Black Isle Media

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 Black Isle Journalism Ltd, herein referred to as Black Isle Media, 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 Black Isle Media.

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 their work will be limited to normal business practices. For people in news operations, the recommended practice is to accept no gifts.

Advertising: Any service provided by a Black Isle Media employee or contributer for an account or business will be reflected in direct charges from the Company. An employee may not act as an agency for an account.

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

Black Isle Media is committed to the concept of free, fair and open competition for suppliers, customers and competitors. To achieve that, the people of Black Isle Media l 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 in 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.

INSIDE TRADING POLICY

Shares and Securities Traded by Company Personnel AND Contractors

INTRODUCTION

Employees of Black Isle Journalism Ltd (Black Isle Media). and its subsidiaries may from time to time be in possession of material, non-public information concerning Black Isle Media or other companies. Under UK trading laws, our employees are prohibited from buying or selling stock while in possession of such inside information, and may not otherwise use the information for their own advantage or the advantage of others. Violations of this rule may subject those involved to disciplinary action, as well as severe civil or criminal penalties. Any such legal proceedings would result in adverse publicity and embarrassment to the Company and the individuals involved.

Government agencies vigorously pursue violations of insider trading laws. We would cooperate fully with any investigation into Insider trading.

BLACK ISLE MEDIA’S POLICY

Black Isle Media has adopted this Policy Statement to avoid even the appearance of improper conduct on the part of anyone employed by or associated with our Company (not just so-called insiders). Black Isle Media and its employees have work hard to establish & maintain our reputation for integrity and ethical conduct We cannot afford to have it damaged.

If a director, officer or any employee has material, non-public information relating to our Company, it is our policy that neither that person nor any related person may buy or sell securities of the Company or engage in any other action to take advantage of, or pass on to others, that information.

In addition, the same prohibition applies to trades by employees in the stock of any other company if the employee is in possession of material, non-public information about that company, obtained in the course of employment.

Transactions that may be necessary or justifiable for independent reasons (such as the need to raise money for an emergency expenditure) are no exception.

‘Material information’ generally is any information that a reasonable investor would consider important in a decision to buy, hold or sell stock. In short, it is any information that could reasonably affect the price of the stock.

Common examples of information that will frequently be regarded as material are: projections of future earnings or losses; news of a pending or proposed merger, acquisition or tender offer; news of a significant sale of assets or the disposition of a subsidiary; changes in dividend policies or the declaration of a stock split or the offering of additional securities; changes in management; significant new products or discoveries; impending bankruptcy or financial liquidity problems; and the gain or loss of a substantial customer or supplies. Either positive or negative information may be material.

Tipping Information to Others. Whether the information is proprietary information about our Company or information that could have an impact on our stock price, employees must not pass the information on to others. The penalties apply, whether or not you derive any benefit from another’s actions.

Transactions by Family Members. The same restrictions apply to your family members and others living in your household.

When Information is Public. Generally, a person having material, non-public information must refrain from buying or selling the stock, until after the information either is formally made public or is no longer relevant. As you can appreciate, it is also improper for an officer, director or employees to enter a trade immediately after the Company has made a public announcement of material information, including earnings releases. Because the Company’s shareholders and the investing public should be afforded the time to receive the information and act upon it, as a general rule you should not engage in any transactions until the third business day after the information has been released.

Twenty-Twenty Hindsight. Remember, if your trading transactions become the subject of scrutiny, they will be viewed after the fact, with the benefit of hindsight.

COMPANY ASSISTANCE

If there is any question about the appropriateness of stock transactions under this Policy, employees should consult with the Company management directly, who will then review the matter as necessary with a solicitor.

Remember, however, that the ultimate responsibility for honoring the Policy Statement and avoiding improper transactions rests with you. In this regard, it is imperative that you use your best judgment.

Political Donations

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. Black Isle Journalism Ltd funds cannot and WILL NOT be used for political contributons.

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.

COMPLIANCE WITH LAWS

It is our policy to firmly comply with all laws affecting its business. The consequences to Black Isle Media 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 our actions in court diverts the talents and energy of its employees from the pursuit of its business goals.

It is Black Isle Media’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.

GENERAL COMPLIANCE; DISCIPLINARY ACTION

Each employee is expected to report what he or she believes in good faith are violations of the law or Company policy, whether accidental or deliberate, by any Black Isle Media employee OR contractor. If you become aware of any conflict, relationship, payment or other action. involving yourself or others, which could conflict with these policies, it is your obligation to disclose the matter fully and in writing to the company management. 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.

Failure to comply with this policy may result in disciplinary action. Disciplinary action will be the prerogative of the Company’s management and may include a reprimand which is documented in the personnel 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.

If you have any questions, or if you wish to report a violation or possible violations, please contact Alexander Tiffin. There 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.

Diversity Policy

Inclusiveness is at the heart of thinking and acting as journalists. The complex issues we face as a society require respect for different viewpoints.

Race (ethnicity), class, sexual orientation, generation, gender, religion, Gender Identity and geography all affect points of view. Reflecting these differences in our reporting leads to better, more nuanced stories and a better-informed community.

We are interested in hearing from different ethnic, civic and business groups when reporting and strive encourage more diverse reporting.

We report openly and honestly about every side of immigration, which may include any negative side effects, and other aspects of diversity, including race, ethnicity and gender issues. While this may seem uncomfortable to some, it is important that we give an impartial view of any facts. At all times we will approach this matter with dignity and respect.

Diverse staffing report:
We seek diverse voices in our management and reporting staff. It is a company policy that minorities are represented as much as possible.

Black Isle Media prides itself on reporting from an alternative viewpoint than traditional news outlets. We do this by inviting people of all backgrounds and beliefs to contribute.