Activision Blizzard | Code of Conduct - Acting With Integrity (2024)

This chapter covers guidance on the Right Way2Play: it’s how we live our Code. Our ethical culture is created by all of us. We all have the responsibility to not only react when something’s wrong, but also step up and speak up to keep things right. Keep reading to learn more on getting guidance and making reports.

THE ASK LIST: WHERE YOU CAN GO FOR HELP

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

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

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

Note that any of the reporting options on the ASK List can be used for reporting any types of concerns. We hope you trust our process for handling matters internally, but please know that nothing in our Code prohibits you from reporting any illegal activity, including any violation of the securities laws, antitrust laws, environmental laws or any other federal, state, or foreign law, rule or regulation, to regulatory or government authorities. Employees, officers, and directors shall not discharge, demote, suspend, threaten, harass or in any other manner discriminate or retaliate against an employee because he or she reports any such violation.

Get to Know Your Way2Play Heroes

While creating a safe and inclusive culture is everyone’s responsibility, the Way2Play Heroes on our team go the extra mile. As your local points of contact on ethics and compliance, they serve as a bridge between our business and experts on the Way2Play Team*. Heroes are the allies in the room, our in-person guides, and the advocates of doing the right thing. They are appointed to the Way2Play Heroes program after a careful vetting process and receive extra training to help guide you if you have questions or concerns about what to do. Click here* to find your local list of Heroes.

Unsure What to Do?

Check out the Activision Blizzard Ethical Decision-Making Guide:

Am I living our values & following our policies?

Is what I’m about to do in line with our core values of Integrity, Responsibility & Creativity? Have I checked the relevant policy for guidance?

Have I checked my intentions?

Have I confirmed that social pressure isn’t influencing my decision? Am I confident that I’m not overreacting to high stress or pressure? Is there a clear precedent for this action that confirms it’s ethical and the right thing to do?

Is it legal?

Am I conducting business legally? Do I know that my action won’t inadvertently lead to violating a law in a different region or department where we do business?

Would I feel proud if this becomes public?

If my words or actions made it to the front page of a newspaper, would it make me proud? Would my fans, fellow players, and friends think it was a good move?

Always Speak Up: Ask Questions and Raise Concerns

We are committed to providing a workplace where individuals feel comfortable reporting concerns immediately - when concerns occur or upon learning of them; however, you should not be discouraged to report concerns that have occurred in the past; we still want to know about those. We understand that there are times when you feel that you can address an issue yourself or maybe you think the concern isn’t serious enough to report. Sometimes you may be afraid to report, fearful of retaliation or fallout. We take retaliatory conduct seriously, we prohibit it, and we are committed to fostering a workplace where individuals can report their concerns without fear of retribution.

Speaking up and seeking answers is a key company value. So if you know or suspect something’s wrong, including a violation of our Code or policies, we encourage you to speak up right away – even when others don’t. Similarly, People Leaders who know or suspect something’s wrong must promptly report such misconduct. But, of course, do so in good faith. Remember, making a “good faith” report does not mean your suspicions have to be correct. It just requires that you provide truthful and accurate information and believe that the conduct you are reporting occurred or is going to occur.

The Right Way2Play:

“We prohibit retaliation of any kind. If you believe you are being unfairly treated, reach out to theWay2Play Team*- or anyone on theASK List*. To learn more, please read ourWorkplace Integrity Policy*.”

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

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