Ethics and Compliance

At WarnerMedia, we are committed to fostering a business environment where fair, honest and respectful dealings with each other, our customers, competitors, suppliers, government agencies and communities are everyone's responsibility. Our unwavering commitment to high ethical standards of business conduct is a core value that is strongly supported at every level of management.

Standards of Business Conduct

The company's Standards of Business Conduct embodies our commitment to running our business according to the highest standards of ethics and integrity.  The Standards of Business Conduct applies to all corporate employees of WarnerMedia, and serves as a model for similar codes of conduct that have been adopted at each of the company's businesses. Offices outside the United States also have adopted standards of business conduct with modifications as appropriate in light of local laws and rules. Our Standards of Business Conduct stress the importance of abiding by the law, being truthful, being transparent in our business dealings, putting the needs of our shareholders and customers first, and avoiding excesses and ethical lapses. More detailed policies on various ethics and compliance topics, such as anti-corruption, information security and social media, provide additional guidance to company employees.

Since business situations can often be complicated or unclear and the laws governing ethics and compliance are numerous, a strong compliance environment needs more than codes of conduct and policies. It also requires training, education, and employee trust. To that end, all new hires who are regular domestic employees receive training on the Standards of Business Conduct shortly after their arrival at the company, and annual ethics and compliance training is also conducted for existing employees. Ongoing efforts in this area include multi-media training programs, as well as multi-faceted awareness campaigns that use a variety of media and print outlets to reach our employees. We have also provided additional training to those employees involved in conducting international business in areas including anti-corruption, data privacy and competition.

Employee Awareness and Non-retaliation

We encourage employees to report any concerns about conduct or incidents that may run counter to our values, and we have a strict policy prohibiting retaliation for concerns raised or reported in good faith. Data from an employee survey in 2010 confirm that our employees know they can report concerns without jeopardizing their status in the company and know who to contact for guidance on ethics and compliance issues. We are also pleased to report that our employees believe that War senior management, as well as their direct supervisors, act with integrity and set high standards of behavior.

Accountability and Enforcement

Enforcement is also key to an effective ethics policy. A Corporate Compliance Review Committee meets regularly to review individual compliance matters for the entire company. The Audit and Finance Committee of the Board is responsible for reviewing and recommending changes to the Standards of Business Conduct for approval by the Board and for overseeing the company's ethics and compliance program. The Audit and Finance Committee also approves the appointment of the company's Chief Ethics and Compliance Officer, who provides the Committee with regular reports on the company's ethics and compliance program.

System of Internal Control over Financial Reporting and Disclosure Controls and Procedures

We also devote substantial resources to our system of internal control over financial reporting and disclosure controls and procedures. Internal control over financial reporting is the process the company has in place to provide reasonable assurance of our ability to record, process, summarize and report financial data. The disclosure controls and procedures are designed to ensure that information required to be disclosed by WarnerMedia in reports filed or submitted by the company under the Securities Exchange Act of 1934, as amended, is recorded, processed, summarized and reported within the time period specified in the Securities and Exchange Commission's rules and forms. Information that is required to be disclosed by WarnerMedia is accumulated and communicated to the company's management to allow for timely decisions regarding disclosures. As part of this effort, specialized training is provided to financial executives and lawyers at the company on these standards to promote consistent compliance with these comprehensive internal controls and procedures.