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Financial interests

Associated Press employees who regularly write or edit business or financial news must always avoid any conflict of interest or the appearance of any conflict of interest in connection with the performance of these duties. For these reasons, these employees must abide by the following rules and guidelines when making personal investment and financial decisions.

These employees must not own stock, equities or have any personal financial investment or involvement with any company, enterprise or industry that they regularly cover for the AP. A technology writer, for example, must not own any technology equities; a retail industry writer must not own the stock of any department store or corporate enterprise that includes department stores. Staff members who are temporarily assigned to such coverage or editorial duties must immediately notify a manager of possible conflicts to determine whether the assignment is appropriate. If necessary, employees might be asked either to divest or to suspend any activity involving their holdings.

Editors and writers who regularly cover the financial markets may not own stock in any company. They may invest in equity index-related products and publicly available diversified mutual funds or commodity pools.

Financial news employees must also avoid investment activities that are speculative or driven by day-trading or short-term profit goals because such activities may create the impression that the employee is seeking to drive market factors or is acting upon information that is not available to the public.

Instead, the personal financial activities and investments of these employees must be based upon the longer term and retirement savings. For these reasons, an employee covered by this policy should not buy and sell the same financial product within 60 days, unless he/she gains the permission of the department manager and is able to demonstrate financial need that is unrelated to information discussed or gained in the course of his/her employment. This trading limitation does not apply to equity-index funds, broadly diversified and publicly available mutual funds and commodity pools.

All employees must comply with federal and local laws concerning securities and financial transactions, including statutes, regulations and guidelines prohibiting actions based upon "inside information." All employees are reminded that they may not act upon, or inform any other person of, information gained in the course of AP employment, unless and until that information becomes known to the general public.

Employees should avoid any conflict of interest or the appearance of a conflict of interest in the investments and business interests of their spouses or other members of their household with whom they share finances. They are expected to make every effort to assure that no spouse or other member of their household has investment or business interests that could pose such a conflict.

Employees should be aware that the investment activities and/or financial interests of their spouses or other individuals with whom they share financial interests may make it inappropriate for them to accept certain assignments. Employees must consult with their managers before accepting any such assignment.

Employees who are asked to divest holdings will be given one year from the date of the request to do so, in order to give them the opportunity to avoid market fluctuations.

When this document requires the sale of stock holdings, an employee can satisfy this requirement by putting the shares into a blind trust (or into an equivalent financial arrangement) that meets the same goal: preventing an individual from knowing, at any given time, the specific holdings in the account and blocking an individual from controlling the timing of transactions in such holdings. If AP assigns a staff member to a new job where mandatory divestiture would impose a financial hardship even after the one-year grace period, AP will reimburse the staff member up to a maximum of $500 for the reasonable costs of setting up a blind trust.)

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