Code of Conduct

1Chapter

Header

1.1

Section header

Repeles dipsanda di dit ipsam, es ea nis eiumquos dolupid minventiae di dolores a as

dolorep ellaborepudi iunt aliquid uciatinus aut ea que nonseque odit voluptam, consedit

opta conessunt volo veritaque consedit latat.

Aperspe rferum repudip isciatectur apiendi ut et dolupti dolo blaut volor mos et, qui odi

odio. Ictio deliae pa dolorrum apeles simus dolectia pra duciissi te ernam quosse et et

doloria sitios sollaborem duci sit fuga. Nam, suntotaturis sitibus doluptatet asitibea quos

auda ipsunt inullupta si dit poraecab id quaernatet quossi bernamet laudis escitatem que

porum quodita temperepe volecto debitae que volectu rerspernam quis at re nus quisi

si blabo. Obis solecerferum dolupti conserume ni doluptatetur aut auta derum hiliquam,

quassed ignienia doluptas etum repturemos voluptatum comnis autatet et verrum quis

nimus.

Que enim eum et atempor eriaspedi nihillabo. Itatqui omni odioria deleni ius sin re

perchiciet ero bera quae la quia venia parum suntium harumqu isquam que ratum

quiberum aut explisite nonsequatur, tem id modis conecernam sa nustiatiam

volorempossi tem cone dernam et aut quate non pa velit plabo. Luptatempor aut quatur,

volutem porumquam elit ea dempore labo. Us, quis qui arum id quis aut eius.

1.2

Section header

Nam rae esto voluptatem aliqui arum volum at es aut odi ut faciam expligenit quat et

reiunt pores et magniaector sa cullo doluptatur? Imusam id quis prem volupta qui cor

serrum licatur? Udaest am sequam simus et dolorit, essedi occaborem lis senduci

mporatatis si oc totas doluptatio commoles as dolut optat occum net verferum rem. Ut

eum quam, sunte consecearum culpa voluptas eostis estions erferuptibus aces ut autem

aliquam, nossunt atet quis evenim eos erfero cus, que nimpel ium volut resequiam alitessi

dollab inverfe ribusanto ea netur? Omnient adios magnatur? Onsedis eum voloreriossi

solore sam et odi reptam ipsam a arcitiume num voluptat optiure ctotas sam audi rehent

et volo isto et magnime voluptae. Culluptatio eatur, totatur anto est, sequasp erovid mint.

Margin header

Repeles dipsanda di dit ipsam, es ea nis

eiumquos dolupid minventiae di dolores

a as dolorep ellaborepudi iunt aliquid

uciatinus aut ea que nonseque odit

voluptam, consedit opta conessunt volo

veritaque consedit latat.

Aperspe rferum repudip isciatectur

apiendi ut et dolupti dolo blaut volor

mos et, qui odi odio. Ictio deliae

pa dolorrum apeles simus dolectia

pra duciissi te ernam quosse et et

doloria sitios sollaborem duci sit fuga.

Nam, suntotaturis sitibus doluptatet

asitibea quos auda ipsunt inullupta

si dit poraecab id quaernatet quossi

bernamet laudis escitatem que porum

quodita temperepe volecto debitae

que volectu rerspernam quis at re

nus quisi si blabo. Obis solecerferum

dolupti conserume ni doluptatetur aut

auta derum hiliquam, quassed ignienia

doluptas etum repturemos voluptatum

comnis autatet et verrum quis nimus.

Margin header

Que enim eum et atempor eriaspedi

nihillabo. Itatqui omni odioria deleni ius

sin re perchiciet ero bera quae la quia

venia parum suntium harumqu isquam

que ratum quiberum aut explisite

nonsequatur, tem id modis conecernam

sa nustiatiam volorempossi tem cone

dernam et aut quate non pa velit plabo.

Luptatempor aut quatur, volutem

porumquam elit ea dempore labo. U

Integrity

is at the

core of

who we are.

Code of Conduct

October 2023

We are

Verizon.

We have work because our customers value

our high-quality communications services.

We deliver superior customer experiences through our products and our actions.

Everything we do we build on a strong network, systems and process foundation.

The quality and reliability of the products we deliver are paramount. Customers

pay us to provide them with services that they can rely on.

We focus outward on the customer, not inward.

We make it easy for customers to do business with us, by listening, anticipating and

responding to their needs. We know our products and can explain them to customers.

We focus on fundamental execution. We are accountable and we follow through with

a sense of urgency. We know that having the highest ethical standards is a competitive

advantage.

We know teamwork enables us to serve

our customers better and faster.

We embrace diversity and personal development not only because it’s the right

thing to do, but also because it’s smart business. We are driven not by ego but by

accomplishments. We keep our commitments to each other and our customers. Our

word is our contract. We respect and trust one another, communicating openly, candidly

and directly since any other way is unfair and a waste of time. We voice our opinion and

exercise constructive dissent, and then rally around the agreed-upon action with our full

support. Any one of us can deliver a view or idea to anyone else, and listen to and value

another’s view regardless of title or level. Ideas live and die on their merits rather than

where they were invented.

We believe integrity is at the core of who we are.

It establishes the trust that is critical to the relationships we have. We are committed

to do the right thing and follow sound business practices in dealing with our customers,

suppliers, owners and competitors. Our competitors are not enemies; they are

challengers who drive us to improve. We are good corporate citizens and share our

success with the community to make the world in which we work better than it was

yesterday.

We know that bigness is not our strength,

best is our strength.

Bureaucracy is an enemy. We fight every day to stay “small” and keep bureaucracy

out. We are more agile than companies a fraction of our size, because we act fast and

take risks every day. We see crisis and change as opportunities, not threats. We run to

a crisis, not away. Change energizes us. We work hard, take action and take personal

accountability for getting things done. Our actions produce measurable results.

Everything we do is built on the strong foundation

of our corporate values.

We work 24x7 because our customers depend on us 24x7. We know our best

was good for today. Tomorrow we’ll do better.

Integrity

Respect

Performance

excellence

Accountability

Social

responsibility

A letter

from Hans

Hello V Team,

Trust and transparency are the bedrock of any business. At Verizon, we conduct our

work at the highest level of operational excellence with integrity and accountability as

core values baked into the very fabric of our culture and Credo.

Guiding our operations, processes and behaviors is a Code of Conduct that reinforces

how we must manage our relationships and business. It provides a framework to gauge

when we need to seek guidance on ethical dilemmas and what to do when faced with

compliance concerns. Most of all, it’s a moral compass that lifts up our Purpose so that

we can continue to move the world forward.

Everyone has a role to play in making sure we hold ourselves to the highest ethical

standards and integrity in our work. At times, that may mean making some tough

decisions, but to remain at the forefront of the industry means we lead by example with

our values guiding us forward.

Please review our Code of Conduct and seek guidance if you have any questions or

concerns. Being part of the V Team means we have the honor of serving our customers

and communities who trust us and are counting on us to do right by them. It’s important

to not only understand our values but put them into practice by living them every day.

Together, we will continue to grow and elevate our standards to make our company even

greater than it is today. And we will do it the right way — the V Team way.

#ForwardTogether

Hans

Table of

contents

Introduction 6

Where to report 6

Cooperation with investigations 7

Section 1

A respectful, safe and professional workplace 8

A respectful and inclusive workplace 9

Commitment to diversity 9

Discrimination and harassment 9

A safe and healthy workplace 10

Workplace safety and environment 10

Workplace violence 10

Drugs and alcohol 11

Misconduct outside the workplace 11

A professional workplace 12

Solicitation and fundraising 12

Gambling 12

Employee privacy 12

Monitoring and recording at work 12

Section 2

Integrity and fairness in the workplace 14

Conflicts of interest 15

Personal conflicts of interest 15

Outside employment 16

Outside activities 16

Political interactions and contributions 17

Seeking public oce 17

Insider trading and securities transactions 17

Outside financial interests 18

Loans 18

Section 3

Protecting Verizon’s assets and reputation 19

Preparing, disclosing and maintaining accurate records 20

Promoting transparent and complete disclosure 20

Safeguarding company information 21

Acquiring other parties’ non-public information 21

Intellectual property 21

Gathering information about competitors 22

Protecting company communication

and information systems 22

Proper use of Verizon resources 22

Security of facilities 23

External communications 23

5 Verizon Code of Conduct Table of contents

Section 4

Integrity and fairness in the marketplace 24

Relationships with customers 25

Customer privacy 25

Customer marketing 25

Selling with integrity 26

Relationships with business providers and partners 26

Relationships with competitors 26

Relationships with former employees 27

Gifts and entertainment 27

Gifts 28

Entertainment 28

Bribery, anticorruption and government ethics 29

Anti-money laundering laws 29

International relationships 29

Locating oces or receiving

services outside the US 30

Compliance with sanctions

and anti-boycott laws 30

Import/export compliance 30

Sources of help 31

Quick references 31

Introduction

We are defined by our values: integrity, respect, performance excellence, accountability,

and social responsibility. These values should guide us in how we deal with every problem

at work, large and small. The Code of Conduct gives us detailed guidance about how to

apply Verizon’s values to specific issues and challenges that arise in our jobs. It reflects

our changing business environment and has been approved by the Verizon Board of

Directors.

You must follow the law, the Code of Conduct, and all Verizon policies and guidelines.

You can’t violate any of these rules for any reason, even if you are instructed to do so by

a supervisor. Violations of this Code, or any other Verizon policy, can lead to discipline up

to and including termination of employment.

But following the Code of Conduct is just a starting point. We’re all expected to help

maintain and promote the culture of integrity that is one of Verizon’s greatest competitive

advantages. A critical part of maintaining a culture of integrity is making sure that each

of us asks questions and raises concerns. If you do this, you can help the company spot

issues before they turn into problems. Reporting misconduct or ethics concerns isn’t just

an option – it’s each employee’s responsibility. You must report suspected misconduct

and violations of the Code.

Employees in supervisory roles have a special duty to set the right example. Supervisors

must promote an open door culture in which employees are comfortable speaking

their mind. Verizon prohibits retaliation against employees for submitting complaints or

cooperating with investigations, and anyone engaging in retaliation is subject to discipline,

up to and including termination of employment. If you believe that you or anyone else is

the subject of retaliation for reporting misconduct or cooperating with an investigation,

you must report it to the Legal Department, Verizon Ethics, or Human Resources.

If your local laws conflict with the Code of Conduct or your business unit has more

restrictive policies or practices, you must comply with the local law or the unit’s policy

or practice.

Where to report

You have an array of resources to assist you should you have any concerns or questions

about how the Code applies to a particular issue. Verizon Ethics is available 24 hours a

day, 7 days a week at 844-894-8433, verizonethics.com, or ethics@verizon.com. You

can make anonymous reports to Verizon Ethics, and you can contact Verizon Ethics

either to report misconduct or just to ask a question about the Code of Conduct

or company policy. A complete list of available resources is available at the end of the

Code of Conduct.

You must immediately report any instance of violence, hostile behavior, or possession of

weapons on company property to Security and a supervisor. In cases of imminent danger,

My manager is directing me to violate

the expense policy. I am concerned

that she will retaliate against me if

I report her. What do I do?

You should report the manager’s

misconduct. Retaliation against

employees who report concerns

is strictly prohibited, and if you have

concerns about retaliation, you must

report those as well. In addition,

you have the option of making an

anonymous report to Verizon Ethics.

you should contact 911 or local law enforcement first, and then contact

Security at 800-997-3287 (US) or 972-615-4343 (International).

You must report any concerns or questions you have about the accuracy or integrity of

Verizon’s financial statements, reporting, accounting, internal accounting controls, or

auditing matters to Verizon Ethics.

Cooperation with investigations

You must cooperate completely in any investigation. You must be honest and forthcoming

at all times during an investigation, and you must provide any investigator with full,

accurate, timely, and truthful information. Misrepresenting facts or failing to disclose

facts during an investigation is strictly prohibited. You can’t interfere with or obstruct

an investigation conducted by the company or by any government agency.

You are required to comply with this Code as a condition of continued employment. This

Code may be changed by the company at any time, except pursuant to any applicable

collective bargaining obligations, without notice to you. Except where applicable law

provides otherwise, employment with Verizon is “at will,” which means that you or Verizon

may terminate your employment, at any time, with or without cause, with or without

notice, for any reason not prohibited by law, unless governed by a collective bargaining

agreement or specific contract of employment. Any at will employment relationship may

not be modified except in a written agreement signed by an authorized Verizon ocer.

I work in a store, and a police ocer

came into the store to demand

records about a customer. What

should I do?

You should refer any requests from law

enforcement to Security or the Legal

Department immediately. Additional

information about the handling of

external requests is available on page

23 and contact information for Security

and the Legal Department is available

at the end of the Code of Conduct.

7Verizon Code of Conduct Introduction

Verizon Code of Conduct A respectful, safe and

professional workplace.

Verizon Code of Conduct

A respectful,

safe and

professional

workplace.

We are committed to a safe, healthy, and professional work environment in which

each of us is treated with respect and given the opportunity to achieve performance

excellence.

A respectful and inclusive workplace

As a Verizon employee, you are expected to treat customers, fellow employees,

and vendors with respect, dignity, honesty, fairness, and integrity at all times.

Not only is this sound business practice, it’s also the right thing to do.

Commitment to diversity

An inclusive workplace is key to our success and we will win in the marketplace by

attracting, retaining, and developing a highly qualified, dedicated, and diverse workforce.

Our commitment to inclusiveness extends beyond our workplace. Verizon seeks to do

business with diverse suppliers and vendors. And we refuse to use facilities, sponsor

events, or maintain memberships at organizations that have exclusionary membership

practices.

Discrimination and harassment

We are committed to maintaining a workplace free from illegal discrimination

or harassment, including sexual harassment or harassment based on any other

legally protected category.

We respect and comply with all laws providing equal opportunity to individuals without

regard to race, color, religion, age, sex, pregnancy, sexual orientation, gender identity

and expression, genetic information, national origin, disability, marital status, citizenship

status, veteran status, military service status, union activity or membership status, and

any other protected category under applicable law.

Unlawful harassment comes in many forms and includes conduct or language that

creates a hostile or oensive work environment. It can be physical, verbal, or visual.

For example, sexual harassment may include inappropriate touching, unwelcome

romantic advances, lewd gestures, or the display of obscene material. Other forms

of harassment may include racist comments, ethnic slurs, religious stereotypes,

or homophobic jokes.

A respectful, safe and

professional workplace.

Verizon Code of Conduct

We do not tolerate such behavior. If you are subjected to or observe unlawful

harassment, you should report it to your supervisor (if appropriate), Human Resources,

Verizon Ethics, or the Legal Department, and, if you are comfortable doing so, confront

the perceived harasser and ask that they stop. Supervisors who become aware of

harassment concerns must report the issue.

A safe and healthy workplace

We share a responsibility for maintaining a safe and healthy workplace and for doing

business in a way that meets our responsibilities to each other, our customers, and

the public.

Workplace safety and environment

We are committed to providing a safe workplace and to meeting our environmental

responsibilities. We have implemented an environmental, health, and safety (EHS)

management system, and provide the resources and governance needed to meet

our commitments and continuously improve performance.

That means that each of us must perform our jobs in a safe and environmentally

responsible manner and in compliance with Verizon programs and the law. Supervisors

must ensure that direct reports are trained in the safety and environmental practices

of their jobs, report potential noncompliance, and investigate all EHS concerns of which

they become aware.

You must report a work-related crash or injury; a hazard or incident; or a violation of an

environmental, health, or safety law or company policy to your Supervisor or the EHS

hotline at 800-386-9639. You should also contact the EHS hotline if you need advice

on EHS compliance, a regulator visits your worksite or asks to schedule an inspection,

or you believe an unsafe condition or environmental issue is not being properly

addressed.

Workplace violence

We are committed to maintaining a work environment that is free from violence

and weapons, or threatening, hostile, or abusive behavior.

You must never engage in violent or threatening behavior toward fellow employees,

customers, or business partners.

We maintain a weapons-free workplace. Under no circumstances should anyone possess

or use any weapon or weapon component (e.g., ammunition) on company property, in

a company vehicle, or while conducting company business. Unless expressly permitted

by local law, this includes weapons stored in a locked personal vehicle on company

property. The only exceptions to the above requirements are authorized Verizon Security

Corporate Protection Operations programs that have been approved in advance by the

Chief Security Ocer, with the concurrence of the Chief Compliance Ocer.

It is critical that you take personal responsibility for immediately reporting any instance

of violence, threats, hostile behavior, or weapon possession on company property to

Security and your supervisor. In cases of imminent danger, you should immediately notify

local law enforcement (e.g., 911 or other applicable local emergency service number).

A respectful, safe and

professional workplace.

Verizon Code of Conduct

Domestic violence

Domestic violence can also have an impact on workplace safety. If you are the victim of

domestic violence, you should notify the police and Security about any person who may

be threatening your safety or the safety of fellow employees. You can also contact your

HR Business Partner and the Employee Assistance Program for help.

Forced labor and slavery

Verizon does not tolerate forced labor, slavery, or human tracking in any form, and will

not knowingly work with any supplier or contractor who engages in such practices. In

addition, Verizon does not tolerate child labor and adheres to minimum age laws in all

places where we conduct operations.

Drugs and alcohol

Substance abuse is incompatible with workplace health and safety.

You may not report to work under the influence of alcohol, an illegal drug, or any

controlled substance for which you do not have a prescription. If you are taking

prescription medication that may aect your perception or responsiveness, you must

notify your supervisor and Human Resources. Never operate a vehicle or machinery

while in an impaired state.

You must not use or possess illegal drugs or drug paraphernalia while on company

property, in a company vehicle, or when on company time. You should not possess

or use controlled substances or prescription drugs that have not been prescribed

to you by a physician.

Marijuana is an illegal drug under U.S. federal law. Even if you work in a jurisdiction that

has legalized marijuana for medical or recreational purposes, you may not report to

work under the influence of marijuana, or use or possess marijuana while on company

property, in a company vehicle, or when on company time.

Possession and use of alcohol are prohibited on company property, while in Verizon

vehicles, and when conducting company business. There are limited exceptions

to this prohibition:

• alcohol may be served at social functions on company premises, but only

with prior approval from a vice president level (or above) leader;

• alcohol may be consumed if it is served at an external event at which you

are representing Verizon (e.g., a business dinner or cocktail reception).

In such cases, consumption of alcohol must be voluntary, in moderation, and

in a manner that does not embarrass the company.

A respectful, safe and

professional workplace.

Verizon Code of Conduct

Misconduct outside the workplace

Each of us must avoid any misconduct o the job that could impair our ability

to do our jobs or aect the company’s reputation or business interests.

Accordingly, you must promptly report to Verizon Ethics any arrest, charge,

or conviction for:

• a felony (or equivalent under local law);

• an oense involving dishonesty, assault, or battery;

• a drug-related oense;

• an alcohol-related oense relating to conduct while on company property

or business or that may otherwise aect your ability to perform your job,

or aect the company’s business interests; or

• any other oense which may aect your ability to perform your job

or otherwise aect the company’s business interests.

A professional workplace

We are committed to maintaining a professional, productive work environment.

Solicitation and fundraising

You may not engage in solicitation or fundraising during work time (defined as the work

time of either the employee making or receiving the solicitation), and you may not engage

in the distribution of nonbusiness literature during work time or in company work areas.

Further, you may not use company resources to solicit or distribute at any time. Non-

employees may not engage in solicitation, fundraising, or the distribution of literature

on company property.

There are limited exceptions to this policy:

• company pre-approved communications relating to employee benefits or services;

• communications about charitable initiatives undertaken with the approval of the

Corporate Social Responsibility Team;

• political activities undertaken on the company’s behalf in coordination with the

Public Policy and Legal Department; or

• activities conducted pursuant to the Employee Resource Group (ERG) Guidelines.

Gambling

Gambling is illegal in many jurisdictions and can contribute to an unprofessional

workplace. You may not gamble (online or oine) on company property, when using

company systems, or while conducting company business. You may not participate in

games of chance (including sports pools, raes, or lotteries) on company property, when

using company systems, or while conducting company business without written approval

from Verizon Ethics.

A respectful, safe and

professional workplace.

Verizon Code of Conduct

Employee privacy

You must take appropriate steps to protect confidential personal employee information,

including social security numbers, identification numbers, passwords, bank account

information, and medical information. You should never access or obtain, and may not

disclose outside of Verizon, another employee’s personal information obtained from

Verizon business records or systems unless you are acting for legitimate business

purposes and in accordance with applicable laws, legal process, and company policies,

including obtaining any approvals necessary under those policies.

Monitoring and recording at work

To maintain a safe and professional work environment, Verizon monitors employee

use of company property, consistent with applicable law. Monitoring applies to

company facilities and vehicles. Such monitoring also applies to company-provided

communications devices, our networks and computer systems (including corporate

email, encrypted and unencrypted internet access, and any application, such as

web-based email, accessed from company provided devices and systems).

In cases involving safety or suspected misconduct (for example, investigating claims

of sexual harassment, workplace violence, or suspected theft), the company reserves

the right to monitor or inspect, without notice, any company property or any personal

property on company premises that may contain evidence of misconduct, consistent

with applicable law or any local data privacy notice. With respect to company provided

or paid for communications devices or accounts, the company may, as permitted by

law or any local data privacy notice, access any stored information (whether on the

device, our servers or with a third-party) that may contain evidence of misconduct, and

employees are required to cooperate, including by providing access to the information,

when requested by the Legal Department or its designee, or Security.

Unless you are participating in an approved observation program or have obtained prior

approval from Security or the Legal Department, subject to applicable law or any local

data privacy notice, you may not record (photo, video, or audio) an employee (while

the employee is at work or engaged in business activities), a customer, partner,

or competitor without that individual’s knowledge and consent, or access another

employee’s information systems or business records without that employee’s

knowledge and consent.

A respectful, safe and

professional workplace.

Verizon Code of Conduct Integrity and fairness

in the workplace.

Verizon Code of Conduct

Integrity and

fairness in the

workplace.

Our company’s reputation is based on the actions of its employees. Each of us must

act with integrity and respect at all times.

Conflicts of interest

You must avoid any relationships or activity that might impair, or even appear to impair,

your ability to make objective and fair decisions when performing your job. When acting

on behalf of the company, you must advance the company’s legitimate interests when

the opportunity to do so arises. If you identify a situation where the company’s interests

are being harmed, you must report the matter to Verizon Ethics.

You must never use Verizon property or information for personal gain or take personal

advantage of any opportunity that arises in your work for Verizon.

You must disclose any potential or actual conflict to Verizon Ethics as soon as you

become aware of it.

Personal conflicts of interest

Certain types of personal relationships can create actual or apparent conflicts

of interest both internally at Verizon and in our interactions with third parties. Never use

your position at the company to improperly advance your personal interests or those of a

friend or relative.

Internally, you may not supervise – directly or indirectly – someone with whom you share

a close personal relationship, such as anyone in your family or household, or someone

with whom you have or had a romantic relationship or other similar relationship. Even if a

family member or romantic partner is not in your reporting chain, if you interact with such

a person as part of your Verizon work responsibilities, you must avoid any actions at work

that could create even the appearance of a conflict of interest. If you are uncertain about

what interactions are appropriate, you must contact Verizon Ethics.

Externally, you may not participate in the selection process for, have discretionary

authority involving Verizon’s business with, or supervise Verizon’s relationship with,

a company that does business with Verizon if it employs someone with whom you

have a close personal relationship or is a company with which you have a business

relationship. Exceptions to this restriction are extremely limited and require the

approval of Verizon Ethics.

Integrity and fairness

in the workplace.

I am a Vice President and one of

my reports disclosed a personal

conflict of interest to me. I promptly

implemented controls to minimize the

risk. Is that sucient?

No. All conflicts and potential conflicts

of interest must be cleared by Verizon

Ethics.

I work with several vendors and

wanted to introduce them to my

college-age daughter, who is looking

for a summer internship. She’s very

qualified, and would be a tremendous

asset to any of the vendors. Can I ask

the vendors to meet with her about an

internship?

If you work with a vendor, asking that

vendor for personal favors is generally

prohibited. Here, it is not okay to ask

the vendor to consider one of your

relatives for a position, even a summer

internship. The request could create

the appearance of favoritism and place

inappropriate pressure on the vendor.

Verizon Code of Conduct

If a family member or person with whom you have a close personal relationship

is employed by an entity that does business with Verizon, you cannot interact

with that individual about business between Verizon and the outside entity.

Outside employment

You may not—with or without compensation—be self-employed or employed by,

consult with, own, perform services for, or aid:

• a company or organization (including a charitable organization) that is a vendor,

supplier, partner, contractor, subcontractor, or competitor of Verizon; or

• a company that provides services that are provided by Verizon, or that Verizon

is seeking to provide.

Outside work must not interfere with your work for Verizon or have any connection to the

company (for example, soliciting coworkers for business or investments). This limitation

also applies to simultaneous employment by Verizon and its subsidiaries, aliates, and

joint ventures in which the company maintains an ownership interest. Exceptions to the

requirements of the previous paragraph may be granted only upon written approval by

Verizon Ethics.

Unless you receive the prior written approval of your supervisor and Human Resources,

you may not engage in any outside employment or self-employment or perform any

commercially-related services—with or without compensation—while absent from work

on any company-approved leave of absence, absence due to sickness or disability,

Family Medical Leave, or comparable leave provided for by applicable law.

Outside activities

When employees participate in outside activities, Verizon draws a distinction between

personal activities (not representing Verizon) and service on behalf of the company

(representing Verizon). Many employees, in their personal capacities, participate in

outside civic and charitable activities by serving as trustees or members of various

community organizations such as local not-for-profits, religious institutions, parent

teacher associations, or homeowners’ associations. If a matter regarding Verizon’s

services or products arises when performing such outside civic or charitable activities,

you must remove yourself from discussing or voting on the matter or on any matter

that involves the interests of Verizon or its competitors to avoid conflicts of interest,

such as whether your organization should select Verizon phone service, or purchase a

competitor’s products rather than Verizon’s. Participation in outside civic or charitable

activities should not interfere with your work for Verizon. To the extent your participation

infringes on company time or involves the use of Verizon resources, your supervisor’s

approval is required.

Service in an outside organization on behalf of Verizon means that you are expected

to represent Verizon’s interests when participating in the organization’s activities. Prior

to serving as a representative of Verizon with any outside organization, you must obtain

the prior approval of Verizon Ethics and your vice president level supervisor.

Special approval requirements apply when seeking to serve on any outside company’s

Board of Directors:

• Service on the Board of Directors of a public corporation must be approved in

advance by both Verizon Ethics and your organization’s executive vice president.

• Service on the Board of Directors of a non-public corporation must be approved

in advance by Verizon Ethics.

How do I find out if the company

where I have a second job is providing

services that are also provided by

Verizon?

Verizon provides a wide array of

products and services. Many are

obvious, including telephone, internet,

and television service. However, Verizon

provides many other services, and if

you think there is any chance that an

outside employer might be operating

in the same space as Verizon, you must

contact Verizon Ethics for guidance.

My supervisor knows that I have a side

job designing apps for mobile devices.

Do I have to let anyone else know?

A “side hustle” related to the field in

which you work for Verizon, or involving

any product or service in which Verizon

might be active, must be approved by

Verizon Ethics.

Integrity and fairness

in the workplace.

I have been asked to participate in

an investor expert network as a tech

industry professional. This expert

network does research to assist

investors. If I do not reveal any

confidential Verizon information, can I

participate?

Employees and executives are generally

prohibited from participating in expert

networks for investors due to insider

trading concerns. You should consult

with Verizon Ethics regarding this

request.

Verizon Code of Conduct

Political interactions and contributions

The company encourages us to participate in the political process and each of us is

responsible for ensuring compliance with all laws and regulations relating to interactions

with government ocials, including laws governing campaign finance, government

ethics, and lobbying. In addition, all lobbying activities on behalf of the company must be

authorized by the Public Policy and Legal Department.

If you are appearing before a government body or engaging in contact with a public

ocial outside of your ordinary work duties regarding a business in which Verizon is

engaged or a business issue in which Verizon has an interest, make it clear that you

are not representing Verizon and advise your supervisor in advance.

Your personal political contributions and activities must be kept separate from the

company. If you make political contributions, you may not refer to your employment

or use the company’s assets, including its name, in connection with your contributions,

unless required to do so by law. You may not make payments of corporate contributions,

whether monetary or non-monetary assets, to any domestic or foreign political party,

candidate, campaign, or public ocial unless that contribution is permitted under

applicable laws inside and outside the U.S., and approved in advance by the Public Policy

and Legal Department. In addition, you may never reimburse anyone for any political

contribution.

Verizon and its subsidiaries administer Political Action Committees (PACs) that accept

contributions from employees who wish to support Verizon’s goals through the political

process. Your personal contributions to these PACs are entirely voluntary.

Seeking public oce

Before you seek any elected or appointed public oce, including a local position,

such as school board, you must obtain the approval of your director level or above

supervisor and Verizon Ethics.

Insider trading and securities transactions

Insider trading occurs when a person trades in a company’s securities using material

inside information—that is, information that is not publicly available and that could

reasonably aect a person’s decision about whether to buy or sell the securities.

It also occurs when a person gives material inside information to someone else who

trades on it. Insider trading is a serious violation of the law and can result in severe

penalties, including imprisonment.

As a Verizon employee, you may become aware of material inside information about

Verizon or other companies with which Verizon does business. You must never use

material inside information (even if you acquired it as a “tip” from others) to trade in

Verizon’s or any other company’s securities, including options and other derivative

securities. In addition, you may not provide material inside information to any other

person, including members of your family or your friends, or assist any other person

in trading using material inside information.

Integrity and fairness

in the workplace.

Verizon Code of Conduct

The rules that relate to insider trading are complex. If you are not sure whether these

restrictions apply to you, you should consult the Legal Department before making any

decision to trade in a security, or before you disclose any information to another person.

As a general rule, non-public information concerning a company’s business, financial

prospects, major transactions, regulatory or legal matters, significant cybersecurity

incidents, or management issues, is often considered “material.”

In addition, you may never engage in any transaction that permits you to benefit from

the devaluation of Verizon’s stock, bonds, or other securities, including engaging in

short selling or buying “put” options on Verizon stock. You also may not participate

in transactions in the stock or other securities of business providers or prospective

business providers that could influence, or appear to influence, your business judgment

on behalf of Verizon.

Outside financial interests

You may not transact any business in a company’s securities or derivatives of those

securities if you conduct or supervise Verizon business with that company.

If you have a pre-existing stock interest in a company and your position at Verizon

requires you to conduct or supervise business with this company, you must disclose

your ownership interest to a vice president level or above supervisor. You may not trade

in that company’s securities without advance approval from the Legal Department.

You may not take a significant financial interest in a company that is a business provider

or that competes with or is in one of the same lines of business as Verizon. A significant

financial interest is any financial interest that is more than US$100,000 and that

represents either (1) more than 25% of your annual gross income or (2) more than 1%

of the value of the other company. If any investment appreciates over time so that it

creates an actual or apparent conflict of interest, it should be brought to the attention

of the Legal Department.

Loans

Personal loans from the company to any executive ocer (as defined by securities

law) are unlawful and strictly prohibited. Personal loans from the company to any other

employee must be approved in writing in advance by the Legal Department or under an

approved Verizon program. Loans greater than US$25 between employees in a direct

or indirect reporting relationship are prohibited.

Can I purchase stock in a company

that is a vendor on a project I am

working on?

If you are working with that vendor, you

cannot purchase stock in that company.

Integrity and fairness

in the workplace.

Verizon Code of Conduct Protecting Verizon’s

assets and reputation.

Verizon Code of Conduct

Protecting

Verizon’s assets

and reputation.

We are all accountable for protecting the company’s assets and reputation.

Preparing, disclosing, and maintaining

accurate records

We are committed to maintaining and providing truthful information that satisfies all legal

requirements. We do not tolerate the falsification or improper alteration of records.

You must create and maintain true and accurate records. If you identify any mistakes

or discrepancies, no matter how small, you must try to resolve them immediately, and

you must promptly notify your supervisor.

You may never direct anyone to create or approve a false or misleading record,

or intentionally take any action that helps to create a false or misleading record,

such as withholding information from someone preparing a record.

Company records must be retained according to applicable laws and Verizon’s Records

Management Policy. You may never destroy, alter, or conceal any record if you have been

directed to retain it or if you know – or reasonably believe there is a possibility – of any

litigation or any internal or external investigation concerning that record.

If you believe a record was intentionally falsified or created to be misleading, or if anyone

directed you to violate any section of this policy, you must immediately contact Verizon

Ethics.

Promoting transparent and complete disclosure

Our investors and shareholders are key to our success and we are committed to

transparency in financial reporting. All disclosures made in financial reports and

in public communications must be full, fair, accurate, and understandable.

You may not selectively disclose (even in one-on-one or small meetings) any material

information regarding the company. You should be particularly careful not to disclose

such information if you make presentations to customers, business providers, investors,

or other third parties.

I am required to track and record

the time I spend working each

week. I sometimes fail to properly

record half-days as vacation days or

personal time, but it is not a common

occurrence. Is this a big deal?

Yes. Failure to accurately record your

time is a violation of the Code and could

result in discipline up to and including

termination of employment.

Protecting Verizon’s

assets and reputation.

Verizon Code of Conduct

We use auditors to ensure the accuracy of our reporting. You must cooperate with

auditors and provide them with complete, accurate, and timely information, and you

must never improperly influence or mislead any auditor.

Safeguarding company information

Our business depends on protecting its proprietary, non-public, and confidential

information, as well as the information others entrust to us as part of our business.

Examples of such information include: “inside information” that could lead someone to

buy or sell Verizon stock, marketing presentations, or copyrighted materials. You must

comply with all company policies regarding the protection of Verizon’s information. You

may not release non-public company financial information to the public or third parties

unless specifically authorized by Verizon’s Controller.

You may not release other non-public company information to the public, third parties,

or internet forums (including blogs or chat rooms) unless you are specifically authorized

to do so by a vice president level or above supervisor, and the Legal Department. You

may only disclose non-public company information to employees who have demonstrated

a legitimate, business-related need for the information.

Your obligation to safeguard Verizon information continues even after your employment

at the company has ended, and you may never disclose or use non-public company

information absent Verizon’s specific written authorization.

Acquiring other parties’ non-public information

You cannot accept or use non-public information belonging to a third party (including

information from a former employer) unless the person disclosing the information is

authorized to do so, Verizon has the owner’s written permission to receive it, and the

information is provided according to a written agreement approved in advance by your

supervisor and the Legal Department.

Intellectual property

Our intellectual property is a valuable asset and must be protected by everyone. Similarly,

you must respect the proprietary rights of others by complying with all applicable laws

and agreements, including those with business providers, competitors, and customers.

You must not acquire the intellectual property of others through unlawful or inappropriate

means. You may not copy, use, or share copyrighted materials unless you obtain the

specific, written, prior consent of the owner, or unless such use is permitted under

applicable law as determined by the Legal Department.

If you have entered into any agreement with a prior employer with respect to intellectual

property, non-competition, non-solicitation, or non-disclosure, you are required to

disclose such an agreement to your supervisor.

A customer shared a competitor’s

pricing in connection with a pending

bid because the customer wants to

make it clear that there is a certain

“price to beat.” Can I use this

information?

No. This information is almost certainly

proprietary and the customer may

not be authorized to share it with

Verizon. You should contact the Legal

Department, preserve the email, and

do not take further action until directed

by Legal.

A competitor’s pricing information

was posted on a blog. It’s marked

“confidential.” Can I use it?

If you have reason to believe the

blogger wasn’t authorized to post the

information and that it is non-public,

contact the Legal Department to

receive guidance before using it.

In connection with a pending

transaction, a partner sent me

confidential information. A properly

approved NDA is in place. Can

I accept the information?

Yes, you can accept confidential

information pursuant to a properly

approved NDA.

Protecting Verizon’s

assets and reputation.

Verizon Code of Conduct

Gathering information about competitors

Gathering information about competitors is a common business practice, but you must

always do so with integrity. You must always accurately represent yourself and may never

misrepresent your identity when gathering information. You are also required to direct

that all consultants and agents with whom you work on behalf of Verizon do the same.

You may generally obtain information from public sources, industry gatherings, surveys,

and competitive research, but it is never acceptable to obtain or request non-public

information from any source, including the internet. It is never appropriate to engage in

theft, espionage, or breach of a competitor’s non-disclosure agreement. If information

you receive is marked private or marked in such a way as to indicate it is private, absent

an appropriate confidentiality agreement, do not use it and contact the Legal

Department for guidance.

Protecting company communication

and information systems

Verizon’s communication and information systems, including all company computers

and mobile devices, are critical to the company’s operation. You must protect company

information from accidental or unauthorized disclosure. You must also protect the

security of user IDs and passwords for all company systems and devices. Additionally,

you must also comply with all company policies relating to the use of computer hardware

and software on company systems, and the acquisition, use, and disposition of data on

company systems. Only approved software and hardware may be used on company

systems, and such media must have a legitimate business purpose and be malware free.

You may not use company systems, such as email or instant messaging, to engage in

activities that are illegal, violate company policy, or could result in Verizon’s liability or

reputational harm. Some examples of improper uses of company systems include:

• pornographic, obscene, oensive, harassing or discriminatory content;

• unauthorized mass distributions; and

• communications on behalf of commercial ventures.

You may make limited personal use of company systems, so long as it does not interfere

with your work responsibilities, incur costs, or otherwise violate the Code or Verizon

policy. You may not send non-public company information to personal email unless you

are authorized to do so by a supervisor and comply with company policies regarding

encryption.

Proper use of Verizon resources

You are required to protect Verizon’s resources, as well as property belonging to

customers, business providers, and co-workers. All company resources must be used

appropriately, and never for personal gain. Company property cannot be taken, sold,

loaned, intentionally damaged, given away, or otherwise disposed of, regardless of its

condition or value, without specific authorization.

Protecting Verizon’s

assets and reputation.

Verizon Code of Conduct

You are never permitted to use Verizon equipment or vehicles for personal purposes,

or any device or system to obtain unauthorized free or discounted service.

Verizon benefits plans and programs must be used honestly. You are not permitted

to misrepresent any fact regarding your health status, covered members, beneficiaries,

or any other facts, including reasons for absence, for any purpose.

Security of facilities

To ensure a safe work environment and the integrity of the company’s facilities,

you must take all appropriate precautions to protect Verizon’s systems and premises.

Do not leave visitors unescorted or sensitive areas unattended or unlocked. When on

company property and conducting company business, wear your identification badge

and request identification from others you do not recognize. You must report all

suspicious activity to Security.

External communications

Unless you receive prior approval from both your supervisor and Corporate Public

Relations, when presenting your personal views in public or at professional, community,

and other events, you may never suggest you are speaking on behalf of the company.

External requests and inquiries seeking information from the company must be directed

to the appropriate organizations:

• Media Relations is responsible for contact with the news media and inquiries

about community relations.

• Investor Relations handles communications related to the company’s financial

performance and all contacts with the financial community.

• Human Resources handles inquiries regarding current and former employees,

including employment verification.

• Public Policy, and Legal and Security Departments handle contacts from

outside attorneys, law enforcement, legislative bodies, and regulatory agencies.

This includes responses to subpoenas, court orders, and inquiries from law

enforcement, including requests to access Verizon facilities. You may never confirm

or deny the existence, or discuss the substance, of any subpoena, warrant or court

order, and must immediately refer any such inquiries or requests to Security or the

Legal Department. If you receive any legal documents relating to Verizon, you must

immediately forward them to the Legal Department.

Verizon generally does not make company-sponsored endorsements or provide

testimonials. You may not use Verizon’s name, nor may you make any endorsement,

without the explicit approval of the Legal Department and Brand Management.

If I am using my personal social media

account on my personal time, does

the Code of Conduct apply?

Yes, portions of this Code of Conduct

still apply to your personal use of social

media. For example, if you identify

Verizon as your employer and post a

racist comment or encourage acts of

violence on your social media pages,

such behavior may constitute prohibited

o-duty misconduct.

Can I post an online review of a

Verizon product that I purchased

in my individual capacity?

Yes, but you must always tell the truth

and you must disclose your employment

relationship with the company.

Where can I get more information

about the company’s policies on

social media?

More information can be found

on vzweb.verizon.com/

social-media-compliance.

Protecting Verizon’s

assets and reputation.

Verizon Code of Conduct Integrity and fairness

in the marketplace.

Verizon Code of Conduct

Integrity and

fairness in the

marketplace.

Our relationships with customers, suppliers, and society are fundamental to our

commercial success and are a critical part of our social responsibility. Each of us

must ensure that our interactions outside the company are based on integrity and

respect for internationally recognized human rights.

Relationships with customers

Customer privacy

We are all responsible for protecting customers’ privacy. You must only obtain, use,

or share customer information for legitimate business purposes.

Verizon’s privacy policies describe the information the company collects from and about

customers and website visitors and how that information may be used and shared. The

privacy policies also explain the choices customers have about certain uses and sharing

of that information. You must respect these choices.

You must not, and must not permit others to access, listen to, monitor, record, tamper

with, or disclose any customer communication, except as required by the duties of your

position to comply with a valid service or installation order, to comply with a valid legal

order or law, or for the limited purpose of quality monitoring and training, or as approved

by the Legal Department.

You must also protect customer information. That means you may not access, view, use,

modify or share customer information without a proper business reason. You also may

not access account information concerning yourself, or your friends, acquaintances,

family, or coworkers without prior approval from your supervisor.

Verizon contractors and business partners also must protect customer information.

Before sharing any customer information with a third party, ensure that a written

agreement that protects customer information is in place.

If you are aware of or suspect unauthorized access to, disclosure of, or loss of customer

information, you must report it immediately to the Legal Department or Verizon Ethics.

Integrity and fairness

in the marketplace.

Verizon’s privacy policies may be

found at verizon.com/about/privacy/

privacy-policy-summary. The Privacy

Oce can assist with any questions

or concerns.

Verizon Code of Conduct

Customer marketing

You must follow all company policies and applicable laws before using any customer’s

information to market to the customer, including marketing for additional products

and services. When customers are also telecommunications carriers or resellers of

telecommunications services, you may not use their subscriber information, orders,

or services to aid in Verizon’s retail marketing or sales eorts.

Selling with integrity

You may never deceive customers, and you must fully, clearly, and directly inform

customers of the terms and conditions of our services:

• All advertising and sales materials must be truthful and accurate. All claims must

be substantiated in advance with a factual basis and backup. No advertising

or sales materials should be released without Legal Department approval.

• When selling to Verizon’s customers, never disparage or misrepresent the

company’s products or services.

• When advertising the price of Verizon’s products and services, the customer

must be clearly informed of all material terms and restrictions for obtaining the

advertised rate in marketing and promotional materials. There should be no

hidden charges.

• All rules regarding sales and promotions must be followed without exception.

• Promote Verizon’s products and services by focusing on their strength, quality,

reputation, and where appropriate, through fair and accurate comparisons with

our competitors. You should not disparage competitors, or make misleading or

inaccurate comparisons with competitors’ products and services.

• Report to the Legal Department any loopholes or flaws in promotions or oers

that allow customers or the company to be harmed.

Relationships with business

providers and partners

You must use good judgment when selecting and maintaining relationships with

all of Verizon’s business providers and partners. Employees who select, supervise,

and work with business providers must:

• use a selection process that is fair, lawful, does not improperly discriminate,

and complies with all company policies;

• ensure that business providers and partners are apprised of their obligation

to abide by all applicable Verizon policies, including the Verizon Supplier Code

of Conduct;

• put all agreements in writing and obtain all required approvals for agreements; and

• protect the confidential information of business providers and partners.

Relationships with competitors

We depend upon a fair marketplace for our success. Accordingly, we will never seek

to eliminate or reduce competition through illegal agreements with competitors. To

safeguard against this risk, you may not enter into agreements with competitors without

advance approval from the Legal Department. When thinking about what companies

Integrity and fairness

in the marketplace.

Verizon Code of Conduct

could be competitors, take a broad view and, if in doubt, contact the Legal Department

prior to making any agreement.

You must avoid agreements that could violate antitrust and competition laws such as

fixing prices, dividing markets or products, rigging bids, or boycotting particular suppliers

or customers. Explicit agreements, informal “gentlemen’s agreements,” and even a

“wink and a nod” are against the law and can result in criminal penalties for Verizon

or you personally.

When interacting with competitors externally – including at trade association activities

or in informal settings – do not discuss Verizon’s pricing, terms, or marketing plans.

Relationships with former employees

Your obligation to follow the company’s standards continues even after your employment

at Verizon ends:

• When leaving or retiring, you must return all Verizon property, including all records

and equipment. You can’t use or disclose Verizon’s non-public information in any

subsequent employment, unless you receive written permission in advance from

a Verizon vice president level employee and the Legal Department.

• You may not provide any Verizon non-public information to former employees

unless properly authorized. If a former employee solicits non-public information

from you, you must immediately notify Security or the Legal Department.

• You may not rehire a former employee or engage a former employee as an

independent contractor or a contract worker, whether engaged through a stang

company or other third-party vendor, unless the former employee has been

separated from the company for six months. In extremely limited circumstances,

the Executive Vice President for Human Resources may, in writing prior to the

engagement, and upon a finding of a compelling reason, approve the rehire of

a former employee or the engagement of a former employee as an independent

contractor or a contract worker, as described above, within six months of that

person’s separation.

• You may not receive services or purchase products from a former employee

on behalf of Verizon unless the former employee has been separated from the

company for six months. Verizon Ethics may, upon finding of a compelling reason,

approve such interactions on Verizon’s behalf with a former employee within six

months of that person’s separation. When a former employee has been separated

from Verizon for more than six months, you must obtain authorization from your

supervisor before purchasing products or receiving services from the former

employee.

Gifts and entertainment

Gifts and entertainment can be part of promoting a successful working relationship

with our business partners and customers. However, if you fail to follow the rules

relating to gifts and entertainment, it can damage our relationships, harm our reputation,

and expose the company to legal risk.

No gift or entertainment can be exchanged if (a) it might create the appearance

of undue influence, unfairness or impropriety, (b) it is intended to improperly influence

another person’s business judgment, or (c) you are participating in, conducting,

or directly supervising a formal Verizon procurement process.

Integrity and fairness

in the marketplace.

My colleague left Verizon last month

to work for one of our vendors where

he is working on Verizon matters. Can

I interact with the former employee

regarding Verizon business?

It depends. When a former employee

has left Verizon, depending on the role

he plays at his new employer, there may

be restrictions on Verizon employees’

ability to immediately interact with

the person. You should reach out to

Verizon Ethics to discuss the individual

circumstances.

Verizon Code of Conduct

If you receive or want to oer a gift or entertainment that is outside of Code standards,

you must contact Verizon Ethics for guidance.

Moreover, you may never use your own funds to circumvent our rules regarding gifts

and entertainment, and you must ensure that all gifts and entertainment are accurately

reflected in Verizon’s books and records, including expense reports. Our rules regarding

gifts and entertainment can apply to your family and individuals with whom you have

a close personal relationship when those individuals receive gifts and entertainment

because of your position at Verizon.

Gifts

A gift is anything of value, including promotional trinkets, food, beverages, and event

tickets, that you give or receive. To be permissible, a gift must comply with all applicable

laws and be:

• unsolicited;

• not cash or usable as cash (including gift cards unless they have been approved

as part of an authorized Verizon program and by the Legal Department); and

• no more than US$150 in value in a calendar year to or from the same organization,

unless approved by a director level supervisor and Verizon Ethics.

You must receive approval from Verizon Ethics before oering or accepting any gifts

of travel or lodging.

Entertainment

Entertainment is any meal or event you attend with a customer or business provider.

If you do not attend an event with a customer or business provider, the tickets to the

event are considered a gift, not entertainment. To be permissible, entertainment must

comply with all applicable laws and be:

• attended by both a Verizon employee and a business provider’s employee,

and be an occasion where business is discussed;

• no more than US$250 in value per occasion, per person, unless approved

by a director level supervisor and Verizon Ethics; and

• at a venue and conducted in a manner that does not violate other provisions

of the Code or harm the Company’s reputation (e.g., attending an event at an

adult entertainment venue).

Integrity and fairness

in the marketplace.

Verizon Code of Conduct

Bribery, anticorruption and

government ethics

We win business fairly. And we maintain strict policies against bribery and corruption,

which apply to all of us regardless of the country in which we work. Compliance with

these policies is critically important, regardless of what the customs might be in a

particular country. In addition, Verizon employees must comply with all anti-bribery

and anti-corruption laws applicable in any jurisdiction in which we operate.

You must not oer or pay a bribe to anyone, and you must never receive or solicit a bribe

from anyone. If you are ever oered a bribe by anyone, you must report it to the Legal

Department immediately.

You must obtain Legal Department approval before oering any gifts, entertainment,

meals, or anything else of value to any government ocial, whether they are based inside

or outside of the United States. You must also obtain Legal Department approval before

entering into personal business with a government ocial as a consultant on behalf

of Verizon (for example, hiring a government ocial or entering into a joint venture

or partnership with a government ocial).

You may never make payments to any third party you suspect may be passed on

to government ocials or otherwise used to improperly influence anyone’s decision

making to obtain business or other benefits for Verizon. Whenever you retain any agents

or consultants in connection with our global business, you must verify that there are

adequate controls to prevent funds provided to those agents from being used to make

improper payments.

You must ensure that Verizon and any agents or consultants hired to represent Verizon

properly document all transactions and maintain accurate records regarding all

payments, including amounts, recipients, and purpose of payments.

If you have questions about any anti-corruption or anti-bribery related issue, contact

the Legal Department immediately.

Anti-money laundering laws

Money laundering is an attempt to hide or disguise the proceeds of criminal activity

through a series of otherwise legitimate business transactions. Be sure products and

services are reviewed before release to determine if any features could be susceptible

to money laundering. We prohibit knowingly engaging in transactions that facilitate

money laundering or result in unlawful diversion.

International relationships

We must follow the law, wherever we do business. If you find that there is a conflict

between applicable law and the Code or Verizon policy, you should comply with the

law and seek further guidance from the Legal Department.

Integrity and fairness

in the marketplace.

Who counts as a “government

ocial?”

Legal definitions of “government ocial”

can vary. For the purpose of complying

with company policy, you should take

the broadest possible view of who is

a government ocial. This includes all

elected and appointed ocials and any

employee of any government entity,

at any level, including national, state,

provincial, local, or municipal level.

It also includes ocials and employees

associated with quasi-governmental

entities and state-owned companies.

If you’re in doubt as to whether

someone should be treated as a

government ocial, contact the Legal

Department for assistance.

In conjunction with an international

deal I am working on, a government

ocial has asked Verizon to pay a

“processing fee” to expedite clearing

customs. What should I do?

“Expediting” or “facilitating” payments

are unlawful in many circumstances

and are generally prohibited at Verizon.

You must immediately notify the Legal

Department about any requests to pay

what you believe may be an expediting

or facilitating payment.

Verizon Code of Conduct

Locating oces or receiving services

outside the United States

If you are considering (a) locating a project, group, or any Verizon activity outside the

United States, or (b) obtaining services from employees or external providers located

outside the United States (including call center services or IT services), you must contact

the Legal Department in advance to obtain guidance regarding the policies that apply.

Compliance with sanctions and anti-boycott laws

Sanctions laws (including embargoes and boycotts) restrict or prohibit business activities

with targeted countries, governments, entities, organizations, and individuals. The United

Nations and many countries, including the United States and European Union member

countries, maintain lists of sanctioned parties that include persons involved in terrorism,

money laundering, drug tracking activities, or human rights abuses. Often, it is unlawful

to engage in business with the listed entity or entities that are owned or controlled by the

listed entity. You must check with the Legal Department before conducting business in

or with sanctioned countries and governments or with listed parties.

Not all countries agree on sanctions and boycotts. From time to time, a country may

prohibit Verizon from complying with another country’s sanctions and/or boycott laws.

For example, U.S. laws prohibit or penalize compliance with the Arab League’s boycott

of Israel, and EU laws restrict compliance with certain extraterritorial U.S. sanctions. You

must contact the Legal Department if a sanctions or boycott law appears to conflict with

the laws of another country.

Import/export compliance

International trade laws regulate where Verizon can send or receive its products

and services. These laws are complex, and apply to:

• imports and exports of goods and software from or into any country; and

• exports of technical data.

What constitutes “export” or “import” under the law is broad. Examples include:

• sending goods or software from one country to another;

• permitting the download of software by someone in another country;

• exposing or allowing access by non-U.S. persons to U.S. technical information,

regardless of what country the exposure occurs in; and

• transporting technical data or software on your phone or laptop, or transporting

tools or equipment in your luggage when traveling to another country.

Before engaging in export or import activities, you must obtain approval from the Legal

Department or Verizon’s Import Export Compliance group. Be aware that the laws of

more than one country may apply. Know the end use and end user of our transactions,

and the requirements regarding customs clearances and payment of duties and taris.

Integrity and fairness

in the marketplace.

Where can I get more detail about

export rules?

Go here for more information about

export and import laws.

Which countries are covered by

sanctions laws?

Check with the Legal Department for

specific guidance, but the U.S. maintains

broad prohibitions on dealings with

countries such as Cuba, Iran, North

Korea, and Syria.

In connection with an RFP, a potential

customer asked if Verizon does

business with Israel. What should I do?

You must contact the Legal Department

if you receive any request relating to

Verizon’s relationships with Israel or

blacklisted companies or a request

regarding anyone’s race, religion,

gender, national origin, or nationality.

Sources

of help

Verizon provides many resources to help you make ethical decisions. In addition to your

supervisor, you may consult with Human Resources, the Legal Department or call

Verizon Ethics.

Verizon’s VZWeb (intranet), vzweb2.verizon.com, contains expansive helpful contact

and subject matter information. In addition, please reference the chart below for

some important resources.

Quick reference chart

Resource Phone number

Verizon Ethics

website

844.894.8433 US

International dialing

Human Resources

website

Consult website

Security (US)

website

800.997.3287

Global Corporate Security Operations

website

+1.800.483.3565

+1.972.457.8450

Consult website

Verizon Compliance

website

Consult website

Internal Audit

website

844.894.8433 US

International dialing

Privacy Oce

website

Consult website

32 Verizon Code of Conduct Sources of help

Resource Phone number

Environment, Health & Safety

website

800.386.9639 US

+1.800.386.9639 International

Export Control Compliance

website

Consult website

Public Policy, Law & Security

website

Consult website

Subpoenas & Court Orders

website

800.451.5242

Media Relations

website

Consult website

Investor Relations

website

Consult website

Corporate Responsibility

(including Verizon Foundation)

website

Consult website

Employee Assistance Program

website US

website International

888.441.8674 US

Consult website International

integrity

always

matters