Dow Jones & Co. and Ottaway Newspapers, Inc.

CONFLICTS OF INTEREST POLICY

This policy statement is designed to provide all employees with guidelines which will enable them to avoid conflicts of interest that might be construed to be detrimental to the best interests of Dow Jones or Ottaway Newspapers. All references in this policy to Dow Jones apply also to all Ottaway Newspapers. Because of the nature of the Company's business, this statement also applies to the families of each employee (except for Item 1).

1. Dow Jones and Ottaway Newspapers employees are prohibited except with written approval of the chief executive officer from serving as directors or officers of any other company devoted to profit-making. This prohibition, of course, does not apply to employees appointed to serve as directors or officers of companies in which Dow Jones has a significant equity interest. If an employee is involved in a family-owned, profit-making business, clearance should be obtained from your publisher and the chief executive officer of Ottaway Newspapers.

2. Employees should not requisition, order, approve or otherwise participate in the purchase of goods or services on behalf of Dow Jones or Ottaway Newspapers from any company which furnishes material, equipment supplies or services to Dow Jones or Ottaway Newspapers if the employee has any significant financial interest in that company, whether by way of stock ownership or loans or otherwise.

3. Employees should not accept, directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies, nor should they accept payment, loan, services, employment or any other benefit from any company, or individual that furnishes or seeks to furnish news, material equipment, supplies or services to Dow Jones or Ottaway Newspapers.

4. Employees should not offer or provide, directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies, nor should they offer any material, equipment or services to any company or person in a position to make or influence any business or governmental decision affecting Dow Jones or Ottaway Newspapers.

5. Dow Jones and Ottaway Newspapers do not contribute directly or indirectly to political campaigns or to political parties or groups seeking to raise money for political campaigns or parties, and Dow Jones or Ottaway Newspapers do not and will not reimburse any employee for any political contribution made by an employee.

6. Employees should not use, directly or indirectly, for personal financial gain, any information about Dow Jones or Ottaway Newspapers which the employee obtained in connection with Dow Jones or Ottaway Newspapers employment. Further, employees should not disclose to anyone confidential information obtained in connection with Dow Jones or Ottaway Newspapers employment until such information has been made available to the public.

7. No Dow Jones or Ottaway Newspapers fund or asset which is not fully and properly recorded on the books and records shall be created or permitted to exist.

8. No transaction shall be executed and no payment shall be made on behalf of Dow Jones or Ottaway Newspapers with the intention or understanding that the transaction or payment is other than as described in the documentation evidencing the transaction or supporting the payment.

9. All employees will comply with Dow Jones' and Ottaway Newspapers' accounting principles, procedures and controls and no false, artificial or misleading entries in our books and records shall be made for any reason whatsoever.

10. No Dow Jones or Ottaway Newspapers employee will:

a. issue or authorize any official company document that is false or misleading;

b. knowingly accept and treat as accurate a false or misleading document prepared by a person outside Dow Jones or Ottaway Newspapers: and,

c. knowingly make false or misleading statements to our external, internal or other auditors.

11. Dow Jones and Ottaway Newspapers have had a strict policy on security transactions by employees who have access to inside information regarding unpublished stories or advertising schedules. It also has had a strict related policy on the conduct of news and advertising staff members dealing with corporations we cover or whose advertising we carry. Each employee is expected to bend over backwards to avoid any action, no matter how well intentioned, that could provide grounds even for suspicion:

(a) that an employee made financial gains by acting on the basis of inside information obtained through a position on our staff, before it was available to the general public. Such information includes hold-for-release material, our plans for running stories, items that may affect price movements, or projected advertising campaigns;

(b) that the writing of a news story or item or scheduling of advertising was influenced by a desire to affect the stock's prices;

(c) that an employee is financially committed in the market so deeply or in such other way as to create a temptation to biased writing or scheduling of advertising;

(d) that an employee is indebted to brokers or any other group we cover or advertisers. Such indebtedness could arise through acceptance of favors, gifts or payments for performing writing assignments or other services for them;

(e) that an employee is beholden for any tips. allocations or underwritten new issues or in any other way to anyone in the business or financial community.

While we do not want to penalize our staff members by suggesting that they not buy stocks or make other investments, we reiterate that it is not enough to be incorruptible and act with honest motives. It is equally important to use good judgment and conduct one's outside activities so that no one - management, our editors, an SEC investigator with power of subpoena, or a political critic of the Company - has any grounds for even raising the suspicion that an employee misused a position with the Company.

It is important for all employees to keep in mind the tremendous embarrassment and damage to the Company's reputation that could come about through a lapse in judgment by one person, no matter how well intentioned that person may be. Because we think it so essential that every employee be above suspicion, we consider any slip in judgment in this area or others covered in this policy statement to be serious enough to warrant dismissal.

With these general propositions in mind, here are some specific guidelines:

(i) First and foremost, all material gleaned by you in the course of your work for Dow Jones or Ottaway Newspapers is deemed to be strictly the Company's property.

This includes not only the fruits of your own and your colleagues' work, but also information on plans for running items and articles on particular companies and industries and advertising schedules in future issues.

Such material must never be disclosed to anyone outside the Company, including friends and relatives. Viewing information as the Company's property should avoid a great many of the obvious pitfalls.

(ii) No employee regularly assigned to a specific industry should invest in any company engaged in whole or significant part in that industry.

(iii) No employee with knowledge of a forthcoming article, item or advertisement concerning a company or industry should, prior to the publication of such article, item or advertisement, invest in that company or companies in that industry; nor, if the employee already owns any such security, should the employee sell it prior to publication without the approval of the appropriate publisher.

(iv) Further, any employee having prior knowledge of a forthcoming article, item or advertisement, should delay trading in the securities of the companies involved until the general public has an opportunity to read and digest the information contained in any Dow Jones or Ottaway Newspapers publication or news service. Employees should wait two full trading days after an article or advertisement first appears in a Dow Jones or Ottaway Newspapers publication or news service.

(v) If an employee should inadvertently buy or sell a security or otherwise invest contrary to the guidelines set forth in (iii)or (iv), or if an employee should buy a security prior to publication, and then acquire knowledge of a proposed article, item or advertisement, the employee should notify his or her department head as soon as practical. In the case of a purchase, the employee should hold the security for six months.

(vi) No employee should engage in short selling of securities.

We believe these guidelines should be easily understood. They aren't intended to deter any employee from participating actively in civic or charitable organizations or oards, provided they have no impact on or connection with Dow Jones or Ottaway Newspapers. Participation in political organizations or government advisory boards may often involve a conflict of interest and should be avoided. Employees are asked to refrain from activity in political or government organizations or boards unless prior approval is given by their newspaper publisher.

We urge that whenever a situation comes up where a conflict may arise between the interests of Dow Jones, Ottaway Newspaper or your newspaper, civic, charitable. political or governmental organization, you refrain from participating in order to avoid any appearance of a conflict of interest. Should any questions ever arise in your mind as to the propriety of your activity, you are urged to consult in confidence with your newspaper publisher.

We would like to emphasize that we have complete confidence in all our employees. It is essential, however, that all of us maintain the highest standards of ethics in the conduct of Dow Jones' or Ottaway Newspapers' business by acting within the framework of these guidelines. Please retain this policy statement in your files.

Your cooperation is greatly appreciated.

—— Dow Jones & Company, Inc.

Ottaway Newspapers, Inc.