DEFY MEDIA, LLC JOURNALISTIC ETHICS GUIDELINES

Defy's editorial site (each, a "Site") teams should ensure that their writing complies with journalistic ethical standards that our readers can trust that our views and opinions are our own and to ensure that we are correctly disclosing any relationships that may be perceived to influence our writing. Any personal or professional interests that conflict with that obligation, whether in appearance or in reality, risk compromising our credibility. Staff needs to be vigilant in disclosing to both our supervisors and the public any circumstances where loyalties may be divided - extending to the interests of spouses and other family members - and when necessary, recuse themselves from related coverage. Under no circumstances, excepting with respect to "embedded" advertorial coverage, which will always be clearly disclosed, should we skew our reports for personal gain or to please advertisers or partners. Decisions about what we cover and how we do our work are made by our journalists, not by those who provide the company with financial support.

In order to increase transparency to our readers, please review and comply with the ethics policies below. If you have questions on any of these guidelines, please reach out to your direct manager and they will engage management and/or business affairs as needed.

Reporting of Fact, Allegation, and Opinion

Before writing about allegations, use best efforts to secure more than one source. The source could be original screenshots we've taken of the posts in question, or gathered from reputable websites or newspapers, or other reasonable sources.

When writing about allegations, we will use language that does not assume the alleged actions have taken place. We will use phrases like "The accused allegedly" or "So-and-so claims that" when describing the events.

If staff members write personal opinions in a news post or in a forum thread, we will clearly identify them as the opinions of the writer and not as fact.

Acceptance of Material from Publishers/Vendors/Advertisers

Our Sites may accept product from publishers/vendors/advertisers for the purposes of review or analysis. All physical copies remain the property of Defy Media LLC and are added to our library of product and used for reporting purposes. We will honor all requests from the publishers/vendors/advertisers to return or dispose of the provided product.

Our Sites may accept promotional materials such as branded merchandise. On an annual basis, we may elect to donate this merchandise to a suitable charity or save it to give away to our readers in contests or other promotions. All such decisions are the responsibility of your Site's editorial directors.

Our Sites may allow the host of press events to pay for travel and lodging of our editors. The sole purpose for this is so that we can provide information for properties (games, TV shows, movies, comic books, etc.) to our readers we could not otherwise provide without travel assistance. If we post a write-up (preview, interview, etc.) derived from an event, we will disclose whether accommodations were paid for by the host. Our Sites will not, however, participate in an event specifically designed around providing early, controlled access to a property for the purpose of a scored review.

Conflicts of Interest by Editors and Contractors

All Site staff must tell their supervisors in advance about potential conflicts of interest. When first assigned to cover or work on a matter, disclose to your immediate supervisors any business, commercial, financial or personal interests where such interests might reasonably be construed as being in actual, apparent or potential conflict with our duties . This includes situations in which a spouse, family member or companion is an active participant in a subject area that you cover. In the financial category, this does not include an investment by you or your spouse, family member or companion in mutual funds or pension funds that are invested by fund managers in a broad range of companies (unless, of course, the assignment concerns those specific funds). When a spouse, family member or companion is involved in political activity, be sensitive to the fact that this could create real or apparent conflicts of interest. In such instances, advise your supervisor so that it can be determined whether you should recuse yourself from a certain story or certain coverage. For example, if an editor provided a line of voice talent to a game, he might be required to disclose that on coverage of the game. If an editor were a level designer for a game, he would have to recuse himself from reviewing the game.

. This includes situations in which a spouse, family member or companion is an active participant in a subject area that you cover. In the financial category, this does not include an investment by you or your spouse, family member or companion in mutual funds or pension funds that are invested by fund managers in a broad range of companies (unless, of course, the assignment concerns those specific funds). When a spouse, family member or companion is involved in political activity, be sensitive to the fact that this could create real or apparent conflicts of interest. In such instances, advise your supervisor so that it can be determined whether you should recuse yourself from a certain story or certain coverage. For example, if an editor provided a line of voice talent to a game, he might be required to disclose that on coverage of the game. If an editor were a level designer for a game, he would have to recuse himself from reviewing the game. Site staff are permitted to contribute to crowdfunding campaigns and subscription services like Patreon. If editorial content is derived from these contributions, disclose the contribution. However, staff may not create content surrounding a crowdfunding effort if they are a contributor to the effort, and the effort will not be funded if it fails to reach its goals.

create content surrounding a crowdfunding effort if they are a contributor to the effort, and the effort will not be funded if it fails to reach its goals. Certain coverage topics may be the property, directly or indirectly, of Defy investors, partners, and/or staff. Examples are as follows; if you have a question as to whether a disclosure is necessary, please speak to your supervisor.



Strauss Zelnick, Chief Executive Officer and Chairman of the Board of Directors of Take-Two Interactive Software, Inc., is the head of ZelnickMedia, an investor in both Take-Two and Defy Media, LLC, The Escapist's parent company.



Alexander Macris, general manager of The Escapist, is the founder and majority owner of Autarch, LLC.



Lionsgate, the studio behind ________, is an investor in Defy Media, LLC, The Escapist's parent company.

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