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 maintain strict separation between revenue sources and 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 and competition 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

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 and raise any potential issues with an attorney in the Legal Department.

We always 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 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 control, 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 country, entity or person 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 transactions or payment activities that seem suspicious, 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 consulting with the FOX Government Relations Office in Washington D.C.. In the case of non-U.S. officials, we must first consult with 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 and 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, or even making donations to a foundation or charity of his or her 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 she or he favors.

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, or even personal favors may be considered bribes if given for an improper purpose.

Consultants and Other Third Parties:  We require that consultants, agents and other third parties acting on behalf of FOX companies adhere to the principles contained in our anti-corruption policy.

We ensure that all payments to third parties are recorded accurately and documented appropriately.

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 but not limited to 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 actions and not actions taken on behalf of the Company.

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 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 or accept elected or 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 lobbying activities 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 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.