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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.
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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.
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Employees are permitted to report violations directly to governmental agencies or whistleblowing entities without requiring prior company clearance.
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The company provides a global reporting infrastructure featuring toll-free hotlines in twenty-four countries across North America, Europe, Asia, and Oceania.
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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.
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The policy specifically prioritizes the identification of financial irregularities, including fraud, embezzlement, kickbacks, and accounting or auditing discrepancies.