BUSINESS ETHICS – OUR COMMITMENT TO FAIR COMPETITION, CONTENT INTEGRITY AND THE COMMUNITIES WE SERVE
The marketplace of ideas is where FOX and its business units thrive. Our success is built on the principles of free expression, free inquiry and freedom of choice. That’s also true of our participation in the business world generally, where we protect our reputation for honesty, transparency and fair competition. Our credibility is at the core of our success.
Our credibility is at the core of our success
Editorial Independence and Broadcast Standards
The First Amendment and the fundamental values it reflects are integral to who we are and what we do. As an important source of news, information, analysis and media, we play a leading role in the marketplace of ideas. Our flagship news properties are some of the most influential in history, and we respect the significant responsibility that comes with being a steward for the people’s right to know. In keeping with the Constitution’s protections for the freedom of the press, we guard and defend our journalists in their search for the truth.
We do not let revenue sources dictate our news and opinion content. Our opinions do not drive our news reporting, which pursues the facts wherever they may lead. And we resist all attempts to silence us. Indeed, we believe so strongly in these core values that we have often come to the defense of our competitors, recognizing that a free press benefits all of us and requires the support of each and every one of us.
Maintain Corporate Credibility
Media and Analyst Inquiries: We refer all media and analyst inquiries to the appropriate people within FOX for response. Unless you are explicitly authorized by your business unit to respond to such inquiries, refer all media inquiries to either Corporate Affairs and Communications at FOX or to the person your business unit has designated to respond to the media. All financial analyst inquiries must be referred to the FOX Investor Relations team.
Refer all media and analyst inquiries to the appropriate people
We do not make deliberately false or misleading statements about our businesses or about other companies.
We safeguard the confidential information provided to us by business partners and others with whom we do business.
We obtain competitive information legally. We do not obtain information about competitors through theft, blackmail, wiretapping, trespassing or other methods prohibited by law.
Be Responsible Corporate Citizens
One of the primary foundations of good business and free markets is the rule of law. Compliance with the law is crucial to the reputation of FOX and its business units, and to our ability to conduct our business with freedom, creativity and independence.
Compete Hard and Fairly
We succeed through integrity, innovation and hard work. We don’t cut corners in any of these areas. We always engage in fair competition in the free market, obeying all applicable antitrust laws. These laws generally forbid any understanding or agreement, written or verbal, implicit or explicit, between competitors to engage in conduct that restrains competition. Here are some guidelines on . This guidance is covered in more detail in FOX’s Principles Governing Fair Competition, which you should be familiar with and abide by in your business dealings.
Antitrust and competition laws can be very complex, differ by country and often carry severe penalties, including prison sentences for the individuals involved. They potentially apply to a wide range of business practices (for example, exclusive licensing, bundling and price discounts).
FOX is committed to fair competition in the free market
In particular, if you have marketing, sales or purchasing responsibilities, have contact with competitors, or are involved in mergers, sales or acquisitions of businesses, you should be familiar with the antitrust and competition laws that apply to your work, closely follow the guidance in FOX’s Principles Governing Fair Competition, and raise any potential issues with an attorney in the Legal Department.
We respect intellectual property rights and proprietary information—our own and those of others. Just as we vigorously protect our intellectual property and proprietary information, we scrupulously honor the rights of others. Do not seek or accept the confidential information of competitors or business partners to gain an improper commercial advantage.
Do not download or use copyrighted materials—such as pictures, films or videos, music, software or source code—without a proper license.
Be Good Citizens
We take our corporate social responsibilities seriously. Specifically, in the context of our business, we are always and everywhere dedicated to advancing our core values of free inquiry, free speech and free expression for all people.
As a company, we are at all times truthful and accurate when dealing with government entities or officials. If you are contacted to submit information on behalf of FOX, immediately refer them to the Legal Department and inform your supervisor.
We adhere to all applicable trade, labor and other laws wherever we do business.
We are committed to conducting our business with integrity and in an ethical manner without usage of goods or services generated by forced labor or human trafficking.
We follow all applicable laws and regulations regarding data privacy to safeguard the personal information of our customers.
We comply with all applicable environmental laws and in all circumstances strive to abide by non-wasteful, non-polluting practices.
Comply with Trade Laws
FOX is committed to conducting business in compliance with applicable U.S. and non-U.S. international trade laws, including all applicable import and export controls, economic sanctions, and
You must consult with an attorney in the Legal Department or FOX’s Chief Ethics and Compliance Officer to determine whether sanctions or other international trade restrictions apply to the countries, entities or persons with which you are doing business.
Detect and Prevent Money Laundering, Terrorist Financing or Fraudulent Activity
In addition to always acting legally and ethically ourselves, we avoid doing business with those who engage in illegal or unethical conduct. In today’s fast-paced global environment, we must always be careful to avoid doing business with parties who may be engaged in money laundering, terrorist financing, tax fraud or other forms of illegal or fraudulent activity that could damage our reputation.
We should never assist or tolerate illegal conduct by others. Know the companies and individuals with whom we do business. If there is any reason to question their legitimacy or integrity, or if you are asked to enter into , immediately notify your supervisor, an attorney in the Legal Department, or FOX’s Chief Ethics and Compliance Officer for guidance. Similarly, if you are ever asked by another party to falsify documents or misrepresent the nature of a business transaction, you should immediately escalate those concerns within FOX.
Avoiding Corruption, Bribery and the Appearance of Impropriety
We never engage in, tolerate or condone bribery, corruption or similar conduct. We are responsible and honest in all of our dealings with and scrupulously follow the law at all times.
Doing Business with a Government Official: We consult with the Legal Department before we do business with any Government Official, foreign or domestic.
Giving Anything of Value to Government Officials: We do not give anything of value, even if nominal, to a U.S. government official without first receiving approval from the FOX Government Relations Office in Washington, D.C. In the case of non-U.S. officials, we must first receive approval from an attorney in the Legal Department or the Chief Ethics and Compliance Officer. It’s important to remember that business practices that are acceptable in a commercial context, such as the giving of gifts or hospitality, may be completely forbidden when the individual involved is a government or political party official.
Avoiding the Appearance of Indirect Payments to Government Officials: We are careful to avoid situations in which things of value are given to those close to a government official, if such conduct may be viewed as a means of circumventing the intention of anti-bribery laws. Giving things of value to an official’s family members (such as a job or internship), or even making donations to a foundation or charity of an official’s choice, may appear corrupt under certain circumstances. We never attempt to influence a government official by giving things of value to family members or to entities they favor.
We know and abide by the FOX Global Anti-Bribery and Anti-Corruption Policy. We don’t offer, give, solicit or accept bribes or kickbacks, either in cash or in the form of any other thing or service of value. It is important to remember that “bribes” can be more than just cash payments. Objects of value, hospitality, business discounts, jobs or internships, charitable donations or even personal favors may be considered bribes if given to an official or their family members or close associates for an improper purpose.
Consultants and Other Third Parties: We require that consultants, agents, suppliers, vendors and other third parties acting on behalf of FOX companies adhere to the principles contained in our anti-corruption policy. Always remember that a third party may not make a payment on behalf of FOX that FOX itself cannot make directly, and that a bribe paid by a third party for the benefit of FOX could well be viewed as a bribe paid by FOX. Because of the significant risk presented in situations where FOX is contemplating retaining a third party to represent FOX in relation to a governmental decision of any kind (for example, obtaining a license or permit), we notify and seek advance approval to retain the third party from the Legal Department, a Compliance Liaison, or the Chief Ethics and Compliance Officer.
We ensure that all payments to third parties are recorded accurately and documented appropriately.
Integrity in Sports and Sports Betting
FOX is a premier sports reporting and broadcasting organization. It also operates a licensed sports-betting marketing affiliate site and has other relationships with and involving the licensed U.S. sports-betting industry. For all of these reasons, ensuring the integrity of sporting events and wagering, and avoiding even the appearance of impropriety, are critical. This has several implications.
We Do Not Share Non-Public Information Except as Part of Our Journalistic Responsibilities. We Never Use It for Personal Gain. FOX personnel from time to time may become aware of non-public informationconcerning sports leagues, teams or athletes not known to the general public. That information may not be shared with others, except, where applicable, through public channels in your role as a journalist (for example, on a FOX Sports broadcast, through a public tweet or other public social media channel). And under no circumstances may you use that non-public information for personal gain (for example, by using the information to wager on an event that may be impacted by the information).
We never use non-public sports-related information to our personal advantage—or help others do so—in sports betting or similar activities. You are also prohibited from sharing such information with others (including family members and friends) who could use it for similar purposes. For example, members of the production team on FOX’s broadcast of an NFL football game might learn before the game begins that one team’s starting quarterback suffered a serious injury while warming up—information not yet known to the general public. Any FOX personnel learning of this information would be prohibited from betting on the game and would also be prohibited from sharing the information with friends, family members, or acquaintances before it becomes known to the general public. Similarly, if the injured football player was a member of the USFL, or employed by a league that FOX maintains an ownership interest in, that player’s teammates would be barred from sharing the information with third parties.
We May Not Wager With or Through a FOX-Controlled or Affiliated Sportsbook or Marketing Affiliate. FOX currently does not own a majority interest in or control any sportsbook; however, FOX’s Outkick Media LLC, for example, is a licensed sports-betting marketing affiliate. FOX personnel may not open any account or place any wager through Outkick or any other marketing affiliate or sportsbook in which FOX may acquire a majority interest or control in the future.
We Do Not Promote Unlawful or Unlicensed Betting. As part of our commitment to comply with law, FOX prohibits its personnel from endorsing, promoting or otherwise advancing unlawful or unlicensed sports betting or gambling. This applies to us in our capacity as a FOX employee or representative, and also in any other capacity where our activity reasonably may be attributed to or identified with FOX, negatively affect FOX’s licensing status with gaming regulators or otherwise impair FOX’s reputation.
Always Uphold the Integrity of Sporting Events or Sports Betting that FOX Broadcasts or Promotes. FOX’s unique position as a leading sports broadcaster, coupled with its relationship to the sports betting industry, necessitates extra care to avoid even the appearance of impropriety in this area. We avoid taking any step that might be viewed as creating that perception and promptly report any incident or event that might do so. If you are ever unsure about the appropriate course of action, discuss the matter with an attorney in the Legal Department, the Chief Legal and Policy Officer, or the Chief Ethics and Compliance Officer.
Engaging In Political Activities and Lobbying
As an individual, you are welcome to engage in the political process in any way allowable by law, including donating money to the candidates of your choice and volunteering on campaigns. And you are of course always free to contact your elected representatives for any personal reason you wish. But it should always be clear to outside observers that these are your personal motivations and not actions taken on behalf of FOX. Keep in mind that FOX corporate officers, as well as employees who are registered lobbyists or solicit government business, are required to contact the FOX Government Relations Office in Washington, D.C., prior to making a personal contribution or soliciting a contribution at the state or local level, or to a state or local official running for federal office.
Never convey the impression that you speak for FOX or any of its business units in any way when you engage in personal political activities.
Observe all laws governing gifts to elected officials.
Contributing Company Assets: We do not donate any corporate money, services, products or facilities to any political party, candidate or political committee unless previously approved by FOX’s Head of Government Affairs in Washington, D.C. Always keep in mind that “contribution” is defined broadly and does not necessarily mean money. It may, under some circumstances, even include the use of FOX telephone lines or email to solicit donations or support. Please see the FOX Political Activities Policy for more information.
Seeking Public Office: An employee or member of the Board of Directors who wishes to seek elected office or accept an appointed public office while working at FOX or any of its companies must first seek the authorization of FOX’s Chief Legal and Policy Officer.
Lobbying: Employees should not engage in on behalf of FOX with respect to any governmental entity in the United States—federal, state or local—without the prior involvement and approval of FOX’s Government Relations Office in Washington, D.C. Employees should not engage in lobbying activities on behalf of FOX with respect to any non-U.S. government without the prior involvement and approval of an attorney in the Legal Department.