Business conduct and ethics

BlackRock’s  Code of Business Conduct and Ethics sets out basic principles to guide employee conduct. The code is supported by employee conduct policies and programs and reinforced through employee training. We have zero tolerance in relation to illegal or unethical conduct and this is articulated in our relevant policies, including policies on conflicts of interest, gifts and entertainment, money laundering and counter terrorism, fraud, sanctions, outside activities, political contributions, and bribery and corruption. Any employee who violates the requirements of the Code of Business Conduct and Ethics, or many of our other policies, is subject to disciplinary action.

BlackRock expects the same high standards of those who represent us and we conduct appropriate due diligence on our business partners according to the risks they present, including corruption risk.  BlackRock’s Supplier Code of Conduct & Ethics outlines the minimum expectations and standards of all BlackRock Suppliers in relation to human rights, inclusion and diversity, environmental sustainability, integrity and ethics in management practices.

Non-Retaliation

BlackRock will not retaliate or discriminate against any employee because of a good faith report. Employees have the right to report directly to a regulator and may do so anonymously; employees may provide protected disclosures under whistleblower laws and cooperate voluntarily with regulators, in each case without fear of retaliation by BlackRock. Please consult the Global Policy for Reporting Illegal or Unethical Conduct and local compliance manuals for additional detail.