LegalTake-Two Interactive
Policy for Reporting Misconduct
1 Apr 20232 pages~4 min full read
Take-Two Interactive’s April 2023 misconduct policy mandates that all employees, consultants, and agents report violations of law, regulations, and the company's Global Code of Business Conduct and Ethics.
The policy explicitly prohibits retaliation against individuals who report suspected misconduct in good faith, citing protections under Section 806 of the Sarbanes-Oxley Act and Section 922 of the Dodd-Frank Act.
Employees are permitted to report violations directly to governmental agencies or whistleblowing entities without requiring prior company clearance.
The company provides a global reporting infrastructure featuring toll-free hotlines in twenty-four countries across North America, Europe, Asia, and Oceania.
Reporting channels include direct communication with supervisors, legal counsel, HR, the Board of Directors, or a 24/7 third-party ethics hotline that supports anonymous reporting where legally permitted.
The policy specifically prioritizes the identification of financial irregularities, including fraud, embezzlement, kickbacks, and accounting or auditing discrepancies.
The April 2023 misconduct reporting policy for Take-Two Interactive Software establishes a mandatory framework for identifying and addressing violations of law, regulation, and the Global Code of Business Conduct and Ethics. The policy applies to all employees, consultants, and agents acting on behalf of the company and its global subsidiaries. It emphasizes the necessity of reporting financial irregularities, including fraud, embezzlement, kickbacks, and accounting or auditing discrepancies. By mandating transparency, the company aims to maintain internal controls and ensure compliance with international business standards.
The scope of the policy is global, providing specific toll-free hotline numbers for twenty-four countries across North America, Europe, Asia, and Oceania. Reporting mechanisms are designed for accessibility and include in-person or telephonic communication with supervisors, legal counsel, human resources, or the Board of Directors. Additionally, a third-party ethics hotline operates twenty-four hours a day, allowing for anonymous reporting where permitted by local law. The company commits to prompt, discrete investigations and appropriate remedial actions while maintaining confidentiality to the fullest extent possible.
A central tenet of the policy is the strict prohibition of retaliation against individuals who report suspected misconduct in good faith. It explicitly forbids interference with the reporting process, aligning with statutory protections such as Section 806 of the Sarbanes-Oxley Act and Section 922 of the Dodd-Frank Act. Furthermore, the policy clarifies that internal procedures do not preclude individuals from reporting violations directly to governmental agencies or whistleblowing entities without prior company clearance. This dual approach ensures that the organization remains accountable to both internal ethical standards and external regulatory requirements.
