MAINTAINING OUR SHAREHOLDERS’ TRUST

Just as we build our co-workers’ trust by living up to high standards for how we treat each other, we earn our shareholders’ trust by holding ourselves to, and meeting, extremely high standards in the areas explained in this chapter. Although some of the concepts below may sound unfamiliar, it is important that we get to understand what they really mean and uphold them every day.

Records

Be Accurate and Transparent

All of our company records and reports must be full, fair, accurate, timely and understandable. This includes financial and accounting records, business travel and entertainment expense records, work activity and time records and other records made on behalf of the company. We should never misstate facts, omit critical information, or modify records or reports in any way to mislead others, and never assist others in doing so.

If you believe information our company has provided is somehow incomplete, inaccurate, or otherwise misleading, you should report it to the Law Department immediately.

Manage Them

Keeping accurate records is not just about creating documents—it is also about managing them. We must know and follow our internal controls and policies about records management, including maintaining, retaining, and correctly disposing of records. Doing this in the right way is key to protecting the integrity of our business. Record management is especially important when it comes to
legal holds.A legal hold might be put in place if the company is involved in or anticipates litigation. If you become subject to a legal hold, the Law Department will contact you with instructions on preserving certain records related to specific topics.

If you have questions about record management, please see the policy or procedure that applies to you. Or you can always reach out to the Law Department for guidance.

Insider Trading: Don’t Do It

It’s never okay to buy or sell stock while you have "material, nonpublic information" about our Company, companies we do business with, or any publicly traded company. You may think that only senior management has access to this type of information, but that’s not the case.

Some examples of things that might be
material, non-public informationPeople who are likely to have access to material non-public information can be subject to trading blackout periods during which they are prohibited from trading in Activision Blizzard stock. Of course, you will be informed if this applies to you.
are.

Information about future earnings or losses
Pending or proposed mergers or acquisitions
Significant sales of assets
Executive management changes
Significant new discoveries, products, or developments
Changes to trends in a business or game

We keep this information confidential before it’s released to the public – we never trade while in possession of this information, and we don’t share it with anyone else, even close friends or family. Some of us are subject to trading blackout periods. Please see the Policy on Insider Trading and Tipping*. If you have any questions, contact the Trading Compliance Committee: tcc@activision.com, tcc@blizzard.com, or tcc@king.com.

Money Laundering: Watch for It

Money laundering Money laundering is an attempt by another person or organization to conceal illicit funds or make those funds look legitimate.
can take many shapes and forms. If you’re working directly with distributors, vendors, or other business partners, raise a flag if someone:

tries to make large payments in cash and that person is not mentioned in the contract
wants to pay more than the contractual sum
tries to make payments in other currencies than those specified in the contract
makes payments from an unusual, nonbusiness account

If you have any questions, contact the Law Department.

Anti-Corruption: Business without Bribery

Bribery is never an option. We do not:

offer, pay, or accept bribes or kickbacks in any form, whether it involves a public official or a private party, or
tolerate corruption as part of our business dealings

Our relationships with public officials must be transparent and businesslike. There are laws that prohibit or limit the gifts, entertainment, and travel that a public official can accept. And offering any of these things to a public official, no matter how small, may be prohibited because it can create negative consequences for you and the company. Please see the Gifts & Entertainment Policy* and Anti-Bribery & Anti-Corruption Policy*.

Doing Business Internationally: Follow the Rules

Being a global player means there are some extra rules and regulations that we need to follow. A few of these are:

laws about the import and export of products and technical data
laws that prohibit the delivery of products, data or information to certain nations, organizations, or individuals
economic sanctions and trade embargoes
laws that prohibit companies from getting involved in any international boycott that isn’t approved by the applicable government

If you’re unsure whether one of these laws apply to the work you do, if you wish to report an issue about one of the above laws, or you receive a request to be part of an international boycott, please immediately contact the Law Department.

What’s the Right Way2Play?

Consider this scenario:

“I had lunch with my brother-in-law last week, and he was really interested in the financial performance of our company. He wanted to change some investments in his portfolio, and was hoping to invest in our company, but only if he knew a few more things about our management team. I told him I’d think about it. If I pass along a little information that he can probably learn in the next two weeks anyway, would I be doing something wrong?”

The Right Way2Play:

“Yes. Passing along any confidential information is a big deal. Even something that seems small and doesn’t benefit you directly can be a violation of our Policy on Insider Trading and Tipping*. Think before you act, since the consequences may include reputational damage, fines, and/or jail time.”

“Together, we are Making the World Playful. We delight millions of people each day and redefine the world of games again and again. We do all of this with integrity and respect for each other every step of the way.”
- Tjodolf Sommestad, President, King

Remember, the Code of Conduct is not intended to prohibit or infringe on an employee’s rights to discuss wages, hours, working conditions, or other terms and conditions of employment or to otherwise engage in protected concerted activity under Section 7 of the National Labor Relations Act.

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