Corporate Governance

Corporate Governance Guidelines and Code of Conduct

Disclosure Requirements
Journalists who regularly cover business and financial news may not play the market: that is, they may not conduct in-and-out trading, speculate in options or futures or sell securities short. Any of these actions could create an appearance of exploiting information not available to the public. Staff members who regularly cover business aspects of technology or other subjects are also subject to this rule.

All employees are expected to conduct themselves at all times in a manner that leaves no grounds for belief, or even suspicion that:
-An employee, an employee’s family, or anyone else connected to an employee made financial gains by acting on the basis of “inside” information obtained through employment before that information was available to the general public.
-The creation or dissemination, or non-dissemination, of any news or other information was influenced by a desire to affect the price of any security;
-An employee’s personal financial situation with respect to investments is such that it creates a temptation to violate these rules; or
-An employee is beholden to news-makers, information providers, advertisers or market participants, creating a temptation to violate these rules.

In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of may engage in the short selling of securities.

News and advertising personnel and members of senior management with any responsibility for news or advertising also must not buy or sell futures or options. However, these employees may invest in equity index-related products and publicly available mutual funds or commodity pools that invest in futures or options. No news or advertising personnel assigned to report or call on a specific industry may buy or sell securities in any company engaged, in whole or significant part, in that industry, nor may any member of the immediate family of any employee do so.

Compliance With This Code takes this code of conduct very seriously. All employees of are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment, and to attest in writing that they have done so; all employees shall be required, at the time this code is first promulgated, to read it and so attest. Such written attestations shall be required once each year.


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