PROTECTING OUR COMPANY

We create great entertainment for millions of people. To continue creating products for our fans and customers – and ourselves – we need to keep doing business the right way. This chapter explains how to go about your day-to-day work, including how to deal with company assets, unsolicited ideas, social media, gifts and entertainment in business contexts and conflicts of interest.

CONFIDENTIAL INFORMATION
AND INTELLECTUAL PROPERTY: PROTECT IT

One of the most valuable assets at the company is our intellectual property and confidential information. And we all share the same responsibility to protect this information and keep it confidential.

Confidential information can take many forms, including:

Information about new products and designs

Programs and computer code

Trade secrets

Marketing strategies

Financial information and business plans

Salary and personnel information

Information shared at All Hands Meetings

Internal metrics

If disclosed, this kind of nonpublic information can be used by competitors or harm our company. We also have to remember that not all confidential information is our information. We need to protect confidential information disclosed to us by business partners and third parties, or we risk our relationships with them and may expose the company to legal liability.

Please always be proactive and try to prevent mistakes before they happen. As an example, you should always handle business-related paperwork, voicemails, and emails with care – and use caution when discussing or viewing them in public places such as restaurants, cafés, trains and airplanes. If you need to share such information as part of your job, always use company-approved tools to do so.

Remember, we all signed agreements relating to our company’s proprietary information, and our obligation to protect this information continues even after we’ve left the company. If you have any questions, that’s what the ASK list is for.

Physical assets and information systems: use them wisely

Every day we use our company’s physical assets and information systems. These can be electronic equipment, facilities, funds, email, the intranet, or other company property. Whatever they are, it’s important we treat these assets responsibly, professionally and in line with company policies. And protect them from theft, misappropriation, and damage.

Remember that employees can’t expect privacy when they use company information systems – our company may monitor the use of our IT systems, equipment and networks, and the activity and content of traffic on them – at any time, unless prevented by any applicable law. The laws may vary depending on where in the world you are working, so it’s really important that you understand the Electronic Communications Systems Use Policy applicable to you, as it provides more detail about how and why we monitor.

GIFTS AND ENTERTAINMENT: BUILD RELATIONSHIPS THE RIGHT WAY

Are you in contact with business partners or people seeking to do business with us? It’s important that you know how to deal with gifts and entertainment. Offering or accepting gifts or entertainment can cloud judgment and influence business decisions. Even if you think you aren’t going to be influenced, the mere appearance of being improperly influenced is a serious risk. So whether it’s a laid-back dinner, tickets to a game or an expensive gift, always check the Gifts & Entertainment Policy to find out what’s okay before you act. Remember that the ASK list is there if you’re in a tricky spot or aren’t sure what to do.

CONFLICTS OF INTEREST: AVOID CONFLICTS THAT MAY HURT OUR BUSINESS

Each of us has an obligation to always do what’s best for our company. While that sounds obvious, it can be trickier than it seems. A “conflict of interest” can arise any time our personal interests conflict with - or even just appear to conflict with - the interests of the company. We are all responsible for avoiding these situations. And the most important thing to remember if you come across a potential conflict is to disclose it. Often, a potential conflict can be worked out.

Before we get to examples of potential conflicts of interest we might face, here are some general questions you should ask yourself to help you understand whether or not a situation you are facing might create a conflict of interest.

Could this activity or situation lead me to make a choice that benefits myself, my friends or my family at the expense of the company?
Could this activity or situation negatively impact my ability to do my job?
Could this activity or situation potentially harm the company?
Could this activity or situation embarrass the company or me if it showed up on the front page of a newspaper or blog?
Is this activity potentially competitive with the company’s business?
Would it, or could it, appear that I am putting my best efforts towards my own projects, as opposed to the company’s projects?

If the answer to any of these questions is “yes”, the relationship or situation is likely to create a conflict of interest, and you should avoid it. If you have any question as to whether or not a situation is likely to create a conflict of interest, the most important thing to remember is to ask about it right away.

Check out some examples of potential conflicts of interest:

Working with family and friends

Are you thinking about hiring or referring a relative or someone you have a close personal relationship with for a job at the company? Or are you already working with them? Or perhaps someone close to you is working with or for a competitor, supplier or another business partner of our company? This could be a conflict of interest – please see the Personal and Family Relationships at Work Policy.

Personal and Family Relationships at Work Policy

Outside employment or other outside activities

No matter the purpose, whether it’s paid or not, outside employment or an outside activity can create a conflict of interest if it has the potential to compete with our company, interfere with your job or damage our reputation.

Side projects or inventions

Are you thinking about creating or developing something in your spare time? Just make sure that it doesn’t overlap with or potentially compete with our company’s business. Remember, we all signed agreements relating to our company’s proprietary information. Please, find out more below about your local process for review of independent projects before you start working on your project.

Side project process

At Blizzard: the side projects process.
At King: the outside interests process.
And everywhere else: the online conflict of interest process.

How to report a Side Project:

Step 1. Talk to your manager or your HR partner.
Step 2. Fill out the applicable form.
Step 3. Wait for an official response before you get started.
Step 4. Keep us updated if the situation changes.

Financial interests or investments in other businesses

Having a business interest in a current or potential competitor or business partner, such as providing a loan to, investing in or taking ownership in them, may cause a conflict of interest.

Board memberships / participation

Serving on the board of directors of an outside company, even if that company doesn’t do business or compete with us, can still create a conflict of interest.

Corporate opportunities

A conflict of interest can arise if you’re pursuing, or assisting a friend or family member in pursuing, a business or investment opportunity that you discovered while using company property or information.

In each of these situations, the rule is the same – if you are considering entering into a situation that creates a conflict of interest, don’t. If you are in a situation that may create a conflict of interest, or the appearance of a conflict of interest, submit a conflict of interest inquiry. Finally, it’s important to understand that as circumstances change, a situation that didn’t present a conflict of interest before may present one now or later.

Remember. The ASK list is your go-to if you have questions.

We’ve updated our Privacy Policy. You can view the revised policy here. By continuing to use Activision’s websites, products or services, you acknowledge this revised Privacy Policy.