COMCAST CORPORATION

CODE OF
CONDUCT
FACING ETHICAL AND COMPLIANCE
ISSUES WITH INTEGRITY

UPDATED: JUNE 2018

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CONTENTS
STATEMENT OF INTEGRITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 OUR COMMITMENT TO OUR COMPANY . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Intellectual Property. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
RESOURCES FOR EMPLOYEES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

OF INTEGRITY
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Security and Emergency Preparedness. . . . . . . . . . . . . . . . . . . . . . . . . 26
WHAT TO KNOW ABOUT OUR CODE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Purpose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
OUR COMMITMENT TO OUR SHAREHOLDERS. . . . . . . . . . . . . . . . . . . . . . 33
Principles of Business Conduct. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Financial Responsibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Ethical Decision-Making. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Insider Trading and Stock Tipping. . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Interpretation, Approvals and Waivers . . . . . . . . . . . . . . . . . . . . . . . . . . 8 OUR COMMITMENT TO OUR BUSINESS PARTNERS. 38

FOR EMPLOYEES
. . . . . . . . . . . . . . . . .

RESOURCES
Which Law Applies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Business Relationships. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
Penalties for Violation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Gifts and Business Entertainment with Commercial Business Partners . . . 42
Business Unit Policies and Procedures. . . . . . . . . . . . . . . . . . . . . . . . . 10 Interacting with Governments and Political Activities. . . . . . . . . . . . . . . . 44
Integrity Websites. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
OUR COMMITMENT TO THE LAW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
What Employees Must Do . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
What Supervisors Must Do. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Complying with Competition Laws. . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

13 Anti-Bribery/Anti-Corruption Laws. 51

ABOUT OUR CODE

What Happens When Concerns Are Raised. . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . .

WHAT TO KNOW
Money Laundering Prevention. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
CODE POLICIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
International Trade Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
OUR COMMITMENT TO EACH OTHER. . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
GLOSSARY OF TERMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Fair Employment Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Environmental, Health and Safety. . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Privacy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

CODE POLICIES
i This Code of Conduct supersedes all prior versions of the Comcast Corporation © 2018 Comcast
Code of Conduct. 2
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STATEMENT OF INTEGRITY
Having integrity, and operating with integrity, is the most important thing in life and in business.
When my father, Ralph, founded Comcast in 1963, he knew that the path to success was built
on creating an entrepreneurial culture that valued integrity and respect, above all else.

OF INTEGRITY
OF
STATEMENT
STATEMENT
More than 50 years later, those values are stronger than ever.

INTEGRITY
Comcast NBCUniversal is a special company. We have a talented and diverse team that cares
deeply about the work we do, our customers and viewers, and each other. Across our businesses,
we have the unique opportunity—every day—to connect millions of people to the moments and
experiences that matter most to them. It is a responsibility we take seriously, and one that requires
honesty and heart.

FOR EMPLOYEES
That is why our Code of Conduct is so important. It is the common framework for what we stand

RESOURCES
for and how we operate. I am personally asking you to commit to following this Code and its
principles as a guide for how you do your job and represent our great company. It is as simple
as doing the right thing and always treating people the right way.

I am constantly inspired by the pride and enthusiasm of our employees. Thank you for your
commitment to Comcast NBCUniversal … and to upholding the integrity of this wonderful
organization.

ABOUT OUR CODE

WHAT TO KNOW
Brian L. Roberts
Chairman and Chief Executive Officer

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RESOURCES FOR EMPLOYEES
We want you to ask questions, raise concerns and speak up. That’s why we
created Comcast NBCUniversal Listens, which offers several channels to
do so. Use the option that is most comfortable for you.

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RESOURCES WITHIN YOUR BUSINESS UNIT ADDITIONAL RESOURCES
No matter the question or concern—whether it involves a workplace issue Comcast NBCUniversal Listens also offers additional resources outside of
or suspected illegal or unethical conduct—we want to hear from you. your business unit for reporting concerns about illegal or unethical conduct:
If you have something to say, you may contact any of these resources.
• Helpline – Call 1-877-40-LISTENS (1-877-405-4783) from the United
• Supervisor – Your supervisor is usually in the best position to resolve States or click here to find a toll-free number for other locations.

FOR EMPLOYEES
FOR
your concern quickly. If you’re not comfortable raising a concern with
• Web Portal – Visit www.ComcastNBCUniversalListens.com

RESOURCES
RESOURCES
your supervisor, you may also contact another local leader.

EMPLOYEES
• Comcast Cable Resources – If you are an employee of Comcast
• Human Resources – You may contact your business unit’s Human
Cable, you may also contact a Comcast NBCUniversal Listens
Resources representative.
representative from this list.
• Law Department – The law department within your business unit
• NBCUniversal Resources – If you are an employee of NBCUniversal,
can assist you, especially with questions concerning applicable laws
you may also contact an NBCUniversal Ombudsperson from this list.
and policies.
In the United States, and as allowed by law in certain other countries,

ABOUT OUR CODE

WHAT TO KNOW
you may remain anonymous when using the Helpline or Web Portal.

COMCAST CORPORATION AUDIT

COMMITTEE RESOURCE
If you have a concern related to accounting, internal accounting controls
or auditing matters, you may send an email to:
[email protected].

CODE POLICIES
Correspondence received by the Audit Committee Chair email account is
handled in accordance with procedures established by the Audit Committee.
For more information on the resources described on this page,
please visit the Integrity section of your business unit’s intranet
or www.ComcastNBCUniversalListens.com. 4
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RESOURCES
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Click headings below to navigate through the document.

PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 PENALTIES FOR VIOLATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

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OUR CODE
KNOW
PRINCIPLES OF BUSINESS CONDUCT . . . . . . . . . . . . . . . . . . . . . . . . 6 BUSINESS UNIT POLICIES AND PROCEDURES . . . . . . . . . . . . . . . . . . . 10

CODE
ETHICAL DECISION-MAKING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 INTEGRITY WEBSITES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

APPLICABILITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 WHAT EMPLOYEES MUST DO. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

CODE POLICIES
INTERPRETATION, APPROVALS AND WAIVERS . . . . . . . . . . . . . . . . . . . 8 WHAT SUPERVISORS MUST DO. . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

WHICH LAW APPLIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 WHAT HAPPENS WHEN CONCERNS ARE RAISED. . . . . . . . . . . . . . . . . 13

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PURPOSE
Our Code of Conduct represents our business philosophy and values, and defines how we as a
company conduct ourselves around the world. We are committed to operating ethically and honestly
and to leading with integrity in all of our business activities. Our Code of Conduct provides principles
of business conduct for all of our employees, officers and directors to live up to in order to achieve
our ethical standards and commitment to integrity.

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PRINCIPLES OF BUSINESS CONDUCT
The foundation of the Code consists of the following important principles of business conduct,
which are the key ingredients in establishing and maintaining trust:
• Comply with all applicable laws, regulations, policies and contracts governing our businesses.

• Be honest, fair and trustworthy in all your business activities and relationships.

FOR EMPLOYEES
RESOURCES
• Treat one another fairly and foster a safe, diverse and environmentally responsible workplace.

• Protect our assets and information and the assets and information entrusted to us by others.

• Avoid conflicts of interest, and the appearance of such conflicts, between work and
personal affairs.

• Compete responsibly in the marketplace.

• Ask questions, raise concerns and speak up. Promptly report any concern you have

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about compliance with law, Company policy or this Code.

• Through leadership at all levels, create and sustain a culture where ethical conduct

TO KNOW
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is recognized, valued and practiced by all employees.

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CODE
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ETHICAL DECISION-MAKING
WHAT TO DO
In today’s rapidly changing workplace, you may encounter unfamiliar situations that present ethical
dilemmas. In these circumstances, the right thing to do is not always clear. For this reason, you should
become familiar with the contents of the Code. The Code contains a broad overview of key policy areas

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and examples within each area. It is not all-inclusive. Situations will arise that are not covered here.
For those situations, ask yourself these questions:
• Does it potentially violate any applicable law, regulation, policy or contract?

• Does it feel right?

• Should I check with my supervisor or another local leader?

• How would it look if it was covered in the news?

FOR EMPLOYEES
RESOURCES
• Would I feel comfortable explaining it to my family?

• Could it appear improper?

WHAT TO WATCH OUT FOR

Sometimes, it is difficult even to recognize an ethical problem. When in doubt, ask your supervisor,
a Human Resources representative or a Company lawyer. Don’t disregard a potential issue because
you think:

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• It’s none of my business.

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OUR CODE
• The Company wants me to do this.

KNOW
• Everyone does it.

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• No one will ever know.

If you find yourself thinking these thoughts, ask yourself the questions listed above to help guide your
actions, or contact any of the available employee resources.

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APPLICABILITY
The Code applies to all employees, officers and directors of Comcast and its subsidiaries, all of whom
are required to periodically acknowledge that they have received and are in compliance with the Code,
and that neither the Code nor any of its provisions constitutes an express or implied contract of
employment or guarantee of employment for any specific period of time. Use of the term “Company”
refers to all of these entities and their respective business units. Use of the term “employment” refers

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STATEMENT
to “service” where applicable for directors of Comcast Corporation. Nothing in the Code limits
employees from exercising any right provided by law.

INTERPRETATION, APPROVALS AND WAIVERS

INTERPRETATION
We believe that consistent application of the Code is essential. For help interpreting and applying

FOR EMPLOYEES
the Code or any applicable law, regulation, policy or contract to a given situation, you may contact

RESOURCES
any of the resources within your business unit, including your supervisor.

APPROVALS
In some sections of the Code, you must obtain approval from a supervisor, “Senior Attorney” and/or
“Authorized Approver” before engaging in a particular activity. Senior Attorneys include certain senior
lawyers from your business unit. Authorized Approvers include Senior Attorneys or other senior leaders
from your business unit who have been designated authority pursuant to the Conflicts of Interest policy
or the Gifts and Business Entertainment with Commercial Business Partners policy. Always follow

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the Code’s instructions regarding who to contact if you need to seek an approval. Only authorized
employees, as specified in the Code, may grant approvals under the Code. A list of Senior Attorneys

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and Authorized Approvers can be found here. This information can also be found in the Integrity section

KNOW
of your business unit’s intranet.

CODE
WAIVERS
In rare circumstances, an employee may need to seek a waiver under the Code to engage in a
particular activity. If a supervisor is asked by an employee to grant a waiver, the supervisor must

CODE POLICIES
escalate the matter to a Senior Attorney. Waivers may only be granted by the Comcast Corporation
General Counsel, or by the General Counsel of the requesting employee’s business unit. Any waiver
of the Code for any Comcast Corporation executive officer or director may only be granted by the
Comcast Corporation Board of Directors and will be disclosed to the public as required by law.

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WHICH LAW APPLIES

The Company conducts its business globally. Our employees are citizens of many different countries.
The references in Company As a result, our operations are subject to the laws of many countries, provinces, states and municipalities,
and multi-jurisdictional organizations such as the European Union. An important challenge for all of us
policies to the laws of the
is to understand how these laws may apply to our operations.
United States and the other

OF INTEGRITY
countries where we do Comcast Corporation is a corporation organized in the United States. The laws of the United States

STATEMENT
generally extend to all operations of Comcast and its subsidiaries throughout the world, as well as to
business reflect the reality
the business activities of employees wherever they live and work. Other countries may also apply their
that a global company is own laws outside of their borders to their own citizens and to corporations that are organized under
regulated by many different their laws, such as company subsidiaries.
laws at the same time.
The references in Company policies to the laws of the United States and the other countries where
we do business reflect the reality that a global company is regulated by many different laws at the same
time. In some instances, there may be a conflict between the applicable laws of two or more countries.

FOR EMPLOYEES
When you encounter such a conflict, it is especially important to contact a Company lawyer to

RESOURCES
understand how to resolve that conflict properly.

For employees working, or actions being taken, outside of the United States, references to U.S. currency
in the Code mean the applicable foreign currency equivalent, and references to GAAP mean the
applicable foreign equivalent to U.S. generally accepted accounting principles.

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PENALTIES FOR VIOLATION

Employees, officers and directors who violate the Code or applicable laws, regulations, policies
or contracts are subject to disciplinary action up to and including termination of employment
or service. Misconduct that may result in discipline includes:
• Directly or indirectly violating the Code or Company policy.

OF INTEGRITY
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• Directing or assisting others to violate the Code or Company policy.

• Failure to promptly raise a known or suspected violation of the Code or Company policy.

• Failure to cooperate in Company investigations of alleged Code or policy violations.

• Retaliation against another employee for reporting a potential concern about illegal or unethical
conduct or assisting in an investigation.

• Failure to supervise, to the extent the circumstances of a violation reflect a supervisor’s

FOR EMPLOYEES
disregard for the Code.

RESOURCES
BUSINESS UNIT POLICIES AND PROCEDURES
Your business unit may issue its own policies and procedures relating to appropriate business
conduct consistent with the Code. In some cases, those policies and procedures may impose
additional or more stringent requirements. You must follow those policies and procedures
in addition to those described in the Code.

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WHAT
INTEGRITY WEBSITES

TO KNOW
OUR CODE
KNOW
For more information on many of the topics in the Code, as well as policies that may be applicable

CODE
to your role in the Company, please visit the Integrity section of your business unit’s intranet.

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WHAT EMPLOYEES MUST DO

COMPLY WITH THE CODE
• Personally commit to following the Code.

• Periodically certify that you have read, understood and complied with the Code.

OF INTEGRITY
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• Disclose circumstances that require approval under the Code as outlined in each policy.

RAISE YOUR CONCERNS

• Promptly raise any concern about actual or suspected illegal or unethical conduct using
any of the available channels listed under Resources for Employees.

• Cooperate fully and honestly in Company investigations.

FOR EMPLOYEES
• Notify a Company lawyer or Human Resources representative immediately if you have notice

RESOURCES
of or believe it is reasonably foreseeable that the Company will be the subject of an external
investigation, litigation matter or other legal or governmental proceeding.

• Nothing in this or any other Company policy limits your ability to communicate with or provide
information to any governmental agency or commission, including the Securities and Exchange
Commission, regarding possible legal violations, without disclosure to the Company, as
protected under whistleblower laws. The Company will not retaliate against you for any
of these activities.

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WHAT
SATISFY YOUR COMPLIANCE OBLIGATIONS

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OUR CODE
• Understand the laws, regulations, policies and contracts relevant to your job.

KNOW
CODE
• Promptly complete required trainings assigned to you.

• Periodically visit the Integrity section of your business unit’s intranet for other important tools
and resources, including Company policies and information on how to raise a concern.

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WHAT SUPERVISORS MUST DO

In addition to their responsibilities as employees, supervisors must also:

SET THE RIGHT EXAMPLE

• Never cut ethical corners and lead with integrity through your own words and actions—every day.

OF INTEGRITY
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• Demonstrate that business needs and results are never more important than ethical conduct and
compliance with Company policies.

• Support the Company’s compliance program, trainings and initiatives and encourage your
employees to do the same.

• Allot adequate time and resources to your employees so they can complete their compliance
obligations, including trainings.

FOR EMPLOYEES
RESOURCES
CREATE AN OPEN REPORTING ENVIRONMENT
• Foster an environment where employees feel safe and comfortable asking a question or raising
a concern.

• Make yourself available to employees and allot appropriate time to listen to and discuss
their concerns.

• Ask for additional information in a respectful and reassuring manner.

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• Remind employees that we strictly prohibit retaliation for any report made in good faith.

• Thank employees for bringing issues to your attention.

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KNOW HOW TO RESPOND TO A CONCERN

CODE
• For a workplace issue, such as a day-to-day problem with a co-worker or question about
Company benefits, take immediate action to resolve the issue or contact your supervisor
or a Human Resources representative for assistance so that you may provide a timely
response to the employee.

CODE POLICIES
• For an integrity issue, such as an allegation of suspected illegal or unethical conduct,
immediately report it to any Human Resources representative or the Comcast NBCUniversal
Listens Helpline or Web Portal, or use another employee resource to speak up.

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• If an employee asks you to grant a Code waiver, escalate the matter to a Senior Attorney.

• If an employee asks you to interpret or apply the Code or any applicable law, regulation, policy
or contract to a given situation, and you’re unsure how to respond, contact a Company lawyer
for assistance.

• Never investigate an integrity issue yourself.

OF INTEGRITY
• Never hire an outside investigator.

STATEMENT
• Never engage in any form of retaliation and do not allow retaliation by others.

WHAT HAPPENS WHEN CONCERNS

ARE RAISED
CONCERNS ABOUT ILLEGAL OR UNETHICAL

FOR EMPLOYEES
CONDUCT WILL BE INVESTIGATED

RESOURCES
• A trained investigator will be assigned to review any integrity concern.

• The investigator will determine the facts through interviews, review of documents or other
appropriate means.

• If wrongdoing is confirmed, appropriate discipline and/or corrective action will be taken regardless
of the position of individuals involved.

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CONFIDENTIALITY IS RESPECTED

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OUR CODE
The identity of the employee (if provided) and the information provided will be shared only to the extent

KNOW
necessary for purposes of investigating or resolving the concern.

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RETALIATION VIOLATES COMPANY POLICY

Our policy strictly prohibits retaliation against any employee, officer or director who in good
faith raises a concern or participates in good faith in the handling or investigation of a concern
regarding an actual or suspected violation of the Code or policies, or applicable laws,
regulations or contracts (even if the concern is eventually unsubstantiated). No employee,
officer or director should be discharged, demoted, suspended, threatened, harassed, If you feel that you have been

OF INTEGRITY
retaliated against, speak up.

STATEMENT
intimidated, coerced or retaliated against in any other manner as a result of his or her raising
in good faith or assisting in good faith in the handling or investigation of a complaint. Note,
however, that an allegation of retaliation does not exempt an employee from normal standards
of performance and conduct.

If you feel that you have been retaliated against, speak up. Retaliation for raising an integrity
concern in good faith is prohibited by the Code and could lead to disciplinary action up to
and including termination of employment. For more information on this subject, you should
refer to the Anti-Retaliation policy in your business unit’s Employee Handbook.

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Kung Fu Panda

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CODE
POLICIES

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FOR EMPLOYEES
RESOURCES
Click headings below to navigate through the document.

OUR COMMITMENT TO EACH OTHER. . . . . . . . . . . . . . . . . . . . . . . . 16 OUR COMMITMENT TO OUR BUSINESS PARTNERS . . . . . . . . . . . . . . . 38

Fair Employment Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Business Relationships. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Environmental, Health and Safety. . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Gifts and Business Entertainment with Commercial Business Partners . . 42

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Privacy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Interacting with Governments and Political Activities. . . . . . . . . . . . . . . 44

OUR COMMITMENT TO OUR COMPANY . . . . . . . . . . . . . . . . . . . . . . 23 OUR COMMITMENT TO THE LAW. . . . . . . . . . . . . . . . . . . . . . . . . . 48

Intellectual Property. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Complying with Competition Laws. . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Security and Emergency Preparedness. . . . . . . . . . . . . . . . . . . . . . . . 26 Anti-Bribery/Anti-Corruption Laws. . . . . . . . . . . . . . . . . . . . . . . . . . 51

Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Money Laundering Prevention. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

International Trade Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

OUR COMMITMENT TO OUR SHAREHOLDERS . . . . . . . . . . . . . . . . . . 33

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CODE
Financial Responsibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Insider Trading and Stock Tipping. 36

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OUR COMMITMENT
TO EACH OTHER

OF INTEGRITY
STATEMENT
Our Company is only as strong as our workforce.
That means that we can only succeed by investing
in our people and ensuring we have a fair, inclusive
and diverse workplace. We commit to maintaining
a work environment of mutual trust and respect

FOR EMPLOYEES
where all employees are recruited, developed and

RESOURCES
advanced on the basis of their qualifications, talents
and achievements. We commit to lessening our
impact on the environment and providing a safe
and healthy workplace where no one is subject to
unnecessary risk. We commit to handling personal

ABOUT OUR CODE

data of our employees, customers and business

WHAT TO KNOW
partners responsibly and acting in compliance
with applicable privacy laws worldwide.

Fair Employment Practices

Environmental, Health and Safety

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Privacy

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Our Commitment to Each Other > Fair Employment Practices

FAIR EMPLOYMENT PRACTICES

Fair employment practices are an essential part of our business and help contribute to a culture of respect.
That is why we are committed to complying with all applicable labor and employment laws wherever we
operate, including laws pertaining to freedom of association, privacy, collective bargaining, immigration,
wages and hours, as well as laws prohibiting employment discrimination, trafficking in persons and forced,

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compulsory and child labor. It is our collective responsibility to create a work environment in which everyone
is treated with respect and dignity.

WHAT TO KNOW
• We prohibit unlawful discrimination and harassment.

• We promote equal employment opportunities in compliance with applicable laws.

FOR EMPLOYEES
RESOURCES
• We prohibit retaliation against any employee who speaks up in good faith, or who participates
in good faith in the handling or investigation of a complaint or concern.  

WHAT TO DO
• Base employment decisions on job qualifications and merit, such as education, experience,
skills and other job-related criteria.

ABOUT OUR CODE

• Make all employment decisions without considering an individual’s race, color, religion, creed,

WHAT TO KNOW
gender, gender identity or expression, age, national origin or ancestry, citizenship, disability,
sexual orientation, marital status, pregnancy, veteran status, membership in the uniformed
services, genetic information or any other basis protected by applicable law (“protected
characteristics”).

• Never engage in harassing, offensive, disrespectful or retaliatory conduct.

• Promptly raise any concern about an actual or suspected violation of this policy to your
supervisor or Human Resources representative, or use another employee resource to speak up.

CODE POLICIES
CODE
• Contact a Company lawyer if you encounter a conflict between the requirements of this policy
and a local law, custom or practice.

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Our Commitment to Each Other > Fair Employment Practices

WHAT TO WATCH OUT FOR

• Allowing harassment that could create a hostile work environment by, for example: (i) telling jokes ADDITIONAL RESOURCES
or displaying materials that ridicule or offend members of a particular gender, race or ethnic group; IN THE INTEGRITY SECTION
(ii) displaying sexually suggestive materials in the workplace or on Company computers or mobile OF YOUR BUSINESS UNIT’S
devices; or (iii) pursuing a romantic relationship with a co-worker who has indicated that he or she INTRANET
is not interested. • Frequently Asked Questions

OF INTEGRITY
STATEMENT
• Violating a labor law (e.g., hiring a child under the legal minimum age without required permits). • Anti-retaliation policy in your business
• Unequal treatment of others based on a protected characteristic. unit’s Employee Handbook

• Equal employment opportunity policy

in your business unit’s Employee
Handbook

• Harassment policy in your business

unit’s Employee Handbook

FOR EMPLOYEES
RESOURCES
Talk with your supervisor or visit
www.ComcastNBCUniversalListens.com
to learn more about how
to raise a concern.

ABOUT OUR CODE

WHAT TO KNOW
CODE POLICIES
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Our Commitment to Each Other > Environmental, Health and Safety

ENVIRONMENTAL, HEALTH AND SAFETY

We are committed to protecting the environment, as well as the health and safety of employees. Together,
we strive to provide a safe and healthy work environment and to avoid adverse impact and injury to the
environment, as well as adverse environmental, health and safety impacts to the communities in which
we conduct business.

OF INTEGRITY
STATEMENT
WHAT TO KNOW
• We comply with all environmental, health and safety (“EHS”) laws and regulations applicable
to our operations.

• We promote environmentally responsible business practices.

• We develop, and expect every employee to follow, safe work procedures.

FOR EMPLOYEES
RESOURCES
WHAT TO DO
• Conduct your job safely and consistently with applicable EHS policies and standards, including
avoiding unsafe activities and conditions such as:

»» Failing to use prescribed safety equipment or observe safety related signs.

»» Mishandling chemicals.

ABOUT OUR CODE

»» Distracted or reckless driving, failing to wear seat belts or follow Company driving policies.

WHAT TO KNOW
»» Working in high places without fall protection.
»» Working beneath heavy, suspended loads or improperly using cranes.
»» Disabling safety controls or guarding on equipment and machinery.
»» Working on electrical or powered equipment without following safety procedures.
»» Exposed or unsafe wiring.
»» Blocked fire or emergency exits.

CODE POLICIES
CODE
»» Potential exposure to serious infectious diseases.

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Our Commitment to Each Other > Environmental, Health and Safety

• Assess EHS impact and issues before starting a new activity, project or completing a transaction
involving real estate.
ADDITIONAL RESOURCES
• Understand and follow Company policies for managing, shipping, transporting, importing/exporting, IN THE INTEGRITY SECTION
recycling or disposing of regulated materials and chemicals. OF YOUR BUSINESS UNIT’S
• Identify methods to reduce any environmental impact associated with your work activity. INTRANET
• Frequently Asked Questions

OF INTEGRITY
• Promptly raise to your supervisor or EHS lead any concerns of EHS conditions or activities that

STATEMENT
you believe to be unsafe, or use another employee resource to speak up. • Drug and alcohol policy in your
business unit’s Employee Handbook
• Promptly report to your supervisor or EHS lead any personal injury or property damage.
• Safety policy in your business unit’s
WHAT TO WATCH OUT FOR Employee Handbook

• Unsafe EHS activities or practices.

• A delayed response to any EHS concern that you raised.

FOR EMPLOYEES
RESOURCES
• Any risks and liabilities associated with new acquisitions, site divestitures or exits, activities
or projects. Talk with your supervisor or visit
www.ComcastNBCUniversalListens.com
to learn more about how
to raise a concern.

ABOUT OUR CODE

WHAT TO KNOW
CODE POLICIES
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Jurassic World

20
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Our Commitment to Each Other > Privacy

PRIVACY
We are committed to protecting and respecting the privacy rights of our employees, customers and business
partners, including suppliers and contractors. Each employee must know and follow our policies for the
responsible use of personal information.

OF INTEGRITY
STATEMENT
WHAT TO KNOW
• In the United States, many laws regulate customer and employee “personal data” (e.g., name, home
and office contact information and medical and other data), and a number of countries more
stringently regulate the collection and use of personal data.

• Many countries regulate the personal data of employees and other personnel in business-to-business
transactions. A few countries even regulate information about corporations.

FOR EMPLOYEES
• We are committed to handling personal data responsibly and in compliance with applicable privacy

RESOURCES
laws worldwide.

• Every employee is responsible for safeguarding personal data within the Company’s control, and
must be familiar with all policies and security guidelines of the employee’s business unit for the
protection of this information.

WHAT TO DO

ABOUT OUR CODE

WHAT TO KNOW
• Ask about and comply with all of the following, including applicable: (i) laws and regulations of
locations from which personal data is collected and in which it is processed or used; (ii) internal
and customer-facing privacy policies of the Company; and (iii) contractual obligations.

• Be aware of personal data that is subject to specific laws, such as customer financial information,
cable subscriber personally identifiable information, customer proprietary network information
(“CPNI”), health data and children’s information, and contact a Company lawyer with any questions.

• Collect, process and use only the personal data you need for legitimate business purposes.

• Retain personal data in accordance with your business unit’s document retention guidelines

CODE POLICIES
CODE
and ensure it is disposed of securely.

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21
 TABLE OF CONTENTS
Our Commitment to Each Other > Privacy

• Use “anonymous” data (names and other personal information removed and not identifiable) or
“aggregated” data (summarized so as not to be identifiable to an individual) instead of personal
data where possible. ADDITIONAL RESOURCES
IN THE INTEGRITY SECTION
• Limit access to personal data to individuals who need it for a legitimate business purpose, and, if third OF YOUR BUSINESS UNIT’S
parties are involved, carry out a third party risk assessment as appropriate and ensure that there is a INTRANET
written agreement in place that has been reviewed by a Company lawyer.
• Frequently Asked Questions

OF INTEGRITY
STATEMENT
• Use care to prevent accidental loss or destruction of personal data.
• Confidentiality policy in your business
• If you learn that personal data has been used in violation of this policy, or if you learn that the security unit’s Employee Handbook
of any system, device or document containing personal data has been compromised, immediately
notify your supervisor and a Company lawyer.
OTHER APPLICABLE
CODE POLICIES
WHAT TO WATCH OUT FOR • Business Relationships
• Inadequate access or security controls for personal data.

FOR EMPLOYEES
RESOURCES
• Sharing of personal data with third parties, such as suppliers or contractors, who lack appropriate
security safeguards, such as restrictions on information use or a written non-disclosure agreement.

• Transfers of personal data between countries without considering applicable legal requirements.
If you have collected personal data in a country regulated by a “data protection” law (such as most Talk with your supervisor or visit
countries in Europe), contact a Company lawyer. www.ComcastNBCUniversalListens.com
to learn more about how
• Contact a Company lawyer about any new business initiative that may capture or use personal data. to raise a concern.

ABOUT OUR CODE

WHAT TO KNOW
CODE POLICIES
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OUR COMMITMENT
TO OUR COMPANY

OF INTEGRITY
STATEMENT
We must keep in mind our obligation of loyalty and
ethical duty to the Company. We are entrusted with
Company assets, both tangible and intangible,
including intellectual property, confidential
information, time, funds and equipment. We are

FOR EMPLOYEES
each responsible for using Company assets only for

RESOURCES
legitimate business purposes and for protecting them
from damage, loss, theft or misuse. Below are
several areas that focus on this commitment to the
Company and the conduct expected from each of us.

Intellectual Property

ABOUT OUR CODE

WHAT TO KNOW
Security and Emergency Preparedness

Conflicts of Interest

CODE POLICIES
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 TABLE OF CONTENTS
Our Commitment to Our Company > Intellectual Property

INTELLECTUAL PROPERTY
Intellectual property (“IP”) is among our most valuable assets. Protecting, maintaining and defending
our rights, and respecting the IP rights of others, is critical to the success of our Company. Each employee
must be aware of and follow our policies regarding the responsible use of IP and content protection.

OF INTEGRITY
STATEMENT
WHAT TO KNOW
• IP often refers to information protected by the Company’s copyrights, trademarks, trade names,
patents and trade secrets. It can also include many other things such as our brands, logos, package
designs, marketing strategies, motion pictures, television shows, website content, digital and mobile
applications, inventions and other confidential business ideas and information.

• We comply with the laws and regulations that govern protection of our IP, as well as the IP of others.

FOR EMPLOYEES
• Every employee is responsible for safeguarding our IP and respecting the valid IP rights of others.

RESOURCES
WHAT TO DO
• Follow all IP laws.

• Understand and follow your business unit’s applicable policies and guidelines regarding:

»» The handling and security of IP and confidential information.

»» The use of Company trademarks and trade names.

ABOUT OUR CODE

WHAT TO KNOW
»» The requirements for handling unsolicited ideas from third parties and unsolicited
employee submissions.
• Be alert to business practices that may result in the unauthorized distribution or use
of Company IP, and promptly contact a Company lawyer with any concerns.

• Take care in everyday matters by not sharing your ID badge, password or other
access information, and securing all physical and electronic proprietary content
when not in use.

CODE POLICIES
CODE
• Use caution when discussing Company business in common areas and public places,
such as elevators, trains, airplanes and vehicles with hired drivers.

POLICIES
Despicable Me 3 24
 TABLE OF CONTENTS
Our Commitment to Our Company > Intellectual Property

• Understand your responsibilities to the Company regarding creative works, ideas, inventions
and innovations that you develop that relate to the Company’s business.
ADDITIONAL RESOURCES
• Comply with your business unit’s IP guidelines or contact a Company lawyer if you have any IN THE INTEGRITY SECTION
questions about the development, use, exploitation or protection of IP, including when: OF YOUR BUSINESS UNIT’S
»» Using the IP of others. INTRANET
»» Producing or distributing content. • Frequently Asked Questions

OF INTEGRITY
STATEMENT
»» Launching a new service or product. • Confidentiality policy in your business
unit’s Employee Handbook
»» Introducing (or providing information about) a potentially patentable new product or service
to a third party.
»» Communicating about the scope or validity of the Company’s IP (including any belief that
someone may be infringing our IP) or taking action against a suspected infringer.
»» Hiring a new employee, especially a person who previously worked for a competitor.
Talk with your supervisor or visit

FOR EMPLOYEES
»» Accepting confidential or proprietary information from a third party.
www.ComcastNBCUniversalListens.com

RESOURCES
to learn more about how
WHAT TO WATCH OUT FOR to raise a concern.
• Failing to have proper approval and a written agreement in place before you:

»» Distribute, discuss or otherwise disclose non-public IP or other confidential

or proprietary information about our business to a third party.
»» Hire or engage an outside company or person to develop IP.

ABOUT OUR CODE

WHAT TO KNOW
• Unauthorized copying or use of copyrighted works of others (including unauthorized
downloading or distribution of newspaper and magazine articles, website articles,
computer software, music, movies, pictures and graphics).

• Receiving from anyone, or communicating to others within the Company, a suggestion

for a film, television show or new business idea without following your business unit’s
unsolicited idea procedures.

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Our Commitment to Our Company > Security and Emergency Preparedness

SECURITY AND EMERGENCY PREPAREDNESS

The safety of our people and operations is critically important at Comcast. We are committed to protecting
employees through vigilant security regarding our property, technology and business operations. We have
implemented procedures that address the prevention of criminal acts and ensure that employees
understand potential threats to our people, operations and facilities. We create and rely on emergency

OF INTEGRITY
STATEMENT
response plans and business continuity plans to ensure key business functions will continue to operate
effectively in the event of an emergency. It is the responsibility of every employee to take an active role in
helping to ensure the safety of our teams and minimize impacts to our customers and business operations.

WHAT TO KNOW
• We have established policies and procedures for security, business continuity,

FOR EMPLOYEES
RESOURCES
crisis management and emergency action plans.

• We seek to provide a workplace that is safe and secure. Security threats can
include threats to our property, personnel and electronic systems.

• We have zero tolerance for workplace violence.

• We require all users of our facilities, including employees, to have proper

authorization to gain entry, and prohibit the sharing of ID badges.

ABOUT OUR CODE

• We require user identification to be displayed at all times in all of our facilities.

WHAT TO KNOW
• We prohibit the removal of Company property and equipment from our premises
without proper authorization.

• We require each location to have an emergency action plan that defines the
teams, actions and procedures to minimize injuries and save lives immediately
following an incident.

• We require each business group to have a business continuity plan that

outlines how the business unit will continue its business functions

CODE POLICIES
CODE
following an incident should its primary location not be available for an The Fate of the Furious
extended period of time.

POLICIES
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Our Commitment to Our Company > Security and Emergency Preparedness

WHAT TO DO
• Protect Company assets against damage, loss, theft or other misuse.
Train employees in security
and emergency response • Train employees in security and emergency response procedures, and retrain as necessary.

procedures, and retrain • Follow applicable security and emergency response procedures.
as necessary. • Develop business continuity plans for your business unit, conduct exercises to validate your plans,

OF INTEGRITY
STATEMENT
and train team members.

• Know your security leaders and how to contact them.

• Understand life safety guidelines, including evacuation and shelter-in-place procedures.

• Understand and follow your business unit’s emergency action plan, including the communications
strategy, business continuity plans and security protocols.

• Follow procedures for maintaining facility security.

FOR EMPLOYEES
RESOURCES
• Be alert to data or computer system security threats.

• Be aware of your surroundings; if you see or observe suspicious or threatening activity, notify
Security immediately.

• Be alert to and promptly raise any concern about workplace violence to your supervisor, Human
Resources representative or Security contact.

• Properly secure your workspace and computer work stations whenever you are away from your
workspace for any prolonged period, including at the end of each work day.

ABOUT OUR CODE

WHAT TO KNOW
• Comply with global immigration rules and travel policies (including Government and Company
policies, as applicable), especially for travel to high-risk destinations.

• Understand the proper procedures for handling suspicious mail, email and packages.

CODE POLICIES
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 TABLE OF CONTENTS
Our Commitment to Our Company > Security and Emergency Preparedness

WHAT TO WATCH OUT FOR

• Visitors to a Company facility who do not display an employee ID badge or authorized visitor pass. ADDITIONAL RESOURCES
IN THE INTEGRITY SECTION
• Security concerns about your physical surroundings, such as unlocked or damaged doors that are
OF YOUR BUSINESS UNIT’S
not properly secured or other facility issues.
INTRANET
• Any suspicious, threatening or disruptive behavior or activities. • Frequently Asked Questions

OF INTEGRITY
STATEMENT
• Potential physical or computer system security breaches in any of our facilities. • The security section of your business
• Emails from unknown senders and/or containing any suspicious or unfamiliar attachments or URLs. unit’s Employee Handbook

• Unattended or unsecured equipment or property.

• Efforts or offers to circumvent travel safety policies or country entry requirements.

Talk with your supervisor or visit

FOR EMPLOYEES
www.ComcastNBCUniversalListens.com

RESOURCES
to learn more about how
to raise a concern.

ABOUT OUR CODE

WHAT TO KNOW
CODE POLICIES
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 TABLE OF CONTENTS
Our Commitment to Our Company > Conflicts of Interest

CONFLICTS OF INTEREST
On the job or in your free time, nothing you do should conflict with your responsibilities or duty of loyalty
to the Company. Even when nothing wrong is intended, the appearance of a conflict can have negative
effects. That is why you must always consider how your actions may appear, and avoid situations that create
a real or perceived conflict of interest.

OF INTEGRITY
STATEMENT
WHAT TO KNOW
• We all must avoid conflicts of interest and make business decisions in the best interests of the
Company.

• A conflict of interest may exist when you are involved in activities that might interfere, or appear
to interfere, with the performance of your duties and responsibilities, or that could harm the

FOR EMPLOYEES
Company’s reputation or business relationships.

RESOURCES
• You must disclose and receive approval, as needed, for all outside work, financial interests and other
personal activities or relationships that may create, or appear to create, a conflict of interest. A
potential conflict of interest could arise if you have the ability to influence Company decisions relating
to employment or business transactions that affect a family member or close personal relationship.

WHAT TO DO
GENERAL PRINCIPLES

ABOUT OUR CODE

WHAT TO KNOW
• Avoid personal activities or relationships that may cause actual or potential conflicts or create
the appearance of a conflict with your job or the Company’s interests.

• Devote your time, attention and best efforts to the Company’s interests while at work.

• Do not pursue for personal gain opportunities that you learn of through your Company position
or access to Company information.

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Our Commitment to Our Company > Conflicts of Interest

• Do not use Company assets, information, resources or influence for personal benefit or to promote
an outside business or activity of yours, a family member or a close personal relationship. This The term “outside business”
includes the use of Company facilities, office equipment, e-mail, employee or client information, means a company or other
software or computer applications.
for-profit business
• Speak up if you know of a possible conflict of interest involving a supplier or other business partner, organization, including
or another employee or other person representing the Company. a family-owned business.

OF INTEGRITY
STATEMENT
• Contact a Company lawyer or Authorized Approver if you need help determining whether something
raises a conflict of interest or how to apply this policy.

FAMILY MEMBERS/CLOSE PERSONAL RELATIONSHIPS

• A conflict of interest could arise if you have the ability to influence Company decisions relating to
employment or business transactions that involve a family member or close personal relationship.

• Do not:

FOR EMPLOYEES
RESOURCES
»» Direct Company business to, or make Company decisions regarding, an outside business
owned or managed by you, a family member or a close personal relationship; or
»» Make any employment decisions regarding a family member or close personal relationship
(including hiring, promoting or directly supervising).

EMPLOYMENT AND OTHER ACTIVITIES OR ASSOCIATIONS OUTSIDE

OF THE COMPANY

ABOUT OUR CODE

WHAT TO KNOW
• Obtain pre-approval from your supervisor and an Authorized Approver before:

»» Working as an employee, consultant, advisor or officer or being a director of an outside business

while you are a Company employee.
»» Participating in outside writing, blogging, lecturing or other activities that draw on proprietary
or confidential information of the Company obtained as part of your employment with the
Company. For example, seek approval of any activities that may inadvertently disclose
proprietary or confidential information about technology trials, product development, scripts
or show outcomes.

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Our Commitment to Our Company > Conflicts of Interest

• The Company encourages you to participate in civic and charitable activities. Obtain pre-approval
from your supervisor and an Authorized Approver before:

»» Participating in a non-profit organization (such as a civic or charitable organization) on your own

time if such participation might present a conflict of interest or the appearance of a conflict of
interest, or potentially harm the Company’s reputation or business relationships.
»» Participating in civic or charitable activities as a representative of the Company or on Company

OF INTEGRITY
STATEMENT
time or using Company resources or assets.

FINANCIAL INTERESTS
• Owning a financial interest in an outside business that has a current or potential business relationship
with the Company, such as a supplier, contractor, customer, competitor, potential competitor or
company in which the Company has an investment may be a conflict of interest if you have the ability
to influence or affect the Company’s relationship with that business.

FOR EMPLOYEES
• Obtain pre-approval from an Authorized Approver before:

RESOURCES
»» Owning (either directly or indirectly) stock or any other financial interest in any outside business
that has a current or potential business relationship with the Company or is a competitor or
potential competitor of the Company. You do not need approval to own such an interest if:
›› the company is a public company and you purchase stock in the open market (i.e., through
a stockbroker and not directly from the company);
›› you own less than one percent of a traded class of the company’s stock; and
›› you do not perform any business function, provide any advice, or have any ability to influence

ABOUT OUR CODE

WHAT TO KNOW
the policies or activities of the company.
»» Soliciting or accepting any offer (even if unsolicited) to acquire securities (including by having
securities reserved for you in an IPO) of any outside business if the outside business or any
person making the opportunity available to you on behalf of the outside business has a current
or potential business relationship with the Company or is a competitor or potential competitor
of the Company. This restriction applies even if you are paying market price for the securities.

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Our Commitment to Our Company > Conflicts of Interest

WHAT TO WATCH OUT FOR

• Personal relationships that may conflict with your job responsibilities or compromise Company ADDITIONAL RESOURCES
interests. IN THE INTEGRITY SECTION
OF YOUR BUSINESS UNIT’S
• Activities that would lead an impartial person to question whether your motivations are consistent
INTRANET
with your job or the Company’s best interests.
• Frequently Asked Questions

OF INTEGRITY
• Situations that could result in personal gain or interfere with your ability to make an objective

STATEMENT
business decision. • List of Senior Attorneys
and Authorized Approvers

• Outside employment policy in your

business unit’s Employee Handbook

• Social media policy in your business

unit’s Employee Handbook

FOR EMPLOYEES
RESOURCES
OTHER APPLICABLE
CODE POLICIES
• Anti-Bribery/Anti-Corruption Laws

• Business Relationships

• Gifts and Business Entertainment

with Commercial Business Partners

ABOUT OUR CODE

• Interacting with Governments

WHAT TO KNOW
and Political Activities

Talk with your supervisor or visit

www.ComcastNBCUniversalListens.com

CODE POLICIES
CODE
to learn more about how
to raise a concern.

POLICIES
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OUR COMMITMENT
TO OUR
SHAREHOLDERS

OF INTEGRITY
STATEMENT
We are committed to delivering value to our
shareholders while conducting business in an ethical
manner. In our day-to-day decisions, we should never

FOR EMPLOYEES
take actions to secure short-term goals at the

RESOURCES
expense of long-term shareholder value. We take
responsibility for our actions as individuals and
as an organization by reporting information honestly,
timely and accurately, maintaining transparent
Company records and prohibiting trading on material,

ABOUT OUR CODE

nonpublic Company information.

WHAT TO KNOW
Financial Responsibility

Insider Trading and Stock Tipping

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Our Commitment to Our Shareholders > Financial Responsibility

FINANCIAL RESPONSIBILITY
Financial responsibility principles require us to protect the Company through integrity in record keeping,
financial reporting and public disclosures. We have a responsibility to maintain our books and records,
prepare our financial statements and make public disclosures in compliance with the law and
accounting standards.

OF INTEGRITY
STATEMENT
WHAT TO KNOW
• We comply with all applicable laws, rules and regulations governing financial accounting
and reporting.

• Financial responsibility encompasses:

»» Honest, fair and accurate financial reporting.

FOR EMPLOYEES
RESOURCES
»» Making full, accurate, timely and understandable public disclosures to government
agencies, such as the Securities and Exchange Commission, and the public.
»» Complying with our system of internal controls.
• Corrections to our financial records and reports that are identified in a timely manner,
reported in accordance with our system of internal controls and appropriately corrected
within our internal controls system are not violations of this policy.

ABOUT OUR CODE

WHAT TO DO

WHAT TO KNOW
• Ensure that all books and records:

»» Are maintained in accordance with applicable law;

»» Fairly and accurately reflect, in reasonable detail, the transactions or occurrences
to which they relate; and
»» Fairly and accurately reflect, in reasonable detail, our assets, liabilities, revenues
and expenses.

CODE POLICIES
CODE
• Make sure that our books and records do not contain any false or misleading statements
or entries.

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Our Commitment to Our Shareholders > Financial Responsibility

• Never intentionally misclassify any transaction as to accounts, departments or accounting periods.

• Do not change accounting or business practices or policies for the sole purpose of enhancing ADDITIONAL RESOURCES
near-term financial performance at the expense of long-term shareholder value, such as by IN THE INTEGRITY SECTION
“smoothing” or otherwise managing quarterly or annual results. OF YOUR BUSINESS UNIT’S
• Maintain accurate, appropriate and reasonably detailed documentation to support all transactions. INTRANET
• Frequently Asked Questions

OF INTEGRITY
• Provide all relevant information to, and never conceal information from, our internal auditors or our

STATEMENT
independent auditors. • Reporting Obligations of Financial
Professionals Policy
• Prepare all external reports and disclosures that are based on our books and records in accordance
with generally accepted accounting principles (“GAAP”) and securities laws.

• Manage documents and records in accordance with your business unit’s records and information
management policies.

• If you are a professional employee in the areas of accounting, internal audit, finance, financial
Talk with your supervisor or visit

FOR EMPLOYEES
planning and analysis, investor relations, risk management, tax or treasury, also review and
www.ComcastNBCUniversalListens.com

RESOURCES
follow the Company’s Reporting Obligations of Financial Professionals Policy.
to learn more about how
to raise a concern.
WHAT TO WATCH OUT FOR
• Financial records or subscriber statistics that appear inaccurate or are not transparent.

• Inaccurate financial reports or statements, such as overstated travel and entertainment

expenses or erroneous invoices or timesheets.

ABOUT OUR CODE

WHAT TO KNOW
• A request to document a transaction in a way that does not accurately reflect its substance.

• Financial results that seem inconsistent with underlying performance.

• Statements or communications that don’t make business sense or are inaccurate.

• An actual or potential conflict of interest involving an employee with financial reporting,

accounting or internal controls responsibilities.

• Circumvention of proper review and approval processes.

• Inadequate routines and controls to preserve financial records.

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Our Commitment to Our Shareholders > Insider Trading and Stock Tipping

INSIDER TRADING AND STOCK TIPPING

In the course of your employment with the Company, whether through a hallway conversation or as part
of your professional duties, you may learn of material information about the Company or other companies
before it is made public.“Material” information is information that an investor may consider important
in deciding whether to buy, sell or hold securities such as stock. You may not buy or sell securities while

OF INTEGRITY
STATEMENT
aware of material information that has not been made public (doing so is known as “insider trading”) or
convey such information to others who might trade before that information is made public (doing so is
known as “tipping”).

WHAT TO KNOW
• Insider trading and tipping while aware of material, nonpublic information about the Company or any

FOR EMPLOYEES
RESOURCES
other company is prohibited.

• Examples of material information include earnings announcements; financial forecasts; significant

financial developments (including dividend or share repurchase actions); possible acquisitions or
divestitures; important product, technology or strategy developments; changes in key personnel;
major litigation developments; and governmental investigations.

• “Securities” are broadly defined to include not just stock but also put and call options, debt securities
(such as bonds and notes) and any other similar equity or debt or instruments. Additionally, certain

ABOUT OUR CODE

forms of hedging or monetization transactions and other complex transactions can present unique

WHAT TO KNOW
insider trading risks.

• Insider trading and tipping is against the law. It can harm the Company’s reputation and can subject
you to severe penalties including imprisonment, disgorgement of profits, substantial fines and
monetary damages. Those who know or recklessly disregard that an employee was engaging in
insider trading and fail to take appropriate steps to prevent it may also be subject to similar
consequences.

WHAT TO DO

CODE POLICIES
CODE
• Do not buy or sell, either directly or indirectly through another person or entity, securities of the

POLICIES
Company or any other company while you are in possession of material, nonpublic information.

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Our Commitment to Our Shareholders > Insider Trading and Stock Tipping

• For any material, nonpublic information you know about a company, wait until the information
becomes public before:
ADDITIONAL RESOURCES
»» Buying or selling the security; IN THE INTEGRITY SECTION
»» Recommending or suggesting that anyone else buy or sell the security. OF YOUR BUSINESS UNIT’S
• Do not disclose any material, nonpublic information about the Company or any other company that INTRANET
you learn in connection with your employment to anyone until that information is generally available • Frequently Asked Questions

OF INTEGRITY
STATEMENT
to the public. This includes not disclosing this information to analysts, shareholders or other securities
• Fair Disclosure Policy
market professionals.

• Do not make personal financial decisions involving the employee stock purchase plan if you are
aware of material, nonpublic information about the Company.

• Follow procedures to safeguard any material or other sensitive information you learn about the
Company, including not disclosing it outside the Company unless necessary for your business
Talk with your supervisor or visit
activities and proper controls are in place. You also should maintain the confidentiality of information
www.ComcastNBCUniversalListens.com

FOR EMPLOYEES
that you learn in the course of your service about suppliers, contractors, customers, companies
to learn more about how

RESOURCES
in which the Company has an investment and other third parties. to raise a concern.
• If applicable to your role or business unit, learn and follow any additional requirements relating to
buying and selling securities (such as the preclearance of personal trades or being subject to a
blackout policy).

• Contact a Senior Attorney if you have questions about this policy, including any concern about
trading in a security or about whether any information could be deemed material.

ABOUT OUR CODE

WHAT TO KNOW
WHAT TO WATCH OUT FOR
• Buying or selling a security when you have access to information that you believe will make the price
go up or down once it is publicly announced. Even after the information is released to the public, there
must be adequate time for the market to become fully aware of the information before it is considered
to be public information.

• Buying or selling a security before a significant Company announcement.

• Talking to others (both inside and outside the Company) who do not have a need to know information

CODE POLICIES
CODE
about what you have been working on, where you have been traveling on Company business or who
has visited the office.

POLICIES
Imposters on Bravo 37
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OUR COMMITMENT
TO OUR BUSINESS
PARTNERS

OF INTEGRITY
STATEMENT
A critical part of doing business is partnering with
others. We believe that business relationships are
built on trust and mutual advantage. That is why we

FOR EMPLOYEES
make every effort to earn the trust of our suppliers,

RESOURCES
contractors, customers and other business partners,
including government entities. Our commitment
to operating ethically and honestly in our business
relationships is essential to maintaining our
reputation for trustworthiness. We strive to only

ABOUT OUR CODE

do business with others who share our commitment

WHAT TO KNOW
to ethical and lawful business behavior.

Business Relationships

Gifts and Business Entertainment

with Commercial Business Partners

CODE POLICIES
CODE
Interacting with Governments

POLICIES
and Political Activities
38
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Our Commitment to Our Business Partners > Business Relationships

BUSINESS RELATIONSHIPS
We value our business relationships and are committed to doing what’s right for our customers, suppliers
and other partners. Our business relationships are based on lawful, efficient and fair practices. We interact
honestly and with integrity in the marketplace and expect our partners to do the same. We also expect our
suppliers to obey the law, including laws that require them to treat workers fairly, provide a safe and healthy

OF INTEGRITY
STATEMENT
work environment and protect environmental quality, as well as laws prohibiting trafficking in persons
and forced, compulsory and child labor.

WHAT TO KNOW
• We do what’s right for our customers by being honest and forthright in our dealings
and communications with them and delivering on what we promise.

FOR EMPLOYEES
RESOURCES
• We conduct business in a responsible manner and strive to provide an exceptional
experience to our customers in every interaction.

• We are committed to maintaining and improving customer satisfaction.

• We strive to do business only with suppliers who uphold our values and comply
with applicable laws and standards governing labor, health and safety.

• We provide competitive opportunities, where practical, to all suppliers.

ABOUT OUR CODE

• We promote respect for human rights in our supply chain and other

WHAT TO KNOW
business activities.

WHAT TO DO
GENERAL PRINCIPLES
• Conduct all business in a responsible manner.

• Treat our suppliers, contractors, customers, other business partners and competitors
with the same level of respect and professionalism that you expect them to provide.

CODE POLICIES
CODE POLICIES
39
 TABLE OF CONTENTS
Our Commitment to Our Business Partners > Business Relationships

• Help us build long-term business relationships and be a model of integrity in all of your business
interactions.

• Follow all applicable procedures to safeguard confidential and proprietary information entrusted
to us by our suppliers, contractors, customers and other business partners.

• Compete fairly in the marketplace.

OF INTEGRITY
STATEMENT
CUSTOMERS
• Provide the highest quality experience possible for all of our customers regardless of where or how
the interaction takes place.

• Be honest, fair and transparent in all interactions with customers.

• Provide sufficient information so customers can make informed decisions about our products
and services.

FOR EMPLOYEES
• Follow all Company sales practices, including helping customers to access and determine what

RESOURCES
products and services best meet their needs and terminate services without hassle.

SUPPLIERS
• Conduct business only with suppliers that comply with national, local and other applicable legal
requirements and Company guidelines.

• Unacceptable supplier practices include:

ABOUT OUR CODE

WHAT TO KNOW
»» Employing workers younger than the required minimum age or the age of 16, whichever is higher.
»» Using forced, prison or indentured labor, or workers subject to any form of compulsion or coercion.
»» Failure to observe applicable environmental laws and regulations.
»» Failure to observe applicable laws and regulations governing wage and hour, days of service
and overtime payment.
»» Failure to provide workers with a workplace that meets applicable health and safety standards.
»» Failure to maintain and enforce policies requiring adherence to lawful business practices,
including a prohibition against bribery.

CODE POLICIES
CODE
• Provide a competitive opportunity for diverse suppliers to earn our business.

POLICIES
The Office 40
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Our Commitment to Our Business Partners > Business Relationships

• Understand and select suppliers in accordance with your business unit’s sourcing and procurement
procedures or practices (including concerning when to engage sourcing and competitive bidding).
ADDITIONAL RESOURCES
• Conduct appropriate information security reviews before granting a supplier access to the Company’s IN THE INTEGRITY SECTION
data or digital infrastructure. OF YOUR BUSINESS UNIT’S
• Maintain open, honest dialogue with suppliers, consistent with good business practices. INTRANET
• Frequently Asked Questions

OF INTEGRITY
• Evaluate all supplier offerings on the basis of quality, reliability, performance, price, service and

STATEMENT
technical requirements. • Your business unit’s sourcing
policy, if applicable
• Avoid potential conflicts of interest regarding suppliers or potential suppliers.

• Promptly raise any concern regarding supplier relationships, including a concern about a suspected
OTHER APPLICABLE
human rights violation in our supply chain, to your supervisor or a Company lawyer, or use another
CODE POLICIES
employee resource to speak up.
• Anti-Bribery/Anti-Corruption Laws

WHAT TO WATCH OUT FOR

FOR EMPLOYEES
• Conflicts of Interest

RESOURCES
• Inaccurate entries in customer records. • Gifts and Business Entertainment
with Commercial Business Partners
• Improper use of a promotion or offer to secure a customer transaction.
• Interacting with Governments
• Unsafe conditions in supplier facilities.
and Political Activities
• Supplier employees who appear to be underage or
• International Trade Controls
subject to coercion.
• Money Laundering Prevention
• Observable environment hazards in supplier facilities.

ABOUT OUR CODE

WHAT TO KNOW
• Privacy
• Solicitation, receipt or use of a supplier’s proprietary
data other than as authorized by such supplier.

Talk with your supervisor or visit

www.ComcastNBCUniversalListens.com
to learn more about how

CODE POLICIES
CODE
to raise a concern.

POLICIES
41
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Our Commitment to Our Business Partners > Gifts and Business Entertainment with Commercial Business Partners

GIFTS AND BUSINESS ENTERTAINMENT WITH COMMERCIAL

BUSINESS PARTNERS
Gifts and business entertainment can provide opportunities to build business relationships, network
with our Business Partners and promote products and services. If not handled appropriately, however,
gifts or business entertainment can damage the Company’s reputation and even violate the law. That

OF INTEGRITY
STATEMENT
is why it is the responsibility of every employee to understand the principles to consider before offering
or accepting a gift or business entertainment and to know when pre-approval is required.
This policy does not apply to gifts or business entertainment offered to, or for the benefit of, a Government
Official. All gifts, business entertainment or other things of value offered to Government Officials require
pre-approval from a Senior Attorney and must comply with the guidance set forth in the Interacting with
Governments and Political Activities policy and the Anti-Bribery/Anti-Corruption Laws policy.

FOR EMPLOYEES
RESOURCES
WHAT TO KNOW
GENERAL PRINCIPLES
• All gifts and business entertainment must be: (i) offered or accepted with a valid business purpose;
(ii) offered or accepted without the purpose of influencing a business decision or official action;
(iii) prudent and reasonable by local and industry standards (including in terms of value and
frequency); (iv) proper in appearance and without risk of embarrassment or harm to the Company’s

ABOUT OUR CODE

reputation; and (v) compliant with applicable laws and regulations.

WHAT TO KNOW
• All gifts and business entertainment must comply with the Anti-Bribery/Anti-Corruption Laws policy.
This means, among other things, that you may never offer, accept or solicit, directly or indirectly, gifts
or business entertainment to or from a Business Partner if it is intended or could reasonably appear
to be intended to influence any business actions or decisions or to obtain or retain an improper
business or other advantage.

CODE POLICIES
CODE POLICIES
i The terms “gift,” “business entertainment,” “Business Partner” and “Government Official”
are defined in the Glossary. 42
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Our Commitment to Our Business Partners > Gifts and Business Entertainment with Commercial Business Partners

WHAT TO DO
GIFTS AND BUSINESS ENTERTAINMENT ADDITIONAL RESOURCES
IN THE INTEGRITY SECTION
• Follow the requirements in your Business Unit Gifts and Business Entertainment Guidelines before
offering or accepting a gift or business entertainment to or from a Business Partner, or to others
OF YOUR BUSINESS UNIT’S
at the request of or at the direction of a Business Partner.
INTRANET
• Business Unit Gifts and Business
• Make sure that your recording of any gifts or business entertainment is clear and accurate in any

OF INTEGRITY
STATEMENT
Entertainment Guidelines
applicable expense report, pre-approval request or other Company record, and that those
documents reflect the true nature of the transaction. • Frequently Asked Questions

CASH • List of Senior Attorneys

and Authorized Approvers
• Never offer or accept a gift of cash, regardless of amount. This includes a cash equivalent, such
as a pre-paid credit or debit card, bank check, money order, loan, investment security or other
negotiable instrument. OTHER APPLICABLE
CODE POLICIES

FOR EMPLOYEES
SOLICITATION OF BUSINESS PARTNERS

RESOURCES
• Anti-Bribery/Anti-Corruption Laws
• Do not solicit a gift or business entertainment, regardless of value, from a Business Partner for any
• Business Relationships
non-charitable purpose unless you have obtained the appropriate pre-approvals as required by your
Business Unit Gifts and Business Entertainment Guidelines. • Conflicts of Interest

• Obtain pre-approval from the Comcast NBCUniversal Community Investment Department before • Interacting with Governments
soliciting a Business Partner for a charitable purpose using the Company’s name or your position and Political Activities
at the Company.

ABOUT OUR CODE

USE OF PERSONAL FUNDS

WHAT TO KNOW
• Do not seek to avoid the requirements of this policy by using personal funds to pay for a gift or
business entertainment for a Business Partner if you are acting as an employee of the Company
or if the gift or business entertainment relates to a Company matter. Talk with your supervisor or visit
www.ComcastNBCUniversalListens.com
WHAT TO WATCH OUT FOR to learn more about how
to raise a concern.
• Offering or accepting a gift or business entertainment that exceeds the dollar limits or other
guidelines established by your business unit.

CODE POLICIES
CODE
• Offering or accepting frequent gifts and business entertainment to or from the same
Business Partner.

POLICIES
• Incomplete or inaccurate records pertaining to a gift or business entertainment activity.

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Our Commitment to Our Business Partners > Interacting with Governments and Political Activities

INTERACTING WITH GOVERNMENTS AND POLITICAL ACTIVITIES

We conduct business with U.S. and non-U.S. national, state and local governments, government-owned
enterprises and other government entities such as public schools, libraries and hospitals. In the course of
our business activities, we frequently interact with Government Officials. In every instance, employees must
adhere to the highest ethical standards and comply with all applicable laws and regulations, including those

OF INTEGRITY
STATEMENT
relating to offering gifts and business entertainment to Government Officials or special requirements for
government contracts, political contributions and lobbying activities.

Violating any of these laws could result in criminal and civil penalties, a ban or restriction on the Company’s
ability to conduct business and/or reputational harm. That is why this policy requires employees to obtain
appropriate pre-approval before engaging in certain activity involving a Government Official.

FOR EMPLOYEES
RESOURCES
WHAT TO KNOW
• When interacting with a government or a Government Official, complex and often strict
laws can apply. These laws regulate our Company’s activities by, for example, prohibiting
or restricting gifts, business entertainment or political contributions to certain Government
Officials; or requiring Company employees or representatives who attempt to influence
a government decision by engaging in lobbying activities to register and report as
lobbyists or requiring the Company to register and report as a lobbyist-employer.

ABOUT OUR CODE

WHAT TO KNOW
There are also requirements and restrictions that may arise when our Company bids on
government contracts.

• As set forth in this policy, you must obtain pre-approval from your business unit’s General
Counsel before engaging in certain activities with a government entity or Government
Official. Pre-approval from the Comcast Corporation Political Affairs Department is also
required and can be obtained by your business unit’s General Counsel on your behalf.

CODE POLICIES
CODE POLICIES
i The terms “gift,” “business entertainment,” “Business Partner,” “Government Official,”
“government contracts,” “political contribution” and “lobbying” are defined in the Glossary. 44
 TABLE OF CONTENTS
Our Commitment to Our Business Partners > Interacting with Governments and Political Activities

WHAT TO DO
OFFERING A GIFT OR BUSINESS ENTERTAINMENT TO A
GOVERNMENT OFFICIAL
• Obtain pre-approval from a Senior Attorney before providing or offering a gift or business
entertainment to a Government Official or for the benefit of a Government Official.

OF INTEGRITY
»» This requirement applies to a gift or business entertainment offered or provided to any other

STATEMENT
person or entity, including a charity or family member, at the request of or for the benefit of a
Government Official.
Never offer a gift of cash,
»» This requirement applies even if you pay for the gift or business entertainment from your own
regardless of amount, personal funds. Gifts that are clearly unrelated to Company business, such as a holiday gift
to or on behalf of a for your child’s public school teacher, are not subject to this requirement.
Government Official. »» Even de minimis gifts or business entertainment offered to a Government Official must
be pre-approved.

FOR EMPLOYEES
RESOURCES
»» All gifts and business entertainment must comply with the Anti-Bribery/Anti-Corruption Laws
policy. This means, among other things, that you may never offer, directly or indirectly, a gift
or business entertainment to a Government Official if it is intended or could reasonably appear
as intended to influence an official action or decision or to obtain or retain an improper business
or other advantage.
• Never offer a gift of cash, regardless of amount, to or on behalf of a Government Official. This includes
a cash equivalent, such as a pre-paid credit or debit card, bank check, money order, loan, investment
security or other negotiable instrument.

ABOUT OUR CODE

WHAT TO KNOW
• Make sure that all gifts, business entertainment, gratuities or any other thing of value are clearly and
accurately described in any applicable expense reports, pre-approval requests or other Company
records, and that those documents reflect the true nature of the transaction.

CONTRACTING WITH A GOVERNMENT ENTITY

• Obtain required pre-approvals from a Company lawyer before bidding for, entering into or renewing
any government contract. This is necessary because many government contracts are subject to
special rules that can create obligations for the entire Company.

CODE POLICIES
CODE
• Follow government contractual requirements when engaging subcontractors or purchasing

POLICIES
materials in fulfillment of a government contract.

Shrek the Third 45

 TABLE OF CONTENTS
Our Commitment to Our Business Partners > Interacting with Governments and Political Activities

ENGAGING IN LOBBYING
• Obtain pre-approval from your business unit’s General Counsel before engaging in lobbying activities.

»» As a lobbyist-employer, the Company is subject to various federal, state and local laws which
may require it, its employees or outside persons who engage in covered lobbying activity to
comply with certain registration and reporting requirements. Obtaining pre-approval before
engaging in lobbying activities ensures that the Company complies with these regulations.

OF INTEGRITY
STATEMENT
HIRING A THIRD PARTY
• Follow Company due diligence, approval and contractual requirements when hiring or retaining
a third party to interact, directly or indirectly, with a Government Official on behalf of the Company.

HIRING A GOVERNMENT OFFICIAL

• Obtain pre-approval from your business unit’s General Counsel before taking any actions

FOR EMPLOYEES
RESOURCES
to potentially hire any Government Official as an employee or consultant for the Company,
as well as any individual who is related to or has been referred by a Government Official.

• Depending on the jurisdiction, a Government Official may need to disclose contacts with
a company with which he or she is negotiating prospective employment or recuse him or
herself from business affecting the company. Post-employment restrictions may ban a
former Government Official from working on certain matters or meeting with his or her
former agency for a period of time after leaving the government.

ABOUT OUR CODE

• Also, because employment may constitute a thing of value, all employment offers

WHAT TO KNOW
to Government Officials must comply with the Anti-Bribery/Anti-Corruption Laws policy.

MAKING OR SOLICITING A POLITICAL CONTRIBUTION

• Never use Company funds or other Company assets to make a political contribution without
obtaining pre-approval from your business unit’s General Counsel.

»» Federal and certain state and local laws generally prohibit the use of corporate funds
or resources for political contributions. Under no circumstances may you cause the

CODE POLICIES
CODE
Company to reimburse or compensate anyone for their political contributions.

POLICIES
46
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Our Commitment to Our Business Partners > Interacting with Governments and Political Activities

»» In order to prevent an illegal in-kind corporate political contribution, do not use Company facilities,
office space or personnel in connection with volunteer activity (such as fundraising) for a political
campaign, or perform volunteer activity for a political campaign during work hours, without ADDITIONAL RESOURCES
obtaining pre-approval from your business unit’s General Counsel. IN THE INTEGRITY SECTION
OF YOUR BUSINESS UNIT’S
• If you are an officer, director or other employee who receives a notice from the Company that you INTRANET
are subject to state or local “pay-to-play” laws, you must obtain pre-approval from your business
unit’s General Counsel before making or soliciting a personal political contribution. • Frequently Asked Questions

OF INTEGRITY
STATEMENT
• List of Senior Attorneys
ENGAGING IN PERSONAL POLITICAL ACTIVITIES and Authorized Approvers

• Do not engage in personal political activities other than on your own time. Employees are permitted and
encouraged to participate in their personal capacity in federal, national, state and local political activities OTHER APPLICABLE
in compliance with applicable laws, this policy and the Anti-Bribery/Anti-Corruption Laws policy, CODE POLICIES
however, you should not engage in overt, visible or partisan political activity that gives the appearance • Anti-Bribery/Anti-Corruption Laws
that you are expressing the views of the Company, or use the Company’s name in connection with

FOR EMPLOYEES
such activities, without obtaining pre-approval from your business unit’s General Counsel. • Business Relationships

RESOURCES
• Obtain pre-approval from your business unit’s General Counsel before running for election or accepting • Conflicts of Interest
appointment to a national, state or local public office. The term “public office” is interpreted broadly, and • Gifts and Business Entertainment
includes, but is not limited to, school boards, local government councils and all governmental offices with Commercial Business Partners
and positions.

WHAT TO WATCH OUT FOR

ABOUT OUR CODE

• Invitations to Government Officials to attend a business entertainment event. Such invitations must

WHAT TO KNOW
be pre-approved by a Senior Attorney. Talk with your supervisor or visit
• Donations to non-profit organizations that have relationships with, or are solicited by, a Government www.ComcastNBCUniversalListens.com
to learn more about how
Official. For example, we must comply with U.S. lobbying rules that require the reporting of donations
to raise a concern.
to organizations with certain relationships with a U.S. federal official, as well as expenses related to
events that honor or recognize a U.S. federal official. We have established separate procedures to
capture information relating to these payments in order to comply with these reporting requirements.

• Collecting or forwarding political contribution checks from other people to a federal, state or local
candidate, political party or political committee. Any such “bundling” may be illegal and requires

CODE POLICIES
CODE
the pre-approval of your business unit’s General Counsel.

POLICIES
• Fundraising for a political campaign while at work. Such activity requires pre-approval from your
business unit’s General Counsel.
47
 TABLE OF CONTENTS
OUR COMMITMENT
TO THE LAW

OF INTEGRITY
STATEMENT
A fundamental obligation that we owe to the nations
and communities in which we do business is to obey
the law. We adhere to all applicable laws everywhere
we do business. There is no business reason, no
management pressure, no unwritten understanding

FOR EMPLOYEES
that ever justifies violating the law. If you feel

RESOURCES
pressured to violate a law, immediately contact a
Company lawyer or use another employee resource
to speak up. While this commitment refers to all
applicable laws, a few areas are of particular
significance and applicability.

ABOUT OUR CODE

WHAT TO KNOW
Complying with Competition Laws

Anti-Bribery/Anti-Corruption Laws

Money Laundering Prevention

International Trade Controls

CODE POLICIES
CODE POLICIES
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Our Commitment to the Law > Complying with Competition Laws

COMPLYING WITH COMPETITION LAWS

Competition laws, known as antitrust laws in the United States, are designed to ensure open and vigorous
competition in the marketplace. Agreements or understandings among competitors that limit or restrict
competition are, in most circumstances, unlawful. Unilateral actions that injure or prevent competition
can also be illegal if undertaken by a company with significant market power. We comply with all applicable

OF INTEGRITY
STATEMENT
competition laws, rules, regulations, decrees and orders.

WHAT TO KNOW
• Competition laws are complex and their application is fact specific. Always proceed with caution Agreements arise in many
and seek legal guidance when you’re not sure. forms and can be express
• Competition laws prohibit any type of agreement that unreasonably restrains trade. Examples include
or implied, formal or informal,

FOR EMPLOYEES
agreements between or among competitors to fix prices or other competitive terms and agreements written or oral.

RESOURCES
to allocate sales, customers or service territories.

• Unilateral efforts to injure or prevent competition by companies with significant market power may also
violate antitrust laws.

• An entity may be both a valued partner for some purposes and a competitor for others.

• Government agencies can review proposed transactions and investigate Company activities that they
believe may be anticompetitive.

ABOUT OUR CODE

WHAT TO KNOW
• The Company is subject to several consent decree agreements with the Government relating to the
antitrust laws, which impose additional obligations on the Company.

• Violating competition laws or applicable consent decrees can have severe consequences, including
criminal prosecution, criminal and civil fines and large damage awards.

• You can find detailed guidance regarding compliance with competition laws in the Compliance
Guide to the Antitrust and Competition Laws.

WHAT TO DO

CODE POLICIES
CODE
• Understand and follow the Compliance Guide to the Antitrust and Competition Laws and any specific

POLICIES
business unit guidelines regarding complying with competition laws or consent decrees.

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 TABLE OF CONTENTS
Our Commitment to the Law > Complying with Competition Laws

• Unless you have received specific guidance from a Company lawyer, do not:

»» Discuss the Company’s current or future plans or any pricing information with a competitor. ADDITIONAL RESOURCES
»» Share confidential Company information with a competitor. IN THE INTEGRITY SECTION
OF YOUR BUSINESS UNIT’S
»» Agree with one or more competitors on any decision or course of action.
INTRANET
»» Price any product or service below cost.
• Frequently Asked Questions

OF INTEGRITY
»» Seek to raise a competitor’s cost of doing business, such as preventing suppliers or contractors

STATEMENT
from dealing with a competitor, or agreeing to costly contractual requirements on the condition • Compliance Guide to the Antitrust
that a competitor meets the same obligations. and Competition Laws

»» Seek to restrain a competitor from doing business. • Confidentiality policy in your business
unit’s Employee Handbook
»» Seek to control the pricing set by another company, even if it is not a direct competitor.
»» Enter into a joint venture or other collaboration involving an actual or potential competitor.
»» Agree with a competitor that you will not hire each other’s employees, or discuss with a

FOR EMPLOYEES
competitor compensation levels of each other’s employees.

RESOURCES
• Use caution when entering into any exclusivity arrangement. Evaluating such agreements often
Talk with your supervisor or visit
requires careful weighing of many factors. Contact a Company lawyer with any questions.
www.ComcastNBCUniversalListens.com
• Do not enter into any agreements or understandings, or exchange information, with a competitor to learn more about how
regarding prices, rates, terms or conditions of sale, bids, costs, profit margins, market share, to raise a concern.
business strategy or other confidential aspects of competition.

• Even where there are lawful reasons to communicate with a competitor (e.g., where business issues
arise from a genuine buyer-seller relationship), take care to avoid the appearance of anti-competitive

ABOUT OUR CODE

WHAT TO KNOW
behavior and limit discussions to the business at issue.

• Avoid or, if that is not possible, exercise care in situations where competitors are present that could
result in violation of the law, even unintentionally. Examples include trade shows and conferences,
meetings of industry trade associations and communications relating to legitimate joint ventures.

WHAT TO WATCH OUT FOR

• Discussions with competitors at a trade show or other industry event.

CODE POLICIES
CODE
• Discussions with competitors in connection with other legitimate activities, like joint ventures.

POLICIES
• Job-related discussions with personal friends who are employees of competitors.

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Our Commitment to the Law > Anti-Bribery/Anti-Corruption Laws

ANTI-BRIBERY/ANTI-CORRUPTION LAWS
Bribery is illegal, and we prohibit bribery of any kind. Providing anything of value, including gifts or business
entertainment, to influence any actions or decisions of a Government Official or Business Partner or to
otherwise gain an improper advantage in any situation is never acceptable and exposes you and the Company
to criminal sanctions and/or civil liability pursuant to national, state and local anti-bribery laws, including

OF INTEGRITY
STATEMENT
the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and similar anti-corruption laws of other
countries. We prohibit improper payments in all business dealings, with governments or in the private
sector, in every country in the world.

WHAT TO KNOW
• You must never compromise the Company’s reputation or integrity by engaging in,

FOR EMPLOYEES
RESOURCES
or appearing to engage in, bribery or any other form of corruption.

• You may not offer or promise (directly or indirectly) gifts, business entertainment or
other things of value to anyone—including Government Officials, Business Partners or
other third parties—if it is intended or could reasonably appear as intended to influence
official or business actions or decisions or obtain or retain an improper business or
other advantage.

• You may not solicit or accept gifts, business entertainment or other things of value from

ABOUT OUR CODE

anyone if it is intended or could reasonably appear as intended to improperly influence

WHAT TO KNOW
your actions or decisions on behalf of the Company.

• You may not falsify any book, record or account that relates to the business of our
Company or Business Partners, or the disposition of our assets.

CODE POLICIES
CODE POLICIES
i The terms “gift,” “business entertainment,” “Business Partner” and “Government Official”
are defined in the Glossary. Suits on USA 51
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Our Commitment to the Law > Anti-Bribery/Anti-Corruption Laws

WHAT TO DO
GIFTS OR BUSINESS ENTERTAINMENT RELATING
TO GOVERNMENT OFFICIALS AND BUSINESS PARTNERS
• Government Officials: Regardless of value, obtain pre-approval from a Senior Attorney and comply
with the Interacting with Governments and Political Activities policy.

OF INTEGRITY
STATEMENT
• Business Partners: Comply with the Gifts and Business Entertainment with Commercial Business
Partners policy and your Business Unit Gifts and Business Entertainment Guidelines.

• These policies also apply to gifts or business entertainment provided or offered to any other person
or entity, such as a charity or family member, at the request of or for the benefit of a Government
Official or Business Partner.

HIRING THIRD PARTIES

FOR EMPLOYEES
• Follow Company due diligence, approval and contractual requirements when selecting and hiring

RESOURCES
third parties to represent the Company to ensure that they are reputable and qualified, and that they
agree to comply with applicable anti-corruption laws and policies.

• Obtain pre-approvals as required by your business unit before entering into an agreement with a third
party who will have direct or indirect contact with a Government Official on behalf of the Company.

MAINTAINING ACCURATE BOOKS AND RECORDS

• Make sure that all financial transactions are clearly and accurately recorded in the Company’s books

ABOUT OUR CODE

WHAT TO KNOW
and records and that those records contain reasonable detail and reflect the true nature of the
transactions.

SPEAK UP IF YOU SUSPECT IMPROPER ACTIVITY

• Contact a Company lawyer immediately, or use another employee resource to speak up, if you
are concerned that an improper payment or other thing of value has been or will be offered, directly
or indirectly, by the Company or an employee or third party working on its behalf to any Government
Official, Business Partner or someone else in the Company, or if anyone offers you an improper

CODE POLICIES
CODE
payment or other thing of value.

POLICIES
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Our Commitment to the Law > Anti-Bribery/Anti-Corruption Laws

WHAT TO WATCH OUT FOR

• Background information about existing or potential third parties that indicates: ADDITIONAL RESOURCES
IN THE INTEGRITY SECTION
»» Allegations of improper business practices. OF YOUR BUSINESS UNIT’S
»» Reputation for bribes. INTRANET
»» Family or other relationships involving a Government Official. • Business Unit Gifts and Business

OF INTEGRITY
STATEMENT
• Any request for a suspicious payment (such as a payment in cash or payment directed to someone Entertainment Guidelines
not related to the transaction) or other unusual financial arrangement. • Frequently Asked Questions
• Any suggestion to hire or direct Company business through a specific third party due to a • List of Senior Attorneys
“special relationship.” and Authorized Approvers
• Any request to pay unusually high compensation that is disproportionate to the services provided,
or not consistent with reasonable business practices. OTHER APPLICABLE
CODE POLICIES

FOR EMPLOYEES
• Any Business Partner who is unwilling to agree to anti-corruption provisions in its contract.

RESOURCES
• Business Relationships

• Conflicts of Interest

• Gifts and Business Entertainment

with Commercial Business Partners

• Interacting with Governments

and Political Activities

ABOUT OUR CODE

WHAT TO KNOW
Talk with your supervisor or visit
www.ComcastNBCUniversalListens.com
to learn more about how
to raise a concern.

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CODE POLICIES
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Our Commitment to the Law > Money Laundering Prevention

MONEY LAUNDERING PREVENTION

We are committed to complying with all applicable anti-money laundering laws, conducting business with
reputable partners and receiving funds only from legitimate sources. Money laundering is the attempt to
disguise or “launder” the proceeds of criminal activity to make the source appear legitimate. Such proceeds
may derive from a wide range of illegal activity, such as organized crime, narcotics trafficking, trade

OF INTEGRITY
STATEMENT
violations and fraud. Money laundering schemes may involve disguising the origin of funds, or transferring
funds through third parties (such as a supplier) or through financial institutions, and can involve checks, wire
transfers and investments in every type of business. Many countries, including the United States, have
enacted laws against money laundering. The mere acceptance of funds that are known or believed to derive
from a crime can be sufficient to impose criminal liability.

FOR EMPLOYEES
WHAT TO KNOW

RESOURCES
• We take reasonable steps, based on the level of risk, to protect against attempts
to launder money through the Company. This includes only accepting certain forms
of payment and performing reasonable due diligence on our suppliers, contractors,
customers and other business partners.

• Our level of due diligence will be higher where the party is located in a country or
region with a greater risk of money laundering or related activity.

ABOUT OUR CODE

WHAT TO KNOW
WHAT TO DO
• If you are responsible for contracting with business partners or processing or
accepting payments, know the money laundering prevention guidelines applicable
to your business. Contact your finance department for details on these guidelines.

• Contact a Company lawyer immediately, or use another employee resource to speak

up, if you encounter suspicious activity or if you have any questions or concerns
before proceeding further with the transaction.
Mr. Robot on USA

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Our Commitment to the Law > Money Laundering Prevention

WHAT TO WATCH OUT FOR

• Any supplier, contractor, customer or other business partner who hesitates or is unwilling to provide ADDITIONAL RESOURCES
requested background information. IN THE INTEGRITY SECTION
OF YOUR BUSINESS UNIT’S
• Any request for an unacceptable form of payment, such as cash or a payment directed to or received
INTRANET
from someone not related to the transaction, or other unusual financial arrangement, such as a
request for transactions to go through more than one bank. • Frequently Asked Questions

OF INTEGRITY
STATEMENT
• Any request to conduct transactions with unknown financial institutions or financial institutions outside
the country where the transaction is occurring or where the business partner has operations. OTHER APPLICABLE
CODE POLICIES
• Overpayments followed by requests for refunds.
• Business Relationships
• Transactions that occur in regions we have identified as high-risk and known for drug trafficking,
terrorist or other criminal activities.

• Transactions that are unusual for a supplier’s, contractor’s, customer’s or other business partner’s

FOR EMPLOYEES
trade or business.

RESOURCES
• Any request to make an exception to the Company’s policies or procedures. Talk with your supervisor or visit
www.ComcastNBCUniversalListens.com
to learn more about how
to raise a concern.

ABOUT OUR CODE

WHAT TO KNOW
CODE POLICIES
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Despicable Me 3 55
 TABLE OF CONTENTS
Our Commitment to the Law > International Trade Controls

INTERNATIONAL TRADE CONTROLS

International trade control (“ITC”) laws regulate the transfer of goods, software, services and technology
across borders and the conduct of business with certain countries, entities and individuals. ITC laws include
export and import regulations, as well as economic sanctions, and are often based on national security
and foreign policy concerns. In order to do business in today’s global environment, we need to understand

OF INTEGRITY
STATEMENT
and comply with applicable ITC laws and regulations, both in the United States and in other locations where
we do business.

WHAT TO KNOW
• The export of certain items may require government authorization, depending on what is being
exported, what it will be used for, what country it is going to and who will receive it.

FOR EMPLOYEES
RESOURCES
• A wide range of transfers of goods, software, services or technology across national borders
and, in some cases, to foreign entities or individuals, even within the United States, may
constitute exports. This includes a broad range of activities such as physical shipments,
technical presentations, emails, briefings, trainings or access to electronic databases.

• U.S.-based ITC laws generally prohibit transactions or dealings with parties designated on denied
or restricted parties lists, and with certain countries subject to U.S. embargoes (including with
persons or entities in these countries and the governments of these countries). Similar regimes
apply in many other jurisdictions.

ABOUT OUR CODE

WHAT TO KNOW
• U.S. law prohibits U.S. companies and their affiliates from cooperating in or supporting foreign
boycotts that are not supported by the United States (e.g., the Arab League boycott of Israel).

WHAT TO DO
• Contact a Company lawyer to determine whether pre-clearance is required to export goods,
software, services or technology to a foreign country or foreign national.

• Conduct prospective third party screening against government restricted and denied parties

CODE POLICIES
CODE
lists as required by your business unit.

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 TABLE OF CONTENTS
Our Commitment to the Law > International Trade Controls

• Do not conduct transactions or dealings with countries subject to U.S. embargoes without written
pre-approval from a Company lawyer. Contact a Company lawyer for a current list of sanctioned
countries / territories. ADDITIONAL RESOURCES
IN THE INTEGRITY SECTION
• Report a request to comply with a foreign boycott to a Company lawyer. OF YOUR BUSINESS UNIT’S
• Provide complete and accurate information when completing customs forms and other required INTRANET
documents. • Frequently Asked Questions

OF INTEGRITY
STATEMENT
• Do not retain a third party to handle customs matters or other cross-border shipments without
performing due diligence and obtaining approvals required by your business unit. OTHER APPLICABLE
CODE POLICIES
WHAT TO WATCH OUT FOR • Anti-Bribery/Anti-Corruption Laws

• Business activities involving the export of sophisticated equipment, software or technology. • Business Relationships

• Any dealing or transaction (e.g., shipment, communication or other business activity) involving • Complying with Competition Laws

FOR EMPLOYEES
an entity or individual in or affiliated with a sanctioned country.
• Interacting with Governments

RESOURCES
• Documents, including contracts, requests to bid, letters of credit, purchase orders, shipping and Political Activities
and customs documents, certificates of origin and questionnaires that include words such
as “boycott,” “blacklist,” “whitelist” or similar terms.

Talk with your supervisor or visit

www.ComcastNBCUniversalListens.com

ABOUT OUR CODE

WHAT TO KNOW
to learn more about how
to raise a concern.

CODE POLICIES
CODE POLICIES
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 STATEMENT RESOURCES WHAT TO KNOW
TABLE OF CONTENTS CODE POLICIES
OF INTEGRITY FOR EMPLOYEES ABOUT OUR CODE
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GLOSSARY
OF TERMS
 TABLE OF CONTENTS
GLOSSARY OF TERMS
Business Entertainment – “Business entertainment” includes the following Government Official – A “Government Official” is any elected, appointed
when both the offeror and recipient are present: (i) meals; (ii) entertainment; or nominated official (regardless of rank or level), officer, employee or other
(iii) recreational, cultural or sporting events; or (iv) other activities. person acting as a representative (or any candidate for an office) of any:
(i) government entity, including a government agency, department, board,

OF INTEGRITY
Business Partner – A “Business Partner” is a current or potential supplier,

STATEMENT
commission or instrumentality; (ii) government-controlled entity or
contractor, customer or other business partner, who is not a Government instrumentality; (iii) public international organization; or (iv) political party.
Official.
Lobbying – “Lobbying” activity generally includes attempts to influence
Gift – A “gift” is anything of value, whether tangible or intangible, for legislation, rulemaking, ratemaking or other official government actions of
which the recipient does not pay the retail or fair market value, if any. agencies, including the decision to enter into a contract or other financial
A “gift” includes cash, gift certificates or gift cards, products, services, arrangement with the Company. “Grassroots” activity, where the public
transportation, lodging, discounts, promotional items, contributions to or employees are encouraged to contact a Government Official in order to
a charity or other organization, the recipient’s use of the offeror’s time,

FOR EMPLOYEES
influence a government decision, may also be considered lobbying activity.
equipment or facilities, and personal favors such as recommending

RESOURCES
the recipient or his or her family member in an application. A “gift” Outside Business – An “outside business” is a company or other for-profit
also includes the following if not attended by the offeror: (i) meals; business organization, including a family-owned business.
(ii) entertainment; and (iii) tickets, passes or other access to recreational,
Political Contribution – A “political contribution” is any benefit provided
cultural or sporting events.
to a national, federal, state or local candidate, candidate campaign, political
Government Contract – A “government contract” is an agreement with any party, political committee (e.g., a political action committee [“PAC”],
U.S. or non-U.S. federal, national, state, provincial or local government entity. inaugural or ballot measure committee), political convention, any entity
This includes contracts with quasi-government entities, such as state-owned exempt from federal income taxes under Section 527 of the U.S. Internal

ABOUT OUR CODE

WHAT TO KNOW
or state-run broadcasters, hospitals, universities, port authorities and Revenue Code or a 501(c)(4) social welfare organization. This includes
convention centers and arenas. monetary contributions (e.g., a corporate check or purchase of tickets
• Examples of the Company’s government contracting business to a political fundraiser) as well as “in-kind” contributions (e.g., the use
include: (i) providing cable, internet, phone or other services to of corporate personnel or facilities, or the donation of free airtime
government entities, including public schools, libraries, hospitals, to a candidate).
universities, authorities or commissions; (ii) licensing content to
government entities; (iii) production-related agreements (including
participating in tax credit programs or trade-outs with local
tourism agencies); (iv) advertising by government agencies

CODE POLICIES
or quasi-government entities; (v) management agreements
for government-owned facilities; and (vi) offering services
and goods to municipal facilities.

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