CODE OF CONDUCT LOG IN DOW JONES CODE OF CONDUCT Dow Jones Code of Conduct This code is designed to provide all employees of Dow Jones with guidelines for appropriate professional conduct. It is intended not as a statement of new beliefs or a codification of new rules of conduct, but as a reaffirmation of enduring values and practices. Please note that the code was revised effective January 2012 to clarify certain provisions. As a News Corporation company, Dow Jones and its employees are also governed by News Corporation’s Standards of Business Conduct and other written policies and guidelines issued by Dow Jones and News Corporation. If News Corporation’s Standards of Business Conduct does not address certain topics covered by this code, or a specific provision in this code is more restrictive than the Standards of Business Conduct, then this code shall govern. The central premise of this code is that Dow Jones’ reputation for quality products and services, for business integrity, and for the independence and integrity of our publications, services, and products is the heart and soul of our enterprise. Put another way, it is an essential prerequisite for success in the news and information business that our customers believe us to be telling them the truth. If we are not telling them the truth – or even if they, for any valid reason, believe that we are not – then Dow Jones cannot prosper. Dow Jones will suffer, for example, if our customers cannot assume that: Our facts are accurate and fairly presented; Our analyses represent our best independent judgments rather than our preferences, or those of our sources, advertisers, or information providers; Our opinions represent only our own editorial philosophies; or There are no hidden agendas in any of our journalistic undertakings. All companies profess business integrity. But the impact of our work on the work of others, and on their lives and fortunes, places special responsibilities upon all Dow Jones employees. The clear implication of these beliefs is that the responsibility for safeguarding and growing a company that lives up to this code lies with each and every one of us. Every Dow Jones employee holds a position of trust. Acceptance of a position at any level or in any part of Dow Jones includes acceptance of individual responsibility to uphold Dow Jones policies governing legal and ethical business practices. It also includes acceptance of individual responsibility for following all legal requirements and ethical business practices, as well as the responsibility to stress proper ethical behavior among colleagues and subordinates. Moreover, it must be clear to each of us that business integrity is necessary in every business decision and that it is not the special province of news employees, members of the legal department, or anyone else. Business integrity requires that we make all of our business decisions, and approach all business questions, objectively and realistically. Managers, by virtue of their positions of authority, must be ethical role models for all employees. An important part of a manager’s leadership responsibility is to exhibit the highest standards of integrity in all dealings with employees, customers, and the world at large. Managers must avoid even implicit or unspoken approval of any actions that may be damaging to the reputation of Dow Jones, and must always exercise sound business judgment in the performance of their duties. An equally important leadership responsibility is to develop employees’ commitment to our principles and ability to make sound ethical judgments. Managers must communicate the seriousness of Dow Jones’s expectations of ethical conduct, as well as their own personal support for these guidelines. Ethical leadership includes fostering a working environment that encourages employees to voice concerns or otherwise seek assistance or counsel if faced with potentially compromising situations, and also supporting those who raise such concerns. Finally, what follows is not intended to be an exclusive or inclusive list of all laws, regulations, and other norms applicable to Dow Jones and with which compliance is expected. In our rapidly evolving businesses, each of us is challenged by a complex environment that often requires quick response under pressure. No written policy can definitively set forth the appropriate action for all business situations. Accordingly, this code emphasizes and clarifies a standard of ethical conduct that must govern all of our business dealings and relationships. In addition, more detailed guidelines for managers are available for some of the topics covered by this code, and others will be promulgated from time to time; some departments also issue specialized guidelines of their own. Please consult with your supervisor for additional information regarding additional guidelines. Confidential Information Business Relationships and Activities Compliance with Laws, Rules, and Regulations Securities Transactions Political and Civic Activities Books and Records Employment Environmental Concerns Compliance with this Code Confidential Information Any and all information and other material obtained by a Dow Jones employee in connection with his or her employment is strictly the property of Dow Jones. Such information includes not only our own work and that of our colleagues, but also information relating to future activities, including as-yet-unpublished news, information, and advertising, as well as schedules for publishing the same. Such material must never be disclosed to anyone outside Dow Jones, including to friends and family. In no event should any information obtained in connection with Dow Jones employment be disclosed privately to anyone until such information has been made available to the public. Similarly, the use of Dow Jones property of this sort – i.e., forthcoming news, information, or advertising – as a basis for any investment decision is strictly prohibited. No employee with knowledge of any such forthcoming material may, prior to publication, buy or sell securities or in any way encourage or assist any other person in buying or selling securities, directly or indirectly, based on that information. These strictures should continue in force until the third trading day after the content or advertisement appears in a Dow Jones publication or news service. These rules also apply, of course, to confidential information about Dow Jones. Dow Jones employees may not disclose to others any confidential information belonging to the Company, nor may they use such information for their personal benefit or that of others. Each of us who possesses or has access to confidential information has an important responsibility to keep that information confidential and to prevent it from being disclosed to others outside or inside Dow Jones, either purposefully or otherwise. This obligation applies not only during Dow Jones employment, but thereafter as well. In addition, it is important to take care not to discuss such confidential matters with anyone, including family members or business or social acquaintances, or in places where one can be overheard. Within Dow Jones, confidential business information should be divulged only to other employees who need to know the information in order to carry out their business responsibilities. Business Relationships and Activities Dow Jones is entitled to our undivided business loyalty, our single-minded professional attention, and our undistracted focus on our businesses and our customers. Employees must not use Dow Jones’ assets, talents, information, technology, name, or influence for their personal benefit or gain. All of the intellectual fruits of our labors as employees belong to Dow Jones. We recognize that Dow Jones cannot succeed if our customers do not succeed. It is our obligation to deliver our products and services in as timely a manner as possible, and with the highest possible levels of quality. Business dealings should be open and honest, and transactions should be in the best interests of both Dow Jones and the customer. To ensure this, Dow Jones employees should not directly or indirectly offer or provide to customers, prospective customers, or any company, individual, or institution that furnishes or seeks to furnish news, information, material, equipment, supplies, or services to Dow Jones any gift, entertainment, or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place. A reasonably priced meal is an example of an acceptable entertainment expense. Nor should employees offer or provide, directly or indirectly, any material, equipment, or services to any individual in a position to make or influence any business or governmental decision affecting Dow Jones. Conversely, Dow Jones employees should not solicit or accept, directly or indirectly, any payment, loan, service, equipment, or any other benefit or thing of value, or any gift, entertainment, or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place from suppliers or customers, or from any company, individual, or institution that furnishes or seeks to furnish news, information, material, equipment, supplies, or services to Dow Jones, or from anyone else with an actual or prospective business relationship with Dow Jones. Dow Jones employees must remain scrupulously free from obligation to suppliers and vendors. Accordingly, employees should not requisition, order, approve, or otherwise participate in the purchasing of goods or services on behalf of Dow Jones from any supplier or vendor in which the employee or any member of his or her extended family or household has a substantial financial interest, unless there is a compelling business interest and it is pre-approved by the chief executive officer of Dow Jones. Dow Jones employees may not serve as directors, officers, advisors, investors, consultants, or partners of any other company or venture devoted to profit-making, with the following exceptions: Where the employee is appointed to represent Dow Jones; In the case of an investor who owns less than five percent of a private or publicly traded company; or Otherwise as approved by the chief executive officer of Dow Jones. The unauthorized duplication of computer software developed internally or obtained from outside suppliers is prohibited, regardless of whether such unauthorized duplication is for business or personal use. Additionally, all Dow Jones employees must adhere to the Company’s standards and policies regarding the use of its technology and computer equipment. Compliance with Laws, Rules, and Regulations All employees of Dow Jones must obey all applicable laws. The applicable laws as to a given employee will usually be the laws of the place where the employee is based and also the laws of the locations where that employee does business. Employees must also respect the local culture and values of such locations. In addition, as a result of Dow Jones operating across many jurisdictions, certain legal obligations of some countries can also be applicable to all Dow Jones employees even if some of the employees are not located or do not carry out business in such countries. In particular, certain laws of the United States (the country of Dow Jones’ headquarters) including, for example, the U.S. Foreign Corrupt Practices Act, which generally makes it illegal to offer or give a bribe or improper payment or gift to an official (or candidate for office) outside the U.S., whether directly or through third parties such as consultants or agents, apply to all Dow Jones employees worldwide. For more information on anti-bribery and anti-corruption rules, please see the News Corporation Global Anti-Bribery & Anti-Corruption Policy, or contact the Dow Jones legal department. In addition, Dow Jones employees who have dealings with government officials are required to be familiar with any applicable lobbying laws and public disclosure requirements, since the U.S. government, each state, and many local and foreign jurisdictions have laws that impact the ability to interact with, entertain, and give gifts to public officials. A Dow Jones employee should direct any questions to the general counsel of Dow Jones if uncertain about such laws or requirements. Dow Jones will not reimburse employees for any payments that are illegal or improper, including payments made to or for the benefit of any public official to induce or entice such official to influence laws, regulations, or other official acts to benefit Dow Jones. In addition, any Dow Jones employee intending to make a gift in connection with his or her employment to a public official needs to obtain pre-clearance for any such gift from the general counsel of Dow Jones. Securities Transactions Dow Jones has always had a strict policy on securities transactions by employees who have access to non-public information, including information concerning Dow Jones itself. All Dow Jones employees are expected to conduct themselves at all times in a manner that leaves no grounds for belief, or even suspicion, that: An employee, a member of an employee’s extended family, or anyone else connected to an employee made financial gains by acting on the basis of information obtained through Dow Jones employment before that information was available to the general public; such information includes hold-for-release material or publishing plans with respect to news, advertising, or other information, as well as any other items that might affect movements in the prices of any securities; The creation, dissemination, or non-dissemination of any news or other information was influenced by a desire to affect the price of any security; An employee’s personal financial situation with respect to investments is such that it creates a temptation to violate these rules; or An employee is beholden to newsmakers, information providers, advertisers, or market participants, creating a temptation to violate these rules. In addition to these general guidelines, all Dow Jones employees are governed by News Corporation’s Insider Trading and Confidentiality Policy, and are also required to abide by the applicable restrictions set forth below. In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of Dow Jones may engage in short-selling of securities. However, a Dow Jones employee may invest in publicly traded pooled investments (such as exchange traded funds and mutual funds) that rely on “short exposure” as a component of the portfolio. Members of executive management and all news and advertising personnel must not engage in short-term trading of equity securities or of non-investment-grade fixed- income securities; such employees must hold such securities for a minimum of six months unless, in order to meet some special need, they get prior permission for an earlier sale from the general counsel of Dow Jones. The six-month holding rule does not apply to publicly traded pooled investments (such as exchange traded funds and mutual funds). All news and advertising personnel also must not buy or sell futures or options. However, these employees may invest in publicly traded pooled investments (such as exchange traded funds and mutual funds) that invest in futures or options. No advertising personnel assigned to call on a specific company may buy or sell any securities in that company, nor may the employee’s spouse, significant other, or dependents do so. Managers are considered to be assigned to those companies that their reports call on. News personnel assigned to report on a specific industry may not buy or sell any tradable instruments in any company engaged in whole or significant part in that industry or in any pooled investments (such as exchange traded funds and mutual funds) primarily invested in that industry, nor may the spouse, significant other, or dependents of any such employee do so. Editors are considered to be assigned to the industries for which their reporters have substantial responsibilities. News personnel not assigned to report on a specific industry or those covering an area outside of their assigned industry who own individual securities in a company or have a spouse, significant other, or dependent who owns any such securities must recuse themselves from working on any content that relates to that company. News personnel should note that owning securities in individual companies may prevent them from taking on additional assignments, moving to different coverage areas, or assuming other responsibilities. All news personnel can participate in all Dow Jones-sponsored retirement plans managed by third parties without having to recuse themselves from working on content related to those third parties. News personnel who cover a specific industry or beat and have a spouse or significant other employed in that industry or coverage area must notify and consult with the deputy managing editor for ethics or the managing editor. Political and Civic Activities Many companies, for a variety of reasons, participate in the partisan political process at various levels of government. As a publisher, Dow Jones has a different tradition. Dow Jones does not contribute, directly or indirectly, to political campaigns or to political parties or groups seeking to raise money for political campaigns or parties, and Dow Jones does not and will not reimburse any employee for any political contribution made by an employee. All news personnel and members of senior management with any responsibility for news should refrain from partisan political activity. Partisan political activity includes passing out buttons, posting partisan comments on social-networking sites, blogging, soliciting campaign contributions, hosting a fundraiser for a partisan candidate, as well as making a financial contribution to a candidate’s campaign. While these restrictions do not expressly apply to an employee’s spouse, significant other, or family members, all news personnel and members of senior management with any responsibility for news should avoid the appearance of bias. On the other hand, it is not the intention of Dow Jones or of this code to dissuade employees from actively participating in or making financial contributions to civic, charitable, religious, public, social, or residential organizations, or other non-partisan causes. Such activities are permitted, and even encouraged, to the extent that they: Do not detract from performance or effectiveness at work; Do not, by their extensiveness, cause Dow Jones to subsidize or appear to subsidize the activity; Do not otherwise violate this code. In the event that a conflict arises or may arise between an outside organization with which an employee is affiliated and the interests of Dow Jones, the employee should refrain from participating in the conflicting or potentially conflicting activity; and Do not overlap with the coverage responsibilities of any news personnel. No Dow Jones employee should permit his or her Dow Jones affiliation to be noted in any outside organization’s materials or activities without the approval of the chief executive officer of Dow Jones or the general counsel of Dow Jones unless the employee serves as a representative of Dow Jones or unless the affiliation is noted as part of a broader description of the employee’s identity. Books and Records It is essential to the successful operation of Dow Jones as a business that the integrity of our books and records be resolutely maintained. The responsibility for this does not rest exclusively with accounting or other financial personnel – it is shared by us all. Accordingly, No Dow Jones fund, asset, or liability that is not fully and properly recorded on the Company’s books and records shall be created or permitted to exist; No transaction shall be effected and no payment shall be made on behalf of Dow Jones with the intention or understanding that the transaction or payment is other than as described in the documentation evidencing the transaction or supporting the payment; All employees shall comply with Dow Jones’ accounting principles, procedures, and controls, and no false, artificial, or misleading entries in any books or records of the Company shall be made for any reason whatsoever; No employee will issue or authorize anyone else to issue any Company document that is false or misleading; No employee will knowingly accept and treat as accurate any false or misleading document prepared by a person not employed by Dow Jones; and No employee will knowingly make any false or misleading statements to our external or internal auditors. Indeed, when questioned by any auditor, all employees should be fully forthcoming. Employment Dow Jones strives to ensure that all employees are treated with dignity and respect. Among our goals are to make benefits and services available to employees to promote their well-being, to communicate effectively with employees, to ensure equal employment treatment, to maintain a safe work environment, to observe the terms of collective bargaining agreements where applicable, to assist employees in realizing their potential and maximizing their productivity, and to fairly evaluate and recognize performance. For its part, Dow Jones expects employees to perform excellent work in a cost-effective manner, to strive for quality and productivity, to follow directions and instructions, to properly care for facilities and equipment, to anticipate problems and suggest improvements, to treat other employees and clients and customers with honesty and courtesy, and to be energetic in the performance of tasks and fulfillment of goals. Dow Jones values the talents and contributions of its employees. Dow Jones also seeks and values diversity among employees, recognizing that a mix of people enriches the Company and encourages creativity and business growth. Dow Jones’ policy is to provide equal employment opportunities and equal advancement consideration to all individuals based on job-related qualifications and ability to perform the job, without regard to any legally protected status (that is, a protected category such as gender or race). It is also Dow Jones’s policy to provide a working environment that is free of intimidation and harassment. Complete statements of policies setting forth Dow Jones’s standards regarding personnel matters, and other matters relating to employment with Dow Jones, are published by the human resources department. These policies meet legal and regulatory requirements of various jurisdictions in which Dow Jones does business, and employees are required to comply with these policies. Environmental Concerns Dow Jones is committed to maintaining a safe work environment by eliminating all significant recognized hazards in the workplace and to conducting business in an environmentally sound manner based on scientific understanding, customer needs, and local requirements. Employees are required to comply with all applicable health, safety, and environmental laws and regulations, and all related corporate policies. Compliance with this Code Dow Jones takes this code of conduct very seriously. All employees of Dow Jones are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment and to attest in writing that they have done so. In addition, all Dow Jones employees shall be required each year to provide a written attestation that they have read and abided by this code during the previous calendar year. The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal. Any employee who has a question about this code, or has any concerns regarding perceived deviations from the code, should promptly contact his or her supervisor or the Dow Jones legal department. In addition, a dedicated toll-free Alertline telephone number and an Alertline web site are available for all employees of News Corporation companies to report complaints. The number, available 24 hours a day, 365 days a year, is 1 (866) 480-6129, and the web site can be found here. An employee can make an anonymous report through Alertline. Any retaliation against an employee who makes a good faith report about a possible violation of the code will not be permitted or tolerated. Indeed, the most important wisdom about dealing with these questions is: When in doubt, ask. CONTACT LEGAL EQUAL OPPORTUNITY MODERN SLAVERY STATEMENT CODE OF CONDUCT PRIVACY NOTICE COOKIE NOTICE SECURITY PIB CONTENT PRIVACY NOTICENEW SITEMAP © DOW JONES 2021