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.

 

 

 

 

 

THE ASK LIST: WHERE YOU CAN GO FOR HELP

 

The ASK List* is your key go-to resource. It’s a list of people and resources that you can turn to if you have questions, need some advice, or want to report something. You can choose whatever channel or resource makes you the most comfortable.  No matter the circumstances, you can reach out to anyone on the ASK List:

  • Your manager
  • Another manager you trust
  • Any member of the Way2Play Team directly or at way2play@activision.com
  • Any member of HR (or you can reach HR at 877-225-4702 within the U.S. or at HR@activision.com from anywhere in the world)
  • Any member of the Law Department
  • The Integrity Line (1-877-WAY2PLAY or 1-877-929-2752) within North America or way2play.ethicspoint.com from anywhere in the world

 

You can always reach out to your Way2Play Heroes* for guidance about your reporting options. 



We want you to understand more about the Integrity Line so you can decide if it is the right option for you. The Integrity Line is a confidential website and telephone line, operated by an external third-party vendor, which allows you to report concerns 24 hours a day. If you prefer, the Integrity Line allows you to report concerns anonymously. However, providing your name allows us to contact you directly, while still protecting your confidentiality to the extent possible; it also allows us to ask you for further information as we investigate your concerns and may impact our ability to respond and expedite the time it takes us to do so. 


You can reach the Integrity Line by:

 

 

 

Telephone:

  • North America 1-877-WAY2PLAY (877-929-2752)
  • Global
    • Australia 1800 161 117
    • Brazil 0800 000 0474
    • China (Mainland) 4001200531
    • France 0 805 62 01 53
    • Germany 0800 1819538
    • Ireland 1800851838
    • Japan 0120-406-357
    • Malta 8006 5047
    • Mexico 8006815321
    • Netherlands 0800 0229506
    • Romania 0800 890 440
    • Singapore 8004922537
    • South Korea 00798 14 203 0354
    • Spain 900838616
    • Sweden 020 089 00 22
    • Taiwan 00801-49-1714
    • UK & Northern Ireland 0800 046 550

Internet:



way2play.ethicspoint.com

                                                                           

 

Reports submitted through the Integrity Line are automatically directed to members of the Way2Play Ethics & Compliance team and may be escalated as appropriate.

 

 

The Software License and Service Agreement will be updated. Please follow this link [https://www.activision.com/legal/ap-eula] in order to see these changes.

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