Fastest toreport the details. We should also be the Final word -- or the most definitive source -- on major events as well as the Future wordthat tells our audience what's next.

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016

LIST OF JOURNALISM & MEDIA AWARDS
Organization

Date

Winning Category

Article / Feature

Author/Recipient

Adweek 50

November-16

Most Indispensable
Marketing Execs Media &
Tech

N/A

Keith Grossman

Adweek/Fishbowl NY:
Ellie Award Winners

February-16

Single-Topic Issue

Code: An Essay

Bloomberg Businessweek

Bay Area Press Awards

Oct-16

1st place - Business/Tech
Story

Leaked Lyft
Document Reveals a
Costly Battle with
Uber

Eric Newcomer, Leslie
Picker

1st place - Series

The Startup Bubble
Starts to Deflate

Staff

2nd place - Feature/Light

Latter-Day
Carnegies
Bestowing Names
on San Francisco
Hospitals

Alison Vekshin

2nd place - News Story

Uber Raises
Funding at $62.5
Billion Valuation

Eric Newcomer

2nd place - Feature/Serious

A Sex Scandal
Rocks Stanford's
Business SchoolPeter Waldman

3rd place - Business/Tech
Story

Tesla Looks for
What Women WantDana Hull

3rd place - Series

California's Oil-Rich
Past and CleanTech Future

Lynn Doan, Mark
Chediak, Michael Marois,
Chris Martin, Harry Weber

BIMA Awards

July-16B2B Campaign

Media & Interaactive
DesignKinection

Creativity International

Jun-16

Silver Winner - Professional
Online Presentation

State of Media
Presentation

Creative team (Fernando
Mancuello)

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016

Deadline Club Awards

Editor & Publisher:
EPPY Awards

June-16

October-16

Bronze - Cards & Invitations

Bloomberg Pursuits
Baselworld Brochure

Creative team (Stephanie
Silvera)Bronze - Professional Direct
Mail

Bloomberg Pursuits
Mailer Series

Creative team (Fernando
Mancuello)

Silver Winner - Brochure B2B

Bloomberg RPM
Brochure

Creative team (Kim
Coyle)

Promotional Packaging

Bloomberg Pursuits
Baselworld Brochure

Creative team (Stephanie
Silvera)Direct Mail

N/A

Creative team (Kim
Coyle)

Finalist - Business Feature

Shadow Banker

Max Abelson

Winner - Arts Reporting“The Greatest
Museum Never
Known”

Peter Waldman, Golnar
Motevalli

Winner - Best Digital
Magazine

Bloomberg
Businessweek

Bloomberg Businessweek

Finalist - Best
Investigative/Enterprise
FeatureBloomberg Graphics

Finalist - Best Innovation
Project

Amazon Doesn’t
Consider the Raceof Its Customers.
Should It?
Decoding Big
Pharma’s Secret
Drug Pricing
Practices
How to Catch aSpoofer

Finalist - Best Use of
Data/Infographics

The Bloomberg
Carbon Clock

Eric Roston, Blacki
Migliozzi

Finalist - Best Use of
Data/Infographics

Who Marries
Whom?

Bloomberg Graphics

Winner - Best Overall
Website Design

Bloomberg News

Staff

Finalist - Best
Investigative/Enterprise
FeatureBloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Graphics

Matthew Leising, Mira
Rojanasakul, Adam
PearceBloomberg Impact Report 2016
Finalist - BestBusiness/Finance Website

Bloomberg News

Staff

Finalist - Best Business
ReportingMartin Shkreli: Big
Pharma’s Bad Boy

Excellence in Financial
Journalism Awards (NYState Society of CPAs)

April-16

Winner - Investigative

The Coyotes and theBanks

Christie Smythe, Keri,
Geiger, Paul Barrett,Robert Langreth,Rebecca Spalding, Devin
Leonard, AnnmarieHordern
Michael Smith, Esme E.
Deprez

FOLIO

April-16

Top Women in Media Rising Stars

N/A

Michele Chicoine

Top Women in Media Rising Stars

N/A

Courtney Carroll

Top Women in Media Rising Stars

N/A

Lauri Niedermaier

Top Women in Media Rising Stars

N/A

Ellen Bennett

Top Women in Media Entrepreneurs

N/A

Jacki Kelley

Top Women in Media Mentors

N/A

Laura Zelenko

Folio 100 List

N/A

Justin Smith

Folio 100 List

N/A

Jacki Kelley

Folio 100 List

N/A

Keith Grossman

Folio 100

October-16

Folio 30 Under 30

October-16

Folio 30 Under 30

N/A

Ben Katz

Foreign Press
Association (FPA)

November-16

Short-listed - Story of theYear for a full FPA member

The Story of Britain’s
Biggest InsiderTrading Trial

Suzi Ring, Liam Vaughan

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
Gerald Loeb Awards

June-16

Finalist - Commentary

Opening Remark
Columns

Peter Coy

Finalist - Explanatory
ReportingCode: An Essay

Paul Ford

Finalist Images/Graphics/Interactives

Bloomberg:
Interactive Graphics

Finalist - Beat Reporting

The Shale Boom
Blows Up

Christopher Cannon,
Patrick Clark, Keith
Collins, Jan Dash, Jeremy
Scott Diamond, Blacki
Migliozzi, Laurie Meisler,
Anders Melin, Adam
Pearce, Mira
Rojanasakul, Eric Roston,Alex Tribou, Yan Zhang
Dan Murtaugh, Lynn
Doan, Harry R. Weber,David Wethe

Finalist - Breaking News

Cable Cut

Finalist - Feature Story

The Passport KingHow Red Meat
Joined the 478 Other
Things That Might
Give You Cancer
N/A

Bloomberg Graphics

Cannes Flip Book

Creative

Global Editors Network(GEN): Data JournalismAwardsJune-16

Finalist - Data Visualisationof the Year (Large
Newsroom)

Hermes Creative Award

May-16

Platinum - Marketing
Materials

In-Plant Printing and
Mailing Association(IPMA)

May-16

Silver Winner - Booklets

Irish America

Malofiej International
Infographics Awards

Top 50 Power Women

March-16

David McLaughlin, Todd
Shields, Gerry Smith,
Lucas Shaw, Alex
Sherman, Ed Hammond
Jason Clenfield

Creative team for "RPM
Sales booklet"

Jackie Kelley

Bronze - Online Graphics:
FeaturesCourts Are Shaking
Up House Electionsin 2016

Alex Tribou, Adam
PearceBronze - Online Graphics:
FeaturesThis Is How Fast
America Changes Its
Mind

Alex Tribou, Keith Collins

Bronze - Online Graphics:
Features

Star Wars: The
Force Accounted

Jeremy Scott Diamond,Mark Glassman, Chandra
Illick, Chloe Whiteaker

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016

MIN Rising Stars

MIN Sales & MarketingAwards

December-16

December-16

Bronze - Online Graphics:
Features

How to Catch aSpooferMatthew Leising, Mira
Rojanasakul, Adam
PearceBronze - Online Graphics:
Portfolios

Why Climate
Change is True

Tom Randall, Blacki
Migliozzi, Eric Roston,

Silver Winner - Online
Graphics: Features

What’s ReallyWarming the World

Eric Roston, Blacki
Migliozzi

Winner - Climate Change
and Environmental
Commitment - Online

What’s ReallyWarming the World?

Eric Roston, Blacki
Migliozzi

Winner - Equality and
Women’s Promotion –OnlineThis Is How Fast
America Changes Its
Mind

Alex Tribou, Keith Collins

Winner - Rising Stars

N/A

Dave Giumara

Winner - Rising Stars

N/A

Tony Talal, Jack Sheldon

Winner - Sales Team Of The
Year

N/A

Mary Catherine Burdine

Winner - Sales Team Of The
Year

N/A

Alissa Spiwak

Co-winner - Total Integrated
ProgramUBS

N/A

Winner - Sales Team Of The
Year

N/A

Lindsey Nickens

MIN's Magazine MediaAwards

December-16

Best Of The Web - Best Ad
Operations TeamN/A

Ad Ops team (Megan
Latham)National Arts &Entertainment
Journalism Awards(NAEJ)

December-16

2nd place - Print:
Industry/Arts

Carnival Rocks the
Boat

Chris Palmeri

Finalist - Print: Industry/Arts

Hollywood Is
Running Out ofTombstones

Gerry Smith

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
2nd place - Any Medium:Industry/Arts

Viacom is Having a
Midlife Crisis

Felix Gillette, Lucas Shaw

2nd place - Online: Arts &Entertainment Feature

Disney’s Foreign
Curse Could End
With China Resort
Project
How the Lights
Almost Went Dark
on Oscar Winner‘Spotlight
ESPN’s Dilemma ina Mobile Age Where
Fans See Clips All
Day
The Godfather’Studio Is Hoping for
an Offer It Can’t
RefuseLucas Shaw

Chris Palmeri

Gold Winner - Best
Residential Mortgage or
Financial Real Estate
Magazine Story
Gold Winner - Best Online
Residential, Mortgage or
Financial Real Estate Story

N/A

John Gittelsohn

N/A

Prashant Gopal

Gold Winner - BestInternational Real Estate
Story

N/A

Neil Callanan, Suzi Ring

Gold Winner - Best Team
ReportN/AJohn Gittelsohn, Prashant
Gopal

Honoree - Best Economic
Analysis

N/A

Prashant Gopal

Silver Winner - Best Online
Commercial Real Estate
Story

N/A

Jennifer Oldham

Silver Winner - Best
Investigative Report orInvestigative Series

N/A

Heather Perlberg, John
Gittelsohn, Clea Benson

Silver Winner - Best Team
Report

N/A

Heather Perlberg,
Prashant Gopal, John
Gittelsohn

Finalist - Online:
Industry/Arts Hard News

Finalist - Any Medium:
Business

Winner - Print: Headline

2nd place - Journalist of theYear

National Association ofReal Estate Editors(NAREE): Real Estate
Journalism Awards

June-16

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Chris Palmeri

Gerry Smith

Chris Palmeri, Anousha
Sakoui, Lucas Shaw,David Gillen
Lucas Shaw

Bloomberg Impact Report 2016
National HeadlinerAwardsApril-16

1st place - Magazine
affiliated website

N/A

Ellen Joan Pollock, Jared
Sandberg

2nd place - Business News
Coverage, Commentary or
Columns

N/A

Matt Levine

National Press
Foundation

February-16

Finalist - Best Use ofTechnology in Journalism

Carbon Clock

Staff

New York Press Club

April-16

Finalist - Sports:
News/Magazine

A League of His
Own

Tariq Panja, Andrew
Martin, Vernon Silver

Winner - Infographics

Climate Change

Winner - Wires/Spot News

Shkreli, Drug Price
Gouger, Denies
Fraud and Posts Bail

Eric Roston, Blacki
Migliozzi, Mira
Rojanasakul, Adam
Pearce, Jan Dash, Yan
Zhang, Tom Randall
Keri Geiger, Christie
SmytheWinner - Wires/BeatCoverage of Auction
HousesKatya Kazakina

Newswomen's Club of
New York: Front Page
Awards

October-16

NIHCM Foundation
Journalism Awards

May-16

Finalist - Digital Media Awards

The Laws of Pharma
Pricing Physics

Robert Langreth, Blacki
Migliozzi, Cynthia Koons

NY Women in Film &Theater

December-16

Muse Award

N/A

Jacki Kelley

Online Media Awards (TheDrum)

June-16

Best use of photography

N/A

Simon Dawson

Online Media Awards (TheDrum)

June-16

Best National/World News Site

N/A

N/A

Best Business/Finance News
Site

N/A

N/A

Media Sales Individual

N/A

Rob Huckin

Finalist - Explanatory
Reporting/Large

What is CodePaul Ford

Online News
Association: ONA
AwardsAugust-16

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
August-16

Finalist - Innovation in
Investigative Journalism

Amazon Doesn't
Consider the Rate of
Its Customers

David Ingold, Spencer
Soper

August-16

Finalist - General
Excellence/Large

Bloomberg

N/A

People's Telly Awards(US)

December-16

5 awards - Custom Content

N/A

N/A

Peter Lisagor Awards

May-16

Finalist - Best Science,
Health, Technology or
Environment Reporting

Next Frontier ofCybercrime: Hackers
in Your IV Drip

Monte Reel, Jordan
Robertson

Finalist - Best Business orConsumer Reporting

McRevolt: The
Frustrating Life of
The McDonald’s
Franchisee
The Truth About the
Safety Ratings That
Sell Football
Helmets
Space: The
Billionaires’
Playground

Bryan Gruley, Leslie
PattonFinalist - Best In-Depth
Reporting in a Business
Magazine or Newspaper

Next Frontier ofCybercrime: Hackers
in Your IV Drip

Monte Reel, Jordan
Robertson

Finalist - Online: BestBusiness or Consumer
Reporting

McRevolt: The
Frustrating Life of
The McDonald’s
Franchisee
The Truth About the
Safety Ratings That
Sell Football
Helmets
Next Frontier ofCybercrime: Hackers
in Your IV Drip

Bryan Gruley, Leslie
PattonWinner - Online: Best
Feature Story or Series

For 725 Million, aTexas Rance theSize of a Nation

Bryan Gruley

Winner - Print: Magazines –Commentary

N/A

Peter Coy

Winner - Print: Magazines –FeatureGravity Payments’
CEO Dan Price

Karen Weise

Finalist - Best Sports Story

Finalist - Best Technology
Reporting

Finalist - Online: BestBusiness or Consumer
ReportingWinner - Best All Media:
Best Single Story Feature

SABEW Best in
Business Contest

August-16

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bryan Gruley

Julie Johnsson, Dana Hull

Bryan Gruley

Monte Reel & Jordan
Robertson

Bloomberg Impact Report 2016

Scripps Howard Awards

March-16

Shriram Sanlam Award
for Excellence inFinancial Journalism

May-16

SoCal JournalismAwardsJune-16Society of American
Business Editors &Writers (SABEW): Bestin Business Contest
Society of Publication
Designer (SPD) Awards

Winner -Print: Magazines –General Excellence

N/A

N/A

Winner - News Agencies:
Commentary"Matt Levine on WallStreet”

Matt Levine

Finalist - News Agencies:
Explanatory

Free Markets with
ChineseCharacteristics

Dune Lawrence

Finalist: Print – Magazines –FeatureThe Passport King

Jason Clenfield

Finalist - William Brewster
Styles Award forBusiness/Economics
Reporting
Runner up - Sectoral Issues

Code: An Essay

Paul Ford

Pilots Qualified to
Fly in India After 35
Minutes in Air

Kumar Singh

2nd place - Magazine
FeatureCarnival Rocks the
Boat

Christopher Palmieri

2nd place - Magazine
Entertainment Feature

The Dothraki
Industry

Lucas Shaw

1st place - Online Soft News
FeatureCalifornia Dreaming:
Record $500 Million
Tag on L.A. HomeJohn Gittelsohn

2nd place - Business:
newspapers

Star Wars Opens
with RecordBreaking $238
Million Ticket Haul
What Is CodeAnousha Sakoui,
Christopher Palmeri, Jeff
Green

Howard’s End?:
Sirius XM
Contemplates Life
Without Its Biggest
Act
William Wegman
Photography in the2015 Holiday Gift
Guide
The Future of One
Country, Two
Systems

Felix GilletteMay-16

Winner -Innovation

May-16

Gold Winner - Feature
LayoutSilver Winner - PhotographySociety of Publishers inAsia (SOPA) Awards

June-16

Award for Excellence Editorial Cartooning

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Paul Ford

NA

Chris Brummitt, Archana
Chaudhary, Rajesh

Bloomberg Impact Report 2016
Award for Excellence Excellence in Opinion
Writing

The Roots of Rage

Award for Excellence Excellence in Reporting on
the Environment

Farmers Driven
From Homes ‘Like
Pests’ by Dam
Projects
Wife on Run From
Pakistan Honor
Killing Says On One
Can Escape
Loan Sharks: How
Two Guys From
Brooklyn Lost God
and Found $40
Million
How Trump Invented
Trump

Honoree - Excellence inReporting on Women’sIssuesSociety of the SiluriansAward

May-16

Medallion - Magazine:
Investigative and PublicService
Medallion - Magazine:
Feature Writing

South Asian Journalist
Association: SAJA
AwardsJune-16

Finalist - Daniel Pearl Award

June-16

December-16

Zeke Faux

Max Abelson

Khurrum Anis

2nd place - Magazines:
Feature, under 1,000 words

Carnival Rocks the
Boat

Chris Palmeri

Magazines – Entertainment
News or Feature

The Dothraki
Industry

Lucas Shaw

Finalist - Online: Soft News
FeatureCalifornia Dreaming:
Record $500 Million
Tag on L.A. HomeJohn Gittelsohn

2nd place - Daily/weekly
newspapers - Business“Star Wars Opens
with RecordBreaking $238
Million Ticket Haul”
N/A

Anousha Sakoui,
Christopher Palmeri, Jeff
Green

2nd place - Print: Any Outlet– Sports

Finalist - Radio: Hard Newsor News Feature

Telly Awards (US,EMEA, APAC)

Khurrum Anis, Kamran
HaiderWife on Run From
Pakistan Honor
Killing Says No One
Can Escape
Robot Invasion
Undercuts Modi’s
Quest to Put Indians
to Work
The Bulgarian Duo
Leading an Indoor
Rock Climbing
Revolution
Black Cop Faces
Danger, Anti-Police
Sentiment

Winner - Feature Story

Southern California
Journalism Awards

Pankaj Mishra

25 awards - Custom Content

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Natalie Pearlson

Esme Deprez

Esme Deprez

N/ABloomberg Impact Report 2016
University of Michigan:
Livingston Awards

June-16

Finalist - International
Reporting

The Price of Life: In
China, Cancer
Patients Struggle

Natasha Khan, Hui Li

Variety

October-16

Power of Women

N/A

Jacki Kelley

Webby Awards

May-16

Honoree - Best
Home/Welcome Page

Honoree: Bloomberg
Professional Service

N/A

Honoree - Best Use of Videoor Moving Image

Bloomberg Pursuits:
Made Digital Video
SeriesN/A

Honoree - Documentary:
SeriesBloomberg Pursuits:
Made Digital Video
SeriesN/A

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

2016
Impact report
Appendix

PeopleOur Equal Employment Opportunity Policy
Strategic Diversity and Inclusion Partners
Bloomberg Global Resource and Information Core Guide

Bloomberg Impact Report 2016

OUR EQUAL EMPLOYMENT OPPORTUNITY POLICYAs stated in Bloomberg’s Global Resource and Information Core Guide:
Bloomberg is committed to a policy of attracting, retaining, developing and promoting the most qualified individuals without regard torace, color, religion or belief, sex, national or ethnic origin, ancestry, age, marital status, sexual orientation, gender identity, genetic
predisposition or carrier status, protected veteran status/service, pre-JVA veteran status, physical or mental disability, or any otherclassification protected by applicable law. As such, Bloomberg is committed to treating all applicants and employees in a nondiscriminatory manner with respect to the terms and conditions of employment.
This policy governs all aspects of employment, including recruitment, selection, job assignment, promotion, lay-off, recall from lay-off,training, education, social and recreation programs, transfer, compensation, discipline, termination, and access to benefits.
Bloomberg will not discharge or in any other manner discriminate against employees or applicants because they have inquired about,
discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to thecompensation information of other employees or applicants as part of their essential job functions cannot disclose the pay of other
employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in
response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing or action, or (c) consistent with
Bloomberg’s legal duty to furnish information.
Employees are prohibited from engaging in any type of unlawful discrimination. Anyone who believes that he or she has been thesubject of discrimination should contact his or her manager, a Human Resources representative, Ken Cooper, Beth Mazzeo,
or Peter Grauer.

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016

IN 2016, WE COLLABORATED WITH KEY STRATEGIC DIVERSITY AND INCLUSION PARTNERS TO DRIVE INNOVATION IN
THE FIELD AND SPEED OUR JOINT SUCCESS. LISTED HERE ARE SOME OF THOSE PARTNERS:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

30% Club
ACCJ: The American Chamber of Commerce in JapanASCEND
Association of Latino Professionals For America (ALPFA)
Catalyst
Center for Talent Innovation
Council of Urban Professionals (CUP)
Emma Bowen Foundation
Executive Leadership Council (ELC)
Forte Foundation
FourBlockJumpstart
LGBT Film Festival in Japan
Latin American Women's Rights Service (LAWRS)
Lesbians Who Tech
Lime Connect
National Association of Black Journalists (NABJ)
National Association of Hispanic Journalists (NAHJ)
NCWIT
Opportunity Now
Out for Undregrad Technology Conference (OUTC)
Out in Tech
Outstanding
PFLAG
Posse
PrepforPrep
SEO London
South Asian Journalists Association (SAJA)
T.Howard Foundation
The Women's Foundation
Tannenbaum
Toigo Foundation
UN Women
USBLN
Veterans Aid
Veterans Job Mission (fka 100k Job Mission)
Veterans on Wall Street (VOWS)
Women's Bond Club
Women's Foundation

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reservedPrinciples

Policies
Procedures
Global Resource and Information
Core GuideTable of Contents
1.

Important Information about This Guide and Your Employment ................................................... 1

2.

General Human Resources Policies ................................................................................................. 2
Employee Status ....................................................................................................................................... 2
Background Checks .................................................................................................................................. 2
Effective Global Working and Flexible Work Arrangements ..................................................................... 2
Equal Employment Opportunity ................................................................................................................ 2
Reasonable Accommodation .................................................................................................................... 3
Sexual and Other Unlawful Harassment ................................................................................................... 3
Communication and Employee Problem Solving ...................................................................................... 5
Violence in the Workplace......................................................................................................................... 5
Reporting Relationships ............................................................................................................................ 5
Work Authorization .................................................................................................................................... 6
Internal Job Postings ................................................................................................................................. 6
Relocation and Transfer ............................................................................................................................ 7
Travel and Business Expenses ................................................................................................................. 7
Leaving the Company ............................................................................................................................... 7

3.

Employee Responsibilities................................................................................................................. 8
General Standards of Conduct and Ethical Behavior ............................................................................... 8
Conflicts of Interest ................................................................................................................................. 11
Misuse of Confidential Information and Trading Restrictions ................................................................. 12
Gifts ......................................................................................................................................................... 15
Social Media Activities ............................................................................................................................ 15
Personal Data and Information ............................................................................................................... 15
Announcements, References, and Other Requests for Information ....................................................... 17
Access, Solicitation and Distribution ....................................................................................................... 17
Hosting Personal Guests ........................................................................................................................ 18
Hosting External Events at Bloomberg ................................................................................................... 18
Substance Abuse and Testing ................................................................................................................ 19
No Smoking ............................................................................................................................................. 19
Political Contributions .............................................................................................................................. 20
Use of Mobile Communications, Texting and Hand-Held Devices While Driving ................................... 20

4.

Intellectual Property .......................................................................................................................... 20

5.

Bribery and Corruption ..................................................................................................................... 20

6.

Anti-Slavery ....................................................................................................................................... 21

7.

Absences, Time Off, and Holidays .................................................................................................. 21
Absences and Tardiness......................................................................................................................... 21
Paid Time Off/Holidays/Leaves ............................................................................................................... 22

Jury Duty/Civic Duty Leave ..................................................................................................................... 22
8.

Security, Facilities, and Equipment ................................................................................................ 22
Company Equipment............................................................................................................................... 22
Use of Software and Electronic Communications ................................................................................... 23
Telephone Monitoring ............................................................................................................................. 26
Closed Circuit Television (CCTV) Systems ............................................................................................ 26
Protection of Published Materials ........................................................................................................... 27
Personal Property ................................................................................................................................... 27
Property Inspection ................................................................................................................................. 27
Security ................................................................................................................................................... 27
Health and Safety.................................................................................................................................... 27

9.

Employee Services ........................................................................................................................... 27
Employee Assistance Program ............................................................................................................... 27
Out of Office System ............................................................................................................................... 28

10.

Employee Benefits ........................................................................................................................ 28

CONTACT SHEET ...................................................................................................................................... 29
EMPLOYEE ACKNOWLEDGEMENT ........................................................................................................ 30
APPENDIX A: Key Definitions .................................................................................................................. 31

1. Important Information about This Guide and Your Employment
This Global Resource and Information Core Guide (the "Guide") and, where applicable, thesupplement specific to your region, are found on HR<GO>. They are designed to acquaint you
with Bloomberg L.P. and its subsidiaries and affiliates (“Bloomberg” or the “Company”) and toprovide you with supplemental information about your working conditions, benefits,
responsibilities, and some of the policies affecting your employment. This Guide and any
corresponding supplement are applicable to full-time and part-time employees only. You should
read, understand, and comply with all provisions of this Guide. You should also consult youroffer letter and/or employment contract, where applicable, for additional terms and conditions
that may apply and supplement the terms herein.
Failure to comply with this Guide and any referenced policies and/or underlying procedures,
including the Client Data Principles and related policies and procedures, or any othercompany policy, may result in significant negative impact to Bloomberg, and may give rise tocivil and/or criminal liability.
All managers and team leads (“Managers”) shall take appropriate action to correct violations of
this Guide and/or any underlying policies or procedures, including the Client Data Principles andrelated policies and procedures. In addition, individuals found to have violated the Guide or the
Client Data Principles or related policies, may be subject to disciplinary action which shall beconsistent with the severity of the incident, and to the extent permissible by local law, which
may include, but is not limited to:•

Loss or reduction in compensation;•

Loss or diminishment of advancement opportunities;•

Dismissal;•

Cancellation of contracts;•

Legal prosecution; and•Other actions as deemed appropriate by Bloomberg.

No guide can anticipate every circumstance or question about policy. As such, we expect ouremployees to exercise good judgment in their behavior, and should an employee become awareof behavior by others that appears to violate Company policy or which seems questionable, it
should be reported. In addition, as Bloomberg continues to grow, the need may arise, andBloomberg reserves the right, to revise, supplement, or rescind any policies, procedures, or
portion of this Guide at any time as it deems appropriate, in its sole discretion, as permitted byapplicable law. Since the hard copy of the Guide shall only be re-distributed periodically, themost current version will always be available under HR<GO> or IDOC<GO> for your region on
the terminal.

12. General Human Resources Policies
Employee Status
Bloomberg is a large organization with fluctuating workforce needs. Please take the time toacquaint yourself with your employee status in your contract, where applicable and/or as set
forth in the supplement specific to your region. If you have questions about your employee
status, please contact your Manager or Human Resources.
Background Checks
In an effort to reduce operational risk, newly hired employees must, subject to applicable law,undergo and pass a background check prior to commencing employment with the Company.
Some circumstances, including hiring and internal transfers into certain sensitive positions, may
require increased scrutiny, such as additional background screenings, reference checks, credit
checks, or attainment of security clearances, depending on the level of information accessafforded to the newly hired or transferred employee with the Company and applicable law.
Effective Global Working and Flexible Work Arrangements
Bloomberg seeks to support our employees’ abilities to manage both their work and personal
responsibilities. We recognize that throughout an employee’s career a formal flexible working
arrangement may be needed, or that on an ad hoc basis, some form of informal flexibility may
be necessary. Varying work hours or work location provides an opportunity to ensure that bothbusiness objectives and personal needs can be met through creative ways of working.
Bloomberg will consider requests for a formal flexible work arrangement on a case-by-casebasis and retains sole discretion in deciding whether such requests will be granted, as permitted
by applicable law. In making its decision, Bloomberg will consider a number of factors, including,but not limited to, the impact that a flexible schedule would have on the Company’s business,
operations, and ability to service its customers; the effect that the request would have on theemployee’s co-workers; the reason for the request, only if the request is to work from home;whether there are any other reasons for refusing or granting the request; and the impact on theemployee if the request is refused. Compensation for part-time work will be commensurate withthe role being performed and pro-rated according to time worked. The full flexibility policy andrelated forms can be found at HR<GO> on the terminal.
Equal Employment Opportunity
Bloomberg is committed to attracting, retaining, developing and promoting the most qualified
individuals without regard to race, color, religion or belief, sex, national or ethnic origin,ancestry, age, marital status, sexual orientation, gender identity, genetic predisposition or carrier
status, protected veteran status/service, pre-JVA veteran status, physical or mental disability, or
any other classification protected by applicable law. As such, Bloomberg is committed to2treating all applicants and employees in a non-discriminatory manner with respect to the terms
and conditions of employment.
This policy governs all aspects of employment, including recruitment, selection, job assignment,
promotion, lay-off, recall from lay-off, training, education, social and recreation programs,
transfer, compensation, discipline, termination, and access to benefits.
Moreover, Bloomberg will not discharge or in any other manner discriminate against employees
or applicants because they have inquired about, discussed, or disclosed their own pay or thepay of another employee or applicant. However, employees who have access to thecompensation information of other employees or applicants as part of their essential job
functions cannot disclose the pay of other employees or applicants to individuals who do not
otherwise have access to compensation information, unless the disclosure is (a) in response toa formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing or
action, or (c) consistent with Bloomberg’s legal duty to furnish information.
Employees are prohibited from engaging in any type of unlawful discrimination. Anyone who
believes that he or she has been the subject of discrimination should contact his or her
Manager, a Human Resources representative, Ken Cooper, Beth Mazzeo, or Peter Grauer.
Reasonable Accommodation
In furtherance of its commitment to EEO, it is also Bloomberg’s policy to provide reasonableaccommodation for individuals with disabilities to enable performance of the positions for which
they are applying, or in which they are employed, where possible. Employees requesting areasonable accommodation should enter an SDSK ADD ASKH ticket under the sub-category“medical accommodation.” Employees who are requesting a reasonable accommodation that is
not related to a disability should enter an SDSK ADD ASKH ticket under the sub-category “nonmedical accommodations”.
Please be aware that employees’ requests will result in an interactive process with theCompany to determine, in accosrdance with local law, whether the accommodation requested isreasonable, whether another accommodation may be more appropriate and/or whether therequested accommodation would create a disproportionate or undue hardship for the Company.
Sexual and Other Unlawful Harassment
Anti-Harassment Policy
Bloomberg is committed to providing employees with a professional working environment that is
free from all forms of discrimination and harassment as defined under applicable law(“Discrimination” and “Harassment”). Harassment of, or Discrimination against, an individual orgroup on the basis of race, color, religion or belief, sex, national or ethnic origin, ancestry, age,marital status, sexual orientation, gender, gender identity, gender expression, genetic
predisposition or carrier status, veteran status, mental and physical disability, medical condition,or other classification protected by law in your region, is prohibited. Harassment includes
conduct that denigrates or shows hostility or aversion towards an individual based on aprotected classification that (i) adversely affects such individual’s employment opportunities or3

working relationship with the Company, (ii) has the purpose or effect of unreasonably interferingwith an individual's work performance, or (iii) creates an intimidating, hostile or offensive working
environment.
Harassment may take different forms, and may involve, but is not limited to, visual displays,
suggestive or offensive remarks or jokes, slurs or epithets of any kind, gestures, unwelcome
sexual advances or demands, propositions, or unwanted physical contact. Whatever form ittakes, the Company will not permit any employee to harass others with whom he or she hasbusiness interactions, including, but not limited to other employees, customers and vendors, or
permit any outsider to harass its employees. This is true, not only in the workplace, but in any
work-related setting including business trips and business-related social events. All employees
must comply with this policy and take appropriate measures to ensure that such conduct does
not occur.
Reporting and Investigation
It is the responsibility of every employee to further the implementation of the Company’s policies
forbidding Discrimination and Harassment and to ensure compliance within each business unit.
In an effort to avoid any misunderstandings and foster open communication in the workplace,
employees should, but are not required to, communicate their discomfort to those whom they
feel are engaging in inappropriate conduct. Employees who believe they have been subjected to
any kind of Discrimination or Harassment, whether or not they have confronted their alleged
discriminator or harasser, and employees, especially Managers, who witness or are aware of
discrimination or harassment, must immediately notify their Manager (provided he or she is not
the alleged discriminator or harasser) or their Human Resources Relationship Manager, Ken
Cooper, Beth Mazzeo, or Peter Grauer. Bloomberg will promptly investigate any complaint, andsuch investigation will, to the maximum extent feasible, remain confidential, on a strict need-toknow basis. However, investigation of such complaints may require disclosure to the accused
individual and to other witnesses in order to gather pertinent facts. At the conclusion of its
investigation, the Company will take whatever action, if any, it believes appropriate under thecircumstances or to prevent the occurrence of such conduct in the future. In addition,
employees are prohibited from making knowingly false reports.
Non-Retaliation
It is unlawful and expressly against Company policy for any person to retaliate against any otherperson for making a complaint of Discrimination or Harassment, or for cooperating in an
investigation of any allegations of Discrimination or Harassment. Accordingly, individuals whoreport incidents of Discrimination or Harassment, or who cooperate in an investigation regarding
any such allegations will not be subject to any form of retaliation. An employee who believes
that he or she has been retaliated against, or who believes that he or she has witnessed any
form of unlawful retaliation, is required to report it immediately to his or her Manager (provided
he or she is not the alleged retaliator), a Human Resources representative, Ken Cooper, Beth
Mazzeo, or Peter Grauer. The reporting and investigation of allegations of retaliation will follow
the procedures set forth above for the reporting and investigation of Discrimination andHarassment.
4

Communication and Employee Problem Solving
For Bloomberg to succeed, we all must effectively and openly communicate with one another.
Since information is only as good as its source, we encourage you to consult your Manager, thisGuide, or Human Resources should you have any questions.
Since we recognize that no job or organization is perfect and that problems or
misunderstandings may arise from time to time, we are committed to working with our
employees to solve our problems and learn from our mistakes. Employees experiencing any
problems or complaints regarding the application of Company policies, payment of wages,
unlawful Harassment or Discrimination as set forth above, discipline, or other concerns areencouraged to confer with their Manager to resolve such issues. Thereafter, if the issue is not
resolved, or if the problem involves their Manager, employees are encouraged to contact a
Human Resources representative, Ken Cooper, Beth Mazzeo, or Peter Grauer, without fear of
reprisal. The Company wants to listen to and handle your problems internally, but needs yourcooperation to make the problem solving procedure work.
Violence in the Workplace
Bloomberg is committed to maintaining a working environment which is free from all forms ofviolence, including both physical and verbal offenses. Bloomberg does not tolerate violence or
the threat of violence against any employee, client, vendor, visitor or other individual in, or
arising out of, the workplace, or through Bloomberg’s communication systems. This prohibition
also includes statements made in jest, horseplay, or any activity which can be perceived asintended to, or which may potentially result in, physical or psychological harm to any individualor physical damage to Bloomberg property. Employees aware of any threat (expressed or
implied) or act of violence must immediately report such conduct to their Manager, Security, or
Human Resources.
Bloomberg will promptly investigate any report of any act of violence, and such investigation will,to the maximum extent feasible, remain confidential, on a strict need-to-know basis. However,investigation of such complaints may require disclosure to the accused individual and to other
witnesses in order to gather pertinent facts. At the conclusion of its investigation, the Company
will take whatever action, if any, it believes appropriate under the circumstances or to preventthe occurrence of such conduct in the future, which may include alerting the appropriate
authorities. The Company will not tolerate retaliation against any individual who reports
workplace violence or the threat of violence. Employees are also prohibited from knowingly
making false reports.
Reporting Relationships
While it is not Bloomberg's intent to unreasonably delve into the personal lives of its employees,
many problems are caused when employees are involved in personal relationships (including,but not limited to, being related by blood or marriage or having a romantic relationship of anykind) with other employees, Contingent Workers or vendors. Such problems include but are notlimited to conflicts of interest, the appearance of favoritism and/or coercion, exposure to rivalry
5and discord, work scheduling conflicts, access to otherwise unavailable information, theundermining of the integrity of the Company’s operations and difficulties in discipline, andperformance assessment. In order to avoid preferential treatment based on familial relationships
and the appearance of impropriety, and to maintain appropriate financial controls, the Company
generally prohibits the hiring of any relative of current employees, Contingent Workers orvendors (with the exception of individuals who are to be engaged as interns), in accordancewith applicable law. For purposes of this policy, "relative" shall be interpreted to include, for boththe employee, Contingent Worker or vendor and his or her spouse, domestic partner or
fiancé/fiancée, any of the following relations: grandparents, parents, siblings, children,
grandchildren, aunts, uncles, nieces and nephews, and first cousins, and any of their respective
spouses, domestic partners or fiancés/ fiancées. Furthermore, any employees involved in apersonal relationship with each other or with a Contingent Worker or vendor are prohibited frombeing in a direct reporting relationship or in the chain of command of one another, or otherwise
participating in employment decisions involving one another. Employees must immediately
notify Human Resources of any circumstances in which they or other employees may be in
violation of this policy. If the Company, in its sole discretion, believes that personal relationships
between employees, Contingent Workers or vendors directly or indirectly affect its business, theCompany will resolve the situation as it deems necessary, including, but not limited to, reassignment, transfer, deciding not to hire a candidate and/or termination of
employment/engagement.
Work Authorization
All employees must possess valid work authorization at all times. Every new employee must
present such work authorization to Human Resources upon hire and every existing and/ortransferring employee must secure the appropriate work authorization upon the expiration ofcurrent authorization and upon relocation of his or her employment.
In some circumstances Bloomberg may cover the costs for the procurement of permanent
resident status, although in doing so employees must use the Company's legal counsel.
Employees may be asked to sign a permanent resident sponsorship agreement before
Bloomberg will proceed with filing and incurring costs for permanent residence applications. For
further details, contact Human Resources.
Internal Job Postings
Bloomberg encourages employees to develop their careers in many ways, including providing
opportunities to apply for other positions within the Company. Most open positions will be listed
on both www.bloomberg.com and the career portal at PATH <GO>.
Employee Eligibility for Internal Mobility
In order to be eligible to apply for or to be considered for an internal role, employees must havea minimum of 18 months of service in their current role and must be in good standing (e.g., mustmeet or exceed the expectations of their current role, uphold Bloomberg’s core values, have no6

performance concerns, etc.). Exceptions to the 18 months service requirement will be reviewed
on a case-by-case basis and may be approved at the business' discretion.
Employee Communication with Manager Policy
Department Managers (direct manager and skip-level manager) will receive a notification whenan employee submits a formal application for an open job requisition via PATH<GO>. Informal
discussions between an employee and an internal recruiter or hiring manager are encouraged inadvance of the formal application to determine the interest level of both parties.
Employee Transition Policy
Employee transfers will take place as soon as 30 days from the time an offer is extended but nolonger than 90 days unless other arrangements are agreed upon by the receiving and current
Managers.
Relocation and Transfer
Where job opportunities exist outside the employee's current location, Bloomberg will, at its
discretion, provide relocation assistance to support employees with their move and transition to
the new location. Relocation assistance may vary, based on the reason for the transfer and inline with the needs of the business. In the event the employee leaves the Company within a
specified period of time following relocation, the employee may be obligated to pay back a prorated portion of the relocation assistance received. Failure to repay the amount due may resultin legal action taken by the Company against the employee. Please contact your Human
Resources Relationship Manager for any questions regarding relocation assistance.
Travel and Business Expenses
Bloomberg recognizes that many employees incur travel and business expenses in the courseof performing their jobs. Given such, employees will be reimbursed for actual, reasonable andnecessary expenditures incurred while travelling and conducting business for the Company,
provided that such expenses were incurred in accordance with Bloomberg’s policy. For further
details, see EXPT<GO>, TNE<GO> on the terminal, enter a CIAO ticket, or contact the TNE
team.
Leaving the Company
Employees who resign from the Company should consult their contract, where applicable, forthe appropriate notice period. Employees who are at-will are asked to provide their Manager
and/or a Human Resources representative with two weeks’ advanced written notice, or withwhatever notice may be prescribed by applicable law, of their intended resignation. Employees
are to complete an exit interview with Human Resources prior to leaving.
Employees who resign (or who give notice of their intention to resign), or whose employment isterminated (or who have been given notice of the termination of their employment), prior to the
payout date of their incentive compensation, will not be eligible to receive their incentive
compensation, or any portion thereof.
7

Employees who leave the Company for any reason are required to return all Company property,
including, but not limited to, such items as identification cards, resource and information guides,
laptop computers, telephones, cellular and mobile devices, beepers, contact lists, software,books, and computer equipment; to remedy all outstanding loans (including repayment of any
tuition or relocation expenses that are owed to the Company, per the applicable policy, at thetime of employee’s resignation), expense reports and credit card bills; and to complete theapplicable benefit forms. In addition, no data of any kind, including, but not limited to, Bloomberg
intellectual property and Client Data, may be taken or disclosed by employees leaving theCompany. Please see the Client Data Classification Policy at POLY<GO> for additional
information.
Because Bloomberg values the loyalty of its employees, it will not normally rehire employees
who leave the Company to work for another company. In some situations, however, Bloomberg
may consider rehiring individuals who leave the Company for personal reasons such as healthproblems, to raise a family, to care for a family member, or to attend school.

3. Employee Responsibilities
General Standards of Conduct and Ethical Behavior
Employees have an obligation to conduct themselves and our business with the highest ethicalstandards, with integrity, and within guidelines that prohibit actual or potential conflicts ofinterest or the perception of impropriety. This high degree of ethics imposed upon us applies toeverything we do and can have serious implications and repercussions to Bloomberg's
reputation and business dealings. It is imperative that all employees are in compliance with
Company standards, policies and procedures relating to conduct, ethics, integrity, objectivity,
confidentiality, Client Data, use of inside information and conflicts of interest contained within
this Guide and as defined in the Confidentiality Agreement or similar provisions executed at thestart of employment or during employment. Much like Bloomberg takes a proactive, thoughtful,and thorough approach to solving client problems, we expect our employees to exercise good
judgment and diligence in the handling of sensitive material, including Client Data. Our
employees’ thoughtful prudence is critical to protecting Bloomberg’s and our client’s businessinterests. Any employee who has a question about whether a situation he or she is in, or may
enter into, may violate Bloomberg’s standards of conduct should speak to his or her Manager, a
Human Resources representative, Ken Cooper, Beth Mazzeo, or Peter Grauer.
In support of our Standards of Conduct and Ethical Behavior and to maintain Bloomberg’s
integrity, we provide an anonymous Bloomberg Hotline, which is available 24 hours a day, 7days a week at +1-212-617-1595 ((801)1595) or +1-800-777-7217 (toll free in the U.S.), forindividuals to report misconduct or unethical behavior, or to ask whether a particular situation
constitutes misconduct or unethical behavior. All calls are confidential, and employees canchoose to make their calls anonymously. Employees have an obligation to report a suspicion or
knowledge of misconduct, and failure to do so constitutes a violation of our policy. Bloomberg
prohibits retaliation against an employee who in good faith raises a concern or reports
suspected or actual misconduct. Issues raised on the hotline will be forwarded to, andaddressed by the appropriate individuals within the Company.
8

Depending on position or department, standards, guidelines and policies other than those set
forth below may also apply, and will be either discussed with, or distributed to employees by
their Department Manager. In this regard, Bloomberg has promulgated Client Data Principles(“Principles”) to inform and guide decisions made throughout Bloomberg by our employees,
contractors, and temporary staff about data we collect from our clients and end users throughtheir use of Bloomberg's products and services ("Client Data"). The Principles and related
policies can be found at POLY<GO>.
The following list outlines general standards of conduct and behavior which is not acceptable at
Bloomberg. We expect our employees to avoid the following types of behavior. Because it is notpossible to list every type of inappropriate conduct, the following list is not exhaustive nor is it alimitation on Bloomberg's right to discipline or terminate its employees. Therefore, employees
should talk to their Managers or Human Resources if unsure of what to do in a given situation.
That being said, we expect our employees to exercise good judgment, and should an employee
become aware of behavior that appears violative of Company policy or which seems
questionable, he or she must immediately report such conduct to his or her Manager, Security,or Human Resources:
1. Dishonesty, embezzlement, theft, including, but not limited to theft of information or time,
unauthorized removal or possession of property, or conviction of a crime.
2. Fraud or knowing entry of false or misleading information in the Company’s books orrecords, or information systems.
3. Misrepresentation, either verbal or written, or falsification of Company documents
including, but not limited to, employment applications.
4. Immoral, unethical, or indecent conduct.
5. Insubordination, including, but not limited to, refusal to perform work assigned as well as
disrespectful conduct toward superiors, co-workers, suppliers, or customers.
6. Unauthorized use, possession, distribution, purchase or sale of, or impairment causedby controlled dangerous substances or alcohol on Company time, in Company facilities,
or when acting as a Company employee.
7. Unlawful Discrimination or Harassment against others including, but not limited to, coworkers, subordinates, vendors, contractors, suppliers or customers.
8. Accepting employment with, conducting business for, or providing services to any
person or entity other than Bloomberg, even on non-Bloomberg time, without
Bloomberg’s prior written approval. This prohibition includes, but is not limited to, acting
as an employee, independent contractor, self-employed person or agent of any othercompany; serving on the board of directors of another company or organization; or
engaging in your own commercial endeavor. Any employee wishing to engage in any
activity must first submit an SDSK ADD ASKH ticket setting forth in detail the nature of9the proposed activity, and detailing why it would not interfere or conflict with theemployee’s obligations to Bloomberg. Human Resources will provide the employee withwritten confirmation if his or her request is approved. Bloomberg reserves the right, in its
sole discretion, to deny any such request.
9. Sabotage, loss, or damage to property or merchandise of the Company, clients, coworkers, vendors or contractors.
10. Excessive or otherwise improper personal use of Company equipment, facilities orservices, including, but not limited to, electronic or voice mail, the terminal, IB<GO>,
MSG<GO>, the Internet, computers (including installing unauthorized software and/or
hardware), telephones, laptop computers, copy machines, facsimile machines, cellularand mobile devices, postage or mail services, mainframe access and networks, andcommunications media.
11. Accessing, or attempting to access, Client Data or any Company information or
information contained in Company files or databases without authorization, which
includes, but is not limited to accessing such information without having a legitimate
business reason for doing so, or soliciting or attempting to induce others to provide
Client Data or information, or access to Client Data or information, to which one is not
authorized to access.
12. Failure to report any actual or perceived misuse, or inappropriate disclosure of Client
Data. For more information, Bloomberg’s Client Data Principles and related policies canbe found at POLY<GO>.
13. Disclosing to the Company, or otherwise using for the Company’s benefit, any
confidential or proprietary information that an employee may have obtained inconnection with employment with any prior employer, without proper consent.
14. Accessing a third-party computer system without authorization from the owner of thesystem. Employees who received authorization prior to joining Bloomberg must reapply
for such authorization and, if asked, disclose their employment by Bloomberg to theowner of that system. Employees who are obtaining authorization for the first time must,
if asked, disclose their employment by Bloomberg to the owner of that system.
Employees must never access a third-party computer system using log-in credentials
issued to someone other than themselves. The term “third-party computer system”
includes, without limitation, web portals, websites, applications and cloud services.
15. Improperly attempting to influence editorial decisions in order to further the commercial
goals of the Company.
16. Failure to project a positive and professional image, including, but not limited to, failing towear attire appropriate for one’s position and engaging in unprofessional conduct.
17. Disparagement of the Company, employees, contractors, vendors, suppliers,
competitors or clients.
1018. Incompetence, inefficient and/or careless performance of duties, failure to maintainproper work standards, or other poor performance, as determined in the sole discretionof the Company.
19. Excessive or patterned absence or tardiness, or failure to promptly contact Managers
regarding absences and tardiness.
20. Possession, use, or distribution of dangerous weapons, such as knives, guns,
explosives, or any other devices that jeopardize the safety or security of individuals
and/or property on Bloomberg premises.
21. Disrespectful or intimidating conduct of any kind, including, but not limited to, threats,
whether expressed, implied, or in jest.
22. Tape recording or video recording, or attempting to tape record or video record, other
employees, clients, customers, vendors or third parties without their knowledge orconsent, except for Company authorized Telephone Monitoring as described in Section
8 or where otherwise explicitly authorized by Company policy.
23. Failure to comply with applicable country, state, or local tax requirements.
24. Violation of any other Company or department policy, procedure or rule, including those
set forth in this Guide.
25. Involvement in any activities that could be considered to be a bribe or any form of
unethical inducement or payment, including facilitation payments or kickbacks.
26. Failure to report any bribe or unorthodox payment or inducement.
27. Failure to immediately report lost or stolen Company property or information. In theevent any Company property or information is lost or stolen, employees should
immediately notify their Manager who is responsible for escalating as appropriate.
Conflicts of Interest
Employees must avoid situations where their personal interests or other business interest could
conflict with the interests of Bloomberg or could be perceived by others as doing so. Conflicts ofinterest arise when an individual’s position or responsibilities with Bloomberg present an
opportunity for personal gain separate and apart from the direct rewards of employment, or
when an employee’s personal interests or other business interests are inconsistent with those of
Bloomberg and could lead to his or her responsibilities with Bloomberg being compromised.
A conflict of interest, or the appearance of a conflict, may arise in a variety of circumstances andit is not possible to describe every situation. By example, however, a conflict occurs when an
employee, relative of an employee, or individual with whom an employee has a personal
relationship:
1. Directly or indirectly has a personal or financial interest in any transaction which is, ormay be adverse to Bloomberg; or
11

2. Engages in, or recommends a business transaction for Bloomberg that results inpersonal profit or gain.
Beyond the clear cases of conflicts of interest described above, there are situations that areinconsistent with the high standards of business ethics required by Bloomberg, which cannot becompromised. If there is room for suspicion that an interest in, or connection with, anotherventure might affect, or reasonably appear to affect, an employee’s exercise of judgment onbehalf of Bloomberg, the interest or connection shall not be entered into, and once identified,shall be immediately brought to the employee’s Manager’s attention. In all situations, employees
should observe Bloomberg’s Client Data Principles.
Misuse of Confidential Information and Trading Restrictions
As a condition of employment, upon hire, employees are required to enter into confidentiality
provisions or to sign Bloomberg's Confidentiality Agreement. This requirement reflects the factthat Bloomberg employees have access to, and become familiar with, a broad range of highly
sensitive confidential and proprietary information concerning Bloomberg and its clients, vendors
and counterparties, and other third parties with whom Bloomberg has a relationship. The
protection of this information is critically important to Bloomberg’s reputation, relationship with its
clients, and continued success. As discussed more fully below, Bloomberg’s policies regarding
the protection of confidential information, as well as its requirement that its employees act withthe highest degree of business ethics and avoid even the appearance of impropriety,necessarily impact the personal investment activities of employees’ and their Covered Persons(as defined below), and require that each such person comply with the restrictions on suchactivities described below and in the Personal Trading Policy. Employees must also comply
with the disclosure requirements set forth in the Personal Trading Policy.
Consistent with Bloomberg’s strict insistence on the protection of confidential information,
Bloomberg employees may not use or disclose, either internally or externally, confidential
information obtained or learned about in the course of their employment for any purpose whichis unrelated to the specific role they perform at Bloomberg. This prohibition includes, but is not
limited to, employees’ use or disclosure of such information for their own or someone else’s
personal or financial gain. In addition, employees may not misuse their positions at Bloomberg
to impact improperly the securities markets. Thus, Bloomberg employees are prohibited from:(1) disclosing to others (with the exception of people inside the Company with a “need to know”)
material non-public information (as defined below) about the Company or its clients, vendors,
suppliers or third parties with whom Bloomberg has a relationship; (2) trading securities while inpossession of material, non-public information concerning those securities (or their issuer); (3)buying or selling a security with knowledge of a pending publication or dissemination byBloomberg of news, research, analysis or other information that could reasonably be expected
to have an impact on that security’s price; (4) causing Bloomberg to disseminate news,
research, analysis, or other information for the purpose of affecting securities prices; or (5)engaging in any other investment activity that could compromise objectivity or give theappearance of impropriety or of taking unfair advantage of one’s position at Bloomberg.
Notwithstanding this confidentiality provision, and in accordance with the Defense of Trade
Secrets Act, an individual shall not be held criminally or civilly liable under any Federal or State
trade secret law for the disclosure of a trade secret that is made in confidence to a Federal,
State, or local government official or to an attorney solely for the purpose of reporting orinvestigating a suspected violation of law. An individual shall not be held criminally or civilly
12liable under any Federal or State trade secret law for the disclosure of a trade secret that is
made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is
made under seal. An individual who files a lawsuit for retaliation by an employer for reporting asuspected violation of law may disclose the trade secret to the attorney of the individual and use
the trade secret information in the court proceeding, if the individual files any document
containing the trade secret under seal; and does not disclose the trade secret, except pursuant
to court order.
To safeguard against the inadvertent sharing of confidential information, including material nonpublic information, and the potential ramifications of such a disclosure, confidential information
shall not be mentioned in discussions in public settings, including within the office. Bloomberg is
proud of its open floor plan and open environment, and strongly believes that it facilitates
dialogue, collaboration and idea generation amongst employees. Employees need to be
mindful, however, that there may be colleagues, visitors and clients who should not be privy tocertain discussions in our open environment. Employees, therefore, shall exercise judgment
when discussing confidential information in open places such as the pantry, elevators, stairwells
and escalators, and even in workspaces where other employees who should not be privy to theconversation could overhear.
Bloomberg has secure internal email and messaging systems, including MSG <GO> and IB<GO>, that should be used by employees as the primary communications media for businesspurposes. Employees must not maintain, organize, use or otherwise participate in any third
party-hosted solution, including but not limited to any Cloud Services, to communicate, distributeor disseminate Client Data, Internal Data or Third Party Data, unless use of the third partyhosted solution for such communication, distribution or dissemination has been expressly
approved by the Chief Risk and Compliance Office ("CRCO"). Examples of third party-hosted
solutions include, but are not limited to, Google Chat, WhatsApp, weChat, Slack, Scribd,
Dropbox and Google Drive. This prohibition includes, but is not limited to, uploading files to third
party-hosted solutions and sending or making available documents or other files containing
Client Data, Internal Data or Third Party Data to colleagues, clients, or any other third party by
way of a third party-hosted solution, without appropriate authorization from CRCO. If
authorization is granted, unless expressly stated otherwise, such authorisation will be specific tothe sharing of certain, specified Client Data, Internal Data or Third Party Data via a particular
third party-hosted solution only and must not be taken as authorization to share any Client Data,
Internal Data or Third Party Data via any third party-hosted solution. This prohibition also
includes the interoperation of third-party applications with an authorized third party-hosted
solution, unless such interoperation is also expressly authorized by CRCO, as suchinteroperation may allow the third-party application to access Client Data, Internal Data or Third
Party Data stored on the third party-hosted solution. If any employee has any doubt whatsoever
as to whether they have appropriate authorization to upload files to a third party hosted solution
or communicate, distribute or disseminate Client Data, Internal Data or Third Party Data via athird party-hosted solution, they shall refrain from such upload, communication, distribution ordissemination and shall promptly enter an SDSK ASKH ticket.
Bloomberg employees are also prohibited from short selling, purchasing for short term gain (i.e.,
selling securities within 30 days of purchasing them for profit), or purchasing or selling any
derivative instrument (such as options, futures and swaps) other than writing covered calls (i.e.,13hedging long positions with covered calls), since such activities are widely considered to besusceptible to abuse and can often give rise to the appearance of impropriety. Employees
seeking permission to engage in the above activities must receive special and explicit
permission. Requests must be submitted by completing an SDSK ASKH ticket.
These three prohibitions do not apply to any account in which trading decisions and activities
are performed by a third party money manager, in which the account owner does not retain
discretion to direct the trading of securities in that account. The prohibition against trading
derivatives does not apply with respect to writing covered calls, or taking long positions in
spread bets or contracts for difference; however, such actions are subject to the other trading
restrictions described herein.
In addition, employees who work in or with certain groups, such as Bloomberg Tradebook,
BNEF, Bloomberg Intelligence, BVAL, BVAL Derivatives, Bloomberg Indexes, Bloomberg Risk
& Valuation Group, BDVD, and News are also subject to other, more restrictive trading
restrictions set forth in group-specific policies and/or guidelines, as they may be promulgated oramended from time to time, including, but not limited to:•Bloomberg Tradebook Compliance Manual•

BNEF Code of Conduct•

Bloomberg Intelligence Code of Conduct•

BDVD Code of Conduct•

Bloomberg Risk and Valuation Group Code of Conduct•

Bloomberg Indexes Code of Conduct•

Bloomberg BVAL and BVAL Derivatives Code of Conduct•

The Bloomberg Way; or•

Any other Code of Ethics promulgated by a business unit

The prohibitions set forth herein apply to employees’ trading activities for their own accounts, foraccounts in which they have a direct or indirect beneficial interest (including accounts of an
employee’s spouse, domestic partner or equivalent, minor children, or other financial dependent(each, a “Covered Person”) and for any other accounts over which they have discretionary
authority or power of attorney.
For purposes of the prohibitions set forth above, “material non-public information” means any
information that an employee learned in connection with his or her employment at Bloombergthat (a) is not generally available to the investing public, and (b) would be considered importantby a reasonable person in deciding whether to buy or sell a particular security.
Employees shall also be cognizant that their investment activities are also circumscribed bylegal prohibitions on, among other things, the misuse of non-public information and on market
14manipulation. In that regard, the laws in many jurisdictions prohibit buying or selling securities
based on non-public information or under various circumstances, providing non-public
information to another person for that person’s use in buying or selling securities (sometimes
known as “tipping”). Thus, engaging in transactions based on non-public information or “tipping”
may not only violate Bloomberg policy but also subject the wrongdoer to severe criminal andcivil sanctions. Furthermore, any such violation by any employee of the Company could
seriously damage the Company’s reputation and expose it to both embarrassment and legal
claims. Consequently, employees must take care to ensure that their investment activities
comply not only with Bloomberg policies, but also with the various legal prohibitions to which
they may be subject.
When employees have any doubt whatsoever as to whether information in their possession is“material non-public information,” they shall (i) treat the information as “material non-public
information,” (ii) refrain from trading in the security to which such information relates, (iii) refrainfrom disclosing the information further, and (iv) promptly enter an SDSK ASKH ticket.
Gifts
No employee or member of his or her family may, directly or indirectly, receive bonuses, fees,
gifts, entertainment or sports tickets, or any other item that is of more than nominal value fromany entity or person with whom Bloomberg does, or would like to do, business. An exception
may be made for items that are only of token value. Upon receiving gifts, employees must
contact Human Resources for guidance, and the Company reserves the right to dispose of suchgifts as it deems appropriate. Bloomberg employees also may not offer gifts, money orentertainment to vendors or customers with whom they do, or would like to do, business without
management consent.
Social Media Activities
Participation on the Internet by way of social media has reached an all-time high, andBloomberg recognizes the positive impact that this means of communication can have on ourbusiness. Bloomberg recognizes that many employees engage in social media for personal use,and have represented our Company positively by mentioning our brands, products, news, andevents.
The policy which can be found at HR<GO> sets forth the responsibilities of our employees whenengaging in social media and also provides a list of prohibited subjects. The intent of the Social
Media policy is not to restrict the flow of useful and appropriate information, but to minimize risk
to the Company and its employees. Although the policy defines social media and its appropriateuse, the standards outlined in the policy are meant to apply to new tools and technologies as
they come into use in this rapidly-evolving field. Employees must adhere to the policy whenengaging in social media activities.
Personal Data and Information
At various times during their employment, employees will be required to provide the Company
with (or the Company may collect) certain personally identifying data and information (“Personal
15

Data and Information”). The Company uses this Personal Data and Information for purposes ofthe employment relationship, for administration and management purposes and related
analyses, for safety or security purposes, for business purposes, and to ensure compliance with
Company policies and applicable laws and regulations. Personal Data and Information may
include work authorization forms, address and contact information, dates of birth, emergency
contact information, identification documents (e.g., driver’s license, social security numbers, ID
numbers), financial account information (e.g., compensation and banking information),
information regarding education and employment history, medical/health information, datacollected by Closed Circuit Television (CCTV) camera systems, location data (including as
collected by a security badge system, company-issued devices and/or personal portable ormobile devices used for business purposes), and any other personal or sensitive personal data,
including, but not limited to, EEO information, information in connection with background checks
and concerning a prior criminal record (where applicable), and any other information required bylaw or requested by Human Resources or the Company.
In addition, as a condition of employment, employees' personal telephone numbers will bemade available so that other Bloomberg employees and certain vendors of the Company (e.g.,advisors or consultants) may contact them outside the office, if necessary, for business-related
reasons. Similarly, employees’ pictures will be made available for identification purposes. CCTV
footage will also be recorded and reviewed by Company’s Risk Management team and/or guard
force for safety and security purposes.
Bloomberg will ensure that appropriate security measures are taken to prevent unlawful or
unauthorized processing of Personal Data and Information and against the accidental loss of ordamage to Personal Data and Information. Human Resources will hold, retain and destroy all
Personal Data and Information in accordance with the policies of the Human Resources
department and applicable law. Employees must provide the Company with accurate Personal
Data and must notify Human Resources of any changes to their Personal Data and Information
so that the Company can maintain accurate records, and may request access to their Personal
Data and Information to ensure that it is correct and complete. Employees are also encouraged
to forward all documents and materials containing Personal Data and Information, including
without limitation all evaluations, compensation and performance-related materials (whether
they relate to the employee forwarding the materials or to other employees) to Human
Resources for storage in accordance with Company policies. Managers and other supervisory
employees outside of Human Resources should not maintain any such documents or materials
for their own records.
The Company may share employees’ Personal Data and Information under the following
circumstances:
1. With, between or among its offices, affiliates, subsidiaries and any successor entity;
2. With third parties who provide services to the Company such as benefit and payroll
providers, analysis providers, consultants, administrators, legal and other advisors, tax
consultants and security contractors;
16

3. In response to a subpoena, as part of a court order or tribunal process, government
investigation, government request, or other legal or regulatory process; and4. As is necessary to protect the rights, property, interests, safety, or reputation of theCompany, its clients or others.
Personal Data and Information may be shared with and/or transferred to offices or third parties
located outside the country in which the employee is based, including to the United States,
which may have different levels of privacy protection than the employee’s country.
Employees are prohibited from using employees’ Personal Data and Information for nonbusiness reasons.
Announcements, References, and Other Requests for Information
In accordance with their obligation to keep Company confidences, employees are required torefer all requests or inquiries from outside of the Company to the appropriate Company
representative. Any inquiry from a government official, newspaper, magazine, blogger,
broadcast media, book publisher, photographer, film producer or any other person seeking to
publish information concerning the Company must be referred to the Public Relations
department. This includes solicitations for information or inquiries about the Company fromparticipants in social media, as well as requests to use the Company name or logo inadvertisements, Web sites, publications and press releases. Employees may not make or
confirm statements on behalf of, or concerning, the Company to the press or on social media(blogs, Web sites, social networks, and Twitter and LinkedIn) without prior approval from the
Public Relations department.
It is Bloomberg's policy to only verify former and current employees' position, current or final
salary and dates of employment. In most regions, employees can access their own employment
verification letter under the Personal Information section on MYPD<GO>. In regions where thisis not available, employees should contact their Human Resources Relationship Manager forassistance. No employee may give former or current employees or Contingent Workers apersonal reference for employment or other purposes, unless required by local law, in whichcase the employee should contact Human Resources for guidance. Employees may submit arequest to their Manager for a reference for entry into a school program and/or condominium/cooperative acceptance purposes if they have acceptable performance in their current job, as
permitted by applicable law. Employees and their Managers must bring such requests to theattention of Human Resources, and their Managers and Human Resources will review such
requests on a case-by-case basis to determine whether a reference will be given. Violations of
this policy may result in further action, up to and including termination of employment.
Access, Solicitation and Distribution
Access. Persons not employed by Bloomberg are not allowed to access Bloomberg property forany purpose unless they secure advance permission and comply with Bloomberg’s access andsecurity procedures. Persons not employed by Bloomberg are not permitted to distribute17

literature or solicit employees on Company property for any purpose, at any time, nor may they
post solicitation notices in Bloomberg’s offices or on the terminal.
Solicitation. Employees are not permitted to solicit other employees for any purpose during theworking time of either the soliciting employee or the solicited employee. “Solicitation" includes
asking for support, assistance or contributions for, soliciting memberships in, or selling goods forany outside business, charitable, religious, civic or other organization. “Working time” does notinclude lunch breaks, break times, or other periods when employees are not required to beworking for Bloomberg.
Distribution. Employees are generally not permitted to distribute literature in work areas at any
time. "Literature" includes written materials such as fliers, letters, brochures, memoranda andpamphlets of any kind or for any purpose. "Working areas" include all locations on Bloomberg
premises where employees perform work, but do not include non-work areas like lunch rooms.
Bloomberg may permit limited exceptions to its policy governing Solicitation and Distribution forcertain Company-sponsored charitable events from time to time or as required by applicablelaw.
Bulletin Boards. Bloomberg maintains official bulletin boards (whether physical or electronic) tocommunicate important Company-related information and mandatory legal notices. Only
Human Resources or other persons designated by Bloomberg may post material on, or remove
material from, official bulletin boards. Official bulletin boards are not to be used for personal,
charitable, civic, political or other non-business notices, solicitations or materials. Employees
may post personal or other non-business materials only on non-official bulletin boards
designated for employee use. Bloomberg may remove any materials that violate company
policies, including policies against harassment and discrimination.
Hosting Personal Guests
When employees invite personal guests to Bloomberg, it is their responsibility to ensure theirpersonal guests leave the building when their visit is over. While Bloomberg is happy to have
employees show its offices to friends and family, employees should not conduct personal
meetings in Bloomberg offices. Especially with a shortage of conference room space, personal
meetings should be conducted outside the building.
Hosting External Events at Bloomberg
Bloomberg generously opens its office space for business-related tours and meetings.
Generally, our offices are used only for customers, internal business or to support approved
philanthropic relationships. With conference and meeting space at a premium, employees are
not permitted to host meetings or tours for external organizations at Bloomberg. Businessrelated events may be held at the discretion of the Department Manager; related expenses must
be covered by that business group.

18Substance Abuse and Testing
Bloomberg has a vital interest in providing safe and healthy working conditions for its employees
as well as its vendors and clients. Bloomberg, therefore, is committed to maintaining aworkplace free from the influence of drugs and alcohol and at the same time is committed toassisting in the rehabilitation of those employees who voluntarily request assistance.
In furtherance of this policy, employees who use, possess, store, distribute, purchase,manufacture or who are under the influence of illegal or non-prescribed drugs or alcohol whileworking or otherwise on Bloomberg’s premises or vehicles are subject to immediate termination,as permitted by applicable law. Bloomberg reserves the right to, and may, in its sole discretion,require an employee to undergo drug or alcohol screening where it reasonably suspects theemployee to be under the influence of illegal or non-prescribed drugs or alcohol while working orotherwise on Bloomberg's premises or vehicles, as permitted by applicable law. Any employee
refusing to cooperate in such testing as required may be subject to discipline, up to andincluding termination of employment.
Employees who test positive for illegal or non-prescribed drugs or alcohol, or who are otherwise
determined to have violated this policy, may, depending on the circumstances and in the sole
discretion of Bloomberg, be terminated or permitted to undergo rehabilitation, counseling and/or
treatment. If after such treatment, satisfactory evidence of rehabilitation is presented,
Bloomberg, in its sole discretion, may return the employee to work, subject to periodic random
testing for a period of time deemed appropriate by Bloomberg or as may be required byapplicable law. If the employee refuses to follow the recommended rehabilitation, counseling,treatment and/or after-care program or refuses to be subject to follow-up testing or tests positivein any subsequent test or otherwise violates this policy, the employee may be subject toimmediate termination of employment, as permitted by applicable law.
Employees with drug and/or alcohol problems are encouraged to come forward and voluntarily
seek help. Prior to conduct leading to a request to submit to a drug/alcohol screen an employee
may request to participate in an approved rehabilitation, counseling and/or treatment program.
Bloomberg, in its sole discretion, may grant such employee a leave of absence or time off toattend such program(s). Following the completion of such program(s), the employee may beperiodically tested on a random basis for a period of time deemed appropriate by Bloomberg or
as may be required by applicable law. If the employee refuses to follow the recommended
treatment program and/or after-care program or refuses to be subject to follow-up testing or
tests positive in any subsequent test or otherwise violates this policy, the employee may besubject to immediate termination of employment, as permitted by applicable law.
Testing information and results under this policy will not be disclosed to anyone at Bloomberg
who does not have a legitimate need to know.
No Smoking
All Bloomberg employees must work together to maintain the highest possible level of safety
and mutual comfort. Accordingly, smoking, including the use of electronic cigarettes, is not
19permitted in Bloomberg facilities, including Company vehicles, outdoor office space, or withinclose proximity of the entrances to our facilities.
This policy applies equally to all employees, vendors, clients, and visitors.
No retaliatory adverse personnel action will be taken with respect to any employee for lodging
complaints or concerns regarding compliance with this policy. Any employee or applicant who
believes he or she has suffered any such retaliatory action should contact Human Resources.
Political Contributions
In the context of conducting Bloomberg business, no employee shall apply any pressure or
make any suggestion or threat, direct or implied, that failure to make a political contribution or
participate in political activity will result in some disadvantage, or that making a contribution may
result in some advantage, nor may any person provide, or withhold any benefit, inducement or
reward, concerning Bloomberg’s business, to another employee, consultant, vendor or client inan effort to influence that person's decision to support a political candidate or party.
Use of Mobile Communications, Texting and Hand-Held Devices While Driving
Cellular telephone conversations, the use of hand-held devices and other similar distractions
are to be avoided while driving. While the Company supports the use of cellular telephones andhand-held devices for business purposes, we prohibit employees from using cellular telephones
or hand-held devices to conduct business while driving. If an employee needs to make or take abusiness call or send or view a text message or e-mail, while driving, the employee shall pull off
the road and stop in a safe location, if practicable, prior to using the cellular telephone or handheld device. In addition, the Company expects that all employees comply with applicable laws
regarding the use of cellular telephones and hand-held devices while operating a motor vehicle.

4. Intellectual Property
Bloomberg is committed to robust and fair competition. Consequently, Bloomberg requires all of
its employees to sign a Confidentiality Agreement or similar provisions to help protect its
intellectual property and respect the intellectual property rights of others. Employees may not
misuse the confidential or proprietary information or trade secrets of the Company or of a third
party, regardless of how they discover this information. Employees must not use third party
copyrighted material without the authority of the owner, unless the Company's lawyers haveadvised that this use is lawful. In addition, employees must not consciously misuse theCompany’s or a third party's trademarks or service marks or seek to appropriate the goodwill
associated with such marks. Violations of this policy may result in further action, up to andincluding termination of employment.

5. Bribery and Corruption
Bloomberg values its reputation for ethical behavior and has a zero tolerance commitment
against bribery and corruption in any form in any jurisdiction in which Bloomberg operates. Full
20

details of Bloomberg's policy on bribery and corruption, which all employees are required toadhere to, is set out at HR ANTI-CORRUPTION<GO>.

6. Anti-Slavery
Bloomberg values its reputation for ethical behavior and has a zero tolerance approach tomodern slavery in any form.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms
such as slavery, servitude, forced and compulsory labour and human trafficking, all of whichhave in common the deprivation of a person’s liberty by another in order to exploit them forpersonal or commercial gain.
We are committed to acting ethically and with integrity in all our business dealings andrelationships and to implementing and enforcing effective systems and controls to ensure thatmodern slavery is not taking place anywhere in our own business or in our supply chains.
The prevention, detection and reporting of modern slavery in any part of our business or supply
chains is the responsibility of all those working for Bloomberg or under our control. Employees
are required to avoid any activity that might lead to, or suggest a breach of this policy.
Employees must notify their Manager, HR or the anonymous helpline as soon as possible if they
believe or suspect that a breach or conflict with this policy has occurred, or may occur in the
future. If an employee is unsure about whether a particular act, the treatment of workers moregenerally, or their working conditions within any tier of our supply chains constitutes any of thevarious forms of modern slavery, they should raise it with their Manager or HR or through theanonymous Bloomberg Hotline, which is available 24 hours a day, 7 days a week at +1-212617-1595 ((801)1595) or +1-800-777-7217 (toll free in the U.S.).
We aim to encourage openness and will support anyone who raises genuine concerns in goodfaith under this policy, even if they turn out to be mistaken. We are committed to ensuring thatno one suffers any detrimental treatment as a result of reporting any such suspicions.
Any employee who breaches this policy may face disciplinary action up to and including
termination.

7. Absences, Time Off, and Holidays
Absences and Tardiness
Employees are expected to be at work and to report on time. If they expect to be late,employees must promptly contact their Manager to state the reason for such lateness and when
they expect to arrive at work. Employees who are unable to report to work due to illness, injury
or any other reason must notify their Manager and provide the reason for their absence at least
one hour before their normal starting time. Further conditions may apply in your region.
Employees should consult their contract, where applicable, or Human Resources for more
information.

21

Paid Time Off/Holidays/Leaves
Since employees generally need time off for various reasons including rest, relaxation, handlingpersonal matters, and religious observances, Bloomberg may provide employees with paid timeoff. In addition, employees may be entitled to holidays and additional leaves, per applicablelaws. Employees should consult their contracts, where applicable, or speak to their Manager or
Human Resources to determine their time off, holiday, and leave entitlement.
Jury Duty/Civic Duty Leave
Bloomberg encourages its employees to fulfill their civic responsibilities by granting time off toserve jury duty/civic duty leave. Where applicable, Bloomberg may pay employees their fullsalary while on such leave.
Before such leave will be granted, employees must submit a copy of their jury notice or otheracceptable documentation to their Manager as soon as they receive it. Employees who are notrequired to serve as a juror on a scheduled work day, or who are released prior to the end of theregular workday, must return to work. To be paid for such leave, proof of actual jury service orother acceptable proof must be presented to Human Resources upon return to work.

8. Security, Facilities, and Equipment
Company Equipment
In order to assist employees in performing their jobs, Bloomberg provides certain equipment
and materials including, but not limited to, electronic mail, voice mail, telephones, Internet,
postage, copy and fax machines, personal computers, laptop computers, cellular and mobile
devices, other hardware/software, mobile applications, wireless and wired networks, andcommunications media (collectively, “Company Equipment”). Such Company Equipment and all
files and data stored on Company Equipment are and shall remain the property of Bloomberg at
all times. For purposes of recruitment and the employment relationship, administration andmanagement, safety or security, business purposes, managing and assessing compliance with
Company policies and applicable laws and regulations, investigating and taking disciplinary
action relating to violations of such policies, laws and regulations, and to maintain the safety andsecurity of employees, Contingent Workers, customers, vendors, visitors, data and facilities, theCompany reserves the right to access, collect, inspect, review, monitor, decrypt, delete, copy,
remove, change, transfer, record, store, block, disclose (including within Bloomberg and its
subsidiaries and affiliates, and to third parties), and otherwise process (collectively, “Access andProcess”) the data and contents of such Company Equipment, including Bloomberg’s system
usage information, or of any communications (including personal communications, to the extent
permitted under this Section) made using Company Equipment, at any time and without further
notice, by any means.
Company Equipment is made available to employees for use in connection with the Company's
business. Accordingly, employees should not expect privacy in their communications (including
personal communications) made using Company Equipment. All equipment and software
installed on Company Equipment and/or used to access Bloomberg information assets must be
22

approved by the Company and installed by a PC support representative. This includes, but is
not limited to, all software packages and mobile applications (including those placed on
personal devices for business purposes), hardware, keyboards, mice, USB keys, and cameras.
Employees are responsible for the safekeeping of the Company Equipment in their possession.
Unauthorized use, abuse, loss, destruction or personal use of Company Equipment is strictly
prohibited. Personal Data and Information may be acquired by or as a result of use of Company
Equipment, including in connection with employees’ communications made using such
Company Equipment, and such Personal Data and Information shall be treated in accordancewith this policy.
Employees may be required to sign a receipt confirming that they have received specificCompany Equipment. Upon request and/or separation from the Company, all Company
Equipment must be returned immediately to Bloomberg, and all software and/or mobile
applications must be deleted.
To the extent you use your own personal equipment and/or software to access the Company’s
wireless and wired networks or any other Company communication or computer systems, theseguidelines apply to such equipment and/or software as well.
Use of Software and Electronic Communications
In addition to the above, the following guidelines, which are not all-inclusive, have been
established to ensure that employees understand the Company's expectations with regard to
the use of software, the Internet, IB<GO>, MSG<GO>and other email systems, as well as anyother means of electronic communication, provided by Bloomberg (collectively, “Company
Communications Systems”). Bloomberg may in its discretion block access to certain types of
websites, including due to malicious and/or inappropriate content.
For purposes including recruitment and the employment relationship, administration andmanagement, safety and security, business purposes, managing and assessing compliancewith Company policies and applicable laws and regulations, investigating and taking disciplinary
action relating to violations of such policies, laws and regulations, and to maintain the safety andsecurity of employees, Contingent Workers, customers, vendors, visitors, data and facilities,
Bloomberg reserves the right to Access and Process information relating to employees’ use ofCompany Communications Systems.
In this regards, employees should be aware that Bloomberg may exercise any or all of theserights at any time and without further notice, including with respect to communications madeusing Company Equipment or Company Communications Systems (including personalcommunications, whether made through the terminal, the Internet, IB<GO>, MSG<GO>, andother email systems or other means).
In addition, information relating to employees’ use of Company Equipment and Company
Communications Systems, including communications, may be retained for as long as necessary
by the Company for these purposes, and transferred to countries other than the country in which

23the employee is based, including to the United States, which may have different levels ofprivacy protections.
Employees should also be aware that use of the Internet (including email, social media, andblogging websites like Gmail, AOL, Hotmail, Yahoo, Facebook, MySpace and Twitter or otherwebsites through which personal information may be communicated), leaves trace data andinformation on Company Communications Systems and Company Equipment, and such trace
data may be subject to Access and Processing for the purposes described in this Section.
Bloomberg reserves the right to modify its processes with respect to Access and Processing of
information relating to employees’ use of Company Communications Systems and Company
Equipment in accordance with this Section, and may use Bloomberg proprietary or third party
programs, software, appliances, and hardware in connection with these processes.
Employees shall also be aware of and comply with the following:•

Company Equipment and Communications Systems, including Internet access are
made available to employees for use in connection with the Company’s business.
Limited personal use is acceptable on the condition that it otherwise complies with
Bloomberg policies and does not interfere with the performance of the employee’s job,
and that the employee consents to Bloomberg’s right to Access and Process such
communications as described in this Section. Otherwise, personal use of Bloomberg
Company Equipment and Communications Systems is not permitted. In addition,
employees are not to engage in any discussion which may create potential conflicts ofinterest or the appearance of impropriety. Employees shall not "hack" or otherwise
obtain unauthorized access or exceed authorized access into Company Equipment,
Communications Systems or any other network or computer system whether owned
or operated by the Company or a third party.

•

In order to protect the security of Company Equipment and Company
Communications Systems, downloading or uploading of any programs, data, or othermaterial, unless expressly approved by management, is strictly prohibited. Not only is
the Company concerned about inappropriate materials and copyright infringement,
but also special care is especially needed to protect against the spread of viruses.
Employees who have a legitimate business need to upload or download any material
are expected to exercise good judgment, and if they have any questions about thesafety, security or appropriateness of their actions with respect to the material atissue, they shall escalate to the Chief Risk and Compliance Office by entering an
SDSK CRCO ticket for review and approval.

•

The Company vigorously protects its confidential and proprietary information, andabsolutely prohibits the unauthorized use, disclosure, reproduction and/or distributionof its property. Since confidentiality and the security of data cannot be assured whenusing the Internet or email, including but not limited to third party email (e.g., Yahoo!,
Gmail, Hotmail, mail.163, me.com) or cloud storage services (e.g., iCloud, Google
Docs, Dropbox, or Amazon Cloud), transmission of confidential or proprietary24information via these means, even if only temporary, is prohibited, and any suchtransmissions may be Accessed and Processed for the purposes set forth herein. If
employees feel there is a legitimate business need to utilize any such third party
services, they shall request an exception by submitting an SDSK CRCO ticket forreview and approval.
•

The Company's Anti-Harassment policy applies fully to the use of all Company
Communications Systems and Company Equipment, including, but not limited to,Internet, MSG<GO>, IB<GO>, and email. Accordingly, acquisition and/or
dissemination of inappropriate materials, including, but not limited to those whichcontain sexual innuendo, pornographic material, improper jokes, harassing or
threatening statements, or any statement which could be negatively perceived byothers or considered hostile or offensive based on any protected classification,
including, but not limited to sex, race, color, age, religion, ancestry, marital status,
national origin, sexual orientation, gender identity, genetic predisposition or carrier
status, or disability is strictly prohibited.

•

No abusive, profane, or offensive language or defamatory statements are to betransmitted through Company Communications Systems or Company Equipment.
Attempts to circumvent Company safeguards in this regard are also prohibited.

•

The use of Company Communications Systems or Company Equipment to solicit nonCompany business or otherwise for personal gain is strictly prohibited.

•

Employees shall not share their passwords or review other employees' or Contingent
Workers’ files without permission.

•

Visiting any game or entertainment sites (e.g., online gambling sites, music download
sites, video-streaming sites, sexually explicit sites, social networking sites, personal
blogs, etc.) for non-business reasons using Company Communications Systems or
Company Equipment is prohibited.

•

Unless job related and approved by management, the sending of "chain letters" or"broadcast" messages to lists of individuals using Company Communications
Systems or Company Equipment, or the use of Company Communications Systems
or Company Equipment in a way that may cause congestion of the network, isprohibited.

•

All messages transmitted on the Internet and via email using Company
Communications Systems or Company Equipment shall have your name attachedand no messages shall be transmitted under an assumed name.

•

Employees shall be aware that emails, as well as all other communications madeusing Company Communications Systems or Company Equipment, are Company
records and can be used as evidence in a court of law or for any dispute, subject toapplicable laws. As described in more detail in POLY<GO>, Bloomberg retains copiesof all emails and other electronic communications transmitted over its Company
Communications Systems and Company Equipment. Also, employees must exercise
25good judgment in choosing their personal MSG<GO> greeting comments. The
Company reserves the right to remove MSG9 greetings with or without notice wheresuch greetings are deemed inappropriate in the sole discretion of the Company.
•

Employees must comply with policies requiring particular means of authentication toaccess the terminal and other Company Equipment or Company Communications
Systems.

•

Employees shall not use Company Equipment and Company Communications
Systems to conduct or facilitate any unlawful activities.

•

Employees shall not use Company Equipment and/or Company Communications
Systems in any way that could be damaging to Bloomberg’s public image, is forpurposes contrary to the interests of the Company, or is abusive, offensive,
defamatory, obscene, or indecent, or of such a nature as to bring the Company or
employees into disrepute.

•

Employees shall not use Company Equipment and Company Communications
Systems in a manner that will disrupt the intended use of system or network
resources and such use shall be appropriate for the task. Employees shall avoid
excessive, unnecessary consumption of computing resources for either business or
personal use.

•

Any business applications developed by employees shall be supportable andmaintainable and not degrade the existing IT infrastructure.

•

Employees are expected to exercise strong security practices when connecting to theCompany’s wireless networks using Company-issued or personally-owned devices
not issued by the Company. Bloomberg does not maintain firewall software on
personal devices. Employees, therefore, using personally-owned devices not issued
by the Company should install personal firewall software where appropriate, and keep
updated personal firewall software, anti-virus, and anti-malware software.

Telephone Monitoring
In order to ensure compliance with Company policies and applicable laws and regulations, tomaintain the safety and security of employees, customers, vendors, visitors, data, and facilities,
and for legitimate business purposes Bloomberg reserves the right, whether on its own or
through its third-party security contractors to monitor all telephone conversations of its
employees (including voicemail messages left for or by such employees) using Company
Communications Systems, at any time with or without notice, and in accordance with applicablelaws and regulations.
Closed Circuit Television (CCTV) Systems
In accordance with applicable laws, CCTV cameras are installed in some Company offices forsafety and security purposes. Where CCTV cameras are installed, Bloomberg provides notice toemployees and visitors. Footage is accessed and reviewed by Bloomberg’s Risk Management
team and/or its third-party security vendors, and retention periods for the footage vary in26accordance with local laws and regulations. CCTV footage may be shared with and/ortransferred to the Company offices or guard force; such sharing may include transfers of
personal data to countries other than the country in which the employee is based, including to
the United States, which may have different levels of privacy protections.
Protection of Published Materials
Bloomberg subscribes to newspapers, journals, magazines, newsletters, and other services inorder to access business information. It is our policy to protect the rights of the publishers and/or
authors of such media by paying for all subscriptions, unless they are provided free of charge.
Moreover, employees may not copy, fax, print, or redistribute this information except as legallypermitted by the publisher and/or author, whoever has rights to distribution.
Personal Property
Bloomberg does not assume responsibility or reimburse employees or others for the loss, theft,or destruction of any personal property that is brought onto Company premises. Employees are
urged to exercise care in regard to leaving their personal belongings on Company premises.
Property Inspection
Bloomberg and our security representatives reserve the right to inspect all storage areas,
lockers, desks, briefcases, handbags, electronic equipment and other personal property brought
onto or removed from the premises at any time, subject to applicable law. Employees mustcooperate in such inspections should they occur.
Bloomberg does not accept the delivery of personal mail at any of our premises, unlessotherwise pre-approved by the Company.
Security
Bloomberg's premises contain valuable equipment, furnishings, and merchandise. It isextremely important, in order to protect the safety of everyone, that all employees pay close
attention to the security of our facility. Please notify Security and/or Human Resources
immediately if you see anyone or anything suspicious. Employees must wear their identification
badges (with their picture showing) in the office at all times, and swipe their badges uponentering and leaving Bloomberg premises.
Health and Safety
Bloomberg promotes maintaining a safe and healthy environment at the workplace. Employees
shall make themselves familiar with Bloomberg’s fire, medical and security procedures found on
EMER<GO> to ensure that they know what to do in the event of an emergency.

9. Employee Services
Employee Assistance Program27

Today's lifestyles are increasingly hectic. All of us, regardless of our backgrounds or jobs, face avariety of difficulties in our daily lives. Most often, we are able to work situations out by
ourselves. However, at times, many people may face problems that are too complex or
overwhelming to handle alone.
While it is not Bloomberg's intention to become involved in the personal lives of its employees,
Bloomberg recognizes the importance of providing constructive professional assistance to help
employees and their families work through difficult problems, put such problems in perspective,
and find reasonable solutions. Accordingly, Bloomberg offers an Employee Assistance Program(EAP) for its employees.
The EAP is a confidential program, available to all Bloomberg employees and their families,
which provides individuals with an opportunity to discuss and resolve their difficulties with theassistance of experienced, licensed, and certified mental health professionals.
Please contact Human Resources or see EAP<GO> for more details on this program.
Out of Office System
All employees must use the OUT<GO> function on the terminal. Such function allows
employees to record their approved days out of the office and serves as an attendance record.
In addition, the OUT function is linked to employees' FON<GO> records and comments on
MSG<GO>. This function is beneficial to use, as it enables us to better serve our clients.
Employees must receive approval from their Managers prior to scheduling absences in
OUT<GO>.

10. Employee Benefits
Bloomberg provides comprehensive and generous benefits to our employees globally. Please
see HR<GO>, consult your contract, where applicable, or speak to Human Resources fordetails on the range of benefits offered by Bloomberg.

28

CONTACT SHEET

Human Resources General Numbers
Americas+1-212-617-0564

Europe/Middle East/Africa+44-20-3525-9700

Asia Pacific+81-3-3201-6916

Payroll+1-212-617-2530+44-20-7073-3517

Anonymous Hotline+1-212-617-1595+1-800-777-7217 (U.S.)

Human Resources
Ken Cooper – Worldwide+1-212-617-2150

Kate Wheatley – Americas+1-212-617-1562

Patricia Pierotti – Europe/Middle East/Africa+44-20-7330-7599

Melanie Coate – Asia Pacific+852-2293-1971

Additional ResourcePeter Grauer+1-212-617-1956

Beth Mazzeo+1-212-617-6175

29

EMPLOYEE ACKNOWLEDGEMENT
I acknowledge that I have received a copy of the Global Resource and Information Core Guide(“Guide”) for Bloomberg L.P. and its subsidiaries and affiliates (referred to herein as“Bloomberg” or the “Company”). I also acknowledge that the terms of this Guide may besupplemented by any applicable laws, as well as by my contract of employment and/or offer
letter. I hereby acknowledge that I have read the Guide and will abide by its contents as acondition of my employment. If there is anything that I do not understand or have a question
about, I will contact my Manager or Human Resources. I understand that Bloomberg reserves
the right to alter, amend or terminate, in whole or in part, any of the policies described in thisGuide, or to modify or deviate from them, at any time without notice, and in Bloomberg’s sole
discretion, as permitted by applicable law, and that the most up-to-date Guide is available under
HR<GO> or IDOC<GO> on the terminal. I understand that this Guide is neither an employment
contract nor an agreement guaranteeing employment and/or the provision of benefits for any
specified period of time and that, absent an executed employment contract that says otherwise,
either I or Bloomberg can terminate the at-will employment relationship at any time, for any
reason.
By signing below, I further acknowledge that I have carefully read the provision titled “Personal
Data and Information” (Section 3) and “Security, Facilities, and Equipment” (Section 8), and that
I give my express consent to Bloomberg to collect, process, use, store and disclose my
Personal Data and Information, both electronically and in secure personnel files, as described in
the Guide, and to use manual and/or automated processes to access, collect, inspect, review,monitor, decrypt, delete, copy, remove, change, transfer, record, store, block, disclose(including within Bloomberg and its subsidiaries and affiliates, and to third parties), andotherwise process my communications made using Company Equipment or Company
Communications Systems, at any time and without notice, as permitted by applicable laws.
I also give my express consent to the transfer of my Personal Data and Information and/or mycommunications to Bloomberg offices or third parties located outside the country in which I am
based, including to the United States, and/or to other countries that may have different levels ofprivacy protection than my country for the purposes set out in this Guide.

Signature(Please Print Name)

Date

Office30

APPENDIX A: Key Definitions
B-Unit: the Bloomberg Authentication Unit is used by Bloomberg Personnel or end users toaccess the Bloomberg Professional service. Each B-Unit is a mobile card that the user keeps in
his or her possession, and is configured to authenticate a binary number that has been createdbased on limited information from the specific person’s finger image.
BAR: the Business Administrator for Roles is responsible for role engineering andcommunicating any Department access control changes to the CRCO.
BIA: the Business Impact Assessment of critical business functions and critical processes thatmust be recovered. The BIA identifies the potential quantitative and qualitative impacts ofuncontrolled, non-specific events to each Department, site, and system, and establishes
recovery time objectives (i.e., estimated maximum allowable downtime), recovery point
objectives (i.e., acceptable level of losses), and the critical recovery path.
Bloomberg or the Company: Bloomberg Inc., Bloomberg L.P., and any majority-owned orcontrolled subsidiaries or affiliates.
Bloomberg Hotline: +1-212-617-1595 ((801)1595) or +1-800-777-7217 (toll free in the U.S.).
Bribery: a form of Corruption, and a specific offense which is the activity or practice of offering,
giving, or promising to give something in order to gain or obtain an advantage of any kind.
Receiving a bribe is also an offense.
BSAT: the Bloomberg Secure Authentication Technology is used by Bloomberg Personnel orend users to access the Bloomberg Professional service. A BSAT is typically embedded in the
Bloomberg keyboard. Each BSAT is configured to authenticate a binary number that has beencreated based on limited information from the specific person’s finger image.
Business Continuity: the process of ensuring the timely response to and effective recovery ofessential data, products, services, and functions provided to clients from unanticipated businessdisruptions that may affect data, facilities, technology, or Personnel.
Business Continuity Coordinator: appointed by Business Continuity Planning Manager andresponsible for specific or multiple business continuity and disaster recovery plans within a
Department.
Business Continuity Planning Manager: a manager within a Department responsible for theentire Department’s business continuity and disaster recovery plans.
CCTV: closed-circuit television.

A-1

Client Data: data Bloomberg collects from its clients and end users through their use of
Bloomberg’s products and services.
Compliance: the Compliance Department of Bloomberg.
CM: Crisis Management, which is the identification of threats to Bloomberg and its stakeholders,
and the methods used by the organization to deal with threats and other crisis situations once
they have occurred.
Communal Areas: areas and other points where authorized and unauthorized Personnel may
enter.
Community-wide Client Data: Client Data that is available to Personnel and the applicablecommunity of Bloomberg product users, in order to facilitate interaction with one another.
Company Communications Systems: the use of software, the Internet, IB<GO>,
MSG<GO>and other email systems, as well as any other Company-owned means of electronic
communication.
Company Equipment: equipment and materials provided by Bloomberg including, but notlimited to, electronic mail, voice mail, telephones, Internet, postage, copy and fax machines,
personal computers, laptop computers, cellular and mobile devices, other hardware/software,
mobile applications, wireless and wired networks, and communications media.
Contingent Worker Confidentiality Agreement: the confidentiality agreement or
confidentiality terms signed by contractors and temporary staff at the time of engagement.
Contingent Worker Policy Guide: a Company policy designed to acquaint all contractors andtemporary staff rendering services to Bloomberg with Bloomberg and to provide contractors andtemporary staff with information regarding some of the policies affecting their working
relationship with Bloomberg.
Contingent Workers: contractors and temporary staff.
Corruption: the misuse of power (entrusted or otherwise) for private or other gain.
CRCO: the Chief Risk & Compliance Office of Bloomberg.
Crisis: a situation or event that presents a material impact or risk to:• The life, health, personal safety, or rights of Bloomberg Personnel;• Bloomberg assets, management, or business activities;• The reputation of the Company or the confidence in a Company brand; or• Shareholders, customers, business partners or the public.

A-2

Critical Locations: Tier 1 and Tier 2 facilities.
CTO: the Chief Technology Officer of Bloomberg.
Departments: the following are the current Departments of Bloomberg:
Accounting
Analytics
Application Specialists
Bloomberg InstituteChief Risk and Compliance Office
CTO OfficeCommunications and Government
ComplianceContracts
Core Product
Cross-Platform Initiatives
Enterprise Solutions
GellerGlobal Data
Industry Verticals
Legal
Marketing
Media
News
People Operations
Research and Development
Sales
Security
Technical Operations
TradebookTrading Solutions
Workplace Operations
Department Manager: the Manager of a Department.
Department Member: Personnel within a Department.
Department Vendor Manager: a Manager within a Department responsible for managing a
vendor relationship.
Disaster Recovery: a subset of Business Continuity, the process of ensuring the recovery ofsystems, applications, and infrastructure in the event of a disaster.
Discrimination: treating an employee less favorably in connection with the terms andconditions of employment because of his/her membership in a protected class.
EAP: the Employee Assistance Program is a confidential program available to all Bloomberg
employees and their families, which provides individuals with an opportunity to discuss andA-3

resolve their difficulties with the assistance of experienced, licensed, and certified mental healthprofessionals.
Employee Confidentiality Agreement: the confidentiality agreement or confidentiality terms
signed by employees at the time of hire.
Global Resource and Information Core Guide: a Company policy designed to acquaint fulltime and part-time employees with Bloomberg, and to provide full-time and part-time employeeswith supplemental information about working conditions, benefits, responsibilities, and some ofthe policies affecting employment.
Harassment: conduct that denigrates or shows hostility or aversion towards an individual basedon a protected classification that (i) adversely affects such individual’s employment opportunities
or working relationship with the Company, (ii) has the purpose or effect of unreasonablyinterfering with an individual's work performance, or (iii) creates an intimidating, hostile, or
offensive working environment. Harassment may take different forms, and may involve, but is
not limited to, visual displays, suggestive or offensive remarks or jokes, slurs or epithets of any
kind, gestures, unwelcome sexual advances or demands, propositions, or unwanted physicalcontact.
Hiring Manager: the manager in the Department who has extended the offer of employment to
the potential employee.
Human Resources: the Human Resources Department of Bloomberg. Previously referred to as
Professional Development.
Incident: any event that presents a material impact or risk to Bloomberg facilities, Personnel,
business operations, or reputation.
Information Security: the protection of information systems and the data contained withinthose systems which takes into account business and legal or regulatory requirements andcontractual obligations.
Information Systems: the Information Systems Department of Bloomberg.
IRT: the Incident Response Team is comprised of select Personnel from across the Company
who are notified and assembled when an Incident of sufficient magnitude occurs. Core
members of the IRT are the CRCO, Legal, R&D, and Operations.
IRT Leader: the individual selected by Security to lead the IRT.
ISMP: the Information Security Management Program that forms the strategic direction for the
execution of information security within Bloomberg.

A-4

Legal: the Legal Department of Bloomberg.
Legal Hold Order: an order issued by Legal that sets forth the recipients' obligation to takereasonable steps to preserve documents that may be relevant to a potential litigation, audit, orgovernmental investigation.
Management Committee: the Management Committee of Bloomberg.
Managers: managers and team leads.
Office Areas: non-communal or non-secure areas accessible only by authorized Bloomberg
Personnel.
Operations: the Operations Department of Bloomberg.
PDCA: Plan, Do, Check, Act cycle, a four-step repeatable cycle used for managing change andcontinuous improvement.
Personal Client Data: Client Data about an identifiable individual client or end user ofBloomberg products or services.
Personal Data and Information: certain personally identifying data and information that
Bloomberg will require employees to provide at various times during their employment.
Personnel: all employees, contractors, and temporary staff of Bloomberg.
Policy: the specific policy referred to in the Policy Scope section of this document.
Policy Approval Committee: the committee that was delegated the authority by theManagement Committee to approve certain Policies.
Principles: the Client Data Principles.
Procurement: the Procurement Department of Bloomberg.
R&D: the Research and Development Department of Bloomberg.
Records: certain documents and information (whether in electronic or hard-copy form) that shallbe retained to support Bloomberg’s operational business purposes and meet applicable legal
and regulatory requirements, including organizational structure, tax and accounting matters,
Human Resources matters, safety records for Bloomberg’s premises and employees,
environmental compliance, insurance coverage, purchasing records, client contracts and related
invoices, Company-wide policies and procedures regarding Bloomberg information, andupdates, revisions, and waivers corresponding to such policies and procedures.

A-5

Records Classification Scheme: a document maintained by Legal that defines the types ofRecords created, received, processed or retained by Bloomberg.
Records Retention Schedule: a document maintained by Legal that assigns a minimum
retention period for Record classes identified in the Records Classification Scheme.
Recovery Strategy: a defined and documented approach for recovering systems, processes,
or applications in the event of a business interruption.
Restricted Client Data: Client Data that has been deemed highly sensitive and may only beaccessed by or disclosed to Personnel who have a business need; access is controlled directlyby the CRCO.
Risk Assessment Methodology: the process by which Security conducts risk assessments to
identify, quantify, and prioritize risks against criteria for risk acceptance and threats.
Safe Harbor: the US-EU and US-Switzerland Safe Harbor Frameworks regarding personal datatransferred from the European Union to the United States and from Switzerland to the UnitedStates.
SDLC: the risk-based System Development Life Cycle that requires several security controls inthe development process. The risk-based process shall ensure that more critical systems or
systems processing sensitive information are subject to appropriate security controls.
Security: the Security Department of Bloomberg.
Security Operations Centers: dedicated space within data centers where network security andinfrastructure Personnel are located.
Security Steering Committee: the Security Steering Committee is comprised of the CRCO,
Head of R&D, and CTO.
Security Working Group: a group of senior IT managers appointed by the Security Steering
Committee to address various information security topics.
Senior Management: senior level managers within a Department.
Social Media Policy: the policy, found at HR<GO>, which sets forth the responsibilities ofBloomberg employees, contractors, and temporary staff when engaging in social media andalso provides a list of prohibited subjects.
Tier 1 Facility: either a data center/node or a Bloomberg site larger than 25,000 square feet.

A-6

Tier 2 Facility: a service site (e.g., Regis site) or a site that is between 10,000 and 25,000
square feet or has more than 200 Personnel.
Vendor: third party vendors. Vendors include any person or company that:•

Licenses systems, services, or technology for use by Bloomberg Personnel, contractors
or Bloomberg clients;•

Performs functions on Bloomberg’s behalf for those products or services Bloomberg
chooses not to conduct internally or Bloomberg does not originate (outsourcing); or•

Manufactures critical supply chain products and services.

A-7

2016
Impact report
Appendix

Planet
List of Environmental Awards
Responsible Sourcing
Bloomberg Ink FSC Chain of CustodyGreen Language in RFP’s
Green Language in Contracts
Scrapper Certificate of Compliance
Environmental Survey for Electronics Recyclers
Bloomberg Supplier Code of ConductBloomberg Impact Report 2016

LIST OF SUSTAINABILITY AWARDS
2016 Awards & Partnerships
E-STEWARDS ENTERPRISE
Bloomberg is an e-Stewards Enterprise which exemplifies our commitment to make best efforts to use e-Stewards certified recyclers to safely,
ethically, and responsibly recycle our IT assets.
http://e-stewards.org/learn-more/for-enterprises/overview/current-enterprises/

GREEN POWER PARTNER
Bloomberg is an EPA Green Power Partner, helping to support the development of new renewable generation capacity nationwide while also
helping to protect the environment.
https://www.epa.gov/greenpower/green-power-partner-list

GREEN POWER MARKET DEVELOPMENT
Bloomberg earned the Green Power Market Development award which recognizes organizations and individuals building and growing thevoluntary market for green power.
https://resource-solutions.org/press-releases/101716/

GRI GOLD COMMUNITY
Bloomberg is a member of GRI’s GOLD Community members, which includes diverse companies and organizations across business,consultancies, civil society, academia, labor, public and intergovernmental agencies.
https://www.globalreporting.org/network/GOLDCommunity/Pages/default.aspx

INNOVATION IN REPORTING: WINNER
The Bloomberg Annual Impact Report was recognized for the third time by the Corporate Register (CRRA), this time for Innovation in reporting.
http://www.corporateregister.com/crra/?d=2016

LEADERSHIP IN ENERGY AND ENVIRONMENTAL DESIGN (LEED) OFFICES
All new and refurbished offices are built to LEED standards included but not limited to; recycling of construction waste, low VOCs, daylightsensors, efficient HVAC, reduced lighting power and fixtures that reduce water use.
To see a full list of Bloomberg’s completed and scheduled LEED Certified Projects visit:
http://www.usgbc.org/projects?keys=Bloomberg

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
OUTSTANDING CORPORATE LEADER
Sustainability Roundtable, Inc recognized Bloomberg as the Sustainable Business & Enterprise Roundtable's (SBER) Outstanding Corporate
Leader for 2016 “because of its industry leading best practices in driving greater sustainability throughout Bloomberg’s global real estate andoperations portfolio.” Bloomberg, first recognized in 2014, is the first company to be recognized a second time.
http://www.csrwire.com/press_releases/39594-Bloomberg-Named-Outstanding-Corporate-Leader-of-2016?tracking_source=rss

PRODUCT OF THE YEAR (WRVT)
Environmental Leader awarded Bloomberg’s Water Risk Evaluation Tool (WRVT) the Product of the Year designation.
https://www.environmentalleader.com/products/bloomberg-lp-the-water-risk-valuation-tool/

Prior Awards
AWARD OF EXCELLENCE FOR SUSTAINABLE FACILITY OPERATIONS & MANAGEMENT
Bloomberg received the Award of Excellence from the International Facility Management Association (IFMA) in 2015.
http://awards.ifma.org/

CRRA: BEST FIRST TIME REPORT-1ST RUNNER UP (2012) & INNOVATION IN REPORTING-WINNER
The CRRA is the only global annual awards for corporate responsibility (CR) reporting. Bloomberg was recognized for best first time reportand innovation in reporting.
http://www.corporateregister.com/crra/

EPA GREEN POWER PURCHASING
We won an award from the EPA Green Power Partnership at their Green Power Leadership Awards Ceremony for Green Power Purchasing.
We are the 22nd largest procurer of renewable energy credits in the United States.
https://www.epa.gov/greenpower/2012-past-award-winners

PRODUCT OF THE YEAR (CRVT)
We won the 2014 Product of the Year for our Carbon Risk Valuation Tool (CRVT)
https://www.environmentalleader.com/products/bloomberg-lp-the-water-risk-valuation-tool/

ROCKLAND RECYCLES AWARD
Each year the Rockland County Solid Waste Management Authority recognizes excellence in recycling and/or waste prevention/reduction
programs.
http://www.rocklandrecycles.com/page/rockland-recycles-awards-131.html

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016RESPONSIBLE SOURCING AND PROCUREMENT GUIDELINE
Our Mission
Bloomberg L.P. ("Bloomberg") is committed to working with our suppliers to:• Operate an efficient and sustainable supply chain that supports our corporate responsibility programs• Develop sourcing solutions in line with customer, regulatory and wider stakeholder needs and expectations• Highlight and track the Chain of Custody ("CoC") for all precious and conflict minerals as well as other “high impact” items• Ensure that all precious and conflict minerals have been responsibly sourced in accordance with all local, federal and internationallaws and regulations, as well as this guideline.
• Prohibit the use of child, convict/prison or slave labour while ensuring that Bloomberg and our suppliers abide by globally recognized,
UN mandated human rights policies• Create long term value and reduce risk for our business, our suppliers and our stakeholders
How does Bloomberg define its Supply Chain?
Bloomberg defines its supply chain as the goods and services purchased and/or sourced for and utilized in its operations. This includes
raw materials sourced for the construction of its offices and their interiors, including office furniture, as well as Bloomberg branded
products (Flat Panels, Keyboards & B-Units), marketing/premium items provided to our clients and/or employees, electronics hardware
procured for our operations and paper for our publishing business (Markets Magazine & Bloomberg Businessweek). Responsible
sourcing is a key principle in Bloomberg's procurement approach and is given strong consideration alongside other factors such as
price and quality.
To whom does this policy apply?
Bloomberg's Responsible Sourcing Policy applies to all procurement professionals and individuals designated with authority to procure
items employed by Bloomberg, as well as to suppliers and subcontractors who purchase goods or services on behalf of Bloomberg.
What is Responsible Sourcing of Materials?
Responsible sourcing is an ethos which guides supply chain management and product stewardship by taking into account the social,economic and environmental impacts of a product over the entire course of its useful life. It is a holistic approach to managing the
product’s impact from cradle (raw material extraction) to grave (final disposal).
Why do it?
Responsible sourcing gives sourcing professional's confidence that the raw materials and products they choose for use throughout
Bloomberg's operations have minimal adverse social, environmental, and economic impacts.
• Construction & Building
The construction industry has a wide ranging impact on both the local and international environment. Procuring materials through an
Environmental, Safety and Ethical Management System ensures that the impact of the structure can be minimized
Historically, timber construction products were the only products available from a certified, sustainably managed source with acertified CoC beyond that required by regulation. Bloomberg works to ensure that all of its "high impact" raw material inputs (i.e.,bronze, metal stone, timber are tracked in accordance with best-in-class chain of custody standards and other environmental
management systems (such as EMAS, ISO14001, BES 6001, etc.).
• Wood & Timber
It is Bloomberg's policy that 100% of timbers come from legal and sustainable FSC (Forest Stewardship Council) timber sources withfull CoC. FSC CoC is defined as the path taken by raw materials, processed materials or finished products from the forest to theconsumer, including each stage of transformation, manufacturing, storage and transport where progress to the next step involveschange of ownership of the materials or products.
In addition, Bloomberg's suppliers should ensure that wood/wood products are in compliance with applicable local and international
law/regulations governing their sourcing and movement. This would include but is not limited to: the U.S. Lacey Act, rules governing
the use/treatment/disposition of solid wood packaging materials, etc.
There are a number of steps that providers of timber for Bloomberg must undertake to ensure CoC:
1. Notify your timber supplier that only FSC timber is to be delivered to the site
2. Include this requirement in the project’s subcontract documents
3. All logistics staff should be made aware of this requirement and instructed to reject any non-compliant timber at the site

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
4.
5.

You must retain timber delivery tickets as proof of compliance. An example of a timber delivery ticket can be found at theend of this guideline (Example 1)
You must keep a timber register that details the type and quantity of timber delivered to the site.

Paper
Using paper made from recycled and FSC-certified fiber is the cornerstone of our purchasing policy. Choosing recycled and FSC paper
will have a direct, profound and measurable impact. This will reduce pressure on natural forests and their ecosystems by creating ademand for “waste paper” that would otherwise go to landfills. Recycled and FSC paper also reduces energy, water, and chemical use
during the manufacturing process. The FSC certification scheme best meets our criteria for robust forest protection because, among
other attributes, it is the most inclusive and transparent process. The FSC certification scheme also provides a view across multiple
concerns - social, economic, and environmental.
General Procurement
Bloomberg has developed a comprehensive Green Operating Guideline that outlines our policies governing several areas including (butrdnot limited to): Environmentally Preferred Purchasing of goods and services; 3 Party Printer services; Construction Materials andEnergy Star Electronics Equipment. Excerpts from those policies deemed relevant to this Responsible Sourcing and Procurement
Policy are below. The comprehensive Green Operating Guidelines are available on the Bloomberg Impact website at
http://www.bloomberg/bcause/report_supplements.
The procurement of Engineering Hardware, Electronic Products & Appliances should include one or more of the following criteria(where applicable):• Products used should reduce Greenhouse gas emissions compared to comparable products• The delivery of products should take into account the emissions from delivery and seek to minimize where possible.
• Product should come from a local/regional manufacturing or assembly plant.
• Product should have an Energy Star or Energy Smart designation, or some other feature that minimizes power consumption during
its useful life.
• PCs, Notebooks and other equipment should contain power management settings• Products should contain non-brominated flame retardants (BFR). Note some companies are in the process of phasing out
brominates, so inquire as to when the non-brominated products will be released.
• Products should not contain parts made with Polyvinyl Chloride (PVC).
• Equipment should meet applicable environmental, health, and safety standards in the applicable country(s) where the items are to
be made available (i.e., made without Hazardous Substances like lead, which can be harmful to the environment).
• Manufacturers should reduce the amount of waste from the manufacturing process or recycle percentage of waste.
• Company providing products should have Asset Recovery Services (ARS) or a Commercial Asset Recovery Program.
Energy Star
In order to improve the energy efficiency of our inventory, high value products such as computers, monitors, copiers, printers, scanners,
fax machines, refrigerators and other appliances shall meet the criteria listed below. It is Bloomberg's intent that 90% of the cost of theabove mentioned class of items will meet at least these two criteria:• Energy Star when available• Electronic Product Environmental Assessment Tools (EPEAT) bronze level, or higher, rated products
Furniture and Furnishings
When purchasing new furniture, Bloomberg will look for items with the following characteristics: FSC certified wood, recycled or rapidly
renewable resource content, no added urea formaldehyde, manufactured locally, and packaged with minimal material. It is Bloomberg's
goal that 30% of all furniture purchases meet the following additional specifications:• All furniture products should contain recycled content. The acceptable range for furniture manufactured from post-consumer steel andplastic is 30% to 100% for post-consumer recycled content and 50% to 100% for total recycled content (pre-consumer plus postconsumer).
• Desk accessories should be made of recycled materials. The acceptable range for plastic desk accessories such as pencil cups,
magazine files and telephone stands, is that they contain 25%-100% post-consumer recycled content and 50%-100% total recycledcontent (pre-consumer plus post-consumer). The acceptable range for steel or metal desk accessories is that they contain 10%100% post-consumer recycled content and 25%-100% total recycled content (pre-consumer plus post-consumer).
• Bloomberg will endeavor to purchase salvaged, refurbished and/or used furniture for their facilities whenever feasible.
• GreenGuard certified furniture is preferred.
How is Chain of Custody assurance achieved?
Bloomberg will work with all relevant suppliers to ensure that a proper CoC system is in place, which enables the Company to track a

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
product’s entire life cycle from manufacture to disposal. The following systems need to be put in place for any project deemed
substantial to Bloomberg and/or the environment.
Quality System Requirements
1.1

Documented ProceduresCompany shall have documented procedures that detail the following: 1) the company’s procedures for the tracking and handlingof certified material from ordering through final product sales and shipping or use; 2) the responsible personnel or staff positions
for the control system; 3) the forms and records used for certified tracking and handling; 4) the procedures for compiling volume
summary data for certified purchases, production, and sales per product group, supplier/customer, and month; 5) the procedures
for labeling and logo use (if applicable); 6) the protocol for maintaining records that pertain to certification.

1.2 Responsibility• A designated individual shall be responsible for COC controls and compliance.
• Key personnel shall be designated and informed of their specific responsibilities within the Chain-of-Custody control system.
1.3 Product Group Assignment• A product group schedule shall be prepared that includes: 1) the species of each product group; and 2) a designation of the
product group as either 100% ethically sourced or percentage that is responsibly sourced.
• The product group schedule shall be kept up-to-date and available upon request.
1.4 Training• Training requirements for all applicable staff shall be clearly defined.
• Training/orientation on the handling and representation of certified products shall be completed.
• Training records shall be kept to demonstrate training that has taken place.
1.5 Records and Reports• Quantity records of certified material purchasing/receiving, production (including applicable conversion factors), and certified
sales and shipping shall be maintained and readily available in summary format for annual audit review.
• Records shall be maintained for all purchases, processing, and sales of certified products, as well as marketing, advertising,and any other public information pertaining to certification for a minimum of 5 years.
How is responsible sourcing ascertained?
The appropriate materials procured shall have an Environmental Management System such as ISO14001 or EMAS (Eco-Management
and Audit Schemes), or BES 6001 or similar at PROCESS and EXTRACTION stages. If the company is smaller (generally less than 30
staff) then BS8555 can be used (the precursor to ISO14001). Bloomberg also requires that goods be purchased from sources withenvironmental, health, safety and quality standards in place at each stage of procurement.
Labour and Human Rights within Bloomberg's Responsible Sourcing Policy
Bloomberg's Responsible Sourcing and Procurement Policy is based on developing and maintaining an economically sound andprosperous business. Bloomberg assumes its responsibilities towards both the communities and environments in which we operate,
and towards our employees, business partners and society in general. We have distilled our approach into the following key
commitments:• We are committed to doing business with a high degree of integrity and ethics• We comply with all known applicable legal and regulatory requirements that apply in the countries in which we do business• We respect the United Nations Declaration of Human Rights and recognize our responsibility to observe those rights as they informour responsibility toward our employees and the communities in which we operate.
• Suppliers shall not discriminate against any worker based on race, color, age, gender, sexual orientation, ethnicity, disability, religion,
political affiliation, union membership, national origin, or marital status in hiring or in other employment practices such as applications
for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, and termination. Suppliers
shall not require a pregnancy test or discriminate against pregnant workers except where required by applicable laws or regulations
or where prudential concerns around workplace safety make it reasonable to take pregnancy into account. In addition, suppliers shallnot require workers or potential workers to undergo medical tests that could be used in a discriminatory way except where requiredby applicable laws or regulations or where prudent for the maintenance of workplace safety.
• Suppliers shall not traffic in persons or use any form of slave, forced, bonded, indentured, or prison labour. This includes thetransportation, harboring, recruitment, transfer, or receipt of persons by means of threat, force, coercion, abduction, fraud, orpayments to any person having control over another person for the purpose of exploitation. All work must be voluntary and workers
shall be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any
government-issued identification, passports, or work permits as a condition of employment. Suppliers shall ensure that third-party

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016
agencies providing workers are compliant with the provisions of this Guideline and the laws of the sending and receiving countries,
whichever is more stringent in its protection of workers. Suppliers shall ensure that contracts for both direct and contract workers
clearly convey the conditions of employment in a language understood by the worker. Where workers are required to pay a fee inconnection with obtaining employment, suppliers shall be responsible for payment of all fees and expenses in excess of the amountof one month of the worker’s anticipated net wages. Such fees and expenses include, but are not limited to; expenses associatedwith recruitment, processing, or placement of both direct and contract workers.
• Suppliers shall pay all workers at least the minimum wage required by applicable laws and regulations and provide all legally
mandated benefits. In addition to their compensation for regular hours of work, workers shall be compensated for overtime hours at
the premium rate required by applicable laws and regulations. Suppliers shall not use deductions from wages as a disciplinary
measure. Suppliers shall offer vacation time, leave periods, and holidays consistent with applicable laws and regulations. Suppliers
shall pay workers in a timely manner and clearly convey the basis on which workers are being paid.
UN Global Compact
Bloomberg is a signatory of the UN Global Compact demonstrating our commitment in embracing, supporting and enacting, within out
sphere of influence, a set of core values in the areas of human rights, labour standards, the environment and anti-corruption:
Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; andPrinciple 2: make sure that they are not complicit in human rights abuses.
LabourPrinciple 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labour
Principle 5: the effective abolition of child labour; andPrinciple 6: the elimination of discrimination in respect of employment and occupation
Environment
Principle 7: Businesses should support a precautionary approach to environmental challenges;
Principle 8: undertake initiatives to promote greater environmental responsibility; andPrinciple 9: encourage the development and diffusion of environmentally friendly technologies.
Anti-Corruption
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery
Policy on Conflict Minerals
Together with other companies, nongovernmental organizations (NGOs) and governments, Bloomberg is addressing concerns about
the use in our supply chains of “conflict minerals” mined in identified countries of concern. These materials, presently identified as tin,tantalum, tungsten and gold, whose extraction and trade can contribute to destabilizing the country and regions in which they aremined, are mixed with material from non-conflict sources as they move from the identified countries of concern into global processing
and manufacturing operations. Tin, tantalum, tungsten and gold sourced from global markets are used in Bloomberg’s branded
products, as well as electronics that are purchased from our vendor partners. Because of the possible connection, however
remote, between our products and the issues in the identified countries of concern, we have committed to improving our conflict-freesourcing practices in the following ways:• Bloomberg is working to be compliant with the rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act torequire companies to publicly disclose their use of conflict minerals that originated in the DRC or an adjoining country and disclosing
our usage of these materials in the production of Bloomberg branded products• Bloomberg prohibits the explicit purchase of any conflict minerals that knowingly come from the DRC• Bloomberg will support and follow the Electronics Industry Citizenship Coalition and Global e-Sustainability Initiative (GeSI) in
establishing a “Conflict-Free Smelter” program in which metals smelters are audited to verify the origins of their tin, tantalum, gold
and tungsten ores.

Bloomberg recognizes that its influence within the marketplace is limited by comparison to other large
manufacturers/distributors/suppliers of electronics and therefore relies on larger industry players and non-profits to set guidelines andstandards across the industry. Bloomberg will endeavor to follow best-in-class standards (such as those listed above) to drive its
conflict mineral purchases and work across the industry to identify best-in-class suppliers who are abiding by the highest standards andcertifications available in the marketplace.

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved

BLOOMBERG INK, A DEPARTMENT OFBLOOMBERG L.P.
431 RIDGE RD
DAYTON, NEW JERSEY 08810
UNITED STATESIS CERTIFIED FOR FOREST STEWARDSHIP COUNCIL™
CHAIN OF CUSTODY
Certificate Scope
Certificate Type: Multi-site Chain of CustodyStandard(s): FSC-STD-40-003 V1-0; FSC-STD-40-004 V2-1
Product group(s): Notebooks, Notepads, Envelopes, Books, Advertising
Materials, Calendars
Valid from October 30, 2013 to October 29, 2018
Certificate Registration Code: RA-COC-003563
FSC License Code: FSC-C020405
Certificate Issue Number: IN-2013-1
As a multi-site certificate, the activities and products included in the scope of
this certificate are performed by a network of participating sites. Additional
details regarding the scope, including a full list of
products, species, and participating sites, are available at info.fsc.org.

___________________________Jon Jickling, Director, Certification
Rainforest Alliance223 Broadway, 28th Floor New York, NY 10279 USA

RAINFOREST ALLIANCE IS AN FSC® ACCREDITED CERTIFIER

The validity of this certificate shall be verified on info.fsc.org.
This certificate does not constitute evidence that a particular
product supplied by the certificate holder is FSC certified
and/or FSC Controlled Wood. Products offered, shipped orsold by the certificate holder can only be considered coveredby the scope of this certificate when the required FSC claim isclearly stated on invoices and shipping documents.
This certificate is the property of Rainforest Alliance. Thiscertificate and all copies or reproductions of this certificate shallbe returned or destroyed if requested by Rainforest Alliance.

Version July 2013

Bloomberg Impact Report 2016

EXAMPLE OF THE TYPE OF ENVIRONMENTALLY
PREFERRED LANGUAGE IN RFX'S

The primary objective of Bloomberg's sustainability strategy is to decouple the company’s growth from environmental impact, while proving thebusiness case for sustainable operations. This includes procuring goods and services that have a lesser or reduced effect on human healthand the environment when specifically compared with other goods and services that serve the same purpose. To help us achieve our goals
and objectives, Bloomberg highly encourages all Companies to publicly release a Global Reporting Initiative (GRI) Compliant Sustainability
Report. If your Company already releases a sustainability report, please send a web link to the report to
BSUSTAINABLE@BLOOMBERG.NET for Bloomberg’s review. If your company does not publish a sustainability report, Bloomberg asks
vendors submitting responses to this RFx to submit copies of their firm's sustainability initiative, detailing policies and procedures andinformation about what makes your goods and/or services environmentally preferable ("Green"). Information should include, but is not limited
to, whether your firm is listed on the Dow Jones Sustainability Index, is accredited to any recognized Environmental Standards, has employees
who are certified or has environmental educational programs for employees and if the educational programs are available to clients.
Depending on the nature of your business, Bloomberg reserves the opportunity to send a subsequent vendor survey to potential vendors
should we need to clarify any concerns Bloomberg has regarding the Company's commitment to Sustainability.

Please provide Sustainability contact information, so Bloomberg can direct requests for additional information, if required.

Sustainbility Contact(s): _______________________

Phone: ______________________________

Fax: ________________________________

E-mail: ______________________________All goods and/or services procured by Bloomberg must meet and/or exceed any or all local, state or federal governing bodies. Failure tocomply with Bloomberg's environmentally preferable ("Green") requirements may affect future opportunities for your firmBloomberg Impact Report 2016SUSTAINABILITY LANGUAGE IN CONTRACTS

We ask Service Providers to represent, warrant and covenant to Bloomberg and its affiliates that to the extent applicable and practicable, theyshall seek to use products certified under the “Green Seal” certification process, or, at Bloomberg’s discretion, a comparable standard, underthe most recent version of the applicable standard for all goods or products used to provide the Services and Deliverables, and in any event
shall conform to all applicable requirements of law.
In addition, Bloomberg reserves the right to ask Service Providers to provide information regarding their sustainability programs and initiatives
and highly encourages all Service Providers to publicly release a Global Reporting Initiative (GRI) Compliant Sustainability Report. In theevent that a Service Provider releases a sustainability report, it shall send a web link to the report to BSUSTAINABLE@BLOOMBERG.NET forreview. Upon request Service Providers shall provide to Bloomberg ongoing reports and data pertaining to environmental or other aspects of
the Services which may be used by Bloomberg in its discretion to obtain certifications or achieve standards and in each case maintain them.

-1-Bloomberg Impact Report 2016

SCRAPPER CERTIFICATE OF COMPLIANCE
THIS CERTIFICATION is made by [INSERT COMPANY] (“Company”) as of the date of signature below. Company hereby
represents, warrants and covenants to Bloomberg L.P. (“Bloomberg”) as follows:1.

Company is in compliance with all applicable local, city, state, federal and international laws, rules and regulations including, but
not limited to, all antidumping, environmental, safety and health and labor and employment laws, rules and regulations, and shallremain in compliance for so long as Company is performing any services for Bloomberg.

2. Except as otherwise disclosed to Bloomberg in writing, there are no judgments, liens, demands, claims, suits, actions, arbitrations
or other proceedings outstanding, pending or threatened (or for which any basis exists) that in any way questions or jeopardizes(or could question or jeopardize) the ability of Company to perform any of Company’s obligations in connection with the provisionof services to Bloomberg.

2.

Except as otherwise disclosed to Bloomberg in writing, there is no pending enforcement, administrative action or environmental
claim or judgment against the Company, nor has the Company recently settled any such claim or judgment.

IN WITNESS WHEREOF, the Company has executed this Certification as of the date set forth below:[INSERT NAME OF COMPANY]

By: ____________________
Name:

Title:

Date:2016 Bloomberg Impact Report Bloomberg L.P. all rights reserved

Bloomberg Impact Report 2016

ENVIRONMENTAL SURVEY FOR ELECTRONICS RECYCLERS
Company:
Address:
Other Addresses:
Contact Name:
Voice No:Fax No:Email:
Website:1)

Please provide a description of your business and operations.
For example: number of employees, years of operation, ownership and any ownership changes, facilities and their history,
operations and services offered.

2)What materials do you process and Where do you send them?
a)General IT and High Tech:b)

Metal:c)

Plastic:d)

Packing Materials (Cardboard, Foam):e)

Toxic Waste/Batteries:f)

Others:3)

What do you do with the used equipment that you receive? For example, what processing do you do to make electronics
you receive ready for resale or recycling?

4)

What is your data security process for IT equipment that you receive (Hard drive erasure/destruction)?

5)

Do you export any materials? If so, what is the purpose of the export? What are the names of the importing facilities andcountries of location? Please provide documentation of legality.

6)

What materials are sent from your facility and where do you send them?

7)

Do you send waste materials offsite for disposal in landfills or for incineration?

8)

Do you currently have outlets for all of the materials you receive and materials you generate?

9)What is the difference in terms of volume between the input of electronics to your company vs. the output (via recycling
or resale) and what is the difference with respect to the facility at issue in particular?

10) Do you audit the facilities that receive materials from you?
11) Do you provide documentation or certification of final disposition?
12) Do you generate waste that is regulated, e.g. hazardous waste?

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved-1-Bloomberg Impact Report 201613) Are you subject to environmental, health and safety regulation? If so, please describe.
14) What regulatory agencies have jurisdiction over your facilities and operations?
15) What environmental, health and/or safety permits, licenses, and registrations are required? Do you have them?
16) What agency notifications are required? Have you provided them?
17) Are you in compliance with all applicable regulations and permits?
18) What is your compliance history? For example, has your facility been inspected by federal, state or other government
agencies having jurisdiction over environmental, health or safety matters within the last five (5) years? If so, with what
results?
19) Are you currently subject to any investigations or proceedings relating to any environmental, health or safety matters?
Do you have any notices of violations that remain unresolved?
20) Do you store any products or wastes outdoors?
21) Do you have an environmental management system, environmental risk management plan, or electronics recycling
certification in place? Please describe.
For example, as to electronics recycling in particular are you certified or do you follow: "e‐ Stewards", "Electronics Recycler'sPledge of True Stewardship", Responsible Recycling "R2" Practices, "Plug into eCycling" guidelines, Recycling Industry
Operating Standard ("RIOS"), Institute of Scrap Recycling Industries Electronics Recycling Operating Practices, "Certified
Electronics Recycler®", ISO 9000 and/or ISO 14000.
22) Do you perform regular environmental, health and safety audits of your operations?
23) Do you have a trained employee who is responsible for environmental, health and safety onsite?
24) Do you provide environmental, health and safety training to your employees?
25) Do you have environmental insurance?
26) Will you allow verification through an on‐site evaluation?
27) Please provide references and contact information for other businesses that have used your services.
28) Are you certified as e-Steward, R2/Rios, or ISO 14001? If yes, what certification do you have for each location?

Bloomberg Impact Report 2016 Bloomberg L.P. all rights reserved-2-

Bloomberg Impact Report 2016

BLOOMBERG SUPPLIER CODE OF CONDUCTGlobalization and sourcing diversification create unique opportunities and challenges for supply chain
management. Bloomberg is committed to working with our suppliers to ensure that their operations are efficient, safe andsustainable and that they support our own sustainability objectives. We have developed a comprehensive Supplier Code of
Conduct (“Code”) which defines our requirements with respect to environmental, social and governance performance of our
suppliers.
This Code is based on the Electronic Industry Citizenship Coalition’s Code of Conduct, and applies to all Bloomberg suppliers
globally, including but not limited to the following:•
Manufacturing•
Assembling•
Packaging•Marketing•Transportation and Logistics•
Scrapping and Recycling•
Constructing and Facilities Management•
Services, including professional services, event management, janitorial services, and pest control
•
Paper
•
Office supplies•
Premiums
To adopt this Code and become a participant (“Participant”), a business shall declare its support for the Code and actively pursue
conformance to the Code and its standards in accordance with a management system as herein.
Participants must regard the code as a total supply chain initiative. At a minimum, participants are also responsible to ensure its
next tier suppliers act in a manner consistent with the Code.
Fundamental to adopting the Code is the understanding that a business, in all of its activities, must operate in full compliance withthe laws, rules and regulations of the countries in which it operates. The Code encourages Participants to go beyond legal
compliance, drawing upon internationally recognized standards, in order to advance social and environmental responsibility, andbusiness ethics. In addition to the EICC Code, this Code and our broader Supply Chain Sustainability Strategy draws uponguidance from the following:•
International Labor Organization (ILO) Conventions and Recommendations•
Universal Declaration of Human Rights•
Social Accountability International (SAI)•
Ethical Trading Initiative (ETI)•UN Global Compact (UNGC)
The Code
The Code is made up of five sections. Sections A, B, and C outline standards for Labor, Health and Safety, and the Environment,
respectively. Section D adds standards relating to business ethics; Section E outlines the elements of an acceptable system tomanage conformity to this Code.
A. LABOR
Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by theinternational community. This applies to all workers including temporary, migrant, student, were used as references in preparing
the Code and may be a useful source of additional information.
The labor standards are:1) Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor, prison labor, slavery or trafficking of persons shall not to be used.
This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force,
coercion, abduction or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave workat any time or terminate their employment. Workers must not be required to surrender any government-issued identification,
passports, or work permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers
must be disclosed.
Participants shall comply with (and shall ensure subcontractors and suppliers comply with) all applicable anti-slavery andhuman trafficking laws, statutes, regulations and codes from time to time in force; and not engage in any activity, practice orconduct that would constitute an offence under sections 1,2 or 4 of the UK’s Modern Slavery Act 2015 or 48 CFR 52.222-50

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Bloomberg Impact Report 2016
Combating Trafficking in Persons of the US Code of Federal Regulations. Participants shall include in their contracts with
subcontractors and suppliers anti-slavery and human trafficking provisions that are at least as onerous as those set out in thisCode of Conduct and shall implement due diligence practices to support this. Participants shall notify Bloomberg as soon as
they become aware of any actual or suspected slavery or human trafficking in a supply chain that has a connection to
Bloomberg and shall maintain a complete set of records to trace the supply chain of all goods and services to Bloomberg which
can be available to view by Bloomberg on request.
2) Child Labor AvoidanceChild labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14
where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for
employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply withall laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the healthor safety of young workers.
3) Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury andillness. Workweeks are not to exceed the maximum set by local law. Further, except in emergency or unusual circumstances, atypical workweek should not be more than 60 hours per week and workers shall be allowed at least one day off per seven-day
week.
4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime
hours and legally mandated benefits. Bloomberg expects suppliers to provide wages and benefits that are sufficient to cover, ata minimum, workers’ basic needs plus some discretionary income. In compliance with local laws, workers shall be compensatedfor overtime. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being
paid is to be provided in a timely manner via pay stub or similar documentation.
5) Humane Treatment
There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental
or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies andprocedures in support of these requirements shall be clearly defined and communicated to workers.
6) Non-Discrimination
Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage indiscrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation,
union membership or marital status, or any other category protected by applicable law in hiring and employment practices suchas promotions, rewards, and access to training. Companies shall apply the principle of equal pay for men and women workers
for work of equal value. In addition, workers or potential workers should not be subjected to medical tests that could be used ina discriminatory way.
7) Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve
workplace and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation,and join workers’ councils, and bargain collectively in accordance with local laws shall be respected. Workers shall be able toopenly communicate and share grievances with management regarding working conditions and management practices without
fear of reprisal, intimidation or harassment. If freedom of association and/or the right to collective bargaining are restricted bylaw, the Participant shall, without violating applicable law itself, not interfere with efforts by workers to develop parallel means
for independent and free association and collective bargaining.
B. HEALTH and SAFETY
Participants recognize that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work
environment enhances the quality of products and services, consistency of production and worker retention and morale.
Participants also recognize that ongoing worker input and education is essential to identifying and solving health and safetyissues in the workplace. Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety
and Health were used as references in preparing the Code and may be a useful source of additional information.
The health and safety standards are:1) Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to becontrolled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures

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Bloomberg Impact Report 2016
(including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means,
workers are to be provided with appropriate, well-maintained, personal protective equipment. Workers shall not be disciplined
for raising safety concerns.
2) Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing
emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures,
worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
3) Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including
provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment;
investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.
4) Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or
administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means,
worker health is to be protected by appropriate personal protective equipment programs.
5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive
lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and mitigated.
6) Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to beprovided and properly maintained where machinery presents an injury hazard to workers.
7) Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, andeating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained to be clean and safe, andprovided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, andreasonable personal space along with reasonable entry and exit privileges.
C. ENVIRONMENTAL
Participants recognize that environmental responsibility is integral to producing world class products. In manufacturing
operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding thehealth and safety of the public. Recognized management systems such as ISO 14001 and the Eco Management and Audit
System (EMAS) were used as references in preparing the Code and may be a useful source of additional information.
The environmental standards are:1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained andkept current and their operational and reporting requirements are to be followed.
2) Pollution Prevention and Resource Reduction
Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying
production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.
3) Hazardous Substances
Chemicals and other materials posing a hazard if released to the environment are to be identified and managed to ensure theirsafe handling, movement, storage, use, recycling or reuse and disposal. Suppliers shall comply with the Restriction ofHazardous Substances Directives included in the Institute of Electrical and Electronics Engineers (IEEE) publication 1608.
4) Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized,
monitored, controlled and treated as required prior to discharge or disposal.
5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion byproducts generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.

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Bloomberg Impact Report 20166) Product Content Restrictions
Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of
specific substances, including labeling for recycling and disposal.
In addition to the environmental provisions laid out in this Code, Bloomberg has developed a series ofoperational guidelines called BGREEN. The BGREEN OPERATIONAL GUIDELINES include:• 3rd Party Printer Guidelines• BLP Green Construction Policy• Waste Management Policy• Green Cleaning Policy• Integrated Pest Management Policy• Sustainable Warehouse Guidelines• Corporate Green Events Policy
Suppliers are also required to comply with the relevant policies and guidelines contained in BGREEN which will be sent along withthis Code, and can be accessed online at www.bloomberg.com/bsustainable in our comprehensive sustainability report.
D. ETHICS
To meet social responsibilities and to achieve success in the marketplace, Participants and their agents are to uphold the highest
standards of ethics including:1) Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero tolerance policy toprohibit any and all forms of bribery, corruption, extortion, embezzlement (covering promising, offering, giving or accepting any
bribes), and facilitation payments. All business dealings should be transparently performed and accurately reflected on
Participant’s business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliancewith anti-corruption laws.
2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
3) Disclosure of Information
Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance withapplicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices inthe supply chain, are unacceptable. Bloomberg reserves the right to request anti-corruption policies and procedures ofParticipant, Participant's subsidiaries and affiliates, and agents of Participant and/or agents of Participant's subsidiaries andaffiliates.
4) Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects
intellectual property rights.
5) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguardcustomer information must be available.
6) Protection of Identity
Programs that ensure the confidentiality and protection of supplier and employee whistleblower are to be maintained.
7) Responsible Sourcing of Minerals
Participants shall have a policy to reasonably assure that the columbite-tantalite (coltan), cassiterite, tin, tungsten, wolframite
and gold or their derivatives, or any other minerals or their derivatives identified as "conflict minerals" in or pursuant to Section
1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and any applicable amendments
thereto (the "Dodd-Frank Act") in the products they manufacture do not directly or indirectly finance or benefit armed groups thatare perpetrators of serious human rights abuses in the Democratic Republic of the Congo, an adjoining country or any othercountry covered in the Dodd-Frank Act. Upon Bloomberg's request, Participants shall furnish Bloomberg any and all due
diligence measures undertaken by Participant to determine said conclusion.
8) Privacy
Participants are to commit to protecting the reasonable privacy expectations of personal information of everyone they dobusiness with, including suppliers, customers, consumers and employees. Participants are to comply with privacy andinformation security laws and regulatory requirements when personal information is collected, stored, processed, transmitted,
and shared.

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Bloomberg Impact Report 20169) Non-Retaliation
Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
E. MANAGEMENT SYSTEM
Participants shall adopt or establish a management system whose scope is related to the content of this Code. The
management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements
related to the participant’s operations and products; (b) conformance with this Code; and (c) identification and mitigation ofoperational risks related to this Code. It should also facilitate continual improvement.
The management system should contain the following elements:
1) Company Commitment
A corporate social and environmental responsibility policy statement affirming Participant’s commitment to compliance andcontinual improvement, endorsed by executive management
2) Management Accountability and Responsibility
The Participant clearly identifies company representative[s] responsible for ensuring implementation of the management
systems and associated programs. Senior management reviews the status of the management system on a regular basis.
3) Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements,
including the requirements of this Code.
4) Risk Assessment and Risk Management
A process to identify the environmental, health and safety and labor practice and ethics risks associated with Participant’s
operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physicalcontrols to control the identified risks and ensure regulatory compliance.
5) Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s social andenvironmental performance, including a periodic assessment of Participant’s performance in achieving those objectives.
6) Training
Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and tomeet applicable legal and regulatory requirements7) Communication
A process for communicating clear and accurate information about Participant’s policies, practices, expectations andperformance to workers, suppliers and customers
8) Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by thisCode and to foster continuous improvement.
9) Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer
contractual requirements related to social and environmental responsibility.
10) Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations andreviews
11) Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company
requirements along with appropriate confidentiality to protect privacy
12) Supplier Responsibility
A process to communicate Code requirements to suppliers and to monitor supplier compliance to the CodeBloomberg Impact Report 2016 Bloomberg L.P. all rights reserved