Code of Ethics

Ethical Policy for Production Companies

Purpose and Overview

INTEGRITY MATTERS.

Conducting our work ethically sends a strong signal to our audiences and business partners. By making the right choices, we protect our reputation and help ensure that our productions can thrive.

This policy addresses compliance with laws and regulations, adherence to production policies, promotion of integrity and standards of conduct, and the prevention of inappropriate behavior within our organization.

Who Does This Policy Apply To?
This policy applies to everyone working for our company or involved in any of our productions, including executives, cast, crew, talent, and others. It applies to all work-related activities and to anyone representing our company.

As part of our productions, you are responsible for:

Acting with integrity, particularly when making difficult decisions;
Familiarizing yourself with this policy, applicable laws, and policies relevant to your role and work location;
Completing required training in a timely manner;
Staying informed about our standards and expectations;
Seeking guidance when you are unsure how to act appropriately;
Promptly reporting concerns about behavior that may violate this policy, other production policies, or the law—do not investigate on your own; and
Cooperating fully and truthfully if an investigation is required.

Additional Responsibilities of Managers
If you manage or supervise others, you have additional responsibilities, including:

Leading by example every day;
Seeking help and guidance when needed;
Supporting your team by answering questions and listening to concerns;
Creating a safe work environment where people feel comfortable speaking up;
Listening to and responding to concerns when they are raised;
Knowing when and how to escalate concerns to the appropriate department, such as People & Culture, Legal Affairs, or another safety team;
Ensuring that no retaliation or negative consequences result from raising a concern or complaint; and
Discussing with your team how this policy should be followed in practice.
Violations of this policy, other production policies, and/or local laws may result in disciplinary action, including termination of employment, recovery of financial damages, or criminal prosecution.

Compliance with Laws and Regulations
We strive for full compliance with all laws and regulations applicable to our productions. Use good judgment in your work and seek assistance when needed. If in doubt, consult your People & Culture department.

Making the Right Choices
You are not alone when faced with difficult decisions. Resources are available to help you.

Ask yourself:

Is my action consistent with this policy, other policies, and high ethical standards?
Could my action be illegal?
Would I be comfortable if senior management at Warner Bros. Discovery knew about it?
Would I be comfortable if my family or loved ones knew about it?
Would I be comfortable if my decision or actions were made public?
Is this action right for the company’s reputation—and for my own?
If you answer “No” or “I’m not sure” to any of these questions, contact the People & Culture team immediately.

Asking Questions and Raising Concerns
Seek advice if you are unsure what the right course of action is, and report concerns involving legal or ethical issues.

In such cases, we ask that you:

Contact the People & Culture department or the Legal Affairs department; and/or
Contact the Warner Bros. Discovery Ethics Hotline (the “Hotline”) toll-free at +1-800-398-6395 or via wbd.ethicspoint.com. The website lists free phone numbers for all locations where Warner Bros. Discovery operates. Anonymous reports may be made where permitted by law. You may also contact the Warner Bros. Discovery Safety Hotline at +1-877-566-8001 or visit www.safetyontheset.com.
We will ensure that all questions and reports are handled appropriately. Reports made outside the United States may be subject to the laws of the country in which the reporter works.

All reports, including anonymous reports, will be handled in accordance with applicable privacy regulations and other relevant laws.

Cooperation with Investigations and Audits
We take all allegations of misconduct seriously and may conduct investigations to eliminate misconduct from the workplace, minimize its impact, and take corrective action where appropriate.

All employees are expected to cooperate fully with internal and external investigations, audits, and inquiries when required.

Remember:

Never destroy, alter, or conceal documents (including text or chat messages) in anticipation of or in response to an investigation request;
Never provide incomplete, false, or misleading information to an investigator, or attempt to influence others to do so.

Our Policy Against Retaliation
We do not tolerate retaliation against anyone who, in good faith, seeks advice, raises concerns (including formal complaints) about potential violations of this policy, other production policies, or the law, or participates in an investigation.

Raising a concern in good faith means making a sincere effort to provide honest, complete, and accurate information, even if it later turns out to be unfounded or incorrect.

You may also communicate in good faith with a government authority regarding a potential violation of the law.

A government authority includes any national, regional, or local government agency or commission that enforces workplace laws, rules, or regulations.

Whistleblower Position
When communicating with a government authority, you may:

Report a potential violation of the law;
Participate in an investigation or proceeding conducted by a government authority, including by providing documents or other information; or
File a charge or complaint with a government authority.

Diversity, Equal Opportunity, and Non-Discrimination
We strive to maintain a workplace where everyone is treated fairly, respectfully, and given equal opportunities. We are committed to fostering a diverse and inclusive work environment.

The company provides equal employment opportunities and prohibits discrimination based on legally protected characteristics.

We provide reasonable accommodations where required for qualified individuals with known disabilities or in other circumstances as required by local law.

Safe and Healthy Work Environment
A safe work environment is fundamental to everything we do. Everyone is responsible for acting safely to protect themselves and others. Any situation that may pose a risk to health, safety, or the environment must be reported immediately. You may contact the Warner Bros. Discovery Safety Hotline at +1-877-566-8001 or visit www.safetyontheset.com.

Alcohol and Drug Misuse
While working or performing production-related activities—including off-site or after-hours events (such as premieres, finales, wrap parties, and holiday events)—you may not use, possess, or be under the influence of illegal drugs or substances that could impair a safe and effective work environment or harm our reputation.

When alcohol is served at work-related events, you are expected to consume responsibly and refrain from drinking if it could lead to inappropriate behavior, negatively affect performance, compromise safety, damage our reputation, or violate the law.

Serving alcohol at a work or production event on a Warner Bros. Discovery location (such as the Studio Lot) requires prior approval from the People & Culture team.

Workplace Violence
Violence of any kind will not be tolerated, including but not limited to:

Intimidating or hostile behavior;
Causing, threatening, or attempting to cause physical harm to a person’s life, health, well-being, family, or property;
Vandalism, arson, sabotage, or other criminal activity; and
Possession of weapons unless properly licensed, approved by production management, and lawful.
Remember to:

Comply with our harassment and workplace violence policies to ensure a safe, ethical, and professional workplace;
Speak up, if it is safe to do so, when a colleague’s behavior makes others uncomfortable;
Report sexual harassment, including requests for sexual favors or other unwelcome verbal, visual, or physical conduct of a sexual nature;
Behave professionally and avoid inappropriate websites or sexually explicit or offensive material;
Follow all applicable safety, security, and health rules and practices;
Immediately report unsafe equipment or conditions to your manager and the People & Culture team, or contact the Safety Hotline.

Harassment-Free Workplace
We do not tolerate harassment or other offensive behavior. Unwelcome conduct is unacceptable.

Harassment is defined under local law but generally refers to unwelcome verbal or physical conduct directed at a person’s characteristics that violates their dignity, interferes with performance, or creates an intimidating or hostile environment.

While we recognize that certain content in the entertainment industry may differ from other sectors, we do not tolerate the sharing of sexually explicit or similar material with colleagues based on gender, race, sexual orientation, or other personal characteristics. If you feel uncomfortable with discussions or activities related to the creation, production, or distribution of our content, you may raise this with the People & Culture team.

Sexual harassment commonly occurs when:

Submission to unwelcome conduct becomes a condition of employment or is used as the basis for employment decisions; or
An intimidating, offensive, or hostile work environment is created through unwelcome sexual advances, jokes, or other verbal or physical conduct of a sexual nature.

Respect for Human Rights
We respect the human rights and dignity of everyone and comply with all laws that promote and protect human rights and prohibit slavery and human trafficking. Any suspicion or evidence of human rights violations must be reported to the People & Culture team. This includes promoting diversity, accommodating disabilities, and protecting everyone with whom we do business.

Environmental Responsibility
We are committed to operating in an environmentally responsible and sustainable manner. We comply with applicable environmental laws and regulations and strive to minimize our environmental impact in ways relevant to our business and important to the communities in which we operate.

Financial Records and Disclosure
The integrity of our financial records is essential for compliance with accounting, tax, disclosure, and other legal requirements. Everyone is responsible for ensuring that all production records—such as timesheets, expense reports, and financial statements—are accurate, complete, and honest.

If you have concerns about questionable accounting or auditing matters, contact the Legal Affairs department or the Ethics Hotline immediately. Anonymous reports may be submitted where legally permitted. Retaliation for raising accounting or audit concerns is not tolerated.

Insider Trading
Do not buy or sell securities while in possession of material non-public information (“inside information”), and do not share such information with others for improper purposes. Even informal conversations may be considered illegal tipping. Material information is information that a reasonable investor would consider important in making investment decisions.

Misuse of Funds and Fraud
Everyone is personally responsible for safeguarding company assets and ensuring their proper use. Do not use production assets for fraud, theft, embezzlement, misappropriation, money laundering, tax evasion, or other unlawful conduct. Such actions undermine our integrity, damage our reputation, and expose the company and individuals to serious consequences.

Use facilities, materials, and equipment only for authorized work purposes and report suspicious financial transactions or activities to the production’s legal team.

Gifts and Entertainment
Never give or accept gifts or entertainment that could improperly influence—or appear to influence—business decisions.

A gift includes anything of value, such as meals, entertainment, travel, accommodations, tickets, discounts, services, or privileges. Cash gifts or cash equivalents (including gift cards redeemable for cash) are strictly prohibited.

More expensive gifts increase the risk of a conflict of interest. Legal approval is required for any gift given or received with a value exceeding USD $500 (subject to local law). This limit applies to the total value of gifts exchanged with the same source over a 12-month period.

Even modest gifts can create conflicts, so always consider how they may be perceived. Contact the Legal team for guidance.

Conflicts of Interest
A conflict of interest arises when personal or family interests interfere—or appear to interfere—with sound, objective business judgment. You are expected to act in the best interests of the company and avoid situations that create conflicts.

Common conflict situations include gifts, entertainment, outside employment, financial interests in other companies, and workplace relationships.

Financial Conflicts of Interest
Conflicts may arise if you have a financial interest in a production partner or competitor, especially if you can influence business decisions. Disclose such risks using a conflict of interest form.

Providing Services to Other Companies
Outside work must not conflict with your production role, involve confidential information, or use production resources. Consult People & Culture if unsure.

Examples of potential conflicts include:

Working elsewhere during production hours;
Financial interests in competitors or vendors;
Accepting excessive gifts or invitations;
Selecting vendors with whom you have a personal relationship;
Dating or having a romantic or sexual relationship with another production member;
Using information obtained through work for personal gain;
Influencing employment decisions involving someone with whom you have a personal relationship.

Personal Relationships at Work
To prevent conflicts of interest, disclose any personal relationship involving someone engaged with the company if:

You can influence their employment terms, promotion, or hiring; or
You can influence whether the company engages with a specific party.
If unsure, seek guidance from the Legal team and follow company procedures for resolving potential conflicts.

Anti-Bribery and Anti-Corruption
Bribery in any form—whether involving private individuals or government officials—is strictly prohibited. This includes actions by third parties acting on our behalf.

Bribery involves offering, giving, receiving, or soliciting anything of value to improperly influence another’s actions. This includes money, gifts, facilitation payments, charitable donations, services, or favors.

Legal approval is required before:

Offering anything of value to a government official;
Doing business with a government official;
Engaging agents or third parties who may interact with government officials.
A government official includes employees of government bodies, state-owned entities, international organizations, elected or appointed officials, royalty, and political candidates.

Be alert to corruption red flags, especially when working with agents, including requests for cash payments, excessive commissions, incomplete invoices, or claims that payments are needed to “get things done.”

Antitrust and Fair Competition
We support free and fair competition. Antitrust laws are complex, so consult the Legal team when in doubt.

Do not:

Discuss pricing, hiring, bidding, or market allocation with competitors;
Take actions solely to exclude competitors unfairly;
Share or obtain confidential competitive information improperly.
Report suspected violations immediately.

Confidential Information and Intellectual Property
Confidential information includes all non-public information related to the production or company. Protect it, limit access, and use it only for authorized purposes. Respect third-party confidential information and intellectual property.

Confidential information and IP remain protected even after your engagement ends.

Examples include:

Show and film concepts, titles, and content;
Brands, logos, trademarks, and copyrights;
Business and marketing plans;
Methods, systems, software, and technology.
Consult Legal Affairs with any questions or suspected infringements.

Piracy
Piracy—including unauthorized streaming, downloading, uploading, or copying of copyrighted content—is illegal and a violation of this policy, subject to disciplinary action up to termination.

Data Privacy
Follow all applicable data protection laws and company policies when collecting, using, storing, sharing, or deleting personal information. Share personal data only for legitimate business or legal purposes.

Personal information includes identifiable data such as contact details or date of birth, and sensitive data such as financial, health, identification, or children’s information.

Public Communications
To ensure consistency, only authorized individuals may speak on behalf of the production. Do not engage with journalists or external inquiries without prior approval and guidance from the production’s Legal team.

Social Media Use
Do not imply you are speaking on behalf of the company or production unless authorized. Use intellectual property only with permission. Be transparent about your role and include a disclaimer stating that your views are your own.

Do not post or share sensitive information. If unsure, contact Legal Affairs.

Political Activities
You may participate in personal political activities on your own time. Do not imply that your personal views represent the production or company, and do not use production resources for political purposes without authorization.

Production Assets and Property
Be vigilant against theft, fraud, waste, and misuse of production resources, including budgets, facilities, equipment, and information systems.

Remember:

Never use production resources for unlawful or inappropriate activities;
Use budgets only for authorized production purposes;
Protect equipment, systems, and passwords;
Do not create, store, or transmit illegal or offensive content;
Do not leave devices containing company data unattended.

Conclusion
This policy is not intended to limit rights protected under Section 7 of the U.S. National Labor Relations Act or comparable local laws, including discussions about wages, hours, working conditions, health, and safety. This policy supplements existing policies and may be amended at any time.

Contact
Marjanne Wolters
People & Culture Partner
Marjanne.wolters@wbitvp.nl
+31 6 25191086

You may also contact the Warner Bros. Discovery Ethics Hotline at wbd.ethicspoint.com or +1-800-398-6395, or the Safety Hotline at +1-877-566-8001.