The Bureau of National Affairs, Inc. (BNA) has adopted this
Code of Ethics (the "Code") as a set of guidelines pursuant to
which our chief executive officer and senior financial officers
should perform their duties. The Code is intended to deter wrongdoing
and to promote adherence to the standards set forth below. Executives
subject to the Code include the President and Chief Executive
Officer, the Chief Financial Officer, the Controller, and any
person who performs a similar function for BNA and any of its
subsidiary companies (the "Covered Executives".) The
particular executives who are subject to the Code from time to
time will be designated by, and informed of such designation
by BNA.
- In carrying out their duties and responsibilities, the Covered
Executives should endeavor to act with honesty and integrity,
including the ethical handling of actual or apparent conflicts
of interest between personal and professional relationships.
- To promote full, fair, accurate, timely and understandable
disclosure in the periodic reports that BNA files with, or
submits to, the Securities and Exchange Commission and in other
public communications made by BNA, it is the responsibility
of each Covered Executive promptly to bring to the attention
of BNA's Audit Committee any material information of which
he or she may become aware that affects the disclosures made
by BNA in its public filings or otherwise, and to otherwise
assist BNA in fulfilling its responsibilities.
- In addition, each Covered Executive shall promptly bring
to the attention of the Audit Committee any information he
or she may have concerning (a) significant deficiencies in
the design or operation of internal controls which could adversely
affect BNA's ability to record, process, summarize and report
financial data, or (b) any fraud, whether or not material,
that involves management or other employees who have a significant
role in BNA's financial reporting, disclosures, or internal
controls.
- In carrying out their duties and responsibilities, Covered
Executives should endeavor to comply, and to cause BNA to comply,
with applicable governmental laws, rules and regulations. In
addition, each Covered Executive shall promptly bring to the
attention of the Audit Committee any information he or she
may have concerning evidence of a material violation of the
securities or other laws, rules or regulations applicable to
BNA and the operation of its business, by BNA or any agent
thereof.
- Each Covered Executive shall promptly report to the Audit
Committee any information he or she may have concerning evidence
of a material violation of the Code.
- Covered Executives are expected to adhere to the Code. BNA
shall determine appropriate actions to be taken in the event
of violations of the Code by any Covered Executives. Such actions
shall be reasonably designed to deter wrongdoing and to promote
accountability for adherence to the Code.
- BNA will appropriately disclose any substantive amendment
to, and any waiver of, any provision of the Code that applies
to the Covered Executives.