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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

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