This code is designed to provide all employees of Mint with guidelines for appropriate professional conduct. It is intended not as a statement of new beliefs or a codification of new rules of conduct, but as a reaffirmation of enduring values and practices.

The central premise of this code is that Mint reputation for quality products and services, for business integrity, and for the independence and integrity of our publications, services and products is the heart and soul of our enterprise. Put another way, it is an essential prerequisite for success in the news and information business that our customers believe us to be telling them the truth. If we are not telling them the truth -- or even if they, for any valid reason, believe that we are not -- then Mint cannot prosper. The company will suffer, for example, if our customers cannot assume that:

All companies profess business integrity. But the impact of our work on the work of others, and on their lives and fortunes, places special responsibilities upon all Mint employees.

The clear implication of these beliefs is that the responsibility for safeguarding and growing a company that lives up to this code lies with each and every one of us. Every Mint employee holds a position of trust. Acceptance of a position at any level or in any part of Mint includes acceptance of individual responsibility to uphold Mint policies governing legal and ethical business practices. It also includes acceptance of individual responsibility for following all legal requirements and ethical business practices, as well as the responsibility to stress proper ethical behavior among colleagues and subordinates.

Moreover, it must be clear to each of us that business integrity is necessary in every business decision- and that it is not the special province of news employees, or members of the legal department, or anyone else. Business integrity requires that we make all of our business decisions, and approach all business questions, objectively and realistically, and in the long-term best interests of all of our shareholders.

Editors, by virtue of their positions of authority, must be ethical role models for all employees. An important part of an editor's leadership responsibility is to exhibit the highest standards of integrity in all dealings with employees, customers and the world at large. Editors must avoid even implicit or unspoken approval of any actions that may be damaging to the reputation of HT Media, and must always exercise sound business judgment in the performance of their duties.

An equally important leadership responsibility is to develop employees' commitment to our principles and ability to make sound ethical judgments. Editors must communicate the seriousness of the company's expectations of ethical conduct, as well as their own personal support for these guidelines. Ethical leadership includes fostering a working environment that encourages employees to voice concerns or otherwise seek assistance or counsel if faced with potentially compromising situations, and also supporting those who raise such concerns.

Finally, what follows is not intended to be an exclusive or inclusive list of all laws, regulations and other norms applicable to Mint and with which compliance is expected. In our rapidly evolving businesses, a complex environment that often requires quick response under pressure challenges each of us. No written policy can definitively set forth the appropriate action for all business situations. Accordingly, this code emphasizes and clarifies a standard of ethical conduct that must govern all of our business dealings and relationships.