Conflict of Interest Policy

BUSINESS INSIDER CONFLICT OF INTEREST POLICY

Last updated: August 27th, 2019

Welcome to the websites, applications and services provided by Business Insider, Inc. ("Business Insider"), which include without limitation www.businessinsider.com, www.techinsider.io, www.insider.com, intelligence.businessinsider.com, markets.businessinsider.com, coupons.businessinsider.com (in partnership with GSG) (the "Sites").

The Scope Of This Policy

These guidelines generally apply to all members of our company.

The Purpose Of This Policy

Our fundamental purpose is to protect the impartiality and neutrality of Business Insider and the integrity of its news stories. Every staff member is expected to read these rules carefully and to think about how they might apply to his or her duties.

Speaking For The Company

Staff members must not disclose confidential information about the operations, policies or plans of our company.

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 Business Insider 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 Business Insider 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 Business Insider may engage in the short selling of securities.

In addition, all senior managers and all news and advertising personnel must not engage in short-term trading of equity securities or of non-investment grade fixed-income securities; such employees must hold such a securities for a minimum of six month unless, in order to meet some special need, they get prior permission for an earlier sale from the Company. The six-month rule does not apply to publicly-available diversified open end and closed end mutual funds.

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.

Promotion / Links

It is unacceptable for anyone at Business Insider to accept cash or anything else of value in exchange for promotion/links, etc. in a story, especially if the relationship isn't disclosed. There are certain instances in which we are given travel expenses or swag or other benefits for covering a story. And, importantly, when we are given these things, we should always disclose it clearly. There are also certain instances in which our company might be paid to link to sponsors' sites, but those relationships will also be disclosed clearly.

Freelance Writing and Broadcast Appearances

-With approval, staff members may accept freelance assignments that do not directly compete with Business Insider's offerings. Normally, work for competitors will not be permitted. In rare instances, permission may be granted when supervisory editors are not interested in the article or project offered by a staff member.
-Also with approval, staff members may participate in radio, television or online interviews or discussions, local or national, that deal with articles they have written or subjects that figure in coverage they provide, prepare or supervise. Such occasional appearances must not imply that the journalist speaks for our organization. Staff members should ensure that the use of their names and company affiliation is consistent with the Sites's impartiality.
-Staff members must ensure that their freelance work does not interfere with their normal responsibilities.

Returning Borrowed Equipment

Staff members who borrow equipment, vehicles or other goods for evaluation or review must return them as soon as possible. Staff members may keep for their own collections -- but may not sell or copy -- books sent to them for review. Such submissions are considered press releases.

Books, and Rights To Our Materials

Any staff member intending to write a non-fiction book based on material that derives from his or her assignment or beat must notify newsroom management in advance. If the plan is to reproduce content created for any of our media, Business Insider owns that material outright.

Voting and Political Activities

It is not Business Insider's intention to dissuade employees from participating actively in civic, charitable, religious, public, social or residential organizations. Such activities are permitted, and even encouraged, to the extent that they:
-Do not detract from performance or effectiveness of work;
-Do not cause Business Insider to appear to subsidize the activity;
-Do not otherwise violate this code.

Business Insider as a publisher does not participate in the partisan political process on any governmental levels. Business Insider does not contribute (directly or indirectly) to political campaigns, parties, or groups seeking to raise money. Business Insider will not reimburse any employee for their political contributions at any level.

All editorial team members and senior management with any responsibility for news should refrain from partisan political activity. As relates to candidates for elected office, this activity includes passing out buttons, posting partisan comments on social-networking sites, blogging, helping to solicit campaign contributions, or hosting a fundraiser for a partisan candidate. This activity also includes making any level of financial contribution to a candidate's campaign for elected office or any Political Action Committee supporting individual candidates for elected office. While these restrictions do not explicitly apply to an employee's spouse, significant other, children, or family members, all editorial team members and senior management with any responsibility for news should refrain from exhibiting political bias.

Compliance With This Code

Business Insider takes this code of conduct very seriously. All employees of Business Insider 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 Business Insider 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.

The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal.

Any employee who has a question about or becomes aware of his or her own possible violation of this code or by any other employee, or becomes aware that he or another employee is involved in a transaction or relationship that could reasonably give rise to an actual or apparent conflict of interest, should promptly discuss the situation with his or her supervisor. Every effort will be made to maintain the confidentiality of such discussions. Business Insider will not permit or tolerate any retaliation against any employee who makes a good faith report about a possible violation of the code by another employee. Indeed, the most important wisdom about dealing with these questions is: When in doubt, ask.