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Protecting Our Fans,
Customers, and Business
Every day, millions of people welcome our products into their lives. Whether it’s games, esports, or other entertainment, what we do influences and enriches people’s lives. And with great entertainment comes great responsibility.
Fair Sales and Marketing: Be Honest
We make every effort to make sure that what we advertise about our own products – or say about our competitors’ – is clear and true.
Privacy Matters
Many people put their trust in our hands when they give us their personal information. And we honor this trust by making sure that we follow our policies* and applicable laws for handling this information. If you’re ever unsure about this, contact the Law Department.
Product Quality and Safety: Live Up to Our Standards
We take great pride in the quality of our entertainment products, including how we manufacture and distribute them. Our goal is to maintain a supply chain that lives up to our company’s standards for quality and safety. We can only do this by following applicable laws and regulations.
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 section explains how to go about your day-to-day work, including how to deal with company assets, social media, gifts and entertainment in business contexts and conflicts of interest.
Find out more:
If you have questions on the disclosure of confidential information or intellectual property, or you suspect an improper release of confidential information, please contact the Law Department or your information security team right away.
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
Marketing
strategies
Trade
Secrets
Programs
and
computer
code
Financial
information
and business
plans
Personnel
information
Information
shared at
All Staff
Meetings
Internal
metrics
If disclosed, this kind of nonpublic information can be used by competitors or harm our company. Remember, not all confidential information is our information. We must protect confidential information disclosed to us by business partners and third parties, or we risk those relationships and may expose the company to legal liability.
Please try to prevent mistakes before they happen. As an example, you should always handle business-related paperwork, voicemails, texts, instant messages, and emails with care. Use caution when discussing or viewing work in public places such as restaurants, cafés, trains, and airplanes – or even when working remotely from home if you share common space with others. 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; our obligation to protect this information continues even after we’ve left the company. If you have any questions, you can always use the ASK List*.
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. We must protect them from theft, misappropriation, and damage.
Remember that workers 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. Also, you should not use unapproved messaging applications for your work or company business - this includes ephemeral apps (messaging apps in which the messages disappear). The laws may vary depending on where in the world you are working, so it’s really important that you understand the Acceptable Use of Information Technology Resources Policy* that’s applicable to you, as it provides more detail about how and why we monitor. We also have an FAQ* that can help you better understand the policy.
Find out more:
See your applicable information security and data protection policies* for more information. If you see something that isn’t right, please contact the Law Department or your information security team.
Personal Data: Protect It
Do you access personal information about fellow teammates as part of your job? It’s important to protect this information from inappropriate or unauthorized use or disclosure and handle it according to our company policies and procedures as well as the privacy and data protection laws (whether local or international) that apply to your work.
Social Media: Be Transparent and Think Twice
Do you want to write something about our company, our products, the gaming industry, or anything else related to us on your personal social media channels? Per our Social Media Policy*, make sure you:
- disclose your relationship with our company
- make it clear that you’re expressing your own opinion
- consider whether your post could be taken out of context
- be careful not to share any confidential informationThis does not prevent you from freely talking about things protected by law, for example, the right of employees in the United States to talk about wages, hours, or other terms and conditions of employment.
- and most importantly, use common sense!
If you post on social media on behalf of the company as part of your job, remember there are additional guidelines in the Company Sponsored Social Media Policy* that you need to follow. For example, regardless of whether your posts on social media are on behalf of the company, remember that you are still expected to Respect Each Other and to Act with Integrity online, just like in your in-person interactions.
In the event of a crisis or sensitive situation, do not speculate or share unverified information. Direct any inquiries to the designated company spokesperson.
What’s the Right Way2Play?
Consider this scenario:
“One of my colleagues posts a lot on social media, and they’ve recently been promoting one of our new games. I’ve started to see a lot of negative talk about one of our competitors in the threads, and they’re sharing statistics and data that I know are false. Is this an issue?”
The Right Way2Play:
“Yes. We should never misrepresent information about our competitors, so it’s important you notify someone on the ASK List* about this issue. When we post about our industry, it’s also important to use #viewsaremyown and disclose your affiliation with the company according to the policy. To learn more about these guidelines, check out the Social Media Policy* and the Company-Sponsored Social Media Policy*.”
“I’m proud to be a Way2Play Hero to help foster an open and inclusive workplace culture for all of us. I may not have all the answers, but I’m here to listen and point people in the right direction if they ever have a concern.”
- Adrian Ledda, Head of Inclusive Game Design; Way2Play Hero
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. And remember that if you are providing a gift or entertainment to a public official, you must obtain prior written approval regardless of its value. So whether it’s a laid-back dinner, tickets to a game or an expensive gift, always check the Gifts & Entertainment* and Anti-Bribery & Anti-Corruption Policies* to find out what’s okay before you act. Remember to use the ASK List* if you’re in a tricky spot or aren’t sure what to do.
Conflicts of Interest: Avoid Conflicts that May Hurt Our Business
A "conflict of interest" can arise any time our personal interests conflict with - or even simply just appear to conflict with - the interests of the company. We each have an obligation to refrain from engaging in any activity or having a personal interest that presents a “conflict of interest” and should seek to avoid even the appearance of a conflict of interest. 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.
What’s permitted and prohibited under this section will vary based on your working relationship with the company (i.e., employee, contingent worker, consultant). This is why it’s important to reach out for guidance if you are unsure about a potential conflict of interest.
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 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. Employees can find the appropriate ways to disclose potential conflicts and obtain guidance here*. Questions about whether a situation may present a potential conflict that needs to be disclosed can be submitted to the Way2Play Team.
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 relationships with co-workers
We understand that personal relationships sometimes occur in the workplace. While we would prefer not to be involved in employees’ personal lives, some relationships (including relationships between People Leaders and those that they supervise) could present a conflict of interest – please see the 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
If you are considering creating, developing, or working on a video game project in your spare time, these must be disclosed via the appropriate Side Project Process before you begin any work. This includes open source, modification, and game engine projects as well as new games, including those you are working on as a hobby.
All employees should disclose these side projects through the Way2Play Portal*.
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 any of the scenarios mentioned above - or any other situation that may create a conflict of interest, or the appearance of a conflict of interest, you should disclose the potential conflict* and obtain guidance. 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.
What’s the Right Way2Play?
CONSIDER THIS SCENARIO:
“A buddy of mine reached out for help on a new game he’s thinking of developing. I don’t think it would interfere with the work I’m doing at my studio. In fact, I mentioned it to my boss, and they said it sounded cool. Do I still need to get official approval?”
THE RIGHT WAY2PLAY:
“Yes. This is a great example of when you should refer to the Side Projects process. In this case, it sounds like you completed Step 1, but you still need to fill out the online form and wait for an official response before getting started. If your project is time sensitive. you can email Way2Play@activisionblizzard.com to ask for an expedited review.”
Remember, the Code of Conduct is not intended to prohibit or infringe on an employee’s rights to discuss wages, hours, working conditions, or other terms and conditions of employment or to otherwise engage in protected concerted activity under Section 7 of the National Labor Relations Act.
THE ASK LIST: WHERE YOU CAN GO FOR HELP
The ASK List* is your key go-to resource. It’s a list of people and resources that you can turn to if you have questions, need some advice, or want to report something. You can choose whatever channel or resource makes you the most comfortable. No matter the circumstances, you can reach out to anyone on the ASK List:
- Your manager
- Another manager you trust
- Any member of the Way2Play Team directly or at way2play@activision.com
- Any member of HR (or you can reach HR at 877-225-4702 within the U.S. or at HR@activision.com from anywhere in the world)
- Any member of the Law Department
- The Integrity Line (1-877-WAY2PLAY or 1-877-929-2752) within North America or way2play.ethicspoint.com from anywhere in the world
You can always reach out to your Way2Play Heroes* for guidance about your reporting options.
We want you to understand more about the Integrity Line so you can decide if it is the right option for you. The Integrity Line is a confidential website and telephone line, operated by an external third-party vendor, which allows you to report concerns 24 hours a day. If you prefer, the Integrity Line allows you to report concerns anonymously. However, providing your name allows us to contact you directly, while still protecting your confidentiality to the extent possible; it also allows us to ask you for further information as we investigate your concerns and may impact our ability to respond and expedite the time it takes us to do so.
You can reach the Integrity Line by:
Telephone:
- North America 1-877-WAY2PLAY (877-929-2752)
- Global
- Australia 1800 161 117
- Brazil 0800 000 0474
- China (Mainland) 4001200531
- France 0 805 62 01 53
- Germany 0800 1819538
- Ireland 1800851838
- Japan 0120-406-357
- Malta 8006 5047
- Mexico 8006815321
- Netherlands 0800 0229506
- New Zealand 0800 420 067
- Poland 800005301
- Singapore 8004922537
- South Korea 00798 14 203 0354
- Spain 900838616
- Sweden 020 089 00 22
- Taiwan 00801-49-1714
- UK & Northern Ireland 0800 046 550
Reports submitted through the Integrity Line are automatically directed to members of the Way2Play Ethics & Compliance team and may be escalated as appropriate.