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MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWEDDOING BUSINESS RIGHTOUR CODE OF CONDUCT1LAST UPDATED JANUARY 2019
MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWEDA MESSAGE FROM ALEX TAYLORDear Cox Employees:From its humble beginnings as a single newspaper with five reporters, Coxhas grown into a global enterprise with more than 60,000 employees. Duringthat time, a world of wood, horses and telegrams has evolved into a world ofrenewable energy, autonomous vehicles and a network in the cloud.One thing, however, has remained the same: Our commitment to our people,customers and the communities we serve.As a company, our Purpose is to empower our people to build a better futurefor the next generation. We strive to do the right thing for our employees andcustomers while giving back to the communities where we live and work. Thissimple principle makes up our company culture and drives the way we dobusiness. As our company grows, we must continue to foster a workplace thatputs people first and upholds fundamental ideals such as honesty, integrityand accountability.Our Code of Conduct reinforces our pledge to always do business right, andit ensures that our legacy of operating with the highest ethical standards willnever change.I encourage you to review the Code and pledge to follow it throughoutthe year. Please refer any questions to your manager, HR representative orCompliance Officer. Thank you for your dedication to our company.Sincerely,Alex TaylorPresident and Chief Executive OfficerCox Enterprises2
MENU12Go to the hyperlinked tableof contents.345678CONTACTS GLOSSARY LAST PAGE VIEWEDGo to the beginning of keysections of the Code.Go to a listing ofkey contactsand resources.HOW TO USE THIS PDFView definitionsof terms used inthe Code.Go back to thelast page viewed.Go to theprevious page.Go to thenext page.This interactive PDF includesbuilt-in interactivity to aidnavigation and provide easyaccess to resources.This page provides a descriptionof these features.SEARCH – Press Ctrl Fto access the Adobe Acrobatsearch tool.DEFINITIONS – Words definedin the glossary are linked to theGlossary page.The arrow shows thesection you are in.Each section titleincludes links to thecovered topics.Links to resources andrelated content are blueand underlined.Go to theprevious page.Current pagenumber.Go to thenext page.3
1MENU2345678CONTACTS GLOSSARY LAST PAGE VIEWEDCONTENTS MENUItems listed on this page function likelinks in a web browser. Click on anitem to visit that page.4 WE CONDUCT BUSINESSLAWFULLYWe Respect the Privacy of OthersA Message From Alex Taylor2How to Use This PDF3We Are Guided by Our Values51WE KNOW OUR CODE6Why a Code?7Who Has to Follow It?7What Is Ethical Decision-Making?8 What Happens When Our CodeIs Violated?92 WE HONOR OURRESPONSIBILITIES10 Together We Put OurValues Into Practice11Share Concerns12We Don’t Tolerate Retaliation131718We Use Company-Issued Devices Properly 19We Follow the Law Antitrust and Competition Laws19 Anti-Bribery Laws20 Insider Trading Laws215 WE UNDERSTAND OURRESPONSIBILITY TO OTHERS22 e Maintain a Safe and HealthyWWorkplace23 We Honor the Promises We Maketo Our Partners25 We Conduct Business Honestlyand Ethically26 With Our Suppliers26 With Our Competitors266 WE DO THE RIGHT THINGWe Protect Our Assets32We Maintain Accurate Records348WE ARE GOOD NEIGHBORS36We Give Back37 Charitable Contributions37 Political Activities37 Lobbying37 CoxPAC37We Are Good Stewards Environmental – Cox ConservesWe Protect Human Rights383838 Glossary39 Index41 Contacts422713We Avoid Conflicts of Interest283 WE PROMOTE AN INCLUSIVEWORKPLACE14We Don’t Accept or GiveInappropriate Gifts or Entertainment29 We Celebrate Our Diverse Workforce15 We Are Responsible WhenCommunicating About Cox3119 Are You a People Leader?We Respect Each Other7 WE SAFEGUARD OURCOMPANY’S ASSETS30164
MENU1234WE ARE GUIDED BYOUR VALUESOur values have always inspired our work.Governor James M. Cox once said,“Ask yourself one question, ‘Is it right?’Then do what you believe is right for yourtown, your state and your company.”Today, we still live by his words. Ourcommitment to doing what’s right hashelped us to earn our success andreputation, moving business forward.We strive to act with integrity and live byour values in everything we do.5678CONTACTS GLOSSARY LAST PAGE VIEWEDCOX VALUESEMPLOYEESOur employees are our most important resource. Weencourage entrepreneurship and initiative. We recognizeand reward achievement.CUSTOMERSOur customers are our lifeblood. We’re dedicated tobuilding lasting relationships with them and meeting theirneeds with high-quality service beyond their expectations.DIVERSITYWe are committed to having a diverse workforce thatreflects the communities we serve. We embrace andfoster an environment that builds on the unique talentsthat come from a variety of people and perspectives.COMMUNITYWe believe it’s good business to be good citizens ofthe communities we serve through volunteerism andfinancial support.TECHNOLOGYWe embrace new technology to give our customers thevariety and quality of services they demand.INVESTMENTWe invest in new business opportunities with a mixtureof caution and initiative, to enhance our growth.ENVIRONMENTWe are committed to helping shape a better worldthrough responsible company and individual actions.5
MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWED1 WE KNOW OUR CODEFIND OUTOur Code is our cornerstone – the foundation on which ourcommitment to excellence is built. It provides information Why We Have a Codeand answers to help us model our core values and set the Who Has to Follow Itstandard for doing the right thing when acting on behalf How to Make EthicalDecisionsof Cox. What Happens WhenOur Code Is Violated6
1MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE KNOW OUR CODEWHY A CODE?We have a Code to ensure you have theanswers you need to do your job in alawful and ethical manner.Our Code provides an overview of thelaws, regulations, and certain companypolicies and practices that affect ourbusiness as well as some resources wecan reach out to for help. It doesn’t justtell us how to work, but how to embraceour values in every business decisionand action we take.WHO HAS TO FOLLOW IT?So what does that mean?It means doing things the right way.Making decisions guided by integrityand ethics. It’s about keeping ourpromises. Honoring our values. Doingbusiness as a trusted partner, the waywe’ve done it for more than a century.Every employee at Cox has a responsibility toknow and follow our Code and to ask questionsabout issues that are unclear. Please take theresponsibility to communicate with each otherand our partners about the standards we’veput in place with a goal to ensure our companyremains one of the best.7
1MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE KNOW OUR CODEWHAT IS ETHICAL DECISION-MAKING?Remember, our Code is the starting point, not the finish line. It lays out the basic rules for how we conductbusiness, but it doesn’t have the answer to every question you might have or every situation you might face.NOT SURE OF WHAT TO DO? ASK YOURSELF:DOES IT COMPLYWITH OUR CODEOR POLICIES?IS ITLEGAL?NO.STOP.NOTSURE?SEEK HELP.YES.NO.STOP.NOTSURE?SEEK HELP.YES.IS IT GOOD FOR COXAND RESPECTFUL OFMY CO-WORKERS?NO.STOP.NOTSURE?SEEK HELP.YES.WOULD I FEEL GOODABOUT IT IF IT WASPUBLISHED ONLINE ORBROADCAST IN THE NEWS?NO.STOP.NOTSURE?YES.SEEK HELP.THE ACTIONIS PROBABLYOKAY. STILLNOT SURE?ASK FOR HELP.8
1MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE KNOW OUR CODEWHAT HAPPENS WHEN OUR CODE IS VIOLATED?The Cox legacy is built on integrity andethical decision-making. When one personviolates our Code, it affects us all. That’swhy we take violations seriously.Anyone who knowingly violates our Code,our policies, regulations or the law (orknowingly fails to report a violation) isnot doing the right thing and may facecorrective action, up to and includingseparation from employment.It is your responsibility as part of the Coxemployee family to Speak Up when yoususpect wrongdoing and to cooperatefully and honestly in any internal orgovernmental investigation.EXPLORE OUR POLICIES Corrective Action Policy Doing Business Right PolicyLIVE ITPROMOTE ANETHICAL COX.DO YOUR PART– SPEAK UP.9
MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWED2 WE HONOR OUR RESPONSIBILITIESWe’re passionate about our company. That’s why weFIND OUTalways strive to do what’s right. No matter what job we About Your Responsibilitiesdo or where we do it, we’re committed to the highest How to Share Concernsstandards of business conduct. How We Don’t TolerateRetaliation About People Leaders’Responsibilities10
1MENU22345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE HONOR OUR RESPONSIBILITIESTOGETHER WE PUT OUR VALUES INTO PRACTICEWHAT IF.Conduct business legally and ethically. Preserve the trustthat others have placed in us. Be sure there’s no differencebetween what you say you will do and what you do.THERE’S A CONFLICT BETWEEN THE CODEAND A POLICY IN MY DEPARTMENT?Know the policies and procedures that apply to your job.Be aware that some departments or subsidiary businessesmay have policies that apply only to employees in their area.Follow the Code. Bring the conflict to the attentionof your manager and HR representative.Complete your mandatory training. It will help you in notonly knowing our policies and procedures, but also inapplying them to your everyday work.Use the Code. Re-visit Code sections to keep ethical issuestop-of-mind.Ask questions. It’s the best way to be certain you’re on theright path. Always remember: there are people who wantto help you.Take action. If you see or suspect a violation of our Code,say something. Speaking up isn’t just a good idea, it’s yourduty and required by our Code. It helps make our companya better place to work.11
1MENU22345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE HONOR OUR RESPONSIBILITIESSHARE CONCERNSIf you have a problem or concern, you shouldstart with your manager. Our “EmployeeProblem Resolution Policy”means youare free to talk to your manager any timeabout any problems or concerns. If you’reuncomfortable discussing your concerns withyour manager, or if you are unsatisfied withyour manager’s response, the Policy providesyou with other avenues to address yourconcerns including speaking with yourHR representative.The Ethics Hotline is accessible by phoneor web and allows you (anonymously, if youwish) to ask questions or share your concerns24 hours a day, 7 days a week with anindependent, third-party interview specialist.Our Legal Department can also help youunderstand any requirements Cox hasunder the law.No matter who you contact or whatresource you choose, your concern willbe promptly addressed and handled withthe appropriate level of confidentiality.Keep in mind, it may not be appropriatefor the results of an investigation to becommunicated back to you in light ofour obligation to protect privacy andconfidentiality, but you will have the abilityto know whether the review or investigationhas been completed and closed.CoxEthicsHotline.EthicsPoint.comWhen you contact the Ethics Hotline, theinformation you provide is documented indetail and forwarded to the appropriate officewithin Cox for investigation and resolution.YOU CAN REPORT CONCERNS ABOUT: Discrimination or harassment Workplace violence, threats or bullying Conflicts of interest Theft, fraud or bribery Environmental or safety issues Inappropriate gifts or entertainment Accounting or financial issues Code violations Policy violations RetaliationGOT A QUESTION?ETHICS HOTLINE:1-877-329-0696DID YOU KNOW?NEED ADVICE?SUSPECTA VIOLATION?SEE SOMETHING?SAY SOMETHING.SPEAK UP. Other concerning behaviorNote that these are just examples, not an exhaustivelist. Anytime you see or suspect something thatcould harm Cox, our employees or our customers,Speak Up. By reporting misconduct, you helpcontribute to the ethical culture of our company.EXPLORE OUR POLICIES Anti-Retaliation Policy Employee Problem Resolution Policy Ethics Hotline Reporting PolicyCODE OF EXCELLENCE12
1MENU22345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE HONOR OUR RESPONSIBILITIESWE DON’T TOLERATE RETALIATIONARE YOU A PEOPLE LEADER?We want you to feel comfortable comingforward so, as a company, we don’t tolerateretaliation against anyone who speaks up, ingood faith, about unethical or illegal behavior.As a Cox leader, you have a special responsibility tolead with integrity. Show your team, through youreveryday words and actions, that you do businesstransparently and in compliance with our Code.See our Anti-Retaliation Policy to learn more.If you think that you or someone you know hasbeen retaliated against for raising an issue,Speak Up.Be the kind of leader who people feel comfortableapproaching.WHAT IF Support employees who come forward in goodfaith to share their concerns or raise questions.THE CONCERN I WANT TO RAISE IS ABOUTMY MANAGER. COULDN’T I LOSE MY JOB? Listen, take good notes and work together with yourHR representative to resolve issues as quickly andeffectively as possible.The best place to raise your concerns istypically with your manager, but if yourmanager’s conduct concerns you, calling yourHR representative or the Ethics Hotline aregood options. If you call the Ethics Hotline,you’ll speak to an interview specialist whodoesn’t work for Cox, so you can be assuredthat the situation will be treated confidentially.Retaliation by anyone, including your manager,will not be tolerated.EXPLORE OUR POLICIES Anti-Retaliation Policy Employee Problem Resolution PolicyLIVE ITIF YOU’RE A PEOPLE LEADER,BE A ROLE MODEL FORETHICAL CONDUCT. Promote our Employee Problem Resolution Policy. Seek Help if you’re not sure of the right way to go. Make sure employees aren’t subjected toretaliation for speaking up. Properly report allegations of noncompliance.WHAT’S “GOOD FAITH”?Honestly believing in what you’re doing. Sharing aconcern “in good faith” means that you believethat there’s a violation of law or our companypolicies and that you’re not deliberately makinga false report.13
MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWEDWEPROMOTEAN3 INCLUSIVE WORKPLACEThe best thing about Cox? Our employees. We blendour unique experiences, perspectives and talentstogether to create an amazing team.FIND OUT About OurDiverse Workforce How We Work Towarda Harassment-Free Cox14
1MENU32345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE PROMOTE AN INCLUSIVE WORKPLACEWE CELEBRATE OURDIVERSE WORKFORCEThink about families. Although they may bealike in some ways, each member has theirown way of looking at situations, expressingthemselves and doing things.The Cox employee family is no different.While we’re all passionate about providing ourcustomers with the very best experiences,each of us brings a different idea forpowering that passion. It’s that diversity ofbackgrounds, experiences and viewpointsthat drives our success.We’re committed to having a diverse workforcethat reflects the communities we serve and tofostering an environment that builds on theunique talents and perspectives that comefrom a variety of people. It’s one of our corecompany values.We provide equal employment, equitabledevelopment, and advancement opportunitiesand do not discriminate against anyone on thebasis of race, color, religion, sex, pregnancy,national origin, age, veteran status, disability,genetic information, sexual orientation, genderidentity or expression, or any other legallyprotected category.As part of our commitment to providingequal employment opportunities, we providereasonable accommodations to qualifiedindividuals with disabilities. We also providereasonable accommodations for religiousobservances or practices. If you believeyou need an accommodation due to adisability or a religious belief, please discussyour request for accommodation with yourmanager or HR representative.DID YOU KNOW?OUR EQUAL EMPLOYMENT OPPORTUNITYPOLICY APPLIES TO ALL ASPECTS OFEMPLOYMENT INCLUDING: Getting a job at Cox Performance evaluations Promotions and advancement Pay and certain benefitsEXPLORE OUR POLICIES Anti-Harassment Policy Anti-Retaliation Policy Equal Employment Opportunity Policy Discipline and separation Participation in company-sponsoredemployee activities, events and programsLIVE ITHONOR THE INDIVIDUAL EXPERIENCES,CULTURES AND PERSPECTIVESOF EVERYONE.THINK ABOUT HOW YOUR WORDS ANDACTIONS ARE PERCEIVED BY OTHERS.LIVE OUR VALUES.15
1MENU32345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE PROMOTE AN INCLUSIVE WORKPLACEWE RESPECT EACH OTHERWe care about each other and work togetherto promote a workplace free of harassment.We don’t tolerate any behavior (whether verbal,visual, physical or sexual) that would create anoffensive, hostile or intimidating environment.EXAMPLES OF HARASSMENTEXPLORE OUR POLICIES Joking about someone’s race or ethnic background Anti-Harassment Policy Anti-Retaliation Policy E mployee ProblemResolution Policy Ethics Hotline Reporting Policy Unwelcome hugging or touching An unwanted sexual joke, flirtation, advanceor proposition Discussing sexual activities or desires or displayingobscene pictures, cartoons or posters Posting or circulating materials that degrade or expresshate against someone because of race, color, religion,sex, pregnancy, national origin, age, veteran status,disability, genetic information, sexual orientation, genderidentity or expression or other factors protected by lawLIVE ITTREAT EVERYONE FAIRLY AND WITHRESPECT. DON’T SINGLE OUT SOMEONE(OR A GROUP) BASED ON THEIRBACKGROUND, APPEARANCE OR OTHERPERSONAL CHARACTERISTICS.16
MENU12345678CONTACTS GLOSSARY LAST PAGE VIEWED4 WE CONDUCT BUSINESS LAWFULLYWe honor not just the letter of the law (the actual words),FIND OUTbut also the spirit of the law. Our commitment helps to build How We Respect Privacytrust, protect our brand and secure our future. How We’re Pro-Competition How We’re Anti-Bribery How We Protect Inside Information17
1MENU42345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE CONDUCT BUSINESS LAWFULLYWE RESPECT THE PRIVACYOF OTHERSKeeping personal information safe is thefoundation of trust.Our customers count on us to providetransparent processes, respect their privacy,honor their choices and protect their personalinformation.Our fellow employees expect us to respecttheir personal information, so that each of uscan focus on providing the best service to ourcustomers.We are committed to keeping personalinformation safe and secure. We treatour customers’ and employees’ personalinformation the same way we would expectothers to treat our own personal information.Our use of personal information must clearlymeet a responsible business need.We recognize that the security and privacyof personal information is everyone’sresponsibility.WE: Collect only the personal informationthat we need. Are open and honest about how wecollect, use and disclose personalinformation. Provide appropriate choices regardingpersonal information. Take reasonable steps to keep personalinformation secure. Properly destroy personal informationin our possession when it is no longerneeded for business purposes. Notify our customers and employeespromptly (in accordance with applicablelaws) if personal information has beencompromised. Comply with all policies, processes andguidelines to protect the security ofpersonal information. Take the appropriate and requiredtraining to understand our informationEXPLORE OUR POLICIESprivacy obligations. Confidential and Proprietary Information Policy Report violations of any policy, process Employee Privacy Policyor guideline. Global Information Security PolicyLIVE ITPROTECT PERSONALINFORMATION AS IFIT WERE YOUR OWN.KNOW THE RULES WHENIT COMES TO RESPECTING THEPERSONAL INFORMATION OFOTHERS.18
1MENU42345678CONTACTS GLOSSARY LAST PAGE VIEWEDWE CONDUCT BUSINESS LAWFULLYWE USE COMPANY-ISSUEDDEVICE
Dear Cox Employees: From its humble beginnings as a single newspaper with five reporters, Cox . and answers to help us model our core values and set the standard for doing the right thing when acting on behalf of Cox. 1 FIND OUT . business, but it doesn’t have the answer to every quest
