Working with Our Business Partners and Communities

We are all part of a global community. And what we do as a company affects, and is affected by, the world around us. This chapter explains how we compete on fair terms, make a good impression, and interact with our external communities.

WE PLAY FAIR

Wherever we do business, we follow fair competition laws. But what does “fair competition” mean for us? It means that we never make agreements with competitors about:

pricing of products or services
pricing policies or strategies
terms or conditions of sale
production volume
discounts and promotions
market allocation

Although the spirit of these laws seems straightforward, applying them to real life situations can be complex. Competing unfairly can result in severe civil and criminal penalties for both our company and anyone who played a role in breaking these laws. So, if you interact with competitors, it’s critical you understand our policy and these laws.

Trade Associations: Participate with Care

Since there are so many fair competition laws and regulations across the globe, this area can be complex. That’s why we must be extra careful when we take part in
trade associations.An association of people or companies in a particular business or trade, organized to promote their common interests.

COMPETE WITH INTEGRITY

Knowing our competition is an important part of being successful. But we always get to know our marketplace and competitors on fair terms. That is, we follow the laws and never try to discover our competitors’ confidential information or trade secrets in an unethical way.

THIRD PARTIES: DEMAND INTEGRITY

We work every day to conduct ourselves in a way that reflects the company’s commitment to do business the right way. And we expect our business partners to do the same and follow our Vendor Code of Conduct. When we work with other organizations or individuals, we take steps to get to know who they are, since they serve as a reflection on our company. How they act matters.

RESPECT HUMAN RIGHTS

We strive to conduct our business in a manner that respects the human rights and dignity of all, and we support international efforts to promote and protect human rights. We do not tolerate abuse of human rights in our workplace or our supply chain. Each of us can help eliminate abuses such as child labor, slavery, human trafficking, and forced labor. You can start by reporting any suspicion or evidence of human rights abuses in our operations or in the operations of our business partners.

GOVERNMENT CUSTOMERS: WE HAVE THEM

When a government is our customer, we need to stay up-to-date with and follow the laws and regulations specific to government business, such as contractual obligations, procurement or accounting and billing practices. And keep in mind that laws and regulations may limit us from hiring employed or recently retired public officials. If you want to know more, contact members of the Law Department before you take the next step.

Environmental Sustainability: We Are Committed

We care about our planet and are taking concrete steps to reduce our carbon footprint to net zero by 2050. Accordingly, it’s a given that we also follow the environmental laws, rules and regulations that apply to us. If you ever recognize a potential environmental issue, please contact our ESG team at esg@activision.com or our Law Department.

COMMUNICATION OUTSIDE OF THE COMPANY: CHECK WITH THE RIGHT PEOPLE

If you’re approached by the media to speak about a topic, please send that inquiry or request to the Communications and/or Public Relations team. You should not speak to the media without the approval and supervision from the communications team. If you’re at an event and someone outside our company asks for a comment, do not answer any questions or provide comments unless you’re a part of the communications team. Instead, please kindly alert the communications team and introduce the journalist to the communications professional.

If you’re invited to speak outside the company, please reach out to PR@activisionblizzard.com before accepting the invitation. The communications team will then determine whether additional approvals are needed.

It’s the same when it comes to investor relations. We never answer investor related questions about our company or any of our operations unless it’s our specific job responsibility to do so. If you’re contacted by investors, potential investors, or securities analysts, give them the contact details of an authorized spokesperson. Then contact that spokesperson right away with background information about your interactions with the investor, potential investor, or analyst. Please see the Investor Relations Policy* for more information.

Audits and Investigations: Be Helpful and Transparent

Sometimes our company needs to conduct investigations, audits, or other inquiries. These can be performed by internal or external auditors, attorneys, or investigators. And it’s our responsibility to help them when they need our support. We expect you to provide them with accurate and timely information, without manipulating or misleading their work in any way. The Law Department or Way2Play Team will guide us on when and how to aid in any investigation, audit, or inquiry.

Political Activities: Be Responsible

We are each free to engage in the political activities of our choice on our own time and with our own money. We never use company funds for political activities without getting approval from the Law Department or do anything to give the impression that personal donations and contributions represent the company. And of course, we don’t take part in political activities that are against the laws in any of the places where we operate. So, unless you’ve been assigned by our company to represent us or assist with company political activities, you shouldn’t get involved in these activities for the company. Any questions? Contact the Senior Vice President for Litigation, Regulatory, and Public Policy Law.

What’s the Right Way2Play?

Consider this scenario:

“Our team recently went out to celebrate a completed project, and some of our business partners - outside of our company - had way too much to drink. Is this something I need to escalate?”

The Right Way2Play:

“Yes. Our business partners, vendors, and service providers are held to high standards of conduct, just like us. Even if you’re celebrating outside of our offices, we don’t want to create a situation that risks the safety or integrity of our colleagues, business partners, or company. You should always reach out to anyone on the ASK List* to share your concerns.”

“When we talk about the right way to play, I think about how we can be supportive and act responsibly toward each other. We are all working together to build and reinforce our culture every day - in the work we do, in how we collaborate, and what we say. We each need to do our part to ‘play nice and play fair.’”
- Mike Ybarra, President, Blizzard Entertainment

Any request for a waiver of any of the provisions of this Code must be fully disclosed in writing to the Chief Compliance Officer or Chief Legal Officer and approved by the company’s board of directors. If such a waiver is granted, the circumstances will promptly be made public as required by law and stock exchange rules.

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