Code of Ethical Responsibility

The Code of Ethical Responsibility is divided into two parts. The Code of Ethical Responsibility for the Company, outlining Condé Nast Holdings Limited's responsibilities and commitments as an organisation, and The Code of Ethical Responsibility for the Employees, setting forth their responsibilities. These are statements of principle. For additional details about how the principles are applied or if you want to discuss a possible breach of the Code, you should consult with your supervisor, the Human Resources department in your company or your company President.

You may also communicate by sending a message to ethics@condenastint.com where any issues will be treated with sensitivity and discretion.

Ethical Responsibilities of the Company

1. Respect for the Law The company will respect the law in the countries and in the legal jurisdictions where it operates.

2. Honest and Ethical Business Conduct The company will conduct its business in an honest, fair and ethical manner. This applies to its interaction with all those affected directly and indirectly by the company's activities, including: employees, customers, readers, users, advertisers, business partners, suppliers and external organisations and agencies.

3. Fairness to Employees The company will treat its employees honestly, fairly and with respect and courtesy

4. No Tolerance for Harassment The company is committed to providing a workplace free of bullying and harassment, whether sexual harassment or any other type of abuse. Bullying and harassment will not be tolerated.

Harassment may involve conduct of a sexual nature (sexual harassment). This can include any unwanted physical (e.g. touching), verbal (e.g. sexual remarks or propositions, suggesting the submission to or rejection of sexual advances will influence employment related decisions) or non-verbal conduct (e.g. unwelcome sexual advances or the display of pornographic or obscene material). The company will investigate any claims of harassment or abuse and will take remedial measures if necessary.

5. Equal Opportunites The company will provide equal employment opportunities to employees and applicants without regard to race, colour, religion, age, gender, sexual orientation, disability national origin, marital status or any other characteristic which is protected by the laws and regulations to which Condé Nast International is subject.

6. A Safe Workplace The company will maintain a safe workplace. All relevant health, safety, environmental and labour laws will be observed.

7. Employee Privacy The company will respect the privacy and confidentiality of employees' personal information, acquiring and retaining only the data which is necessary for the effective operation of the company or for legal purposes.

8. Customer Data Customer data will be employed correctly. The company will treat and use customer data in accordance with applicable laws and regulations and with accepted business practices.

9 .No Tolerance for Corruption Bribery, kickbacks and corrupt practices will not be tolerated on any level. Guidelines relating to the giving of gifts are set forth in the Anti-Bribery Compliance Policy, which is available on the Condé Nast International's intranet.

10. Contribution to the Community Condé Nast International will strive to make a positive contribution to the markets and communities which are served by its products and services.

11. Intern Policy The policy of treating employees honestly and fairly, and in a respectful and courteous manner, applies also to interns. Working conditions and compensation for interns must conform to the laws and regulations of the country or community where they are interning.

Ethical Responsibilities of the Employee

1. Professional Responsibility Employees shall carry out their professional responsibilities to the best of their abilities and making their best efforts.

2. Conflict of Interest Employees should avoid situations where their personal interests could come into conflict with the interests of Condé Nast International. If a conflict of interest arises, then it should be discussed with management and an effort made to eliminate the conflict.

3. Improper Benefit Employees should not use company property, information or their position in the organisation for personal gain.

4. Working a Second Job Working at a second job or for an external organisation -- including other media, advertisers or suppliers -- is not permitted without the permission of management, unless the country or local regulations prevent Condé Nast International from requiring such permission. In the latter case, the employee is expected to disclose the external job to company management.

5. Risk to Reputation Employees should not take any action or behave in a way which brings harm to the reputation of Condé Nast International.

6. Gift Policy A gift which comes to an employee of Condé Nast International is considered a gift to the company, not to the individual, with the exception of perishable goods like flowers and artisanal foods. Employees are forbidden from soliciting gifts. The management of the company shall decide upon the disposition of any gifts. Giving the gifts to charity or selling them in order to raise money for charitable cause is encouraged.

7. Professional Discounts Some designers and retailers offer a discount to their professional associates, commonly called a "trade discount". Employees are permitted to accept a normal professional discount if it is offered, provided that it is not offered in order to obtain a business advantage or in exchange for favours or benefits. The discount must be offered openly, not secretly. An employee may not purchase an item using a trade discount with the intention of reselling it at a profit.

8. Journalistic Accuracy Employees, especially journalists and editors, should make all reasonable efforts to ensure that information and content is reported honestly, accurately and fairly.

9. Respect for Property Employees should protect company assets against theft, damage, carelessness, waste and misuse, and should respect the property of others.

10. Confidentiality Employees should only share confidential information with other employees or authorised persons who have a legitimate need to receive it. "Confidential information" includes not only information which has been explicitly designated as confidential but also information which one can reasonably expect should be regarded as confidential. Company management can decide and direct an employee to share information when it is appropriate to do so. The instruction not to share confidential information applies to sharing information even with one's family and friends.

11. Electronic Communication Employees must adhere to their company’s policy regarding electronic communication and online activity on company-controlled systems.

These codes are a guide to ethical behaviour by the company and by its employees. They should be regarded with seriousness and followed. These codes may not address every business, personal or ethical question which arises. When there is a question or doubt, the principles of honesty, fairness and respect for others can be considered a general underlying foundation for ethical policy.

January 2018