OVERVIEW

Fox Corporation (FOX or the Company) considers the involvement of its employees in the political process to be an important aspect of civic and community life. This Political Activities Policy (the Policy) is designed to ensure that all FOX employees, officers, and board members comply with the federal, state, and local laws that apply to our political activities due to our employment or association with FOX. To avoid conflicts of interest or, worse, violations of the federal, state, and local laws that relate to political activity, employees, officers, and board members are requested – and in some instances required – to receive approval from the FOX Chief Legal and Policy Officer and FOX Government Relations office prior to engaging in the political activities described in this Political Activities Policy. To help you comply with relevant laws, the FOX Government Relations staff is available to answer your questions about the permissibility of political activities and will do so in coordination with the FOX Chief Legal and Policy Officer.

The FOX Political Activities Policy focuses on six areas of political activity: providing gifts or other items of value to “covered officials”; lobbying lawmakers and government officials on policies that are important to FOX; making corporate or personal political contributions; running for political office; supporting the FOX Political Action Committee (FOXPAC); and maintaining trade association memberships. It is important to note that in the United States the federal government, all states, and many local governments each have their own laws regulating political activities. These laws impose significant restrictions on giving gifts to elected officials and government employees, regulate communications with government officials, place limitations on political contributions, and in certain instances guarantee equitable access to media coverage to candidates for public office. The FOX Political Activities Policy establishes standards for employees, officers, and board members to ensure compliance with applicable laws at every level of government. In addition, your business unit may have additional or more restrictive requirements with which you must also comply.

The Company’s Board of Directors, through its Nominating and Corporate Governance Committee (the Committee) reviews and oversees compliance with this Policy. In addition, the Committee reviews and oversees a Political Activities Report prepared by the FOX Law & Policy office with details of the Company’s political activities over the prior calendar year. A copy of the annual Political Activities Report can be found on the Company’s website. The Political Activities Report focuses on four areas of prior year activity: contributions made by FOXPAC; corporate political contributions to state and local candidates; lobbying activities and expenditures by FOX; and the Company’s participation in trade associations and contributions to non-profit entities.

1. GIFTS

FOX employees are required to consult the FOX Government Relations office or the FOX Chief Legal and Policy Officer to determine the permissibility of a gift prior to it being offered or given to a public official at any level of government. The executive branch of the U.S. government, the U.S. Senate, the U.S. House of Representatives, various states, and certain local jurisdictions have laws prohibiting or restricting the giving of gifts to public officials. These gift bans prohibit providing – directly or indirectly – any gift, entertainment, food or beverage, lodging, transportation, or anything else of value to any public official or employee. Additional examples of gifts that may fall under gift ban laws include tickets to sporting and awards events, paying for dinner at a local restaurant, or covering an official’s greens fees for a round of golf. These prohibitions include providing any gift to a non-profit organization (e.g., a charitable organization) on behalf of, or on the recommendation of a public official or spouse or immediate family member of a public official. Journalists engaged in newsgathering must also comply with any rules or policies in effect within their business unit as well.

Federal Gift Compliance

The U.S. government maintains gift laws that apply to both the executive and legislative branches. These gift bans include things of value such as gifts, food and beverage, transportation, and lodging as well as favorable treatment or special courtesy to executive branch officials and Members of Congress, including staff and their family members. Additionally, FOX, its employees, officers, board members and lobbyists must disclose any payments relating to events associated with or held to honor or recognize a Member of Congress or staff. Restrictions on payments related to events associated with certain federal executives apply as well and require disclosure. Prohibitions also apply to payments to an entity such as a charity that is named for, solicited by, or associated in any way with an executive or legislative branch official. Gift bans apply to payments to a charity, a Presidential Library or Presidential inaugural committee associated in any way with a member of either the legislative or executive branches of government. Employees, officers, and board members must consult FOX Government Relations before providing any gift, entertainment, food or beverage, travel, lodging or anything else of value to a federal official.

State and Local Gift Compliance

Each state and many localities have their own gift laws, many with significant criminal penalties. Employees, officers, and board members must consult FOX Government Relations before providing any gift, entertainment, food or beverage, travel, lodging or anything else of value to a state or local official.

2. LOBBYING

Federal Lobbying Compliance

Before seeking to influence any federal legislation, regulation, official agency actions, or nominations/appointments through communications or attending a meeting with any “covered official” – Member of Congress, staff member, or executive branch official – FOX employees, officers and board members must notify the FOX Government Relations office which will seek approval for the proposed activities from appropriate legal counsel or the Chief Legal and Policy Officer. The executive branch of the U.S. government, the U.S. Senate the U.S. House of Representatives, various states, and certain local jurisdictions have laws requiring registration and reporting of activities by lobbyists and, in many cases, by the lobbyist’s employer. The thresholds of reportable lobbying activities are often low, generally including any attempt to directly influence a government decision such as legislation, rulemaking by a government agency, or decisions regarding government contracts or franchises. Reportable “lobbying activities” also include indirect, “behind-the-scenes” efforts in furtherance of direct lobbying. When lobbying a ”covered official” to change a law, regulation, or to influence an official act, any form of written or verbal communication is considered lobbying, i.e., email exchanges and texts, direct conversations in person during meetings or over the phone, by letter or through third parties. In turn, FOX Government Relations is required by law to file lobby disclosure reports. This policy does not apply to the communications of journalists only in a regular and ordinary newsgathering capacity, and no employee shall engage in any other communications and activities described in this section except at the sole direction of the Executive Vice President and Head of Government Relations for Fox C