Code of Conduct
Code-of-Conduct
Code-of-Conduct
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<strong>Code</strong> Policies > Our Commitment to Our Shareholders > Insider Trading and Stock Tipping<br />
that company’s securities is material, nonpublic information, and<br />
you should not, until after the information has become public:<br />
– buy or sell the security; or<br />
– recommend that anyone else buy or sell the security. If you are<br />
unsure whether information could be deemed “material,”<br />
contact the law department in your business unit.<br />
• Do not disclose to any person any material information about<br />
Comcast, our subsidiaries or any other company that you learn<br />
in connection with your service with the Company until that<br />
information is generally available to the public. This includes not<br />
disclosing this information to analysts, shareholders or other<br />
securities market pr<strong>of</strong>essionals.<br />
• Treat decisions relating to investments in Comcast stock through<br />
your 401(k) plan or the employee stock purchase plan the same<br />
way you would treat decisions involving a direct purchase or sale<br />
<strong>of</strong> securities. Accordingly, you should not switch into or out <strong>of</strong><br />
Comcast stock in your 401(k) plan or change your payroll<br />
deduction in the employee stock purchase plan if you are<br />
aware <strong>of</strong> material, nonpublic information about Comcast.<br />
• Maintain the confidentiality <strong>of</strong> proprietary or other important<br />
or sensitive information about the Company and do not convey<br />
information to anyone outside <strong>of</strong> Comcast<br />
unless necessary for your business<br />
activities. You also should maintain<br />
the confidentiality <strong>of</strong> information<br />
that you learn in the course <strong>of</strong><br />
your service about suppliers,<br />
contractors, customers,<br />
companies in which the<br />
Company has an investment<br />
and other third parties.<br />
• If the nature <strong>of</strong> your business activities and your position in the<br />
business subject you to additional requirements relating to buying<br />
and selling securities (such as the preclearance <strong>of</strong> personal trades<br />
or being subject to a blackout policy), learn and follow all <strong>of</strong> those<br />
requirements, and review the Comcast Blackout Period and<br />
Pre-Clearance Policy. In addition, CNBC employees and<br />
employees in the various news divisions <strong>of</strong> NBCUniversal<br />
are subject to additional policies and guidelines.<br />
• If questions arise, consult a Senior Attorney before trading<br />
in the relevant security or disclosing the types <strong>of</strong> information<br />
described above.<br />
WHAT TO WATCH OUT FOR<br />
• Buying or selling a security because you learn information that<br />
you think will make the price go up or down once it is publicly<br />
announced. Even after the information is released to the public,<br />
there must be adequate time for the market to become fully aware<br />
<strong>of</strong> the information before it is considered to be public information.<br />
• Buying or selling a security before a significant Company<br />
announcement.<br />
• Talking to people (both inside and outside the Company) who do<br />
not have a need to know information about what you have been<br />
working on, where you have been traveling on Company business,<br />
or who has visited the <strong>of</strong>fice.<br />
ADDITIONAL RESOURCES IN THE INTEGRITY<br />
SECTION OF YOUR BUSINESS UNIT’S INTRANET<br />
• Frequently Asked Questions<br />
• Blackout Period and Pre-Clearance Policy<br />
• Fair Disclosure Policy<br />
TABLE OF<br />
CONTENTS<br />
STATEMENT<br />
OF INTEGRITY<br />
RESOURCES<br />
FOR EMPLOYEES<br />
WHAT TO KNOW<br />
ABOUT OUR CODE<br />
CODE POLICIES<br />
Talk with your supervisor or visit www.ComcastListens.com to learn more about how to raise a concern. 30