Activision Blizzard, Inc. (the "Company") has a responsibility for the stewardship of company resources and for fostering the public and investor support and confidence that will enable the Company to achieve its corporate goals. In pursuit of those responsibilities, we are committed to full compliance with all laws and regulations governing our company. We are also committed to operating in a manner that is not merely lawful, but consistent with sound business ethics. We require similar commitments from our employees, contractors, subcontractors, agents and all others who conduct business with us. Those commitments extend to the manner in which we record and report our financial performance and results of operations.
In keeping with those responsibilities, the Audit Committee of the Board of Directors is establishing this policy to enable and encourage the reporting of any conduct that appears to raise ethical or legal concerns in connection with the Company's accounting, internal accounting control, financial reporting or other auditing matters. Any individual who files a report pursuant to this policy shall be protected from retaliation, in connection with the filing of such report, by the Company's Reporting and Non-Retaliation Policy.
This policy is intended to ensure (1) that any report questioning accounting, internal accounting control, financial reporting or other auditing matters is properly received, treated and retained, and (2) all employees and others who deal with the Company have the ability to submit their concerns confidentially, anonymously and without fear of retaliation.
In performing their responsibilities hereunder, the Chief Legal Officer and Audit Committee shall:
Due to certain requirements under data protection laws, the Company may be obligated to inform any person identified in a report of a violation that the report was filed, and how he or she may exercise his or her right to access, correct or suppress the information relating to him or her. However, this right to access information does not entitle the subject of the allegation to information identifying the person who reported the allegation.
Either the Chief Legal Officer or the Audit Committee may retain outside legal counsel, accounting, auditing or other experts to conduct or advise with respect to any investigation or report.
Questions about this policy may be directed to any member of the Audit Committee, the Chief Legal Officer or the Chief Compliance Officer.