Ethics Policy

Introduction

The Scope Of This Policy: These guidelines apply to all members of our company.

The Purpose Of This Policy: The fundamental purpose is to protect the impartiality and neutrality of dearJulius.com and the integrity of its news stories. Every staff member is expected to read these rules carefully and abide by them as they apply to his or her duties.

Compliance With This Code: dearJulius.com takes this code of conduct very seriously. All employees of dearJulius.com 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 dearJulius.com 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. dearJulius.com 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. Please consult with the Talent team if you have any questions on this.

Nothing in this Policy is intended to preclude or dissuade employees from (a) reporting possible or suspected violations of law or regulation to any governmental agency or entity, cooperating with any such agency in an investigation, or making other legally protected disclosures; or (b) engaging in any other legally protected activity, including but not limited to, activities protected under Section 7 of the National Labor Relations Act (NLRA), such as collectively discussing wages, benefits or terms and conditions of employment or raising complaints concerning working conditions.

Financial Disclosures

Disclosure Requirements: Journalists who regularly cover business and financial news (including, but not limited to crypto-currencies) may not play the market: that is, they may not conduct in 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 dearJulius.com 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 dearJulius.com 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 newsmakers, information providers, advertisers or market participants, creating a temptation to violate these rules

Personal Investments: In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of dearJulius.com 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 months 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.

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.

Avoiding Conflict of Interests

Promotion/Links: It is unacceptable for anyone at dearJulius.com 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, those relationships will also be disclosed clearly.

Employees cannot be members of any Board of Directors that would constitute a conflict of interest with The Company. Staff members should disclose information regarding any Board of Directors they are currently on or any they may be contemplating to determine whether a conflict does exist.

Voting and Campaigns: It is not dearJulius.com'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 dearJulius.com to appear to subsidize the activity;
• Do not otherwise violate this code.

All editorial team members as well as 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.

Gifts

The goal of these guidelines is to ensure fair reporting and full transparency for our readers.

Gifts/Freebies:

• Employees may accept gifts/freebies valued at less than $100 as long as: (a) it's a de minimis promotional item or tchotchke (i.e. coffee mug, T-shirt, or umbrella) or (b) has been received as a one-off "thank-you" or other expression of appreciation (i.e. a bunch of flowers or a moderately priced bottle of wine) and not as a quid pro quo. The acceptance of the gifts/freebies should in no way compromise or guarantee editorial coverage of the product/service or use of a vendor / service provider.
• Any item with a value of over $100 must be specially approved by your manager. Items not approved must be returned or donated.
• In general, we cannot accept meals/transportation/services except as specified below for certain shoots. However, use your best discretion: if you are getting a drink with a PR person and they insist on paying, that's a judgment call. Dinner at Per Se, on the other hand, is out of the question.

Product Reviews / Shoots:

• Return products when we can or ask for test items, otherwise products should be donated. In the event that donation is not reasonably possible, products can be kept if approved by your manager.
• Employees cannot accept any gifts/freebies/gift certificates after publishing a story. Donate them or offer to send them back if you see them pop up in the mail.
• Employees may not resell gifted items.

Endorsements:

• Employees cannot accept compensation in exchange for endorsing any companies or products on social media or anywhere, regardless of whether the account is the company account or a personal account.
• Employees cannot accept discounts on products in return for any type of endorsement.
• Endorsements should be based on your honest opinion.

Social media guidelines

Introduction: The attached lays out our policy in detail, but here is a brief overview. The guidelines are simple:

• Use good judgment.
• Remember that almost nothing you post is truly private.
• Remember that you are a professional.

If you want to remember only one thing about social media, it's this:

When you publish on Twitter, Facebook, or other platforms, you are not sharing something with a few "friends" or "followers." You are stepping up to a microphone and making public statements that will be recorded forever and potentially broadcast to everyone on earth.

Most people won't be listening when you first make your remarks or share your pictures or videos. But some will. And if you should ever happen to say or post something particularly provocative or newsworthy or offensive or shocking, millions of others will immediately tune in.

Importantly, it doesn't matter what you meant or what you were thinking when you hit "publish." What matters is what people think you meant. Perception is reality. So use good judgment.

Understand Social Media: In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including to your own or someone else's web log or blog, journal or diary, personal website, social networking or affinity web site (e.g., Twitter, Facebook, LinkedIn, MySpace, Instagram, YouTube and wikis), web bulletin board or a chat room, whether or not associated or affiliated with the Company, as well as any other form of electronic communication.

Know and respect Company policies: Please make sure that you are familiar and comply with this policy and all of the policies in the Employee Handbook, to ensure that your postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful content will not be tolerated and may subject you to disciplinary action up to and including termination of employment.

Be careful what you post: You are personally responsible for what you post. Remember that anything you post may be public for a long time, even if you try to modify or remove it later. The Company disclaims any responsibility or liability for any errors, omissions, loss, or damages claimed or incurred due to any of your electronic communications.

Speak for yourself, not the Company: Your postings should reflect your personal point of view, not that of the Company. If, however, you post about the Company or any of its business contacts, you must clearly identify yourself as a Company employee and be sure to include a prominent disclaimer stating that the views being expressed are your own, not those of the Company.

Be respectful and professional: Always be fair and courteous. If you decide to post complaints or criticisms, avoid using statements that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage your co-workers or business contacts or that might constitute harassment or bullying. Examples of such conduct include offensive posts meant to intentionally harm someone's reputation or posts that could contribute to a hostile work environment on the basis of any characteristic protected by law or Company policy. Please be professional and respectful of others in your communications, show consideration for others' privacy and refrain from posting statements, photographs, video or audio that are false, misleading, obscene, defamatory, threatening, harassing, fraudulent, discriminatory, or invasive of the privacy of others. Note, however, that this policy is not intended to preclude or dissuade employees from engaging in activities protected by state or federal law, including the National Labor Relations Act such as discussing wages, benefits or terms and conditions of employment, including discussions regarding forming, joining or supporting labor unions, raising complaints about working conditions or other legally protected activities.

Be honest and accurate: Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered.

Respect laws and confidentiality: Respect copyright, trademark, privacy, financial disclosure, regulatory and all other laws. Do not disclose confidential or sensitive information about the Company, other individuals or business contacts that may have been obtained through your position with the Company, unless you have the right to do so and are taking into account intellectual property and privacy concerns. For example, ask permission before posting someone's photograph, article, or music in a social network or publishing in a blog a conversation that was meant to be private. In accessing or using a social media site, comply with the legal terms or code of conduct governing such site.

Report your concerns: If you feel that an employee of the Company has engaged in conduct that may violate this policy, please discuss your concerns with Human Resources. The Company prohibits retaliation against any employee for reporting concerns under this policy or for cooperating in an investigation.

Plagiarism

At dearJulius.com, as at most journalistic organizations, we have a strong policy against plagiarism.

Fairness

Reporters must seek both sides of the story by providing an opportunity for those subject to negative accusations with an opportunity to respond. Reporters seek to convey accusations in detail and allow a fulsome response.