The Scope Of This Policy: These guidelines apply to all members of our company.
The Purpose Of This Policy: The fundamental purpose is to protect the impartiality and neutrality of BUMPPY and the integrity of its news stories. Every staff member is expected to read these rules carefully and abide by them as they apply to his or her duties.
Compliance With This Code: BUMPPY takes this code of conduct very seriously. All employees of BUMPPY are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment, and to attest in writing that they have done so; all BUMPPY employees shall be required, at the time this code is first promulgated, to read it and so attest. Such written attestations shall be required once each year.
The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal.
Any employee who has a question about or becomes aware of his or her own possible violation of this code or by any other employee, or becomes aware that he or another employee is involved in a transaction or relationship that could reasonably give rise to an actual or apparent conflict of interest, should promptly discuss the situation with his or her supervisor. Every effort will be made to maintain the confidentiality of such discussions. BUMPPY will not permit or tolerate any retaliation against any employee who makes a good faith report about a possible violation of the code by another employee. Please consult with the Talent team if you have any questions on this.
Nothing in this Policy is intended to preclude or dissuade employees from
(a) reporting possible or suspected violations of law or regulation to any governmental agency or entity, cooperating with any such agency in an investigation, or making other legally protected disclosures; or
(b) engaging in any other legally protected activity, including but not limited to, activities protected under Section 7 of the National Labor Relations Act (NLRA), such as collectively discussing wages, benefits or terms and conditions of employment or raising complaints concerning working conditions.
Journalists who regularly cover business and financial news (including, but not limited to crypto-currencies) may not play the market: that is, they may not conduct in in-and-out trading, speculate in options or futures or sell securities short. Any of these actions could create an appearance of exploiting information not available to the public. Staff members who regularly cover business aspects of technology or other subjects are also subject to this rule. All BUMPPY employees are expected to conduct themselves at all times in a manner that leaves no grounds for belief, or even suspicion that:
- An employee, an employee’s family, or anyone else connected to an employee made financial gains by acting on the basis of “inside” information obtained through BUMPPY employment before that information was available to the general public.
- The creation or dissemination, or non-dissemination, of any news or other information was influenced by a desire to affect the price of any security;
- An employee’s personal financial situation with respect to investments is such that it creates a temptation to violate these rules; or
- An employee is beholden to newsmakers, information providers, advertisers or market participants, creating a temptation to violate these rules
In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of BUMPPY may engage in the short selling of securities. In addition, all senior managers and all news and advertising personnel must not engage in short-term trading of equity securities or of non-investment grade fixed income securities; such employees must hold such a securities for a minimum of six months unless, in order to meet some special need, they get prior permission for an earlier sale from the Company. The six-month rule does not apply to publicly-available diversified open end and closed end mutual funds.