Center for the Study of Ethics in the Professions at IIT

Correct ethical and legal conduct is particularly at the heart of the operation of a company engaged in communications with and on behalf of the public. In all matters and in all divisions, the highest professional standards must be practiced in every Gannett activity to guarantee the independence and the integrity of all our news, editorial, information, advertising and marketing services. We believe respect for others and our commitment to diversity represent vital strengths of our Company. In every case, necessary safeguards must be maintained to prevent any action or any association that might reflect adversely, directly or indirectly, upon Gannett.

CONFLICTS OF INTEREST

Influence: An impartial, arms' length relationship will be maintained with anyone seeking to influence the news.

Outside Interests: Employees will not have any outside interest, investment or business relationship that dilutes their loyalty to the Company or dedication to the principle of a free and impartial press.

Gifts: Payments, gifts or entertainment by or to an employee in conjunction with business will be limited to normal business practices. (The U.S. tax laws' limit on deductibility of gifts is $25.) For people in news operations; the recommended practice is to accept no gifts.

Advertising: Any service provided by a Gannett employee for an account will be reflected in direct charges from the Company. An employee may not act as an agency for an account.

Circulation: Circulation employees may not buy newspapers at wholesale to cover "down routes.

Mailroom and circulation employees preparing draws or determining press runs may not be involved in direct sales to subscribers or in newsstand operations.

Banking: Any banking relationship, including membership on a board of directors, must be arms' length to ensure no impact on company bank relations.

Confidential Information: Employees will not use confidential company information for their own advantage or profit. Employees will not disclose confidential Company information. in any form, to anyone who does not need to know it in order to conduct the Company's business.

RELATIONSHIPS WITH OTHERS

Gannett is committed to the concept of free, fair and open competition for suppliers. customers and competitors. To achieve that, the people of Gannett will:

Avoid actions that restrict freedom of competitive opportunities. We will not disparage our competitors or their products or services.

Maintain an arms length relationship all dealings, including those with suppliers or others dealing with the Company. This includes any credits or return of money for services such as from collection agencies

Keep senior management informed on any matters that might be considered sensitive to preserving the Company's reputation, even when less candor might seem to protect the Company or its management from criticism.

CORPORATE PAYMENTS

Contributions: Personal contributions to political parties or candidates are a matter of individual choice. Such contributions may not-be represented as being on behalf of the Company. Gannett funds cannot be used for political contributions.

Entries: Company funds will be used only for business purposes and all must be recorded. Fund usage must be only for the described purpose and backed by appropriate supporting documents. Employees will cooperate fully with our independent auditors.

Consultants: Any fees of more than $10.000 to consultants and agents needs approval in advance by the division president.

COMPLIANCE WITH LAWS

It is Gannett's firmly established policy to comply fully with all laws affecting its business. The consequences to Gannett and its employees of any departure from this policy can be very serious. In addition, the effort, energy and expense required to respond to government investigations and to defend Gannett's actions in court diverts the talents and energy of its employees from the pursuit of its business, goals.

Each employee is expected to report what he or she believes in good faith is violations of the law or Company policy, whether accidental or deliberate, by any Gannett employee. The knowing failure to report a violation is itself a violation of Company policy.

Employees will not be disciplined or suffer retribution for reporting honestly and in good faith suspected violations.

It is Gannett's policy to cooperate with all government investigations of possible unlawful conduct. If a criminal violation has occurred, the Company will take appropriate steps to stop the criminal conduct and to prevent such conduct from reoccurring.

Disciplinary action will be the prerogative of the Company's management and may include a reprimand which is documented in the personal file, loss of compensation, change of responsibilities to avoid repeat violations, demotion, termination or other measures management deems appropriate.

• • This policy highlights some of the more frequent ethical and legal questions you may face at work. You should be familiar with the Gannett Finance and Accounting Reference Manual and the Gannett Legal Manual which discusses many of these issues in more detail. You may also seek further advice from corporate staff representatives in the Law and Personnel Departments.

If you have any questions or if you wish to report a violation or possible violations. please feel free to call

800-234-41.06. The phone mail hotline number that has been established for this purpose. 'Mere is no need to identify yourself if you prefer not to do so. All reports will be treated in confidence except as necessary to conduct investigations.