• About Acxiom

This Code of Ethical Conduct (“Code”), to be read in conjunction with the Company’s Guidelines to Business Ethics which is applicable to all associates, sets forth principles which the senior financial officers are expected to adhere to and advocate. The Code embodies rules regarding individual and peer responsibilities, as well as responsibilities to Acxiom Corporation (the “Company”), the public and other stakeholders.

In my role as the principal executive officer, principal financial officer, principal accounting officer or controller of the Company, I recognize that I play a critical role in corporate governance, and I am committed to ensuring that stakeholders’ interests are appropriately balanced, protected and preserved.

I certify that I will adhere to and advocate the following principles and responsibilities governing my professional and ethical conduct. I understand and agree that failure to adhere to this Code constitutes grounds for discipline, termination of employment, and any other remedies available under the law.

To the best of my knowledge and ability:

1. I will act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships. When conflicts of interest do arise, I will disclose such conflicts to the chief legal officer of the Company. In addition, I will disclose to the chief legal officer any material transactions or relationships that reasonably can be expected to give rise to such a conflict. I understand that a conflict of interest can arise any time a member of my family or I have any interest in any business, property or transaction, or have any right or obligation from or to any person, which might affect the fulfillment of my job responsibilities to the Company.
2. I will provide my constituents with information that is accurate, complete, objective, relevant, timely and understandable. In particular, I will do my best to ensure that reports and documents filed with or submitted to the Securities and Exchange Commission and The NASDAQ Stock Market, or otherwise publicly communicated by the Company, contain full, fair, accurate, timely, and understandable disclosure. If I become aware that any information contained in such reports or publicly communicated by the Company is materially false or misleading or omits material information, I will promptly disclose this fact to my leader and to the Company’s chief legal officer. If I do not feel that prompt action has been taken by my leader or the chief legal officer to address my concerns, I understand that it is my duty to report my concerns to the Chairman of the Board of Directors’ Audit Committee in accordance with the Company’s procedures for the receipt, retention and treatment of complaints and concerns regarding accounting, internal control or auditing matters. I understand that reports to the Audit Committee may be made on an anonymous basis.
3. I will comply with all applicable laws, rules and regulations of the federal, state, provincial and local governments, and other appropriate private and public regulatory agencies.
4. I will act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing my independent judgment to be subordinated.
5. I will respect the confidentiality of information acquired in the course of my work except when authorized or otherwise legally obligated to disclose it. I will not use any confidential information acquired in the course of my work for personal advantage.
6. I will share knowledge and maintain the skills important and relevant to my constituents’ needs.
7. I will proactively promote and demonstrate ethical behavior as a responsible partner among my peers in my work environment and community.
8. I will exercise responsible use of and control over all assets and resources employed by or entrusted to me.
9. If I become aware of a violation of the law or of this Code, I will promptly report the violation to the Company’s chief legal officer.
10. As a senior financial officer of the Company, I acknowledge that any waiver of the provisions of this Code may only be made by the Board of Directors, and that any such waiver will require immediate public disclosure.