When Concerns are Raised
Workplace questions or concerns may be handled by managers, Human Resources, or other appropriate personnel. Concerns about illegal or unethical conduct are promptly routed to trained investigators to be addressed. We expect employees to cooperate fully and honestly in Company investigations. Some concerns may require an in-depth investigation, which could include interviews and reviews of documents. A violation of the Code or a Company policy may result in disciplinary action, including but not limited to termination of employment, impact to compensation, or other appropriate action, regardless of an employee’s title or tenure.
The Company will keep investigations confidential to the extent possible consistent with the need to conduct a thorough investigation and to resolve the concern.
Contact the Board
Concerns related to accounting, internal accounting controls, or auditing matters may also be sent to Audit_Committee_Chair@comcast.com and will be handled in accordance with procedures established by the Audit Committee of the Comcast Corporation Board of Directors.
Retaliation is Not Tolerated
No matter how you report a concern, we have no tolerance for retaliation. Company policy prohibits retaliation against any employee, officer, or director who in good faith raises a concern or participates in the investigation of suspected illegal or unethical conduct, even if a reported concern is ultimately unsubstantiated. Any violation of our anti-retaliation policy may result in disciplinary action, up to and including termination.
Nothing in this Code or any other Company policy limits the ability of an employee, officer, or director to communicate with or provide information to any governmental agency or commission, including the U.S. Securities and Exchange Commission, regarding possible legal violations without disclosure to the Company, as protected under applicable whistleblower laws. The Company prohibits retaliation for any of these activities.
More Information on These Channels is Available
For more information on the resources described in this section or to find additional reporting channels within your business unit, please visit the Integrity or People section of your business unit’s intranet or www.ComcastNBCUniversalListens.com or www.ComcastSkyListens.com.
Lead by Example: Additional Manager Responsibilities
As people leaders within the organization, a manager has additional responsibilities in support of our Company culture of integrity. Managers must set the right example and serve as role models for their teams and all employees.
Managers must foster an open reporting environment that encourages employees to ask questions, raise concerns, and speak up. When managers receive a concern, they must respond as follows:
- For a workplace issue, such as a day-to-day disagreement with a co-worker or question about Company policies, take immediate action to resolve the issue or contact your manager or a Human Resources representative for assistance in order to provide a timely response to the employee.
- For an allegation of suspected illegal or unethical conduct, such as an integrity issue, immediately report it using a designated channel. These channels include Legal (including Compliance), a Human Resources representative, or the Comcast NBCUniversal Listens or Sky Listens Helpline or Web Portal. Never investigate an allegation of suspected illegal or unethical conduct yourself.
Regardless of the concern raised, managers must never engage in any form of retaliation and must report retaliation by others.
