WSJ employees told to fill out code of conduct questionnaire
Employees of the Wall Street Journal and other Dow Jones publications were reminded today to take the Dow Jones Code of Conduct Questionnaire. Rupert Murdoch’s company says it’s “designed to remind all of us at Dow Jones of our need to maintain the highest possible standards of behavior in order to keep the public trust so vital to our continued success.”
The staff memo is below and the questionnaire is after the jump.
From: [Dow Jones HR Dept.]
Sent: Wednesday, April 04, 2012 11:23 AM
To:
Subject: IMPORTANT: Dow Jones Code of Conduct QuestionnaireREMINDER:
Please complete the Code of Conduct Questionnaire by April 9, 2012.Original Email from March 28, 2012:
To: Dow Jones Employees
Our Code of Conduct is designed to remind all of us at Dow Jones of our need to maintain the highest possible standards of behavior in order to keep the public trust so vital to our continued success. The Code of Conduct, which predated the acquisition of Dow Jones by News Corporation, continues to apply to all employees. As a News Corporation company, Dow Jones and its employees are also governed by News Corporation’s Standards of Business Conduct. You may review the Standards of Business Conduct Policy via the following link.
Once again this year, we are asking all Dow Jones employees to specifically attest that they have complied with the Code of Conduct. I ask that you please electronically complete the Code of Conduct questionnaire via the following link to our internal website: Code Of Conduct Questionnaire.
Please note that the questionnaire relates to employee conduct in calendar year 2011. As a result, although the Dow Jones Code of Conduct was revised in January 2012, the questionnaire relates to the previous version of the Code. For your convenience, this previous version of the Code is accessible via [an internal link].
Please submit your completed questionnaire electronically by April 9th, 2012.
After you submit your questionnaire you will receive an email confirmation. Keep this confirmation for your records as proof of submission.
In addition, feel free to contact Kristin Mannarino in Compliance at [email address] if you have questions regarding the Code of Conduct questionnaire.
Thank you in advance for your cooperation.
Best regards,
Jason P. Conti
Chief Compliance Officer
VP & Associate General Counsel
THE CODE OF CONDUCT QUESTIONNAIRE IS AFTER THE JUMP
I. Confidential Information
01) During 2011, have you disclosed any non-public information obtained in connection with your Dow Jones employment to anyone outside of the Company that was not authorized by your supervisor or required by the nature of your position?
Yes
No
02) During 2011, have you used any non-public information obtained in connection with your Dow Jones employment to buy or sell securities or to encourage or assist in any way any other person in buying or selling securities?
Yes
No
03) During 2011, have you used any non-public information obtained in connection with your Dow Jones employment for your personal benefit or for the benefit of others?
Yes
No
II. Business Relationships & Activities
01) During 2011, did you directly or indirectly offer or provide any gift, hospitality or other thing of more than nominal value or that otherwise exceeded customary courtesies for that time and place, to customers or prospective customers?
Yes
No
02) During 2011, did you directly or indirectly offer or provide any equipment, material, or services to any individual in a position to make or influence any business or governmental decision affecting Dow Jones?
Yes
No
03) Are you aware of any other person having directly or indirectly given, offered or promised to give any such gift, hospitality or other thing of value as referred to in Questions 1 and 2 above?
Yes
No
04) During 2011, did you directly or indirectly solicit or accept any payment, loan, services, equipment, gift, hospitality or other thing of more than nominal value or that otherwise exceeded customary courtesies for that time and place from suppliers, customers, anyone with an actual or prospective business relationship with Dow Jones, or any company, individual or institution seeking to furnish news or information?
Yes
No
05) During 2011, have you requisitioned, ordered, approved or otherwise participated in the purchase of goods or services on behalf of Dow Jones from any person or entity in which you or any family or household member has a substantial financial interest, whether by way of stock ownership or loans or otherwise?
Yes
No
06) During 2011, have you served on the board of directors or as an officer or partner of any company devoted to profit-making for which you have not received proper written approval from the Company?
Yes
No
07) During 2011, have you duplicated without authorization computer software developed internally or obtained from outside suppliers for business or personal use?
Yes
No
III. Securities Transactions
01) *Please refer to the Explanation of Terms at the bottom of the Questionnaire*
During 2011, have you invested in or sold a security in any company about which you received inside information as a result of your employment with the Company?
Yes
No
02) During 2011, have you engaged in short selling of securities?
Yes
No
03) If you are a senior manager or a member of a news or advertising department, during 2011, have you engaged in short-term trading of equity securities or non-investment grade fixed-income securities (other than trading of publicly available diversified mutual funds)?
Yes
No
N/A
Please Note: You cannot answer N/A if you are a senior manager or a member of a news or advertising department.
04) If you are a member of a news or advertising department or a member of senior management with any responsibility for news or advertising, during 2011, have you purchased or sold any futures or options (other than equity index related products and publicly available mutual funds or commodity pools that invest in futures or options)?
Yes
No
N/A
Please Note: You cannot answer N/A if you are a member of a news or advertising department or a member of senior management with any responsibility for news or advertising.
05) If you are a member of a news or advertising department, during 2011, have you or any immediate family member bought or sold securities in any company engaged in whole or significant part in an industry that you were or are assigned to report or call on?
Yes
No
N/A
Please Note: You cannot answer N/A if you are a member of a news or advertising department.
IV. Political & Civic Activities
01) During 2011, have you authorized any Company payment as, or been reimbursed by the Company for, a contribution to any type of political organization or campaign?
Yes
No
02) During 2011, have you permitted your Dow Jones affiliation to be noted in any outside organizations’ materials or activities without the express written approval of a member of senior management (other than where your affiliation is noted as part of a broader description of your identity)?
Yes
No
V. Books & Records
01) During 2011, have you established or permitted to exist any fund, asset or liability on behalf of the Company which has not been fully and properly recorded in the financial records of the Company?
Yes
No
02) During 2011, have you effected any transaction or payment with the intention or understanding that the transaction or payment is other than as described in the documentation evidencing the transaction or supporting the payment?
Yes
No
03) During 2011, have you executed or authorized any false, artificial or misleading entries in any books or records of the Company?
Yes
No
04) During 2011, have you issued or authorized anyone else to issue any Company document that is false or misleading?
Yes
No
05) During 2011, have you knowingly accepted and treated as accurate any false or misleading document prepared by a person not employed by the Company?
Yes
No
06) During 2011, have you made any false or misleading statements to the Company’s external or internal auditors?
Yes
No
VI. Other
01) Are you aware of any potential violations of the Code of Conduct or any applicable laws or regulations by you or by any employee of the Company or person acting on behalf of the Company that have not already been reported to the Company?
Yes
No
Please Note: Any retaliation against an employee who makes a good faith report about a potential violation will not be permitted or tolerated. If you prefer not to report a potential violation through this questionnaire please take note of other reporting options which are detailed at the end of this questionnaire.
02) If you are a member of the news departments of The Wall Street Journal, Newswires or MarketWatch, during 2011, have you engaged in any conduct that is inconsistent with the guidelines contained in the Policies for Employees of the News Departments of the Wall Street Journal, Newswires and MarketWatch? (The Policy is accessible via the following link: WSJ-DJN-MW_Newsroom_Policies.pdf).
Yes
No
N/A
Please Note: You cannot answer N/A if you are a member of the news departments of The Wall Street Journal, Newswires or MarketWatch.
Jim – who cares? This happens every year at Dow Jones and has been going on for decades. It’s the same questions every year. What’s the news?
07)Have you ever tapped a phone or listened to phone messages without authorization? (Extra points if the phone belonged to someone who turned up dead)
08)Have you ever bribed a police officer for business purposes? (Don’t say yes if you were just trying to get out of a traffic ticket. Extra points if it was a really, really high-ranking police officer.)
“During 2011, have you disclosed any non-public information obtained in connection with your Dow Jones employment to anyone outside of the Company that was not authorized by your supervisor or required by the nature of your position?”
This would seem to prohibit chatting about the details of one’s day with one’s spouse.
Do other places have newsroom conduct codes of similar scope? Serious question. WSJ employees(and I am one) must fill out this form once a year. It’s been that way for at least the 17-plus yrs I’ve been here.