At Conde Nast, the core values driving our mission are creativity, passion , innovation, empowerment, collaboration, and integrity. Together we stand united on a foundation of quality. To continue to build and maintain that unity, we are committed to an environment characterized by dignity and mutual respect, in which each one of us acts ethically and with integrity. Our reputation is our greatest asset, and maintaining it requires that each of us- without exception-consistently follows these principles.

This Code of Conduct is the embodiment of our principles. It contains the guidelines and standards that enable us to support our mission and adhere to the laws governing our industry.

It's important that we all carefully read this document, understand how the standards apply to each of us and to those with whom we work, and comply with its rules and spirit. If you encounter any situation you believe might violate these standards, or if you have any concerns about business practices oi- possible misconduct, you should speak to a trusted member of the management team or to The People Department. Conde Nast strictly prohibits any form of retaliation against anyone who reports a possible violation of this Code of Conduct or assists in the investigation of such a report.

Adherence to our principles is essential for the continued success of our company. With your help, we can maintain our strong integrity. Thank you for furthering our mission.

Our Values

Everyone working at Conde Nast must treat others with dignity and respect. To support our core values of creativity, passion, innovation, empowerment, collaboration, and integrity, all work done for Conde Nast must be performed in a professional and ethical manner, adhering to our Employee Code of Conduct and all applicable laws. Any behavior or business practice that violates this Employee Code of Conduct or applicable laws is unacceptable.

General Guidance

The success of our business depends upon the trust and confidence we eam from our employees, customers, readers, and business partners. We engender respect by adhering to our commitments, treating others with dignity, and operating ethically.

• Our Employee Code of Conduct applies to employees' conduct at Conde Nast (the "Company"),as well as to employees' dealings with external stakeholders, such as government agencies, vendors, suppliers, advertisers, readers, customers, and members of the general public.

• Our Code provides general principles to guide us and is not intended to address every specific situation. Employees are encouraged to seek advice and/or guidance on any issue from a trusted member of the management team or to The People Department as needed.

• Employees are expected to exercise good judgment and to perform their work with honesty and integrity at all times, whether or not the situation is specifically addressed in this policy.

Policy Prohibiting Harassment

The Company maintains a professional working environment for all employees, free of any form of discrimination or harassment. Inappropriate conduct toward others that is based on an individual's race, color, religion, national origin, ancestry, sex (including pregnancy), age, marital or domestic-partnership status, disability, perceived disability, genetic information (including the refusal to submit to genetic testing), predisposing genetic characteristics, veteran status, military status, domestic-violence -victim status, sexual orientation, gender identity or expression, and/or any other characteristic protected under applicable federal, state, or local laws will not be tolerated. Such conduct may result in disciplinary action up to and including termination.

Unacceptable conduct includes, but is not limited to:

• Suggesting, directly or indirectly, that submission to or rejection of sexual advances will influence employment-related decisions;
• Display of objects or pictures of a sexual nature;
• Display of pornographic, obscene, or sexually explicit material;
• Unwelcome sexual remarks, advances, propositions, touching, or other physical contact;
• Repeated unwelcome requests for social engagements;
• Leering or staring at, or comments about an individual's body or appearance;
• Threatening or profane language;
• Verbal abuse; racial or ethnic slurs or jokes; pranks; or other conduct that may be considered unacceptable and/or offensive to others; and/or
• Fighting with, assaulting, or injuring another person.

Harassment Or Discrimination Complaint Procedure

If you feel harassed or discriminated against, you may tell the offender, regardless of their position in the Company, that the behavior is unacceptable and ask the person to stop. The Company recognizes, however, that this is not always possible or effective, and employees are not required to do so before making a complaint. Please do not assume the Company is aware of what is happening. Managers and supervisors are required to report any complaints of harassment or discrimination, or any observation of potentially harassing or discriminatory behavior in the workplace , to the People Department.

If you believe you have been subject to harassment or discrimination, immediately notify your supervisor or manager, any other supervisor or manager with whom you feel comfortable, a department head or the People Department. If the complaint involves your supervisor or manager, please do not go to them but instead contact a People Department representative. Additionally, if the complaint involves a vendor or other party doing business with the Company, report the incident to a trusted member of the management team or to The People Department.

You may also submit a harassment or discrimination complaint in writing. To obtain a complaint form, please contact the People Department.

The Company strictly prohibits any form of retaliation against an employee who lodges a complaint or assists in the investigation of a complaint.

Reports of harassment and/or discrimination will be investigated promptly, in the most confidential manner possible. A People Department representative will conduct a fair, timely and thorough investigation of each complaint on behalf of the Company to determine the nature of the conduct reported, whether it constitutes harassment and/ or discrimination, and make a decision as to whether appropriate disciplinary or remedial action is warranted.

If any party directly involved in a harassment or discrimination investigation is dissatisfied with the outcome or resolution of that investigation, they may ask the Chief People Officer to review the decision.

This anti-harassment policy applies to all employees, supervisors . managers, corporate executives, vendors, contractors, freelancers, service representatives, and others conducting business with the Company . Additionally, the actions of Company vendors are covered by the Conde Nast Vendor Code of Conduct, which can be found on Connect. The Company considers harassment, discrimination, and retaliation to be serious offenses, and any person who violates this policy will be subject to immediate remedialaction, up to and including termination

External Resources

In addition to violating Company policy, harassment, discrimination and retaliation are also prohibited by state, federal, and, where applicable, local law. In addition to the internal complaint procedures outlined above, employees may also choose to pursue legal remedies in state or federal court or with administrative agencies, which have the authority to award various forms of relief. Employees may obtain more information about pursuing legal remedies by contacting the following governmental entities:

• United States Equal Employment Opportunity Commission (EEOC) (enforces federal anti-discrimination laws, including Title VII of the 1964 federal Civil Rights Act (codified as 42 U.S.C. §2000e et seq.); www.eeoc.gov
• New York State Division of Human Rights (DHR) (enforces The Human Rights Law, codified as N.Y. Executive Law, art. 15, § 290 et seq.); www.dhr.ny .gov
• New York City Commission on Human Rights; www.nyc.gov/html/cchr/htm Vhome /home.shtml
• If you are subject to conduct that could constitute a crime (e.g., coerced physical confinement or coerced sex acts), you may also contact the local police department.

Perosnal Relationships

Conde Nast prohibits romantic or sexual relationships between a manager or other supervisory employee and an employee who reports directly to or is in the reporting line of the manager or supervisor. If you have any questions about this policy, please contact The People Department.

Our Guiding Principles of Ethical Business Conduct

In order to create and sustain a culture in which we act ethically and in accordance with applicable laws, employees must adhere to the following principles of business conduct:

• Act with integrity. We must all be trustworthy, honest, and respectful in our relationships with customers, readers, suppliers, third parties, and any government or political entity.

• Comply with applicable laws, regulations, and policies. We must adhere to all laws and regulations that apply to our business. If you are unsure whether a contemplated action is permitted by law or Conde Nast policy, please seek advice from a trusted member of the management team or a People Department representative. Be aware of and be sure to follow all applicable laws, regulations, and policies, including but not limited to policies regarding:

• Anti-bribery and anti-corruption (refer to the Company's Anti-Bribery Policy on Connect for details);

• Insider trading or stock tipping ;

• Financial accounting and reporting standards; and/or

• Special requirements for interactions with governments and political organizations.

• Lead by example. Demonstrate integrity through action·s and set the tone for others.

• Foster a professional and supportive work environment at all levels. Promote and nurture an inclusive culture in which everyone feels valued, respected, and safe.

• Protect Company information and assets against damage, loss, theft, and/or misuse. Safeguard and avoid mistreating/misusing or improperly disclosing the Company's assets and resources and ensure their confidentiality, integrity, availability, and efficient use. Abuse of Company assets and resources for personal gain is prohibited. For information regarding the safeguarding of our technology assets, refer to the Company's Cybersecurity Guidelines on Connect. Avoid conflicts of interest. Avoid relationships , activities, or the performance of services that may interfere or even appear to interfere-with the interests of the Com pany, regardless of whether or not third-party financial compensation is involved. Even when no wrongdoing is intended, the appearance of a conflict can have negative effects. Disclose any potential conflicts of interest to a trusted manager or a People Department representative.

• Compete fairly and ethically in the marketplace. Conduct business honestly and fairly. Offering, promising, giving, accepting, or authorizing bribes, kickbacks, and/or improper payments directly or indirectly to any individual, company, or organization is prohibited. Employees should not offer, solicit, or receive anything of value , including gifts and entertainment, if it is intended to exert an improper influence over the recipient.

• Communicate responsibly. The Company is committed to ensuring that communications about its business are accurate, and to protecting its confidential and proprietary information. The Company expects employees to exercise good judgment and common sense when using social media (Linkedln, Facebook, Twitter, lnstagram, Snapchat, etc.) or engaging in any other online activity. Never assume that actions, behaviors, and comments online are private, and take care to protect the Company's confidential and proprietary information. Employees should also ensure that their online activity complies with applicable laws and Company policy, .including the policy prohibiting harassment, as well as the rules set forth by the applicable social media platform.

Communication on Behalf of the Company Only those officially authorized to do so may speak on behalf of the Company. If you have any questions regarding what you can and cannot discuss or share with the press or public, please seek advice from the Chief Communications Officer.

Our Responsibilities

It is the responsibility of each employee to actively ensure that Conde Nast's core values and guiding principles are upheld. Our individual responsibilities include the obligations to:

• Understand and comply with the rules and spirit of the Code of Conduct;

• Promote a professional, respectful, and safe environment that encourages openness and candor;

• Conduct business ethically;

• Comply with all applicable laws, regulations, and Company policies;

• Avoid any conflict of interest (or even the appearance of a conflict of interest) or any activity that violates the law or jeopardizes the integrity of Conde Nast and/or its employees.

At Conde Nast, everyone should feel comfortable to speak their mind. We strive to create an open and supportive environment in which employees feel comfortable raising concerns with respect to conduct. If you have doubts about a situation regarding yourself.a colleague, or a stakeholder, contact any of the available resources listed at the end of this document if necessary. When in doubt, speak up.

Examples of the types of suspected misconduct that should be reported are:

• Discrimination, harassment, and/or retaliation;
• Workplace violence;
• Verbal or physical threats;
• Criminal conduct and violations of law;
• Inaccuracy of financial records (statements, expense reports, timesheets, etc.);
• Accounting and auditing irregularities;
• Theft or fraud;
• Bribery, corruption, or illegal payments;
• Safety and environmental hazards;
• Conflicts of interest;
• Requests for others to violate Conde Nast policy.

Note that this is not an exhaustive list. Employees are expected to use their judgment in each situation.

Managers have a heightened duty to set the right example, foster an environment where employees feel comfortable asking a question or raising a concern, and promptly address any misconduct once it has been communicated or identified. Managers should immediately notify a People Department representative or a department head of any complaints or potential concerns regarding violations of this Code.

Examples of Misconduct

Below are some common situations that may arise and ways for employees to address them if they happen to find themselves in a similar situation. Please note that this is not an exhaustive list. Employees are expected to use their judgment in each situation.

Q: I overheard a colleague using racist language. What should I do?

A: If you are comfortable doing so, say something directly to your colleague. In addition, whether you speak with your colleague or not, you should share your concerns with a trusted member of the management team or a People Department representative. Please note that managers and supervisors are required to report any complaints of harassment and/or discrimination to The People Department.

Q: One of our vendors complained to me that a fellow Conde Nast employee was harassing them. What should I do?

A: Immediately contact a trusted member of the management team or a People Department representative and share this information.

Q: My colleague and I disagree on whether to report an unusual transaction involving a supplier with whom the Company has a long-standing business relationship. What should I do?

A: Discuss the matter with your manager or a department head. If your manager or department head is involved in the questionable transaction, you may speak with the Chief People Officer. Everyone is responsible for identifying and reporting potentially unusual or suspicious transactions or activities. Doing so will facilitate further review of the transaction and can help protect you and the Company from any involvement in questionable or illegal activities. Suspected violations of this policy can also be reported, anonymously or otherwise, to the Company's Fraud Hotline at 888-673-9269.

Q: I am often presented with gifts from vendors and colleagues. Which gifts are unacceptable?

A: While the exchange of reasonable and customary gifts for valid business purposes may be acceptable, trying to improperly influence the recipient is not. Examples of inappropriate conduct include:

1. Accepting or offering gifts and/or business entertainment that are not aligned with Company objectives or do not have a valid business purpose;

2. Accepting a paid trip, or other expensive gift, for you or your family;

3. Accepting or offering valuable goods to inappropriately incentivize a business transaction; or

4. Accepting a gift that could be perceived as creating a conflict of interest.

Q: An employee at one of our vendors has offered me a pair of tickets to a sporting event. Can I accept the tickets?

A: Generally, yes. You are allowed to accept reasonable and customary gifts. However, if you believe the tickets may have been offered to influence you in making a business decision, accepting them would be inappropriate. If a gift or invitation seems inappropriate, contact your manager or a People Department representative for guidance.

Q: How do I determine if a business relationship creates a conflict of interest?

A: Always consider how your actions may appear, and avoid situations that create a real or perceived conflict of interest. If the business relationship creates a situation in which your personal or external interests are (or appear to be) contrary to the Company's interests, it may be inappropriate. For example:

1. Directing Company business to, or making Company decisions regarding, an outside business owned or managed by you, a family member, or a close friend without disclosing the relationship and obtaining prior approval from your manager.

2. Participating in outside business that is competitive with the Company and/or presents a potential conflict of interest.

Q: My close friend owns a production company that does excellent work at a fair price. May I recommend this company to perform work for Conde Nast?

A: You may recommend your friend's company, but you must disclose your relationship when making the recommendation. Normal bidding procedures should be followed. If your job would involve negotiating or administering a contract involving a close friend or a relative, you may not participate in a decision to secure work for their company. Be alert to potential conflicts of interest and be proactive in discussing with your manager, a People Department representative, or a department head any situation that could be perceived as a conflict of interest.

Q: I work for Bon Appetit and now have an opportunity to open a catering business with some friends. Can I participate in this venture?

A: Although Bon Appetit is not in the food service business, your participation in this venture could still constitute a potential conflict of interest (or the appearance of a conflict of interest). If you are interested in pursuing this opportunity, you must first disclose it to a People Department representative and obtain their approval before proceeding.

Resources

The Company is dedicated to providing multiple channels through which everyone can feel comfortable asking questions, raising concerns, and speaking up. Whether it involves a workplace issue or suspected illegal or unethical conduct, we want to hear from you.

• Report suspected violations of the Employee Code of Conduct to a trusted member of the management team or a People Department representative.

• Report or ask for guidance regarding behavior in violation of the Company Policy Prohibiting Harassment by contacting a trusted member of the management team or a People Department representative.

• Report suspected incidents of corporate fraud by contacting the Company Fraud Hotline via phone (888-673-9269) or online (www.reportlineweb.com/fraudhotline).

• Report any issues with respect to the safeguarding of technology assets or security concerns by contacting the Cybersecurity Team via phone (212-286-7955) or email (cyber@condenast.com).