VeriSign Global Registry Services (VGRS), the registry business of VeriSign, Inc., will at all times strive to operate as a trusted and neutral third party provider of Registry Services. VGRS recognizes that domain names are the means by which businesses, individuals and consumers gain access to, navigate and otherwise benefit from the global Internet. These benefits cannot be fully realized, however, unless the DNS resources are administered in a fair, efficient and neutral manner that makes them available to all qualified parties in the competitive DNS space. To ensure the provision of neutral Registry Services, VGRS will comply with the following Code of Conduct:
1. VGRS will not show any preference or provide any special consideration to any ICANN-accredited registrar with regard to Registry Services provided for the .com TLD.
2. All registrars accredited by ICANN who are authorized to register domain names in the .com registry shall have equivalent access to Registry Services provided by VGRS.
3. VGRS shall not in any way attempt to warehouse, or register domain names in its own right other than through an ICANN-accredited registrar, except for names designated for operational purposes in compliance with Section 24 of the Registry Agreement. VGRS will certify to ICANN every six months that it is abiding by this commitment.
4. Any subsidiary or affiliate of VGRS that operates as an ICANN-accredited registrar shall maintain separate books of account with respect to its registrar operations.
5. VGRS subsidiaries and affiliates engaged in providing Registry Services shall not have access to, and VGRS itself will not use, confidential user data or proprietary information of an ICANN-accredited registrar served by VGRS, received by VGRS in the course of providing Registry Services, except as necessary for registry management and operations.
6. VGRS will take appropriate precautions to prevent the disclosure of confidential user data or proprietary information from any ICANN-accredited registrar, received by VGRS in the course of providing Registry Services, to its affiliates or subsidiaries, except as necessary for registry management and operations.
7. Confidential information about VGRS's Registry Services for the .com TLD will not be shared with employees of any ICANN-accredited registrar, except as necessary for registry management and operations.
8. VGRS will conduct internal neutrality reviews on a regular basis. In addition, VGRS and ICANN may mutually agree on an independent party that ICANN may hire, at ICANN's expense, to conduct a neutrality review of VGRS, ensuring that VGRS and its owners comply with all the provisions of this Registry Operator Code of Conduct. The neutrality review may be conducted as often as once per year. VGRS will provide the analyst with reasonable access to information and records appropriate to complete the review. The results of the review of the Neutrality Analyst will be provided to ICANN and shall be deemed to be confidential and proprietary information of VGRS and its owners.
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