CMG Culture Code

The Culture Code: A Look Into CMG’s Values & Principles
October 1, 2022
A MESSAGE FROM DAN YORK
CMG Team –
Cox Media Group’s success is founded on our mission - to

inform, entertain, and elevate our viewers, listeners and
communities. We do this as we embody our CMG values:
Integrity, Quality, Fiscal Responsibility, Diversity, and
Teamwork. These values form the foundation of our
inclusive workplace that is accountable, drives performance,
and rewards exceptional results.
That’s what The Culture Code, formally called the Code of

Conduct, is all about. Adhering to this code and living our values
is how we’ll continue to be an industry leader that always does business the right way.
The Culture Code: A Look Into CMG’s Values & Principles was written to capture our mission as a
company and ensure that HOW we bring that mission to life is done ethically and lawfully. It provides an
overview of the laws, regulations, and certain company policies and practices that may affect our
business, and it includes helpful resources to ensure we all operate together within The Culture Code.
Every one of us has an unwavering responsibility to follow The Culture Code, which means we must all
read, understand and attest to it. As you review it, I want you to consider what it says and then use it to
guide how you approach your work and interact with others both internally and externally. As you live by
this code and to stand up against unethical conduct, know that CMG is behind you.
Thank you in advance for reading and attesting to The Culture Code and for your dedication to Cox Media
Group and the communities we serve every day.
Sincerely,
Dan York
President and Chief Executive Officer
Cox Media Group
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October 1, 2022
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October 1, 2022
Table of Contents
Who Must Follow The Culture Code ............................................................................................................................ 6

Why The Culture Code Is So Important At CMG………………………………………………………………………….....6
What Happens If Our Code Is Violated? ....................................................................................................................7-8
We Respect Each Other And Conduct Business Lawfully ............................................................................................ 9
We Respect the Privacy Of Others ............................................................................................................................... 9
We Use Company-Issued Devices Properly ................................................................................................................. 9
We Follow the Law ........................................................................................................................................................ 9
Antitrust And Competition and Anti-Bribery ............................................................................................................... 9
Insider Trading .......................................................................................................................................................... 9
We Promote Diversity And Inclusion At Work ............................................................................................................. 10
Inclusive Language ................................................................................................................................................ 10
We Do the Right Thing ................................................................................................................................................ 11
Conflicts Of Interest ................................................................................................................................................. 11
Media Outreach and Speaking Engagements ........................................................................................................ 11
Political Activities and Lobbying .........................................................................................................................11-12
We Safeguard and Protect Company Assets ............................................................................................................. 13
We Maintain Accurate Records ............................................................................................................................... 13
Contacts & Other Resources................................................................................................................................... 14
Appendix ..................................................................................................................................................................... 15
Equal Employment Opportunity Policy…………………………………………………………………………………….…16
Reasonable Accommodations Policy………………………………………………………………………..………………16
Open Door—Problem Resolution Policy ..................................................................................................................... 17
Anti-Discrimination and Anti-Harassment Policy ................................................................................................... 18-21
Anti-Retaliation Policy ................................................................................................................................................. 22
Standards of Conduct and Discipline Policy ……………………………………………………………………………..…23
Solicitation and Distribution Policy…………………………………………………………………………………………...24
Smoke-Free Workplace Policy.................................................................................................................................... 24
Employment Status, Salary Basis/Safe Harbor and Pay for All Time Worked Policy……………………….……...25-26
Conflicts Of Interest Disclosure Policy ................................................................................................................... 27-28
Culture Code and “Doing Business Right” Policy ....................................................................................................... 29
Driving While on Company Business Policy ………..………………………………………………………………….30-31
Drug & Alcohol-Free Policy .................................................................................................................................... 32-35
Confidentiality And Proprietary Information Policy………………………………………………………………………….36
Electronic Information Systems Policy ........................................................................................................................ 37
Social Media Policy…………………………………………………………………………………………..………..…...38-40
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Newsroom Ethics Policy ............................................................................................................................................. 41

Personal Data Security Policy Introduction ............................................................................................................ 42-43
Inspection and Monitoring Policy…………………………………………………………………………….…………….…44
Reporting Safety Concerns Policy……………………………………………………………………………………………44
Workplace Violence Prevention Policy ............................................................................................................... …45-46
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September 2022
WHO MUST FOLLOW THE CULTURE CODE

This Culture Code (“Code”) is for Cox Media Group and its affiliates (“Cox Media Group,” “CMG” or “Company”).
The Code applies to all employees. If you are an employee who is covered by a collective bargaining
agreement, where the terms of the Code and the collective bargaining agreement conflict, the collective
bargaining agreement will apply, unless otherwise required
by applicable law.
Unless you are represented by a union or have an

individually negotiated agreement, in writing and signed by
an authorized management representative of CMG, your
employment at CMG is at-will. The policy of at-will
employment means that either you or CMG are free to
terminate the employment relationship, at any time, with or
without cause or notice.
As an employee at CMG, you are responsible for knowing

and following the Code and asking questions about any policy or any portion of a policy that is unclear to you.
You may direct questions to your designated People Solutions representative. Remember, our Code is the
starting point, not the finish line.
Unless prohibited by law, CMG may, from time to time and as it deems appropriate, revise, supplement, or rescind
any of its benefit programs and policies, whether they are outlined in or outside of the Code, with the exception of
CMG’s policy of at-will employment. CMG also may add or develop new benefit programs or policies, from time to
time as it deems appropriate.
No policy contained in the Code is intended to limit employees’ rights to engage in protected activity or to express or
imply any contractual obligation by CMG to continue your employment or to follow any stated policy or procedure
with respect to your employment, except that the Code contains the entire agreement between CMG and employees
with respect to the at-will employment relationship.
WHY THE CODE IS SO IMPORTANT AT CMG

CMG has a Code to ensure you have the answers you need to do your job in a lawful and ethical manner.
Our Code provides an overview of the laws, regulations, and certain company policies and practices that affect our
business as well as some resources we can reach out to for help.
It means doing things the right way, making decisions guided by integrity and ethics, keeping our promises and
being a trusted partner.
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WHAT HAPPENS IF OUR CODE

IS VIOLATED?
We take violations seriously. Anyone who knowingly violates our
Code, our policies, regulations or the law (or knowingly fails to report a
violation) may face corrective action, up to and including separation
from employment.
It is your responsibility to always strive to do what’s right as part of

CMG, report when you suspect wrongdoing, and cooperate fully and
honestly in any internal or government investigation. Be sure there’s
no difference between what you say you will do and what you do.
Know the policies and practices that are important to both the
Company and your job. Complete your training, as it will help you
apply our policies and practices to your everyday work.
Take action if you see or suspect a violation of our Code;

it’s your duty and required by our Code. Taking action helps make our
company a better place to work.
If you have a problem or concern, you should start with your manager.
Our “Open Door Problem Resolution Policy” means you are free to talk
to your manager any time about any problems or concerns. If you’re
uncomfortable discussing your concerns with your manager, or if you
are unsatisfied with your manager’s response, CMG’s Open Door
Problem Resolution Policy provides you with other avenues to address
your concerns.
The Ethics Hotline number 844-775-6640 or website: coxmediagroup.ethicspoint.com or by using this link
EthicsPoint - Cox Media Group allows you to anonymously ask questions and/or share your concerns with an
independent third-party, 24 hours a day, 7 days a week.
You must report concerns about:
• Discrimination or harassment • Environmental or safety issues

• Workplace violence, threats or bullying • Code violations
• Conflicts of interest • Policy violations
• Theft, fraud or bribery • Retaliation
• Inappropriate gifts or entertainment • Other concerning behavior
• Accounting or financial issues
Note that these are just examples and not an exhaustive list. Anytime you see or suspect something that could
harm Cox Media Group, our employees or our customers, say something.
We want you to feel comfortable sharing your concerns. As a company, we don’t tolerate retaliation against anyone
who speaks up, in good faith, about unethical or illegal behavior.
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If you are a leader at Cox Media Group, you have a special responsibility to lead with integrity. Show your team,
through your everyday words and actions, that you do business transparently and in compliance with our Code.
Support employees who come forward in good faith to share their concerns or raise questions. Listen, document
your conversation(s), and work with your designated People Solutions representative to resolve issues as
quickly and effectively as possible. Make sure employees aren’t subjected to retaliation for speaking up, and
properly report allegations of noncompliance.
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September 2022
WE RESPECT EACH OTHER AND CONDUCT BUSINESS

LAWFULLY
We care about each other and work together to promote a workplace free of harassment. We don’t tolerate any
behavior (whether verbal, visual, physical or sexual) that would create an offensive, hostile or intimidating
environment.
Treat everyone fairly and with respect. Don’t single out someone (or a group) based on their background,
appearance or other personal characteristics.
We honor not just the letter, but also the spirit of the law. This commitment helps to build trust and protect our brand.
WE RESPECT THE PRIVACY OF OTHERS

We are committed to keeping personal information safe and secure. We treat our customers’ and employees’
personal information the same way we would expect others to treat our own personal information. Our use of
personal information must clearly meet a responsible business need.
WE USE COMPANY-ISSUED DEVICES PROPERLY

In general, you should not use Company-issued physical or technology assets for your personal activities.
Occasional personal use of things like email, internet access, and phone is okay.
Be aware that anything you create, send, receive, download or store on our systems is Company property, and may
be reviewed at any time, where permitted by law. You shouldn’t have any expectation of privacy when it comes to
using our electronic systems.
WE FOLLOW THE LAW

Antitrust and Competition
Antitrust laws help to ensure fair and normal business competition by prohibiting such activities as price fixing, price
discrimination and certain product purchase requirements. Cox Media Group employees should not enter into any
agreements or arrangements with other parties (competitors, vendors, customers, etc.) that could illegally limit or
restrict competition.
Be fair and transparent in your business dealings. Avoid even the appearance of anything that could suggest
something unfair or deceptive. Never take advantage of anyone by lying or manipulating information, and never
make false, misleading or disrespectful comments about our competitors or their products or services.
Anti-bribery
We conduct business with integrity. Giving or receiving bribes and other payments to or from any supplier,
customer or other third party for the purpose of obtaining a business advantage is not only unethical, but also
illegal. It is also illegal to offer or make a payment to a public official for the purpose of influencing an official act or
decision. Never offer, make or authorize a payment or anything of value to influence a business decision, whether
in the public or private sector. Acts of bribery and corruption are simply not part of the way we do business.
Insider Trading
We protect inside information. Your job may bring you into contact with material, nonpublic information or “inside”
information about one of our customers, vendors, current or potential strategic partners or competitors. If so, don’t
buy or sell stock or engage in any other action to take advantage of that information. Passing along inside
information to friends, family or anyone outside the company is called “tipping,” and is also prohibited.
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September 2022
WE PROMOTE DIVERSITY AND INCLUSION AT WORK

At CMG, we blend our unique experiences, perspectives and talents together to create an amazing team.
Although we are alike in many ways, we all have our own way of looking at situations, expressing ourselves, and
contributing to the business. It’s that diversity of
backgrounds, experiences and viewpoints that drives our
success and reflects the communities we serve.
We provide equal employment, equitable development,

and advancement opportunities and do not discriminate
against anyone based on race, color, religion, sex,
pregnancy, national origin, age, veteran status, disability,
genetic information, sexual orientation, gender identity or
expression, or any other legally protected category.
As part of our commitment to providing equal employment

opportunities, we also provide reasonable
accommodations to qualified individuals with disabilities,
and/or for religious observances or practices.
Inclusive Language
Words are powerful! So often our choice of words and use of certain figures of speech can create unintentional
offenses to readers and listeners. However, by using language that is inclusive, we can convey respect and show
sensitivity to the differences of those we’re engaging. As we strive to create an inclusive culture at CMG, all
employees are encouraged to use Inclusive Language by avoiding phrases, idioms, and words that are
misappropriations of their original meanings and/or historical significance. Some examples of frequently used, non-
inclusive phrases include, but are not limited to:
o Calling important meetings “pow wows.” This is a misuse of the Indigenous Community’s sacred
gathering to honor their culture.
o Using “ladies and gentleman” as a salutation. This excludes individuals who identify in non-binary
terms (does not identify as male or female).
o Using the terms “bi-polar,” “OCD,” or “off their meds” Using these terms to describe anything other
than a medically diagnosed condition makes light of mental health disorders.
o Referring to individuals and/or their comments coming as from the “the peanut gallery.” In the late
1800’s, the “peanut gallery” was the cheapest section of seats, usually occupied by people with limited
means. It was also used as a synonym for the upper balcony where blacks sat in segregated theaters
and was typically referenced in a vulgar way.
o Using the term “Nazi” as a reference to vigilant or forceful practices.
CMG’s intent isn’t to suppress an employees’ right to freedom of expression. However, CMG does expect its
employees to engage and communicate in ways that are respectful, professional, and culturally sensitive.
You can learn more about CMG’s commitment to creating an inclusive culture by visiting our Diversity, Equity and
Inclusion resources on the CMG Hub.
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September 2022
WE DO THE RIGHT THING

Conflicts of Interest
Our lives outside of Cox Media Group are filled with activities, but when those activities interfere with your ability to
make independent business decisions, that puts you and Cox Media Group in an awkward position and can impact
your effectiveness as an employee of Cox Media Group.
A conflict of interest exists when what you do (or what your family members do) outside of Cox Media Group
interferes with the job you do as an employee. There are certain situations in which conflicts typically arise, and you
have an obligation to avoid even the appearance of a conflict.
Gifts and entertainment can also pose a conflict of interest when they make it hard for someone to be objective
about the person or the company that provides them. Avoid doing anything that might compromise (or appear to
compromise) the decisions you make as an employee of Cox Media Group.
The rules for giving gifts, entertainment or travel to government employees or public officials are very strict and
violating them can have serious consequences for the giver, the giver’s organization and the receiver.
Media Outreach
Every word we speak, write or share about Cox
Media Group has an impact on our reputation, our
brand and our people. That’s why only a few
people are authorized to make official statements
about the Company. We want to make sure
information that’s communicated on behalf of the
Company is reliable, consistent and accurate.
Unless you’re authorized to handle media

relations, don’t speak on behalf of Cox Media
Group if contacted by the media, and avoid
sending confusing messages or sharing
information that’s incorrect and could have
possible legal implications. We ask that you direct
all media relations inquiries to
[email protected]
Speaking Engagements
If you’re asked to sit on a panel or make a speech to an outside group or participate in a joint press release with
one of Cox Media Group’s vendors, you’ll need to consult with your manager before accepting an outside offer to
speak on behalf of the Company.
Political Activities and Lobbying

We respect your right to engage in personal political activities, but again, you must do so on your own time, with
your own resources. Don’t use Cox Media Group time, equipment or property (including, envelopes, email,
letterhead or postage) for personal political activities.
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We are prohibited from making contributions as a company to any federal candidates and will not reimburse any
employee for making a campaign contribution to a federal, state or local candidate or other campaign committee,
even if state and local laws permit it.
If your work involves contacts with legislators, regulators, executive branch officials (or their staffs), government
contacts, efforts to influence legislative or administrative actions, or support of these activities, make sure you
follow all applicable disclosure rules.
Protect our workplace

We want to make sure that our workplace is secure. We trust you to do your part to protect our building from
unauthorized access. Wear your company-issued badge and make sure it is always visible while on company
property. Protect your badge from loss or theft and report its loss immediately to security. Follow our policies
regarding visitors and don’t allow others to use your employee badge.
Possession of a weapon of any kind on Cox Media Group property, including parking lots (except where specifically
permitted by law), while engaged in an activity for Cox Media Group, or at a Cox Media Group-sponsored event, is
prohibited unless possession or use is approved by the Chief People Officer.
Drugs and alcohol can affect your ability to perform at your best and put you and others at risk. That’s why we
strictly forbid the use of illegal drugs (or abuse of legal drugs) or alcohol while on Company premises, while on the
job, while operating Company equipment or vehicles, or while operating personal vehicles on Company business.
Possession or consumption of alcohol is only permitted on Company property or while engaged in Company
business if in connection with a Company-authorized event where the Company has approved the consumption of
alcohol.
Employees are also prohibited from working or reporting to work under the influence of alcohol or illegal drugs.
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September 2022
WE SAFEGUARD AND PROTECT COMPANY ASSETS

We’re good stewards of our facility. We also protect information assets such as intellectual property we create,
sensitive records about our company, and technology assets like computers and mobile devices.
The physical and technology resources provided by the Company to do our jobs every day are considered
Cox Media Group property. Many of these resources contain our information assets—such as intellectual
property, sensitive business records, and personal information of our employees or customers.
Each of us is responsible for protecting our assets from theft, loss, waste or abuse. Cyber criminals regularly try to
access our systems to steal our valuable information assets or do other harm. When you help protect our assets,
you play a critical role in protecting our employees, customers, partners, and competitive advantage.
Protecting our information assets from theft or compromise depends on each of us protecting our technology assets
from cyber threats.
The security and handling of information assets can be governed by laws, regulations, industry guidelines, and
contracts. Be sure you understand our four information classification categories (restricted, confidential, internal,
and public) and follow the rules and requirements associated with each.
For companies or individuals outside of Cox Media Group, obtain a signed nondisclosure agreement before
providing access to our information assets.
Intellectual Property. This is our knowledge base and includes things like trademarks, domains, patents, copyrights
and trade secrets. Remember copyrightable maternal you generate in the course of your employment with Cox
Media Group is owned by the Company as “works made for hire” under the Copyright Act and applicable state law.
If you come to Cox Media Group from another company, honor the promise you have made to protect that
company’s information assets. And if you leave Cox Media Group, don’t share our information assets with your new
employer (refer to our intellectual property agreement).
WE MAINTAIN ACCURATE RECORDS

The records we create and maintain are important company assets, too. Always be honest, complete, timely and
accurate in what you record.
Before you commit Cox Media Group or its funds, make sure you have obtained all necessary approvals and that
you are authorized to do so.
The accounting and financial reports we file or disclose must comply with applicable regulations and professional
standards. If you’re responsible for preparing these reports, make sure the information you provide is fair, accurate,
timely, understandable and transparent. Additionally, ensure that the report is supported by the appropriate
documentation.
Follow any recordkeeping requirements associated with your job and support transactions with the documentation
necessary to provide a complete, accurate and auditable record. It helps us maintain the records we need to meet
our legal, accounting, tax and regulatory requirements and provides guidance on when to securely dispose of
records that are no longer needed. Take care never to dispose of information that may be relevant to current or
threatened litigation or if you have received a legal hold notice.
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Contacts & Other Resources

CONTACTS
CONTACT: FOR HELP WITH: CONTACT INFORMATION:
People Solutions Team Any issue, question or concern Designated People Solutions
representative
Not sure who to contact, please email

[email protected] to identify your
designated representative
The Ethics Hotline Known or suspected violations 844-775-6640, website:

of our Culture Code or policies coxmediagroup.ethicspoint.com or
via this link EthicsPoint - Cox
Media Group
Executive Vice President & Chief Approval requests for any Mary Ellen Marcilliat-Falkner at
People Officer exceptions to policy as noted [email protected]
in the Code
CMG Compliance Officer Questions or concerns about Eric Greenberg at
legal or regulatory matters [email protected]
OTHER
RESOURCES
OTHER RESOURCES: FOR INFORMATION ABOUT: CONTACT INFORMATION:
MyLife Advisors Payroll, Benefits, PTO, and 1.855.547.8508 or

general employee questions [email protected]
Employee Assistance Personal, family or work-related Magellan Ascend or call

Program (EAP) concerns; counseling and 800.523.5668
wellness support
Corporate Communications and Communicating about Cox Media [email protected]

Public Affairs Group, internally or externally
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APPENDIX
Following are all of the policies that pertain to our Code. Additional policies may relate to your employment,
depending on where you work, the nature of your job, and/or your FLSA status. Contact your designated People
Solutions representative if you have questions or need clarification about the additional policies that apply to you.
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September 2022
EQUAL EMPLOYMENT OPPORTUNITY POLICY

This Company prohibits discrimination on the basis of sex (including pregnancy, childbirth, and medical conditions
related to pregnancy, childbirth, or breastfeeding), sex stereotyping (including assumptions about a person’s
appearance or behavior, gender roles, gender expression, or gender identity) gender, gender identity/expression,
race (including traits historically associated with race, including, but not limited to hair texture and protective
hairstyles such as braids, locks, and twists), color, religion, national origin, ancestry, age, physical or mental
disability, medical condition, genetic information, sexual orientation, marital status, military or veteran status,
citizenship status and any other factor protected by law. We interpret these protected statuses broadly to include
both the actual status and also any perceptions and assumptions made regarding these statuses.
This applies, consistent with applicable law, to all phases of employment, including recruitment, testing,
placement, promotion, training, transfer, layoff, discipline, termination, compensation, benefits, participation in all
Company-sponsored employee activities, events, and programs and all other privileges, terms, and conditions of
employment. This policy and the law prohibit employment discrimination against any employee or applicant on the
basis of any legally protected status outlined above. The Company ensures that employment decisions are based
only on valid job requirements. Employees should refer to the Company’s Anti-Discrimination and Anti-
Harassment Policy for additional protections that apply.
All employees must follow this policy in dealing with co-workers, customers, clients, and visitors. Any employee
who violates this policy will be subject to disciplinary action, up to and including termination of employment.
We are committed to the practice of equal employment opportunity and will not tolerate intimidation or retaliation
against employees or applicants because they have engaged in or may engage in filing a complaint of
discrimination or retaliation; assisting or participating in an investigation; opposing any act or practice made
unlawful by any local, state, or federal law; or for exercising any other legally protected right.
If you feel you have been discriminated against at work, you should bring the matter to the attention of the
Company by utilizing the Company’s Open Door Problem Resolution Policy or, if applicable, the reporting
procedures found in the Anti-Discrimination and Anti-Harassment Policy. All reports describing conduct
inconsistent with this policy will be investigated promptly and effectively in accordance with the procedure
outlined in the Company’s Anti-Discrimination and Anti-Harassment Policy. Retaliation against employees for
complaining about conduct inconsistent with this policy is strictly prohibited as set forth in the Company’s Anti-
Retaliation Policy.
REASONABLE ACCOMMODATIONS POLICY

The Company will provide reasonable accommodations in accordance with applicable law to enable qualified
applicants and employees to perform the essential functions of the CMG job in which applicants apply or CMG
employees hold and enjoy the benefits and privileges of employment available to similarly-situated applicants and
employees. If you have a need for an accommodation due to a disability or pregnancy, or for religious reasons,
you are encouraged to discuss possible accommodations with your supervisor, manager, or designated People
Solutions representative. The Company may request that you provide medical documentation to support your
request or alternatives considered. It is the Company’s practice to keep any information you provide concerning a
disability confidential and not to disclose it, except on a need-to-know basis or otherwise in accordance with
applicable law.
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September 2022
OPEN DOOR—PROBLEM RESOLUTION POLICY

The Company is committed to maintaining a productive and safe work environment that ensures all employees can
do their best work. As in any workplace, however, problems may arise that may need management’s attention. To
assist employees in resolving such issues promptly, the Company recommends the following procedures:
You should first discuss the problem with your immediate supervisor.
• If your immediate supervisor does not resolve the issue, or if you are uncomfortable discussing the matter
with them, you should discuss the issue with the next level of supervisor (i.e., your supervisor’s supervisor),
up to and including the most senior manager at your location. You can also report the matter to the
designated People Solutions representative for your location.
• If you have a problem that involves a claim of harassment as described in the Company’s Anti-
Discrimination and Anti-Harassment Policy, you should follow the procedures the Company has
specifically established for reporting such claims as outlined in that Policy.
The Company believes it is the duty of every supervisor and manager to support this policy. The Company
encourages employees to follow the procedures set forth in this policy to resolve workplace issues. You should feel
free to follow the above procedures with the knowledge that the Company fully supports an Open Door
environment, and therefore you should not fear negative consequences based on your use of these procedures in
good faith to report a problem or concern to management.
Although the Company cannot guarantee that every problem will be resolved to your satisfaction, we value your
input and strongly encourage you to report issues or problems that concern you.
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September 2022
ANTI-DISCRIMINATION AND ANTI-HARASSMENT POLICY

This Company prohibits the discrimination or harassment of any employee based on sex (including pregnancy,
childbirth, and medical conditions related to pregnancy, childbirth, or breastfeeding), sex stereotyping (including
assumptions about a person’s appearance or behavior, gender roles, gender expression, or gender identity)
gender, gender identity/expression, race (including traits historically associated with race, including, but not limited
to hair texture and protective hairstyles such as braids, locks, and twists), color, religion, national origin, ancestry,
age, physical or mental disability, medical condition, genetic information, sexual orientation, marital status, military
or veteran status, citizenship status and any other factor protected by law. We interpret these protected statuses
broadly to include both the actual status and also any perceptions and assumptions made regarding these
statuses.
All employees of this Company should be able to work in an environment free of such discrimination and
harassment by co-workers, supervisors, managers, and non-employees. Depending on work location, employees
may be issued a state law supplement and should refer to the supplement for additional relevant information that
applies based on applicable state or local law.
Coverage
This policy and the law forbid any employee, manager, supervisor, officer, director, client, vendor, or any other third
party that an employee encounters in connection with Company business, to harass, discriminate, or retaliate
against any Company employee, applicant, contractor, intern, or volunteer, on the basis of any legally protected
status or activity. This policy also prohibits offensive conduct that does not rise to a violation of law, as explained
below.
Prohibited Conduct
The conduct prohibited by this policy, whether verbal, physical, or visual, includes any discriminatory employment
action and any unwelcome conduct that is inflicted on someone because of that individual’s protected status.
Examples of the type of unwelcome conduct that is prohibited by this policy include, but are not limited to: epithets,
slurs, taunts, stereotyping, threats or intimidating acts, derogatory or offensive jokes or comments, and the
circulation or posting of written or graphic materials that show hostility towards individuals because of their
protected status as defined above. The Company prohibits such conduct in the workplace even if the conduct is not
sufficiently severe or pervasive to constitute legally actionable harassment, including bullying.
Sexual Harassment
Sexual harassment deserves special mention. Harassing conduct based on gender often is sexual in nature but
sometimes is not. This policy forbids harassment based on gender regardless of whether the offensive conduct is
sexual in nature. Any unwelcome conduct based on gender is also forbidden by this policy regardless of whether
the individual engaged in harassment and the individual being harassed are of the same or are of different
genders.
Unwelcome sexual advances, requests for sexual favors or other verbal or physical conduct based on sex may
constitute prohibited sexual harassment when: (1) submission to the conduct is made either explicitly or implicitly a
term or condition of employment; (2) submission to or rejection of the conduct by an individual is used as a factor in
decisions affecting hiring, evaluation, promotion or other aspects of the individual’s employment; or (3) the conduct
is unwelcome and has the purpose or effect of unreasonably interfering with an individual’s work performance or
creates an intimidating, hostile, or offensive work environment.
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September 2022
Examples of the type of unwelcome conduct based on sex that is prohibited by this policy include, but are not
limited to: offensive verbal kidding, teasing, or jokes that are sexual in nature or based on sex; repeated unwanted
sexual flirtations, advances or propositions; verbal abuse of a sexual nature; graphic or degrading comments about
an individual’s appearance or sexual activity; offensive visual conduct, including leering, making sexual gestures,
the display of offensive sexually suggestive objects, pictures, or cartoons; offensively suggestive or obscene letters,
notes or emails; offensive or unwelcome physical contact such as patting, grabbing, pinching, or brushing against
another’s body; or sexual favoritism.
Reporting Prohibited Conduct
All employees who feel they have experienced or witnessed any harassment, discrimination and/or any conduct
that is inconsistent with this policy must promptly notify your department manager, the designated People Solutions
representative for your location, or the most senior manager for your location. These are the individuals authorized
by this policy to receive and act upon complaints of discrimination, harassment, and retaliation on behalf of the
Company. This policy does not require reporting discrimination, harassment, or retaliation directly to an employee’s
immediate supervisor or to any individual who is creating the harassment, discrimination, or retaliation.
Any manager or supervisor who is aware of conduct inconsistent with this policy or who receives a report of conduct
inconsistent with this policy must report it immediately to his/her designated People Solutions representative who is
a Director-level or above.
Company Response
All complaints will be promptly investigated. To that end, parties involved in the situation (including the reporting
party, anyone identified as the target of the behavior (if different than the reporting party) and anyone who allegedly
violated this policy) will be offered an opportunity to be interviewed or to otherwise respond to a report under this
policy. The Company may put certain interim measures in place, such as a leave of absence or a transfer, while
the investigation proceeds. The Company will take further appropriate action once the report has been
investigated. That action may be a conclusion that a violation occurred, as explained immediately below. The
Company might also conclude, depending on the circumstances, either that no violation of policy occurred or that
the Company cannot conclude whether or not a violation occurred. If an investigation reveals that harassment,
discrimination or other inappropriate or unprofessional conduct (even if not unlawful) has occurred, then appropriate
corrective action may be taken by the Company, which may include discipline up to and including termination of
employment, as warranted by the results of the investigation. All complaints by employees will be kept in the
strictest confidence except as necessary to complete an investigation.
No Retaliation
The Company strictly prohibits retaliation against any individual for reporting harassment, discrimination or conduct
under this policy, for assisting an individual in making such a report, or for cooperating in an investigation of such a
report. An employee who experiences or witnesses conduct they believe to be retaliatory must immediately report
the suspected retaliation in accordance with the reporting procedures described above. The Company will promptly
investigate any report of retaliation. Anyone determined to be acting in a retaliatory manner in violation of this policy
will be subject to discipline, up to and including termination.
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September 2022
External Resources
While you are encouraged to use the procedures above for reporting conduct inconsistent with this policy, you may
file a complaint with your state’s respective civil rights agency or the Equal Employment Opportunity Commission
(“EEOC”).
State and federal laws require that complaints be filed within a certain amount of days after an alleged incident of
discrimination, harassment, or retaliation. Places where you may find information explaining the filing requirements,
deadlines, and other related information, include state-managed websites. Some states require that state agency
contact information be provided by CMG, and such information as well as contact information for the EEOC in those
states appears below or in any separate addenda to this policy.
Illinois Office Locations Complaint Deadline

Illinois Department of Chicago: 100 W. Randolph St., 10th Floor, Intake 300 days after alleged
Human Rights Unit, Chicago, IL 60601 incident
312 814-6200 or 800-662-3942
TTY: 866-740-3953
Springfield: 222 S. College, Room 101-A, Intake

Unit, Springfield, IL 62704
217- 785-5100, TTY: 866-740-3953
Marion: 2309 W. Main St., Marion, IL 62959

618-993-7463, TTY: 866-740-3953
Illinois Human Rights Chicago: 100 W. Randolph St., Suite 5-100, 300 days after alleged
Commission Chicago, IL 60601 incident
312-814-6269, TTY: 312-814-4760
Springfield: William G. Stratton Bldg., Suite 802,

Springfield, IL 62706
217-785-4350, TTY: 217-557-1500
EEOC 500 W. Madison Street, Suite 2000, Chicago, IL 300 days after alleged
60601 incident
800-669-4000, TTY: 800-869-8001
Massachusetts Office Locations Complaint Deadline

Massachusetts Commission Boston: One Ashburton Place, Rm. 601 300 days after alleged
Against Discrimination Boston, MA 02108 incident
617-994-6000 (voice/TDD)
Springfield:424 Dwight St., Rm. 220, Springfield, MA

01103
413-739-2145 (voice/TDD)
EEOC John F. Kennedy Federal Bldg., 475 Government 300 days after alleged
Center, Boston, MA 02203 incident
800-669-4000, TTY: 800-669-6820
Page 20 of 46
September 2022
Vermont Office Locations Complaint Deadline

Vermont Attorney General’s 109 State Street, Montpelier, VT 05609 300 days after alleged
Office, Civil Rights Unit 802-828-3171 (voice/TDD) incident
Vermont Human Rights 14-16 Baldwin Street, Montpelier, VT 05633 300 days after alleged
Commission 800-416-2010 or 802-828-1625 (voice) incident
EEOC John F. Kennedy Federal Bldg., 475 Government 300 days after alleged
Center, Boston, MA 02203 incident
800-669-4000, TTY: 800-669-6820
California employees may locate state-developed online training courses on preventing sexual harassment and abusive
conduct at https://www.dfeh.ca.gov/shpt/.
Page 21 of 46
September 2022
ANTI-RETALIATION POLICY
I. PURPOSE
This policy prohibits retaliation against any individual (including but not limited to employees, contractors,
vendors, customers, or members of the public) who reports a workplace concern, potential policy or legal
violation, or who engages in any other legally protected activity.
II. SCOPE
This policy applies to Cox Media Group employees.
III. POLICY PROVISIONS

Cox Media Group prohibits retaliation against an individual who, in good faith, has reported a workplace
concern, potential policy or legal violation, or engaged in other protected activity. Retaliation means taking
adverse action against the individual because that individual has reported a concern or engaged in protected
activity. Adverse actions may include, but are not limited to, termination of employment, demotion, loss of pay
or benefits, involuntary transfer or reassignment, denial of a promotion, or harassment that creates a hostile
work environment. Cox Media Group also prohibits threats of retaliation related to the report or other
protected activity engaged in by the individual.
More specifically, Cox Media Group prohibits retaliation against any employee who:
• Reports a concern to their supervisor, a designated People Solutions representative, or the CMG
Compliance Officer.
• Assists or participates in any internal or external investigation, compliance review, hearing or any
other activity related to the administration of any federal, state, local, or other applicable law.
• Opposes any act or practice made unlawful by federal, state, local or other applicable law.
• Exercises any other employment right protected by federal, state, local or other applicable law.
Cox Media Group cannot remedy claims of misconduct or wrongdoing unless such concerns are brought to the
company’s attention. Cox Media Group expects employees who become aware of misconduct or wrongdoing, or
who believe they were subject to conduct prohibited by the policy to immediately notify the Company in
accordance with the procedure set forth in this policy.
If any person believes they have witnessed or been subjected to retaliation, they should report the matter
immediately to the designated People Solutions representative for their department or location, contact the
CMG Compliance Officer, or contact CMG’s Ethics Hotline, at 844-775-6640, website:
coxmediagroup.ethicspoint.com or via this link EthicsPoint - Cox Media Group.
Please contact your designated People Solutions representative or the CMG Compliance Officer if you have
questions related to this policy.
Cox Media Group will take corrective action, up to and including separation of employment, when necessary
to ensure employees comply with the Code, all Company policies, as well as all applicable laws.
Page 22 of 46
September 2022
STANDARDS OF CONDUCT AND DISCIPLINE POLICY
If your conduct does not meet CMG’s standards or violates Company policy, you may face disciplinary action,
including but not limited to counseling, warning(s), transfer, demotion, suspension (with or without pay), ineligibility
for incentive awards, or termination of employment. CMG shall decide whether discipline is appropriate, under the
circumstances, as well as the level of discipline. Unless otherwise required, CMG does not need to follow precedent
or engage in progressive discipline.
Below is a non-exhaustive list of examples of conduct that will generally lead to immediate termination for even a first
offense.
• Violating other policies within the Code
• Insubordination
• Neglect of duties
• Sleeping at work
• Excessive absences
• Failing to follow safety rules
• Deliberate, negligent, or reckless behavior that causes actual or potential harm, loss, or injury to the
Company, other employees, or third parties
• Unauthorized use of a Company vehicle
• Operating a Company vehicle in an unsafe, negligent, or destructive manner
• Falsifying illness or injuries, filing fraudulent or misleading reports, claims or other documents, or
misrepresenting information to receive or to attempt to receive certain benefits (such as workers’
compensation claims, short-term or long-term disability benefits, FMLA or personal leave)
• Possession of pornographic or obscene material while at work, on Company premises or equipment, or on
Company business
• Failing to timely report an accident in accordance with CMG policy
• Gambling on Company premises or while working
• Misrepresentation of work history, education, background, or qualifications, on the employment application
or resume, or in the employment interview (whether discovered before or after hiring)
If you have any questions regarding CMG’s standards of conduct, please contact your manager or your designated
People Solutions representative. This policy does not change or limit the at-will relationship.
Page 23 of 46
September 2022
SOLICITATION AND DISTRIBUTION POLICY

Maintaining productivity is a key part to CMG’s success. While employees and outside groups may want to speak to
employees, hand out information, or solicit support at Company locations, these efforts can disrupt productivity.
Below are CMG’s rules on solicitation and distribution.
Allowed
• Solicitation or distribution of any kind of literature for any purpose is prohibited while either you or your co-
workers are on working time. “Working time” means the period of time job duties are being performed, not
including meal and rest break times or other periods when employees are not properly engaged in
performing work tasks.
• You may only distribute materials in non-working areas, like break rooms, parking lots and designated
smoking areas.
Disallowed
• You may not solicit your co-workers or distribute materials for any purpose during working time.
• You may not distribute materials in work areas at any time.
• You may not post materials on Company bulletin boards, as they are maintained for Company-initiated
postings only. Only authorized Company representatives may post on these bulletin boards. Any
unauthorized posts will be removed.
• Anyone who is not a Company employee may not engage in solicitation, distribution, or trespassing of any
kind at any time on Company premises, including building interiors, parking lots, driveways, or any other
Company property.
The Company may approve limited exceptions to this policy for charitable activities or Company-sponsored activities.
SMOKE-FREE WORKPLACE POLICY

You are not allowed to smoke or use tobacco products (e.g., cigarettes, chewing tobacco, e-cigarettes, vaporizers,
or similar devices) on Company premises, except as provided otherwise, or in Company vehicles. You may smoke
or use tobacco products in a designated smoking area that conforms to all state and local laws. If you do so, please
be considerate of others. Failure to follow this policy may result in discipline, up to and including termination.
Page 24 of 46
September 2022
EMPLOYMENT STATUS, SALARY BASIS/SAFE HARBOR AND PAY

FOR ALL TIME WORKED POLICY
Employment Status – Non-Exempt or Exempt
CMG has designated each job position as exempt or non-exempt. Employees who work in non-exempt positions are
eligible for overtime pay under federal and state wage and hour laws, or where specified under an applicable
collective bargaining agreement.
Employees who work in positions that are classified as exempt are not entitled to overtime pay. Their salary or other
base compensation is intended to compensate them for all hours worked each workweek, whether few or many.
CMG intends to maintain the salary basis of all salaried-exempt employees. See Salary Basis/Safe Harbor section of
this policy.
Salary Basis/Safe Harbor

For exempt employees who are paid a salary, it is CMG’s policy to comply with the salary basis requirements for
salaried-exempt employees under the Fair Labor Standards Act (FLSA) and applicable state wage and hour law.
To qualify for one of the FLSA’s exemptions for salaried employees, employees generally must be paid at least $684
per week on a salary basis. Some state wage and hour laws establish a higher salary level. (Note that some
overtime exemptions do not include a salary requirement. For example, there is no salary requirement for exempt
outside sales employees and exempt computer employees may be paid an hourly rate of at least $27.63.)
Being paid on a “salary basis” means an employee receives a predetermined amount of compensation each pay
period on a weekly, or less frequent, basis. The predetermined amount cannot be reduced because of variations in
the quality or quantity of the employee’s work. Subject to certain exceptions, a salaried-exempt employee must
receive the full salary for any workweek in which the employee performs any work, regardless of the number of days
or hours worked. Exempt employees do not need to be paid for any workweek in which they perform no work. If an
employer makes deductions from an employee’s predetermined salary because of the operating requirements of the
business, that employee is not paid on a “salary basis.” If the employee is ready, willing and able to work,
deductions may not be made for time when work is not available.
CMG prohibits management from taking improper deductions from the salaries of exempt employees. If you are a
salaried-exempt employee and believe that an improper deduction has been taken from your salary, please report
this information to your designated People Solutions representative or through the other vehicles available under the
Open Door Problem Resolution Policy.
Reports of improper deductions will be promptly investigated. If it is determined that an improper deduction has
been taken from your salary, CMG will promptly reimburse you for any improper deduction made. CMG does not
tolerate any retaliation against individuals for making reports of improper deductions.
Pay for All Time Worked
CMG requires non-exempt employees to accurately and timely report all time worked, in accordance with CMG’s
timekeeping procedures, so that CMG may pay for all time worked.
CMG strictly prohibits non-exempt employees from working “off the clock” (i.e., not reporting all time worked) and
management from encouraging or instructing non-exempt employees to work “off the clock.” Non-exempt
employees must record all time spent performing work for CMG, including but not limited to time worked outside of
their normal workplace and/or work hours.
Page 25 of 46
September 2022
Employees are expected to seek prior management approval to work away from their normal workplace and/or
outside of their normal work hours, including overtime. That said, employees are required to record and report, and
CMG will pay for, all time worked, even if the employee did not obtain prior approval to work the hours. Stated
differently, failing to seek prior approval to work certain hours does not excuse an employee from recording and
reporting those hours so that CMG may pay them for all time worked.
If you are a non-exempt employee and are asked or pressured to work “off the clock” or otherwise not accurately
record your time for work performed, you must immediately notify your designated People Solutions representative
or make a report through CMG’s Ethics Hotline, 844-775-6640, website: coxmediagroup.ethicspoint.com or via this
link EthicsPoint - Cox Media Group
Any non-exempt employee who makes an error recording his or her time should work with his or her manager to
correct the time immediately. Non-exempt employees may not record time for others, ask others to record time for
them, or falsify timekeeping records.
Employees, including managers, who engage in violations of this policy by will be subject to discipline, up to and
including termination.
Unless otherwise required by state law or an applicable collective bargaining agreement, non-exempt employees
only earn overtime pay for each hour over 40 hours that they work in a workweek at the rate of one and one-half
times the employee’s regular rate of pay. Unless otherwise noted, the workweek begins at 12:00 am on Sunday and
runs through 11:59 pm on Saturday. Each workday begins at 12:00 am and ends at 11:59 pm.
Exempt employees are not entitled to overtime pay. See Employment Status – Non-Exempt or Exempt section of
this policy. Please direct questions regarding pay and/or timekeeping practices or concerns regarding pay, including
concerns about off the clock work” to your designated People Solutions representative or CMG’s Ethics Hotline, at
844-775-6640, website: coxmediagroup.ethicspoint.com or via this link EthicsPoint - Cox Media Group
CMG prohibits retaliation against any employee for reporting possible policy violations or concerns about pay, pay
practices and/or timekeeping practices.
Page 26 of 46
September 2022
CONFLICTS OF INTEREST DISCLOSURE POLICY

I. PURPOSE
This policy establishes requirements for handling actual or potential conflicts of interest.
II. SCOPE
III. DEFINITIONS
Company refers to Cox Media Group, Inc. and its subsidiaries and affiliates.
IV. POLICY PROVISIONS

Cox Media Group recognizes that employees may take part in legitimate financial, business and other activities
outside their responsibilities as employees of Cox Media Group. Those activities must be lawful and free of
conflicts. A conflict of interest occurs when personal or outside interest conflict with the best interests of the
Company.
1. No Division of Loyalty It is impossible to describe every possible type of conflict of interest that may
develop. The basic factor in all conflicts of interest situations is the division of loyalty, or the
appearance of a division of loyalty, between the Company’s interests and your own personal interests.
All employees have a duty to the Company to be free from the influence of conflicting interests when
they represent the Company in negotiations or business dealings with third parties. Employees are not
permitted to intentionally take for themselves, or family members or other third parties, any business or
investment opportunities that belong to the Company or are discovered or made available to
employees by virtue of their position at the Company or through the use of Company information or
property.
2. Association with Competitors or Entities with Business Relations with the Company A potential
conflict of interest may arise when you, a member of your family or other person with a close
relationship is associated with an entity with which the Company has or is likely to have a business
relationship, or with which the Company competes or is likely to compete. Unless otherwise expressly
authorized in writing, employees may not be suppliers to Cox Media Group, transact business with a
relative (as defined herein) on behalf of the Company, provide services that compete with the Company
directly or indirectly have any interest (other than less than 5% of the outstanding securities of a public
company) in competitors of Cox Media Group, or engage in employment (“moonlighting”) or board
service with an entity that creates an actual or potential conflict with the interests of Cox Media Group.
3. Gifts and Other Limitations An employee must not seek or accept, directly or indirectly, payments,
loans, services or travel or entertainment (including discounts not available to the general public or
similarly situated Cox Media Group employees) from any business or individual, including news
sources and on-air guests, doing or seeking to do business with Cox Media Group that may impede an
employee from acting in the best interests of Cox Media Group.
4. Working with Relatives

Cox Media Group recognizes that in some cases, employees may have relatives also working for the
Company. In these situations, work situations should be avoided that create a direct or indirect
supervisory relationship between relatives. A relative should not be in a position to influence the terms
and conditions of another relative’s employment. Any exceptions to this requirement, must be approved
by the Chief People Officer and the Chief Executive Officer.
Page 27 of 46
September 2022
For purposes of this policy, the term “relative” is defined as follows:
• Parent, child, sibling, spouse, domestic partner, aunt, uncle, niece, nephew, grandchild,
grandparent, or
• Cousin of employee.
• In-laws of the above types.
• Foster or step-relatives of the above types.
5. Reporting and Disclosure

The effectiveness of this policy depends on employee cooperation to disclose any situations that may
be contrary to this policy’s intent. Employees must disclose immediately any potential conflict of
interest, including any financial interest, outside activity or business relationship in which they are
involved or plan to become involved which could result in an actual or potential conflict of interest or
which could result in the appearance of a conflict of interest. Disclosures shall be made in writing to
your supervisor as well as to the CMG Compliance Officer or your designated People Solutions
representative.
Your location may have additional requirements for disclosure of potential conflicts of interest, which
should be reviewed in conjunction with this policy.
If you have questions related to this policy, please contact your designated People Solutions
representative or the CMG’s Compliance Officer.
Cox Media Group will take corrective action, up to and including separation of employment, when necessary to
ensure employees comply with the Code and all company policies, as well as all applicable laws. Cox Media
Group does not tolerate retaliation against individuals who report potential policy or legal violations in good faith.
Page 28 of 46
September 2022
CULTURE CODE and “DOING BUSINESS RIGHT” POLICY

I. Purpose
The Culture Code (“Code”) establishes requirements for Cox Media Group’s Ethics and Compliance
Program.
II. Scope
III. Policy Provisions

1. Cox Media Group Commitment to Ethics and Compliance
All Cox Media Group employees are expected to understand and follow the Code’s standards and
consult the Code for guidance.
2. Employee Responsibilities
Cox Media Group employees are expected to follow the Code and Cox Media Group policies. If
unsure about a policy or specific Code provision, employees are encouraged to seek clarification from
their supervisor, designated People Solutions representative or CMG’s Compliance Officer.
3. Manager Responsibilities
In addition to the employee responsibilities listed above, employees who manage others are
expected to:
• Ensure employees have adequate knowledge and resources to follow the Code’s standards;
• Monitor adherence to the Code and all other Cox Media Group policies;
• Support employees who raise questions and concerns about ethics or compliance; and
• Properly report allegations of non-compliance.
4. Code Distribution
All Cox Media Group employees must review the Code and attest to their understanding and
compliance with the standards provided therein. A copy of the Code is located on the CMG Hub under
Departments > People Solutions > Policies or you may contact your designated People Solutions
representative for a copy of the Code. All Cox Media Group employees will be periodically reminded to
review the Code. New employees are required to access and attest to the Code as part of the
employee onboarding process.
5. Compliance Training
All Cox Media Group employees must complete annual compliance training. Certain employees,
including employees new to Cox Media Group, may be required to take additional classes according
to the schedule maintained by the Compliance Officer. Such additional classes designed to provide
the tools necessary to apply specific sections of the Code to an employee’s job function.
6. Questions or Concerns
Employees should reference the Ethics Hotline number: 844-775-6640, website:
coxmediagroup.ethicspoint.com or via this link EthicsPoint - Cox Media Group or contact their
designated People Solutions representative or CMG’s Compliance Officer to address how to report
violations of the Code or Company policy, to ask questions or advice, or to voice concerns.
Cox Media Group will take corrective action, up to and including separation of employment, when necessary to
ensure employees comply with the Code and all company policies, as well as all applicable laws. Cox Media Group
does not tolerate retaliation against individuals who report potential policy or legal violations in good faith.
Page 29 of 46
September 2022
DRIVING WHILE ON COMPANY BUSINESS POLICY

Cox Media Group, (the “Company”) require all employees who operate motor vehicles while on Company business,
to operate such vehicles in a professional and safe manner and to obey all applicable federal, state and local laws
and traffic laws.
This policy and the following requirements apply to all employees who routinely drive personal vehicles as part of
their job on Company business.
License, Insurance, and Motor Vehicle Reports
A valid driver’s license issued by the employee’s current state of residence and at least the minimum amount of
auto insurance required by that state’s law is required by every employee who drives his or her own vehicle on
Company business.
The Company requires a current valid driver’s license and insurance to be verified, at minimum, on an annual
basis.
The Company will obtain a Motor Vehicle Report (“MVR”) on employees who routinely will drive in the course and
scope of their jobs. The Company may obtain additional, periodic MVRs on such employees, on an annual or other
periodic basis as determined by the Company in its sole discretion.
The Company reserves the right to prohibit or restrict an employee from driving personal vehicles for Company
business based on citations, moving violations or other driving related offenses (regardless of whether committed
while driving for work related or personal reasons). If an employee has their license revoked or has had their
license suspended in the past 12 months, they may not drive a personal vehicle on Company business. Employees
are required immediately to report to their supervisor any citation or arrest for a moving violation or other driving
related offense, or any revocation or suspension of their driver’s license.
Vehicle Use
Employees may not drive on Company business while under the influence of drugs and/or alcohol. Drugs include
but are not limited to any prescriptions or over-the-counter medications that could affect the safe operation of a
vehicle.
If you have a medical condition or if you take medication that could affect the safe operation of a vehicle, you must
notify the designated Human Resources Business Partner for your location, and you must receive clearance from your
location’s Human Resources Business Partner before operating a vehicle on Company business.
Seat belts must be worn whenever the vehicle is in motion.
All accidents involving vehicles owned by the employee but being used on Company business must be reported to
your supervisor immediately.
Alcohol, firearms, unnecessary sharp objects, pets, or illegal substances are not allowed in any vehicle owned by the
employee while being used on Company business. The Company expects employees to use common sense on any
other items they may have in their personal vehicle driven while on Company business, subject to local and state laws.
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September 2022
In‐Vehicle Usage of Cell Phones and Other Wireless Communications Devices
Employees must adhere to all federal, state, or local laws, rules and regulations regarding the use of cell phones
or other wireless communications devices (“WCDs”) while driving. WCDs include cell phones, smart phones, tablet
or laptop computers, or any other mobile or wireless communication device. It is the responsibility of employees to
know and comply with the applicable laws of the location in which they operate a vehicle.
Safety should come before all other concerns. No employee of the Company is required, directed, or expected to
use a cell phone or other WCD while driving. The Company recognizes there may be a need to use WCDs to
make or receive telephone calls, however, safety must be the first priority and therefore, employees should refrain
from using WCDs while driving. If an employee needs to make or accept a call while driving, the following safety
precautions must be adhered to:
• If possible, leave the road and find a safe parking space before making or accepting the call. Stopping
on the side of the road is not appropriate except in emergencies such as breakdowns or accidents.
• Let voice mail answer in-coming calls if at all possible.
• Use a hands‐free device if stopping is not possible and you must make or accept a call.
• Avoid making or accepting a call in situations where there is heavy traffic, roadwork, inclement weather
or other potentially hazardous driving conditions.
• Refrain from discussion of complicated or emotional topics.
• Keep your eyes on the road at all times.
• Call for help to protect yourself and others from dangerous situations. Dial 911 (free call) in case of fire,
traffic accident, road hazard, or medical emergencies.
• Learn how to properly operate the WCD and its features, including speed dial and redial, voice
recognition features and any hands-free device.
• The usage of WCDs while driving for “text messaging,” reading or typing emails or other communications,
accessing the internet, or for any other function that may distract you from driving, is strictly prohibited.
Reporting Safety Concerns
If you become aware of a safety or health issue or become injured while working, you must report the issue or your
accident, injury, or illness to your supervisor immediately or as soon as you become reasonably aware of the injury.
If your supervisor is unavailable, report the issue or your injury to your People Solutions representative. Consistent
with the Company’s Driving Policy, all vehicle accidents that happen in a Company vehicle, or non-Company
vehicle on work-related business, must be reported to your supervisor, regardless of whether there is damage or
whether you are at fault. In addition, these accidents must be reported to the police immediately and a police
report must be filed. The only exception is if the accident occurs on private property and local law enforcement will
not take reports on private property.
If you have safety suggestions, please share them with your supervisor or your designated People Solutions
representative.
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September 2022
DRUG & ALCOHOL-FREE POLICY

I. INTRODUCTION
Cox Media Group is committed to protecting the safety, health and well-being of all of our employees and
other individuals in our workplace. We also recognize that alcohol misuse and illegal drug use pose a
significant threat to our business objectives. To reduce the risk that alcohol misuse and illegal drug use pose
to our Company, we have established a drug and alcohol-free workplace policy that balances our respect for
individuals with the need to maintain a drug and alcohol-free environment.
The policy below applies to current and new-hire employees and will be administered in such a manner that
complies with local, state, and federal laws and regulations.
We believe that our employees should work in an environment where their co-workers are not under the
influence of alcohol or illegal drugs. This also includes misusing legal drugs that can impact their safety or the
safety of others and cause liability for the Company.
II. DEFINITIONS
“Illegal drugs” mean all controlled substances, controlled substance analogues, cannabinoids (including
cannabidiol (CBD) and CBD products that contain unlawful amounts of THC), marijuana extracts, synthetic
drugs, designer drugs, and other substances that are not being used or possessed under the supervision of a
licensed health care professional or that are not being used in accordance with the licensed health care
professional’s prescription or whose use or possession is otherwise unlawful under the federal Controlled
Substances Act. (Controlled substances are listed in Schedules I-V of 21 U.S.C. § 812 and 21 C.F.R. Part
1308.)
III. RULES
1. Employees are strictly prohibited from engaging in the following conduct:
• Reporting to work under the influence of alcohol and/or illegal drugs;
• Working under the influence of alcohol and/or illegal drugs while on the job or while on Company
property, including, but not limited to, the use or operation of Company vehicles or personal vehicles
for Company business;
• The sale, purchase, manufacture, distribution, transfer, use or possession of any illegal drug during
working hours (including breaks), while on Company business, on Company property whether on or
off-duty, or while using or operating Company property, including Company-owned or leased
vehicles or personal vehicles driven in the course and scope of an employee's job;
• Possessing or consuming alcoholic beverages on Company property or while engaged in
Company business unless in connection with a Company-authorized event where the
consumption of alcohol has been approved by the Company; and
• Using someone else’s prescription drugs or (b) using prescription or over-the-counter drugs in a
manner, combination or quantity that is inconsistent with the prescription or label indications or (c)
reporting to work under the influence of, or using at work, prescription drugs that could reasonably be
expected to create a safety risk
2. Employees are to report to work fit for duty and free of any adverse effects of illegal drugs or alcohol.
This policy does not prohibit employees from the lawful possession and use of over-the-counter and
prescribed medications. It is the employee’s responsibility to consult with their doctors or other licensed
medical practitioners about the effect of over-the-counter and prescribed medications on their ability to
perform their specific job duties in a safe and effective manner, and to promptly disclose any work
restrictions to their supervisors or the designated People Solutions representative for their location.
3. Employees should not, however, disclose underlying medical conditions, impairments, or disabilities to
their supervisors or People Solutions unless specifically directed to do so by their doctors or other
licensed medical practitioners. The Company reserves the right to temporarily or permanently re-assign
Page 32 of 46
September 2022
the employee to another position if it is determined that such re-assignment will protect the safety of the
employee, other employees, the Company’s customers, and the general public. Information provided by
the employee will be kept confidential by management.
4. Marijuana is an illegal drug under federal law and this policy. The use of marijuana will not be
considered a legitimate medical explanation by the Company and its MRO (Medical Review Officer) for
a positive drug test result for marijuana, except to the extent required by applicable law. In addition, the
Company will not accommodate applicants’ and employees’ use of recreational and medical marijuana,
except to the extent required by applicable law.
IV. EMPLOYEE ASSISTANCE

The Company encourages employees who believe they have drug or alcohol dependency problems to
seek assistance voluntarily through the Company-sponsored Employee Assistance Program (EAP).
Participation in the Employee Assistance Program will be handled in strict confidence. Employees who
participate voluntarily in the EAP will not have their employment affected because of such participation, unless
they violate the terms of the Drug & Alcohol-Free Workplace Policy.
An employee seeking rehabilitation or other medical treatment for alcoholism or drug addiction may be
entitled to benefits under the group medical insurance plan applicable to the employee, in accordance with
the terms of that plan. The employee also may be entitled to a leave of absence under the Company’s
Family and Medical Leave Policy to enter a voluntary drug or alcohol rehabilitation program if they wish to do
so. Employees should contact their designated People Solutions representative with any questions regarding
these benefits.
While the Company wishes to help employees who seek assistance, it is the employee’s responsibility to
seek necessary assistance before alcohol, drug or other problems adversely affect the employee’s
performance or conduct while at work. If an employee violates Company policy or engages in conduct that
warrants disciplinary action, a subsequent attempt by the employee to seek assistance will not prevent or
lessen the severity of the disciplinary action.
V. DISCIPLINE
Except where applicable law prohibits such action, an employee will be subject to disciplinary action up to and
including termination for a confirmed positive test result (as set forth herein), for an employee’s failure to or
refusal to undergo drug or alcohol testing, for tampering with a drug or alcohol test, for failing to fully
cooperate or render a valid sample, or for any other violation of this policy.
Unless prohibited by law, any employee who is convicted of a drug or alcohol related crime must notify the
Company immediately. Depending on the nature of the violation, the employee may be subject to
disciplinary action up to and including termination.
Nothing in this policy prohibits the employee from being disciplined for other violations and/or performance
problems.
VI. DRUG AND ALCOHOL TESTING
A. TYPES OF TESTING
1. Pre-Employment Testing: All applicants who have received offers for regular full-time or part-
time employment, or temporary employment for a specified period of time, must submit to and
pass a drug screening test to qualify for employment with the Company.
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2. Post-Accident Testing: Employees whose conduct may have contributed to a serious work-related
accident may be required to undergo drug and/or alcohol testing. Employees involved in a motor
vehicle accident while performing work, regardless of whether the employee was operating a
Company owned/leased vehicle or a personal vehicle, may be required to submit to drug and/or
alcohol test immediately following the incident, if the accident results in any of the following:
• Loss of life
• Injury to any individual that requires medical treatment or attention at a medical facility or doctor’s
office. If the employee requires medical treatment at a medical facility or doctor’s office, then the
policies and procedures for on-the-job injuries above also apply
• Damage to property in excess of $500
• The police or other law enforcement authority deem the accident was caused by the employee
and/or employee is issued a citation
• Company has reasonable suspicion to believe that the employee’s ability to operate the vehicle
was impaired
• Refusing to take a field sobriety test following a traffic stop or accident occurring during work is
covered by this policy and will be treated the same as a refusal to take a drug/alcohol test under
Section IV (“Discipline”). This policy will be followed regardless of whether the field sobriety test
was declined upon the advice of the employee’s legal counsel.
3. Reasonable Suspicion Testing: An employee will be required to undergo drug and/or alcohol
testing if the Company has a reasonable suspicion that the employee is under the influence of
alcohol or drugs or has violated any of the Company’s rules that prohibit the use of alcohol or
drugs. Some examples of behaviors that may indicate impairment include, but are not limited to:
• Endangering the immediate or long-term safety and health of the employee or others
• Physical signs of impairment that may include slurred speech, dilated pupils, the smell of alcohol
on the breath, or erratic behavior
• Observations suggesting potential drug use, such as the discovery of drugs or related
paraphernalia in the employee’s possession or immediate work area
• Comments by the employee that suggest present impairment
B. Testing Methods and Collection Procedures

Employees who are required to submit to a drug and alcohol test will be escorted to a certified testing site
by a member of management. Samples will be collected and tested in a way that respects the privacy of
the employee, however, collection will be conducted in a manner reasonably calculated to prevent
substitutions or interference with the collection and testing of reliable samples.
Drug testing will include confirmation of any positive result by gas chromatography-mass spectroscopy or any
equivalent scientifically accepted method of equal or greater accuracy before the test will be used as a basis
for disciplinary action, except that an employee may be suspended pending confirmation of a positive test
result. Decisions about pay during a suspension may be deferred until appropriate information is obtained and
evaluated. Should a drug test be reported as positive, a second review by an MRO will be conducted to
confirm the result. The MRO will contact the applicant or employee to discuss the result before communicating
the final result to the Company. The Company will notify employees in writing of test results. The Company
(or one of its service agents) shall advise applicants and employees of their rights, if any, to have their same
specimens retested or their split specimens tested by a certified laboratory.
An employee whose drug and/or alcohol test returns a “positive” result may be subject to disciplinary action
up to and including termination, as allowed by law.
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VII. Confidential Records
Drug and alcohol test results will remain confidential and will not be released except as required by law. The
Company reserves the right to choose the drugs and testing limits for the testing; however, to maintain the
employee’s privacy, the Company will not authorize any tests that identify a specific illness or genetic classifier.
The testing site will only confirm a positive or negative result.
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September 2022
CONFIDENTIALITY AND PROPRIETARY INFORMATION POLICY

The nature of our business requires some Company employees to develop, handle or have access to non-public or
sensitive information, including, without limitation, trade secrets, proprietary information and other confidential
information (collectively referred to as "Private Information") of the Company, its customers, its employees and
others with whom it does business. Company employees are required to hold such Private Information in
confidence in order to protect the business interests of Company operations and the privacy of customers,
employees and others. Consequently, it is important that you as a Company employee not access use or disclose
such Private Information except as required by your job and in accordance with Company policy and procedures.
The Company may establish specific measures to be taken by any or all of its employees in order to safeguard
such information. (For example, your responsibilities with respect to an individual's "Personally Identifiable
Information" to which you may have access is set out in a separate policy on that subject.) It is also important that
you refrain from improperly accessing, using or disclosing Private Information pertaining to any other company,
including the Company's competitors.
Common examples of Private Information includes without limitation such information as planned acquisitions,
customer lists, employee data (e.g., dates of birth, employee financial data, medical records, personal email
addresses, postal addresses, social security numbers, etc.), financial data (e.g., capital investment plans, earnings
or projected earnings, sales figures, wage and salary data, etc.), changes in the Company's management or
policies, business processes, marketing strategies, market expansion plans, new product plans, planned
advertising programs, prototypes, lists of suppliers, suppliers' pricing, testing data, schematics, software
programs/products developed by or for the Company, or any plans the Company may have to improve its products
or services. Of course, Private Information also includes any documents, electronic files or other materials that are
labeled "trade secret," "confidential," "proprietary," "secret," "top secret," "classified," "highly classified" or similar
terms meant to convey the sensitive nature of any associated items.
Accessing, disclosing, copying, removing or destroying any Private Information for purposes other than the
performance of Company business is prohibited and is grounds for disciplinary action up to and including
termination of employment. All Private Information, including all copies and extracts of such information, in
whatever form, must be returned to the Company immediately upon request or upon separation of employment.
The Company reserves the right to take appropriate legal action against individuals who violate this policy or who
the Company reasonably suspects might violate this policy while employed by the Company or following a
separation of employment.
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September 2022
ELECTRONIC INFORMATION SYSTEMS POLICY

All Company electronic business equipment, including but not limited to Company-issued computer hardware and
software, telephones, e-mail, voice mail, Internet and Intranet access, is provided to increase your efficiency and
productivity by allowing you to obtain work-related data. These tools are Company property. Although the Company
does not routinely or randomly exercise such rights, the Company does have, at all times, the legal right, as well as
the occasional legal obligation, to monitor the use of such equipment and to review, inspect and disclose all
material stored or produced, using Company-issued equipment. Therefore, all passwords, keys and other means
necessary to access Company equipment and its contents must be available to the Company.
Although no employee has the right to access any other employee's files or messages without the latter employee's
permission, understand that no communications or information accessed through or stored in any business
equipment should be considered to be truly private or confidential. The Company reserves the right to monitor use
as warranted. Note that even when an electronic or voice mail message or file is deleted/erased, it is still possible
to retrieve/recreate it. You should also be aware that such material may become what is called "discoverable
evidence" in litigation, meaning the Company could be required to preserve it and produce it in court.
The Company strives to maintain a productive workplace free of harassment and is sensitive to the diversity of its
employees. Therefore, the Company prohibits the use of computers, the e-mail system and other electronic
information or telecommunication systems in ways that are disruptive, offensive to others, or harmful to morale.
While the Company does not have any blanket prohibition on personal use of these electronic resources, we do
expect employees to behave responsibly. No material inappropriate for the workplace should be accessed and both
the Company’s and others’ intellectual property rights should be respected.
All general workplace rules apply, including, without limitation, prohibitions on harassing use, creation of a hostile
work environment, or showing disrespect for others. The Company does not permit mass distributions by
employees of non-business material through these systems because of the limited capacity and capabilities of the
equipment and the potentially disruptive nature of such communications.
You are also asked to take appropriate measures to secure confidential, privileged, proprietary, or sensitive
information and trade secrets when sending this type of information via email. Messages should be routed only to
those with a legitimate need to know and they should have appropriate marking that such messages are privileged,
confidential, and proprietary or contain sensitive information, and, if necessary, the transmissions should also be
encrypted.
The following behaviors are examples of actions and behaviors that are considered inappropriate – the display
and/or transmission of voice, images and/or text that are:
• Sexually-oriented
• Ethnic slurs
• Racial comments
• Off-color jokes
• Forgeries or misidentification of the sender
• Alterations to others' messages not clearly identified as such
Anything that may be construed as harassing or showing disrespect for others is considered inappropriate.
Because the Company does not tolerate a hostile working environment, you should contact your immediate
supervisor if you encounter another employee engaged in what you believe to be such inappropriate behavior using
electronic business equipment. Employees who violate this policy will be subject to disciplinary action, up to and
including termination of employment. Employees may also be held personally liable for any violations of this policy.
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September 2022
SOCIAL MEDIA POLICY

Social media is a critical part of communicating and creating connections across the globe. It empowers individuals
to communicate not only with each other, but with the public, sharing personal information, profiles, opinions,
experiences, photos, videos, and other content. This policy covers social media, a category of online media that
uses the Internet to facilitate “one-to-many” conversations and applies
to all employees of the Company.
Social media includes personal and professional networking sites (e.g.,

Facebook, Twitter, Instagram, Glassdoor and LinkedIn), review sites
(e.g., Digg, Reddit and Wikimedia), media sharing sites (e.g. SnapChat,
YouTube, TikTok and Flickr), as well as other electronic media (e.g.,
blogs, message boards, chat rooms, e-newsletters, personal websites
and similar services). This list is not exhaustive - as the platforms and
applications are constantly evolving - but contains examples to illustrate
the breadth of social media.
All CMG media properties strive to reflect the communities served by

the Company without bias towards any group or section of the
community. When reporting news, it is crucial that we are impartial.
What you say or do on social media can reflect on CMG.
As a multi-faceted media company, CMG believes that social media

presents an exciting and valuable tool to grow its business and to better
connect with and serve its audiences and customers. The Company
recognizes the importance of social media in the workplace and in the
personal lives of our employees. This policy has been developed to help
empower CMG employees to interact and exchange ideas and
information on social media, participate with confidence, and maintain
the integrity of CMG’s news reporting.
Employee Usage of Social Media
What you do on social media may, and should be expected to, reflect on CMG. This is not limited to when you
participate in social media as part of your job. Even when participating in social media on your own time, if you
choose to identify yourself as a CMG employee or to discuss CMG or matters related to our businesses, or if you are
a recognizable media personality, you may be viewed by others as representing the Company. CMG has developed
company expectations that apply to all employees and are listed below. Additionally, certain TV and Radio Content
employees are required to follow additional expectations related to their positions, which are also included below.
• Think Before You Post Exercise sound judgment and common sense in utilizing social media. You should
assume that what you post on social media may be viewed by anyone and that your posts are not
anonymous, regardless of whether you use a pseudonym or no name at all. Once information is posted on
social media, you should also assume that it will be permanent, even if you think you have deleted it. You
have sole responsibility for what you post, so be certain you want to post it.
• Your Relationship with CMG If you post about CMG or CMG-related matters, in the interests of “full
disclosure,” we recommend you note your connection with CMG, including your name and your role at CMG.
But employees should also be careful to avoid giving the impression that they are speaking for the Company
when they are not authorized to do so. We recommend that you make clear in posts that your opinions and
views are personal and that you are not authorized to speak for the Company (for example, by saying, “This
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is just my personal opinion and not that of CMG...”). This is especially important when you disclose that you
are an employee of the Company. Only authorized personnel can speak on behalf of the Company.
• Respect Intellectual Property Upon their creation, almost all creative works are protected by copyrights
owned by the creator of that work. Respect the copyrights and trademarks of other people and companies.
Do not take, copy, use or claim authorship of something that is not yours.
• Protect Confidential Information Do not reveal any confidential, non-public, or proprietary or personal
information which belongs to the Company that you learn of in your capacity as an employee about other
employees, customers, vendors or business partners. Confidential information includes but is not limited to
confidential financial/business documents, programming information, plans, procedures and style, advertiser
lists, marketing surveys and analysis, rate cards, promotional ideas and strategies, and includes more than
just documents and electronically stored materials. It also includes many things you see or hear while at
work.
• Do Not Violate CMG’s Policies Do not post harassing, hateful, racist, bullying, or threatening comments,
obscene or pornographic material, or engage in any other conduct that would violate CMG’s policies,
including but not limited to CMG’s policies against sexual harassment, discrimination, and retaliation.
Company policies relating to employee conduct apply, even if you engage in the conduct on social media.
Ignorance of policy is not an acceptable excuse. If you have a complaint or concerns about work, including
complaints about co-workers or management, the Company encourages you to use available internal
procedures for reporting those complaints.
• Business Interests of the Company Avoid posting maliciously false comments about the Company’s
existing or potential customers, clients, products, services, vendors, or competitors.
• Participate Responsibly and Obey the Law When you express your views and opinions in public via social
media, you are legally responsible for your commentary. You may be held personally liable for any
commentary deemed to be defamatory or libelous or that discloses proprietary information or otherwise
violates the law.
• Company Monitoring CMG regularly monitors public postings, comments, or discussions on the Internet
and social media pertaining to CMG, its businesses, competitors, customers and the industry. Employees
should have no expectation of privacy with respect to their publicly accessible postings in social media. Your
postings can be reviewed by anyone, including the Company.
Additional Expectations for TV and Radio Content Employees
These expectations apply to TV and Radio content employees, including but not limited to: On-Air Talent, News
Directors, Programming Directors, Reporters, Promotions Teams, Music Station Personalities, Producers,
Writers and Editors. Radio opinion-based talk show talent should follow the strategy outlined within the station’s
Strategic Action Plan.
• Do not break news on social platforms. The first priority is CMG owned and operated properties. Once reported
by CMG, that news can (and should) be distributed on social media platforms with links back to CMG owned and
operated properties.
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September 2022
• News reports on social media should be accurate, appropriately sourced and approved through normal
leadership channels. The Company expects employees to apply the Company’s broadcast standards in their use
of social media.
• Our audiences should be confident that our original news reporting is not influenced by political pressures or
personal agendas. Posts reporting news while doing so as part of your duties as TV and Radio content
employees or on social media accounts, including individual accounts, that are owned or controlled by the
Company may not include statements of support or opposition to any social issue, political position, office holder
or candidate.
• Do not discuss Nielsen ratings or disclose Nielsen data or claims based on Nielsen data.
• Likes and retweets of others’ posts that include statements of support or opposition to any social issue, political
position, office holder or candidate are also not permitted.
• Do not retweet anything from a competitor or competing network news source. For example, if you work for an
ABC affiliate, do not retweet anything from CNN or CBS News.
• Do not argue or debate with others on social media over their expressions of support or opposition related to any
social issue, political position, office holder or candidate, or otherwise comment on social media about such
expressions of support or opposition of other people.
• At all times, exercise discretion and thoughtfulness for colleagues, business associates, the subjects you are
writing about, competitors and others on social media.
• If you believe you or your reputation have been attacked on social media, please consult with your normal
leadership channels to determine if a response is appropriate and if so, how that response should be worded.
• Keep internal confidential deliberations regarding news coverage confidential. Do not discuss confidential
management decisions regarding news coverage, how a story was reported, written, edited or produced, stories
in progress, interviews conducted, or any future coverage plans.
• Your social media activity is permanent in the public domain. Before you post, please consider the impact of
online actions and remember that the public may view your speech through your role at CMG and assume you
are speaking on behalf of your station.
• Do not post praise or disparage the competition or a competitor employee’s work product.
(Personal and not publicly accessible notes to a competitor or a competitor’s employee are permissible.)
The misuse of social media by a CMG employee can have a severely negative impact on CMG, our stations,
employees and business partners, and could result in a range of consequences, including, but not limited to
disciplinary action up to and including termination of employment. Managers are expected to fully enforce these
expectations among their teams.
Expect This Policy to Change as technology and social media continue to evolve, this policy will be periodically
revised to respond to changes.
Nothing in this Policy prohibits employees from engaging in any activity that is protected under applicable law,
including, without limitation, Section 7 of the National Labor Relations Act.
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September 2022
NEWSROOM ETHICS POLICY

”We believe that the manner in which we accomplish our work is as important as the work itself.”
For CMG, this statement from Cox Media Group’s Guideline to Business Conduct and Ethics (Ethics Guidelines) resonates with special force.
As journalists, we must earn the trust of our audience every day. Our professional integrity is the cornerstone of our credibility. Fairness and
transparency must always be the hallmarks of CMG’s journalism.The principles set forth below supplement Cox Media Group’s Ethics
Guidelines. They define the ethical standards that the news personnel in all of CMG’s newsrooms must strive to attain.
WE SEEK THE TRUTH AND OPERATE TRANSPARENTLY
Our journalistic endeavors are built on a search for truth. That means we must consistently strive to adhere to the highest standards of
truthfulness. In our news reports, we do not lie; we do not fabricate, and we do not distort images or audio in a manner that is misleading. We
report the news accurately and as completely as possible. We are transparent about our values and our news gathering methods. We admit our
errors and correct them.
WE SERVE THE PUBLIC INTEREST
In pursuing the truth, our journalism advances the ‘’ultimate good” of the communities that we serve. To best achieve this result, we have a
responsibility to function as a watchdog on government and other institutions and to seek solutions to problems in our communities. We provide
information that allows our audiences to be effective citizens and enables them to improve their lives. We provide a forum for discussion and allow
a diverse mix of voices to be heard. We defend the rights of a free and independent press on behalf of our audiences.
WE OPERATE WITH INDEPENDENCE
We avoid relationships that could cause our audience to question our integrity or credibility. We avoid conflicts of interest and obligations to those
who seek to influence the news, and we disclose those conflicts that are not avoidable. We make news decisions independently, without outside
influence. We do not accept gifts, favors or compensation from those whom we cover.
WE RESPECT THE LAW AND TREAT OTHERS RESPECTUFLLY
We understand the power of our role and seek to minimize harm. In our news gathering and reporting, we respect the law. We also recognize
that our work may cause distress and discomfort to the subjects of news stories. We treat such persons with respect and dignity. We also treat
competitors professionally. We do not plagiarize. We do not obstruct the reporting of others. Where appropriate, we give attribution.
WE ACKNOWLEDGE A RESPONSIBILITY TO SEEK OUT GUIDANCE TO DO THE RIGHT THING
No code of ethics can cover every circumstance. We acknowledge it is the responsibility of each of us to seek guidance when there are questions
about how to best uphold our values and protect our credibility.
This Code embodies the standards of journalistic conduct applicable across CMG newsrooms. Consistent
compliance with this Code of Ethics is essential to preserving the reputation of CMG and its properties as a credible
and trustworthy source of news.
To even further advance these goals, many of the major platforms within CMG (newspapers, television, radio and
others) have developed more specific Operating Principles relating to particular ethical and practical issues that arise
in their medium. It is important that you are also very familiar with these Operating Principles.
Finally, all CMG personnel (whether employed in newsrooms or not) are subject to Cox Media Group’s Ethics
Guidelines. These Guidelines are online and available from management offices in all units.
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September 2022
PERSONAL DATA SECURITY POLICY INTRODUCTION

This policy is established to help safeguard the Personally Identifiable Information
("PII') of this Company's employees and customers and any other individuals whose PII has come into this
Company's possession. The purpose of this policy is to deter identity theft and fraud as well as to comply with
applicable law.
"Personally Identifiable Information" Defined
Personally Identifiable Information refers to an individual’s name (i.e., first name, last name or first initial and last
name) in combination with one or more of the following personal data elements (in electronic or physical form):
• Social Security Number (any portion)

• Date of Birth
• Place of Birth
• Mother’s Maiden Name
• Biometric Data (e.g., finger or voice print, retina or iris image)
• Telephone Number (landline or cellular)
• Personal Email Address
• Personal Postal Address
• Username (e.g., associated with an employee or consumer)
• Employee ID Number
• Personal Identification Number (associated with any account)
• Credit Charge or Debit Card information
• Driver’s License Number or State Issued Identification Card Number
• DMV Information (including driving record history)
• Passport Number
• Financial Account Information in combination with any security code, access code, routing code or password
• Medical information (includes any individually identifiable information relating to a person’s past, present or
future physical
• An individual’s digitized or electronic signature
• Bill/Invoice Images
• Insurance-related information
• Accounts receivable/collections history
Employee Duty to Secure PII
Company employees are required to secure, safeguard and keep confidential any Personally Identifiable
Information they have access to in the course of their employment with this Company.
To meet the above requirements, all Company employees must adhere to the following: Company employees are
prohibited from:
1. Disclosing or using Personally Identifiable Information for any purpose other than for Company business;
2. Transferring Personally Identifiable Information to or storing it on any non-Company device or unauthorized
communication service;
3. Transferring Personally Identifiable Information to or storing it on any Company device that is not
authorized for use with PII,
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4. Sharing with anyone (e.g., co- workers, contractors or third parties) any Company-issued device or unique
identifier or access password that might grant the user access to Personally Identifiable Information, or
5. Engaging in any other practice that jeopardizes the security of PII.
Examples of inappropriate conduct involving PII include, but are not limited to, providing a co- worker your
username and password to a Company computer network containing PII; permitting a third-party access to a
Company computer containing PII; emailing PII to your personal email account; copying PII to your personal
computer; or disclosing a Company customer list containing PII to a friend or Company competitor.
In addition, Company employees are required to:

1. Limit access to Personally Identifiable Information to only those Company employees and contractors
whose job or work assignment requires such access;
2. Use methods authorized by the Company to securely transmit or distribute Personally Identifiable
Information;
3. Use methods authorized by the Company to securely store Personally Identifiable Information on approved,
Company-issued devices;
4. Use appropriate methods to destroy Personally Identifiable Information; and
5. Observe any additional restrictions designed to protect PII that may be implemented by management.
Examples of appropriate practices involving PII may include, without limitation removing PII from files provided
to employees or contractors that have no need to access PII; encrypting stored files containing PII; encrypting
email messages or attachments containing PII; storing hardcopy files containing PII in locked file cabinets or
using a cross- cut shredder to destroy documents containing PI/. Not all of these examples of appropriate PII
practices necessarily will apply in each Company workplace. depending on available resources and other
practical considerations. The Company will provide separate guidance on the specific practices required in each
situation.
Employee Duty to Report Possible Data Security Breaches To Management
In the event an employee becomes aware of any incident that involves or even "might" involve the unauthorized
use, transfer or disclosure of Personally Identifiable Information, such employee is required to report that incident to
Company management. Management, in tum, in conjunction with the Company's Security and Legal advisors will
determine the appropriate steps to take in response to such possible breach of data security to fulfill the purposes
of this policy and the requirements of applicable law.
Examples of incidents that might involve a breach of personal data security which triggers the reporting obligation
include, but are not limited to, having reason to believe that a device containing PII has been lost or stolen, having
reason to believe that an individual (e.g., employee, vendor or contractor) with legitimate access to a Company
system or network obtains and uses, or might use, Company PII in an unauthorized matter or for illegitimate
purposes, or having knowledge that hardcopy documents containing PII were lost or misdirected by a courier during
shipment.
This Company will not tolerate violations of this policy. Employees who violate this policy will be subject to
disciplinary action, up to and including termination of employment. Employees may also be held personally liable
under law for activities that violate this policy.
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September 2022
INSPECTION AND MONITORING POLICY

CMG may provide offices, furniture, desks, lockers, file cabinets, computers, and other storage equipment for use
by employees. Such items, however, remain the sole property of CMG at all times, whether or not employees have
contents stored in them, and they, as well as the contents found in them, may be inspected by an agent or
representative of the Company, at any time, with or without notice, or when necessary to comply with the law. In
some instances, inspections may include surveillance carried out within the limits of the law. CMG also may
question individuals at a Company location within the limits of the law.
Employees should have no expectation of privacy with respect to anything they bring onto Company property or
their use of Company property, unless otherwise required by law.
REPORTING SAFETY CONCERNS POLICY

If you become aware of a safety or health issue or become injured while working, you must report the issue or your
accident, injury, or illness to your supervisor immediately or as soon as you become reasonably aware of the injury.
If your supervisor is unavailable, report the issue or your injury to your designated People Solutions representative.
Consistent with the Company’s Driving Policy, all vehicle accidents that happen in a Company vehicle, or non-
Company vehicle on work-related business, must be reported to your supervisor, regardless of whether there is
damage or whether you are at fault. In addition, these accidents must be reported to the police immediately and a
police report must be filed. The only exception is if the accident occurs on private property and local law enforcement
will not take reports on private property.
If you have safety suggestions, please share them with your supervisor or your designated People Solutions
representative
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September 2022
WORKPLACE VIOLENCE PREVENTION POLICY

As part of the Company’s commitment to provide a safe and secure work environment, the Company prohibits
threatening behavior, acts of violence, bullying or intimidation, and obscene, abusive, or threatening language or
gestures. The Company has a “no-tolerance” policy which means it will not condone any acts or threats of violence
against its employees, customers, or visitors by any individual on the Company’s premises at any time or while they
are engaged in business with or on behalf of the Company, whether on or off Company premises. The Company is
committed to attempting to diffuse potentially volatile situations involving employees, visitors or customers.
In an effort to minimize the risk of physical injury or harm to employees and except when authorized by Executive
Vice President & Chief People Officer, all employees are expressly prohibited from carrying any type of weapon onto
Company property whether in the employee’s lunch box, locker, or through other means, or possessing a weapon in
a Company vehicle or, unless prohibited by applicable law, a personal vehicle while it is being used on Company
business. To the extent an employee uses a personal vehicle for work-related use in a jurisdiction where the
Company cannot restrict possession of the type of weapon the employee has, the employee must comply with all
applicable weapon-related laws while driving on Company business. Except where prohibited by applicable law,
employees are subject to a search of any property brought into the work area at any time management determines,
in its sole discretion, such is necessary to enforce this policy against workplace violence.
Any employee refusing to consent to such a search or who is discovered to have brought a weapon onto Company
premises or to be in the possession of any type of weapon is subject to immediate termination from the Company,
except where prohibited by applicable law, and then only when the employee is acting in compliance with applicable
law.
Unless prohibited by applicable law or approved by Executive Vice President and Chief People Officer, employees
may not possess weapons while conducting business at a third-party location.
Employees are entitled to a work environment that is safe and secure and that promotes productivity and efficiency.
Therefore, employees are required to report to their supervisor or other management representative any act or
behavior, whether from an employee, visitor or a customer, that they believe to be suspicious, concerning or
threatening. While the Company cannot identify all behavior or comments that might suggest a potentially volatile or
violent situation, employees should report any behavior involving overt or implied threats of physical harm or injury,
loud and disruptive or abusive language, any agitated or hostile behavior that suggests a potentially violent or
explosive situation, or could become a violent situation, any other suspicious or questionable behavior that puts an
employee in fear for his/her safety or the safety of others, or any time an employee is or becomes aware of the
presence of any type of weapon on Company premises or in the possession of an employee, visitor or customer.
If in doubt as to whether you are dealing with a potentially volatile or explosive situation or whether to make a
report, involve your supervisor or other appropriate manager immediately so that appropriate steps or actions may
be taken. The Company will conduct a timely, fair and impartial investigation to determine if there has been a
violation and, if so, the appropriate action to be taken to address any such violation. The Company will decide how
to diffuse any situation and when, if necessary, to promptly respond to the incident, remove individuals from the
Company’s premises, or notify the appropriate authorities.
If the Company is not advised in a timely manner about such behavior, the Company is hampered in its efforts to try
and maintain a safe and secure work environment. Be aware and alert, and let your manager know of anything
alarming or suspicious.
Page 45 of 46
September 2022
The Company takes this commitment to a safe and secure work environment seriously and does not condone acts
that conflict with its commitment. Therefore, any employee found to have acted in a manner contrary to this policy
against workplace violence, whether by bringing a weapon of any type onto Company premises, engaging in
workplace violence or threat of violence, being convicted of an offense involving the use of a weapon or the
commission of violence, or acting in any other manner contrary to this policy, will be subject to discipline, up to and
including immediate termination, except where prohibited by state law, and then only when the employee is acting
in compliance with state law.
In addition, all individuals who apply for or obtain a protective or restraining order which lists or includes Company
locations as being protected areas, must provide to People Solutions a copy of the petition and declarations used
to seek the order, a copy of any temporary protective or restraining order which is granted, and a copy of any
protective or restraining order that is made permanent.
Page 46 of 46

CMG Culture Code

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The Culture Code: A Look Into CMG’s Values & Principles

A MESSAGE FROM DAN YORK

Cox Media Group’s success is founded on our mission - to

That’s what The Culture Code, formally called the Code of

Who Must Follow The Culture Code ............................................................................................................................ 6

Newsroom Ethics Policy ............................................................................................................................................. 41

WHO MUST FOLLOW THE CULTURE CODE

Unless you are represented by a union or have an

As an employee at CMG, you are responsible for knowing

WHY THE CODE IS SO IMPORTANT AT CMG

WHAT HAPPENS IF OUR CODE

It is your responsibility to always strive to do what’s right as part of

Take action if you see or suspect a violation of our Code;

• Discrimination or harassment • Environmental or safety issues

WE RESPECT EACH OTHER AND CONDUCT BUSINESS

WE RESPECT THE PRIVACY OF OTHERS

WE USE COMPANY-ISSUED DEVICES PROPERLY

WE FOLLOW THE LAW

WE PROMOTE DIVERSITY AND INCLUSION AT WORK

We provide equal employment, equitable development,

As part of our commitment to providing equal employment

WE DO THE RIGHT THING

Unless you’re authorized to handle media

Political Activities and Lobbying

Protect our workplace

WE SAFEGUARD AND PROTECT COMPANY ASSETS

WE MAINTAIN ACCURATE RECORDS

Contacts & Other Resources

CONTACT: FOR HELP WITH: CONTACT INFORMATION:

Not sure who to contact, please email

The Ethics Hotline Known or suspected violations 844-775-6640, website:

MyLife Advisors Payroll, Benefits, PTO, and 1.855.547.8508 or

Employee Assistance Personal, family or work-related Magellan Ascend or call

Corporate Communications and Communicating about Cox Media [email protected]

EQUAL EMPLOYMENT OPPORTUNITY POLICY

REASONABLE ACCOMMODATIONS POLICY

OPEN DOOR—PROBLEM RESOLUTION POLICY

ANTI-DISCRIMINATION AND ANTI-HARASSMENT POLICY

Reporting Prohibited Conduct

Illinois Office Locations Complaint Deadline

Springfield: 222 S. College, Room 101-A, Intake

Marion: 2309 W. Main St., Marion, IL 62959

Springfield: William G. Stratton Bldg., Suite 802,

Massachusetts Office Locations Complaint Deadline

Springfield:424 Dwight St., Rm. 220, Springfield, MA

Vermont Office Locations Complaint Deadline

III. POLICY PROVISIONS

STANDARDS OF CONDUCT AND DISCIPLINE POLICY

SOLICITATION AND DISTRIBUTION POLICY

SMOKE-FREE WORKPLACE POLICY

EMPLOYMENT STATUS, SALARY BASIS/SAFE HARBOR AND PAY

Salary Basis/Safe Harbor

Pay for All Time Worked

CONFLICTS OF INTEREST DISCLOSURE POLICY

IV. POLICY PROVISIONS

4. Working with Relatives

For purposes of this policy, the term “relative” is defined as follows: