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Code of Ethics for the Chief Executive Officer And Senior Financial Officers Adopted by the BNA Board of Directors February 12, 2004

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.