Business Ethics

With the understanding that how Acxiom does business and treats others will define Acxiom to the rest of the world, Acxiom has always sought to hire and employ professional, competent people who will make the right decisions in difficult situations. Acxiom associates are expected to behave honestly and with integrity in all of their business practices. Acxiom associates share a responsibility to fulfill their commitments to each other, clients, vendors, and Acxiom and to do so with integrity. By doing so, associates can help shape Acxiom's reputation in a favorable way.

Acxiom’s commitment to doing the right things for the right reasons remains constant. It is the cornerstone of an associate’s success as an individual and as part of the company. It is Acxiom's policy to comply with all laws and regulations applicable to its business around the world, and beyond this, to act in an honest and ethical manner at all times. Associates must NEVER "assume" or "read between the lines" that Acxiom wants them to violate the law or to act unethically in their work. The best thing associates can do when faced with an ethical situation is to ASK for help.

These Guidelines to Business Ethics set forth the principles for identifying ethical situations and the procedure for reviewing and addressing those prospective situations to insure that they do not improperly affect Acxiom business. Associates are expected to become familiar with the contents of the Guidelines and use them as a roadmap when they are unsure what decision or action is appropriate. Policies referenced throughout the Guidelines can generally be found in the Associate Support Book (ASB) and should be reviewed for further information and clarification.

Although no document could possibly describe every problem or ethical challenge associates may encounter in their work, these Guidelines, combined with Acxiom's core values, additional policies contained in the Associate Support Book, and guidance from Acxiom leaders and Organizational Development associates, will help associates find the right course. Associates can turn to the Ethics Reporting Tool (see section entitled “Disclosing Potential Conflicts or Getting Advice") for help in reaching the right ethical decision or to report ethical violations as well.

RESPONSIBILITIES:

To fully achieve an ethical environment, every Acxiom associate must fulfill certain roles and responsibilities.

Acxiom is responsible for:

• Developing policies and guidance that explain Acxiom's position on business ethics and an associate’s related obligations.

• Answering questions and providing advice to associates on ethical issues as they arise.

• Taking appropriate action to prevent future ethical violations. Acxiom will achieve this by restricting the discretion of associates who have failed to follow the Guidelines in the past and/or taking disciplinary action against such associates.

• Maintaining working conditions supportive of associates’ ethical responsibilities.

• Investigating alleged violations of Acxiom’s Guidelines to Business Ethics.

• Maintaining confidentiality to the extent consistent with Acxiom’s fulfillment of its legal and ethical obligations of reported ethics violations.

• Protecting associates who, in good faith, report actual or reasonably suspected ethics violations.

Leaders have a special responsibility for:

• Demonstrating ethical behavior by example.

• Ensuring that all associates understand Acxiom’s Guidelines to Business Ethics.

• Stressing the need for commitment to Acxiom’s Guidelines to Business Ethics.

• Maintaining a workplace environment that encourages the discussion of ethical issues without fear of reprisal.

• Supporting any ethics investigations when called upon.

• Communicating Acxiom’s Guidelines to Business Ethics, standards and procedures to contractors, vendors and agents functioning under their control.

All associates are responsible for:

• Knowing, understanding, and complying with Acxiom’s Guidelines to Business Ethics.

• Contributing to a workplace environment that is conducive to upholding Acxiom's Guidelines to Business Ethics.

• Seeking