LegalTake-Two Interactive
Global Code of Business Conduct and Ethics
1 Apr 202322 pages~42 min full read
Take-Two Interactive enforces a mandatory global code of conduct for all employees, directors, and third-party partners, with violations subject to termination.
See it on page 3The policy mandates strict financial transparency and prohibits market manipulation, including insider trading, antitrust violations, and the unauthorized disclosure of sensitive corporate information.
See it on page 11A zero-tolerance policy applies to bribery, corruption, money laundering, and tax evasion, requiring rigorous due diligence for all third-party agents interacting with public officials.
See it on page 14Employees are required to disclose potential conflicts of interest, including outside employment and romantic relationships, to maintain organizational accountability.
See it on page 7The company provides a 24/7 anonymous reporting hotline managed by the Chief Legal Officer or Audit Committee, supported by formal anti-retaliation protections for whistleblowers.
See it on page 18Compliance is maintained through biennial training sessions, and any rare executive-level waivers of these ethical standards must be publicly disclosed to shareholders.
See it on page 4Operations are subject to strict geographic restrictions, including specific prohibitions on business activities within sanctioned territories such as Iran and North Korea.
See it on page 17Take-Two Interactive maintains a comprehensive framework of mandatory ethical standards designed to ensure integrity, legal compliance, and the protection of human rights across its global operations. These standards apply to all employees, directors, and third-party partners, covering a broad geographic scope that includes specific restrictions regarding sanctioned territories such as Iran and North Korea. By establishing strict protocols for non-discrimination, the protection of corporate assets, and the disclosure of potential conflicts of interest—including outside employment and romantic relationships—the organization fosters a culture of accountability. Compliance is reinforced through biennial training and a rigorous enforcement mechanism where violations may lead to termination.
Corporate integrity is further supported by mandates for financial transparency and fair competition. All financial records must accurately reflect transactions, and the unauthorized disclosure of sensitive information to shareholders or the media is strictly prohibited. To prevent market manipulation, the framework forbids insider trading and establishes clear antitrust guidelines that prevent the exchange of commercial data with competitors or interference with the pricing rights of distributors. Furthermore, the organization enforces a zero-tolerance policy toward bribery, corruption, money laundering, and tax evasion. This extends to third-party agents, who must undergo due diligence to ensure all business dealings, particularly those involving public officials, remain ethical and legal.
To facilitate the reporting of misconduct, a 24/7 anonymous hotline is provided, allowing for the confidential disclosure of grievances to the Chief Legal Officer or Audit Committee. Strong anti-retaliation protections ensure that individuals reporting concerns in good faith are shielded from adverse actions, though disciplinary measures apply to those who provide knowingly false information. Waivers of these ethical requirements are exceptionally rare, requiring formal approval from the Board of Directors or the Chief Legal Officer, with any executive-level exceptions disclosed publicly to shareholders to maintain institutional transparency.
