PROTECTING INTEGRITY – OUR SHARED COMMITMENT TO ETHICAL CONDUCT

FOX expects that everyone, at every level, will strive to conduct themselves with integrity. Each of us has a key role to play in FOX’s success, and that starts for each of us with a daily commitment to integrity, credibility and reliability. Remember, if you are ever in the least bit uncertain of how to behave, please seek advice from either a manager in Human Resources, the Chief Ethics and Compliance Officer, or an attorney in the Legal Department.  

FOX expects that everyone, at every level, will strive to conduct themselves with integrity

How should I seek guidance or report concerns?

You can approach a manager in Human Resources or an attorney in the Legal Department, either in your own business unit or at FOX itself. As an additional resource, FOX has a Chief Ethics and Compliance Officer, and each respective business unit has a designated compliance or legal liaison. These company officers are available to serve as additional resources should questions arise.

You can also use the Alertline, which allows you to report concerns either through a dedicated domestic/international toll-free telephone number available 24 hours a day, 365 days a year, or through a secure website. Translation services are available through Alertline.

The Alertline telephone number is 844-809-9347

The Alertline website is at www.alertline.fox

In addition, there may be certain circumstances when a colleague or anyone with a compliance concern believes that they cannot communicate that concern through regular channels. In such a situation, that person may communicate directly with the Lead Independent Director of FOX’s Board by addressing a letter to the attention of Lead Independent Director, at Fox Corporation, 1211 Avenue of the Americas, New York, NY, 10036.

Can I make an anonymous report?

Alertline allows you to remain anonymous, but keep in mind that anonymity may make it much more difficult to investigate any allegation. If you do choose to share your identity, we will keep it confidential to the extent possible.

What happens when a potential Standards violation is reported?

FOX will gather and review the facts and recommend any necessary corrective action. FOX will also give feedback, if appropriate and if possible, to the person raising the concern.

If you observe or learn of a potential violation of these Standards, do not investigate it yourself. By conducting your own investigation, you may unwittingly compromise evidence or confidentiality, or infringe employment, privacy or other laws, and possibly make matters worse. Instead, report the matter to the appropriate persons at FOX or utilize FOX’s Alertline.

Should I be concerned about retaliation?

FOX absolutely prohibits retaliation. We invite—and expect—employees to raise concerns about potentially illegal or inappropriate conduct. If you make an honest complaint in good faith, even if you are mistaken as to what you are complaining about, you will not be retaliated against. Should anyone attempt to retaliate against you, they will be subject to disciplinary action up to and including termination and you will be protected. If you feel you are being retaliated against or threatened with retaliation, you should immediately notify a manager in Human Relations or an attorney in the Legal Department.

What are the consequences for violations?

The consequences for violating the Standards or any other FOX policy will depend on the nature and severity of the violation and can include verbal reprimands, written warnings, reassignment or demotion, suspension with or without pay, and/or termination on a first offense. FOX will determine, in its sole and absolute discretion, what the appropriate consequences will be for any such violation.

Can the Standards be waived?

Waivers of these Standards of Business Conduct will be granted only in limited circumstances by the Chief Legal and Policy Officer or designee. Waivers for directors and executive officers can only be granted by the Board of Directors and will be disclosed as required by law. If you think a waiver may be required, please contact the Chief Legal and Policy Officer.