Walgreens Code of Business Conduct
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Walgreens Code of Business Conduct
Table of Contents
A message from Greg Wasson ................................................................................... 1
A message from Laura Merten................................................................................... 2
Our Code and Your Responsibilities
The purpose of our Code of Business Conduct ....................................................... 3
Key principles ........................................................................................................... 4
Publication and amendments................................................................................... 4
We are all accountable ............................................................................................. 4
Team leaders have additional responsibilities .......................................................... 4
Where we can seek help........................................................................................... 4
No retaliation policy .................................................................................................. 5
Open Door Policy ..................................................................................................... 5
What happens if we violate our Code?..................................................................... 5
A Foundation of Trust for Our Customers ................................................................. 6
We uphold our trustworthy reputation through product safety ................................ 7
We provide quality, dependable services our customers can count on ................... 7
We market our products and services honestly ....................................................... 7
We expect our suppliers to uphold our values ......................................................... 8
We protect the private information and intellectual property of others .................... 8
We uphold the competition and antitrust laws that apply to our work..................... 8
We obtain competitive information fairly .................................................................. 9
We work on government contracts lawfully and ethically ........................................ 9
We maintain appropriate relationships with healthcare professionals...................... 9
A Foundation of Trust for Our Company and Our Fellow Team Members ............. 10
We foster diversity and inclusion in our workplace .................................................. 11
We respect each other and do not tolerate harassment .......................................... 11
We strive to create a safe and healthy work environment ........................................ 11
We work to protect our company’s assets ............................................................... 12
We safeguard each other’s personal information ..................................................... 12
We use our computer systems appropriately ........................................................... 12
A Foundation of Trust for Our Investors .................................................................... 14
We keep honest, accurate financial books and records........................................... 15
We maintain records in compliance with the law and company policy .................... 15
We avoid conflict of interest situations ..................................................................... 15
Gifts and entertainment ............................................................................................ 16
Doing business with friends and relatives ................................................................ 16
Outside positions...................................................................................................... 16
Business opportunities ............................................................................................. 17
We uphold Insider trading laws ................................................................................ 17
A Foundation of Trust for Our Communities ............................................................. 18
We follow healthcare laws ........................................................................................ 19
We comply with the Federal False Claims Act ......................................................... 19
We work to build sustainable supply chains ............................................................ 20
We follow international trade laws ............................................................................ 20
We do our part to protect the environment .............................................................. 21
We support our local communities ........................................................................... 21
We communicate with a single voice ....................................................................... 21
Waiving Our Code of Business Conduct .................................................................. 21
Asking Questions and Raising Concerns.................................................................. 22
A message from Greg Wasson
Dear team member:
Throughout our 110-year history, Walgreens has
always based our success on our strong values—
honesty, trust and integrity among ourselves and
with our customers, suppliers, the communities we
serve and our shareholders. In fact, values are the
strong foundation Charles R. Walgreen Sr. built his
company on. Greg Wasson
In the mid-1950s, Mr. Walgreen’s son—and our
second CEO—Charles R. Walgreen Jr., took his
father’s commitment to values further by adopting
the Four Way Test in 1955. Its four questions—
“Is it the truth? Is it fair to all concerned? Will it
build good will and better friendship? Will it be
beneficial to all concerned?”—continue to influence and
drive our business decisions and internal and external relationships.
Maintaining integrity is absolutely a team effort, and it’s important for everyone to make business decisions without
compromising our company’s ethics. Failing to do this puts Walgreens reputation at risk—as well as undercuts our
ability to both grow our business and serve our customers. Every one of us is responsible for our actions; and each
of us contributes to fostering Walgreens culture of trust. A key part of our code of conduct—that everyone should
be aware of—allows team members to report known or suspected violations or concerns without fear of retaliation.
It is critical that we all work to maintain an environment where complying with company policies and applicable
laws is a part of our DNA.
This Code of Business Conduct spells out the standards we follow at Walgreens—responsibility, solid ethics,
integrity and trust. Accordingly, it is important that you take the time to read through the Code and make it a part
of your everyday actions—both internally and externally. As a Walgreens team member, you represent our
company, and together we can work to maintain the fine reputation we enjoy. Thanks for taking personal
responsibility to always live up to our company’s values.
Greg Wasson
President and CEO
1
A message from Laura Merten
Dear team member:
As chief compliance officer, my role is to support
the development, operation and monitoring of our
corporate compliance program. Compliance is our
ability to follow company policies, as well as the
laws and regulations that apply to every part of
our business. I work with a compliance team that
assists in the implementation of the program. I’m Laura Merten
also a member of our Compliance Committee, which
is made up of representatives of the company all
dedicated to upholding the highest standards of
business conduct and ethics.
At Walgreens, we are committed to our high standards
of good citizenship and integrity. The objectives of our
compliance program are to:
• Develop and continue to update our Code of Business Conduct procedures described in the following pages
• Support adherence to the Code of Business Conduct through education and training programs
• Provide status reports to the Compliance Committee and the Audit Committee of the Board of Directors
• Investigate compliance issues and questions submitted to my office and provide recommendations,
answers or solutions
• Lead change in the company related to compliance activities
We stand steadfast to our values, but like our business operations, we continue to adapt our Code of Business
Conduct when change is necessary. That’s why we will continue to revise our Code periodically and post the
most current version on our website at www.walgreens.com in the “Investor Relations” section under “Code of
Business Conduct.” This will be a helpful resource when you’re looking for guidance on compliance issues.
As you read through our Code, I want to assure you that I support our policy of open communication that provides
you with an opportunity to use our Open Door Policy to present ideas, raise concerns and ask questions without
fear of retaliation. I also encourage you to use the Walgreens hotline at 1-800-666-5677 to report issues or
concerns.
Laura Merten
Chief Compliance Officer
2
Our Code and Your Responsibilities
The purpose of our Code of Business Conduct Our Code of Business Conduct is a guide to the ethical and legal
responsibilities we share as members of the Walgreens family of companies (collectively “Walgreens”). We use this code for
guidance and direction to resources to help us make the right decisions. It helps us choose the right action to take. We all
encounter situations that force us to make decisions at work, and sometimes the most ethical response is not always the
most obvious choice. As we cannot address every decision you must make, our Code is not a summary of all laws and
policies that apply to Walgreens business. Instead, it is a starting point to help us determine when and where to seek help
when we are unsure.
A Foundation of Trust
for Our Customers
A Foundation of Trust Each of us is responsible
for Our Company for following the principles
and Our Fellow outlined in our Code.
Team Members
A Foundation of Trust
for Our Investors
A Foundation of Trust
for Our Communities
3
Our Code and Your Responsibilities
Each of us is responsible for following the principles outlined Team leaders have additional responsibilities
in our Code. We are all expected to be familiar with and follow Performing honestly and with integrity is an obligation we all share.
company policies, as well as the laws and regulations in every Team leaders, however, are expected to perform beyond our usual
location where we do business. By reviewing and understanding high standards, to lead by example and act as role models. If you
our Code and policies, we become better prepared to handle are a team leader, you can do this by:
ethical issues as they arise. • Reinforcing the Code and ensuring it is consistently applied
Key principles • Making sure each team member has completed all
Each of us is responsible for: required training
• Communicating relevant policies to team members and helping
Integrity and compliance – Achieving our goals with
them to understand the policies
integrity and in compliance with company policy and
legal requirements • Encouraging all team members to raise any questions
or concerns
Open communication – Encouraging open, honest and
full discussion about our policies and procedures • Dealing with reports of misconduct promptly and properly
Raising questions – Raising and resolving questions about • Never ignoring any type of misconduct or retaliation against a
ethical business conduct team member
Team leaders must strive to create a positive work environment
Reporting violations – Reporting actual or perceived Code,
where team members feel comfortable asking for help and raising
policy or legal violations to management, the chief compliance
concerns about this Code. Team leaders must also be alert to any
officer, the general counsel or the company hotline
situations or actions that may violate the letter or spirit of the Code
Cooperation – Assisting with any audit, compliance assess- or company policy or that may damage our company’s reputation.
ment, legal or other internal inquiry with candid, accurate It is important that, as a team leader, you take immediate action to
and complete information address such situations.
Non-retaliation – Ensuring that no punishment or retaliation When team leaders receive reports of a situation that may be
occurs against anyone for raising a good-faith concern. unethical or potentially damaging to our company’s reputation, or
suspect that one exists, he or she must promptly notify the chief
Publication and amendments compliance officer, general counsel or vice president of Employee
The current version of the Code of Business Conduct is posted Relations and work to resolve the issue. Team leaders who know
and maintained on the Walgreens website at www.walgreens.com about, or should know about, misconduct and do not act promptly
>Investor Relations >Corporate Governance >Code of Business to report it and cooperate with the compliance office, general
Conduct. Amendments are also posted on the website, as required counsel or vice president of Employee Relations to correct the
by applicable law. Because the Code is revised periodically, please situation will be subject to disciplinary action.
check the website for the most recent version.
Where we can seek help
We are all accountable If you are unsure about how to proceed, keep in mind our com-
Whatever our role is with Walgreens, our actions represent the pany’s Four-Way Test. Ask yourself: Is it the truth? Is it fair to all
company, and we must always do our best to uphold Walgreens concerned? Will it build good will and better friendship? Will it be
reputation. Our success as a company depends on each of us beneficial to all concerned? Answers to those questions will often
accepting personal responsibility for always doing the right thing. lead you to the most ethical answer. If you are ever unsure about
We must accept the obligation to stop or prevent actions that the best course of action, however, there are many company
could harm our customers or our company’s reputation and to resources available to help you.
report any such actions as soon as we learn of them.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
4
Our Code and Your Responsibilities
If you become aware of or even reasonably suspect any violations
of our Code or company policy, you are encouraged to report My team leader asked me to do something that
your concerns to your direct team leader, the chief compliance I don’t believe is in compliance with the law. Should I
officer, general counsel, vice president of Employee Relations or follow my team leader’s instructions?
the company hotline. Speaking up when you sense any activity
No. We must all obey the law. If you think you have
that could violate our core values helps maintain Walgreens
been asked to do something that is against the law,
culture of trust and integrity and our responsibility to uphold
you have a duty to report the situation. You can use the
our company’s high moral standards.
Open Door Policy or go to another team leader, the chief
There are a number of ways to raise issues. If you believe that a compliance officer, general counsel or vice president
law has been violated or an ethical violation has occurred, contact of Employee Relations, or call the Walgreens hotline.
the chief compliance officer or general counsel immediately. For Remember that all good faith reporting is protected
other matters, you can talk to your team leader or any other mem- from retaliation.
ber of management within our company. Sometimes, just talking
to your team leader will help clarify the situation and answer your
questions. If you still have concerns after talking with your team No retaliation policy
leader, you can always contact the chief compliance officer, Walgreens does not tolerate retaliation against anyone who
general counsel or vice president of Employee Relations. participates in an investigation, raises a legal or ethical concern,
or reports misconduct in good faith. “Good faith” means that the
• The chief compliance officer at 847-964-6519 report was made out of genuine concern for the company or
• The general counsel at 847-315-3004 team members involved.
• Employee Relations at 847-315-4455 Open Door Policy
Our Open Door Policy is a key part of our culture. It encourages
You can also call the Walgreens hotline, a toll-free telephone us to present ideas, raise concerns and ask questions—including
line reserved specifically for team member calls on ethics and those of a legal or ethical nature—without fear of retaliation. You
compliance issues. The Walgreens hotline can be reached at are encouraged to address situations first with your team leader,
1-800-666-5677. The hotline is staffed 24 hours a day, seven who is often best able to resolve the issue. You can avoid many
days a week, 365 days a year by an outside firm experienced in potential violations by simply asking for guidance before acting.
handling sensitive calls and accepting calls in many languages. In certain cases, you may feel uncomfortable discussing a matter
Callers may report anonymously. Anonymous callers should with your team leader, or you might be unable to reach a satisfac-
know, however, that it is sometimes more difficult to follow up tory solution. If this is the case, you may speak with any other
on issues raised by individuals who don’t identify themselves. member of management, the chief compliance officer, general
counsel, vice president of Employee Relations or you may call the
If you reside outside the United States you can seek guidance or company hotline. You will never be punished or retaliated against
report misconduct by accessing the compliance web portal at for making good faith use of our Open Door Policy.
www.tnwgrc.com/walgreens.
What happens if we violate our Code?
Our company is committed to reviewing, evaluating and responding To maintain the highest standards of integrity, we must dedicate
to all reports of misconduct – big or small. To the extent practical, ourselves to complying with our Code, company policies and
considering our need to investigate and comply with company procedures and applicable laws and regulations. Violations of
obligations, Walgreens will make every effort to protect the confi- our Code not only damage our company’s standing in the
dentiality of any person who comes forward with information, as communities we serve—they may also be illegal. Team members
well as the information itself. involved in violating our Code will likely face negative conse-
quences. Walgreens will take the appropriate disciplinary action
in response to each case, up to and including termination. In
addition, team members involved may be subject to government
fines or criminal or civil liability.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
5
A Foundation of Trust
for Our Customers
6
A Foundation of Trust for Our Customers
Walgreens team members must always follow the highest
standards of integrity and ethics when interacting with our
customers and patients. Even team members who do not
interact with customers must be aware that the decisions they
make and the work they perform ultimately affect our customers.
We uphold our trustworthy reputation through product safety
Our customers count on us to sell safe reliable products that
meet the highest quality and safety standards. In our company’s
long history, we have earned our customers’ trust by sticking to
this principle.
As part of our commitment to exceeding our customers’ expecta-
tions, we must also ensure that we purchase only the highest
quality products from our suppliers. If you become aware of any Our marketing materials and company communications are meant
defective products or other issues that could pose a health or safety to inform our customers about our products and services. They
risk, you have a responsibility to report the matter immediately. are expected to meet all industry standards that govern advertising
and promotion. As such, we must follow all relevant laws and regu-
lations regarding the marketing of our products, services and the
As a store manager, I received a notice from the
Walgreens brand. In addition, we must never falsely represent any
company that a certain product is being recalled
of our competitors’ products or services or engage in any decep-
due to safety concerns. I have some reports that I’d
tive marketing practices.
like to complete before pulling the product from the
floor. Is that okay?
I’m having trouble meeting my sales goals. I’ve tried
No. Our customers trust us to provide safe, quality
many selling techniques, but I still can’t meet the com-
products. The recalled item should be pulled from the
pany’s expectations. My team leader said that we should
floor immediately. You should focus on maintaining our
“do what it takes” to meet sales targets. My team leader
customers’ safety and complete the reports later.
becomes eligible for incentives with sales success, and
team members earn rewards for sales results. I’ve heard
that some team members in other areas have been meet-
We provide quality, dependable services our customers
ing sales goals by overstating the benefits of our services
can count on
or issuing unauthorized discounts to offset costs for the
Due to our unique standing as both a retailer and a healthcare
customer. I feel I’m on the verge of disciplinary action for
provider, we must maintain our commitment to the integrity of
my lack of success in sales. What should I do?
our products and services. Many of our customers rely on our
pharmacists and other healthcare providers for advice and You should not engage in any improper sales
dependable service. Those professionals are required to maintain practices to meet these goals. You also should never
current licenses, certifications or registrations and follow standards misrepresent products or services to a customer or issue
of ethics that correspond with their occupations. Further, you may unauthorized discounts. You have a number of alterna-
not give any type of medical, pharmaceutical or other professional tives available to you. For instance, you can speak to your
advice unless you are licensed to do so. colleagues or team leader for help in meeting your goals.
You can also review sales training or practice your use of
We market our products and services honestly
sales techniques, maybe with a team leader or colleague.
We must preserve Walgreens principles of integrity and honesty
You should also report the rumors you have heard about
when we market our products—whether in any advertising,
other team members using improper sales techniques
promotions, packaging, or labeling. Our customers’ trust is one
to the chief compliance officer, general counsel or the
of our most valuable assets, and we are committed to maintaining
company hotline.
that confidence.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
7
A Foundation of Trust for Our Customers
We expect our suppliers to uphold our values
We rely on our suppliers’ and other business partners’ integrity I often communicate with our healthcare providers by
in all our dealings, and we expect them to assure the safety and e-mail. If they request patient information that is private
performance of their products and services. We pursue legally and confidential, is it okay to send it electronically?
compliant ways to make the most reliable purchasing decisions Patient information may be sent by e-mail, but
based on cost, product and quality, so that we can deliver quality only if the e-mail is encrypted. Be sure the provider
goods at competitive prices to our customers. has signed the appropriate agreements to receive
protected health information. In addition, send only
Walgreens develops lasting relationships with suppliers who meet
the information requested.
our high standards of business ethics. Our standing in the commu-
nities we serve is based on the trust that those communities place
with us. To maintain that trust and continue to deliver the best prod- We must never knowingly violate the intellectual property rights
ucts to our customers, we follow all company procurement policies of others. Those of us with marketing or advertising responsibili-
in our purchasing interactions. We will not purchase products from ties should be particularly careful when preparing advertising or
a supplier who uses involuntary labor, prison labor or child labor. promotional materials that use the name, printed materials, or
We respect all applicable laws trademarks of another company. As a general rule, we may not
establishing a minimum age make unauthorized copies of any copyrighted material. Further,
for employment to support the we may not install or distribute software products on company-
Our customers’ trust is end of child labor worldwide owned computers without an appropriate license.
one of our most valuable and we expect our suppliers
assets, and we are In addition, you should not disclose the confidential information
to do the same.
or trade secrets of others, including your former employers. If
committed to maintaining
Our company expects its anyone at Walgreens asks or pressures you to do so, you should
that confidence.
vendors to comply with the report the matter to your direct team leader, another member of
standards outlined in the management, the chief compliance officer or general counsel.
Walgreens Vendor Responsibility Never use or share any information divulged to you by a third
Standards. Any team member who becomes aware of a supplier party—whether intentionally or unintentionally—unless you know
violating this policy must immediately report the supplier to our it is not confidential or a trade secret. If you are unsure of how
chief compliance officer or general counsel. If the report is veri- to use information you have received, contact your direct team
fied, Walgreens will notify the vendor and require that it take leader, another member of management, the chief compliance
steps to immediately comply with our policy. If the vendor fails officer or general counsel.
to comply with our policy, or its conduct or rehabilitation efforts
We uphold the competition and antitrust laws that apply
are not in Walgreens best interests, we will terminate the
to our work
business relationship.
Throughout our history, Walgreens has been dedicated to robust
We protect the private information and intellectual property competition. However, we believe in competing solely on merit—
of others never through deceptive or dishonest practices. In this regard, we
Our relationship with customers is one of our most valuable assets. must always be accurate and truthful in our dealings with suppliers
It is vital to our success as a company that we treat customers with and other business partners, and we expect the same from them.
the highest amount of respect. As healthcare providers, our cus- While we compete actively, we do not misrepresent, manipulate, or
tomers entrust us with health information, which is protected under conceal any material information to gain a competitive advantage.
state and federal law. It is essential that we keep this private data— We promote our products and services based on their high stan-
including names, addresses, dates of birth, social security num- dards, and never by making disparaging or false allegations about
bers, phone numbers, prescription histories and health condition— our competitors.
secure and confidential consistent with company policy. It is impor-
There are strict competition and antitrust laws in place to ensure
tant to use good judgment when handling this type of data, and
fair competitive business practices. Walgreens counts on each of
never disclose a customer’s protected health information to a third
us to obey these laws. Specifically, we never discuss with com-
party without the customer’s express permission. Our customers
petitors any information we may know about pricing, suppliers,
value our discretion with their legally protected information.
promotional strategies, territories or any other sensitive marketing
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
8A Foundation of Trust for Our Customers
information. We never discuss or make agreements about boy-
cotting third parties or allocating markets or customers.
If a competitor tries to engage you in a discussion on any of
the above-mentioned topics, even informally, you must end the
conversation immediately and report the incident to the general
counsel. We should be especially mindful during trade association
meetings or conferences where we are likely to have more frequent
interactions with our competitors. Remember, we must avoid even
the appearance of unethical business practices.
Antitrust laws can be challenging to grasp, and violations carry
serious penalties—both civil and criminal—for the team members
involved and our company. If your job involves sales, marketing
or procurement, you must know and understand these laws as
they apply to your work. For further guidance, please contact programs and even civil liability and/or criminal prosecution for the
the general counsel. team members involved and our company.
We obtain competitive information fairly We maintain appropriate relationships with healthcare
Remaining current on market practices and developments is professionals
vital to the continued success of Walgreens. While we recognize Our relationships with healthcare professionals are heavily regu-
the importance of obtaining information about our competitors, lated and the rules are strictly enforced. A healthcare professional
however, we must only do so in a lawful and ethical manner. is any individual or entity, directly or indirectly involved in the deliv-
This means we obtain information only through publicly available ery of healthcare who can purchase, prescribe, lease, recommend
resources. We also protect any information provided to us in or use our healthcare products or services. The federal and state
confidence by our suppliers and other business partners. laws that govern paying, providing or offering anything of value to
healthcare professionals such as gifts, meals, entertainment or
We must not ask our colleagues to disclose any confidential
grants are complex and highly regulated.
information about their previous employers. If we lawfully obtain
confidential information from suppliers or other business partners, The consequences for failing to comply with these laws can result
we must take care to protect it as we would our company’s own in significant monetary and even criminal penalties. It is important
proprietary data. that you understand and comply with these laws and company
policy when dealing with healthcare professionals. If you have
We work on government contracts lawfully and ethically
questions or need assistance determining whether a particular
Many of our customers rely on our ability to provide the services
relationship is appropriate, contact the chief compliance officer
they need through government-backed healthcare programs such
or Health Law.
as Medicare, Medicaid and other federal and state programs.
When working on potential or existing government contracts or
A local physician hinted that if I made a donation to
funded programs, it is critical that we adhere to all of the laws,
his foundation, he would increase the number of pre-
regulations and procedures that apply to these contracts and
scriptions directed to my location. What should I do?
programs. These rules are often much stricter and more complex
than those that govern our other contracts. Decline the physician’s offer and inform your team
leader, the chief compliance officer or the general
If your work involves government contracts, government-funded counsel. Our relationships with healthcare professionals
programs, or complying with government program parameters, prohibit us from making improper payments that influ-
you have a duty to familiarize yourself with the relevant laws and ence business decisions. This prescriber is putting
regulations that affect your job. To seek help in doing so, contact our company at risk by soliciting for donations, and
the compliance office or Health Law Department. Please note that making this type of donation could subject us to
violations of these rules can result in substantial penalties, the loss serious consequences.
of future government contracts, exclusion from government funded
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
9A Foundation of Trust
for Our Company
and Our Fellow
Team Members
10A Foundation of Trust for Our Company and Our Fellow Team Members
We foster diversity and inclusion in our workplace
We believe fostering diversity and promoting inclusive hiring
practices in the workplace encourages a wider range of abilities
and experiences, and helps us attract the best talent possible.
Diversity helps inspire the innovation that drives our business and
helps enhance the ideas that provide our competitive advantage
as we serve consumers from all walks of life. Our hiring decisions
are based solely on merit. We never make any employment-
related decisions based upon a person’s race, color, gender,
age, religion, disability, sexual orientation, veteran status, marital
status or any other basis protected by law. Diversity and inclusion
are key aspects of Walgreens strong value system and culture,
which have carried us through more than a century of service to
our communities.
We respect each other and do not tolerate harassment
By working for Walgreens, we are committed to treating each
other with respect. Each of us is responsible for ensuring that our
workplace is free from any type of harassment. Harassment is any We believe fostering diversity and promoting inclusive
unwelcome conduct that creates an intimidating or offensive work hiring practices in the workplace encourages a wider
environment—whether it is of a sexual nature or not. Harassment range of abilities and experiences, and helps us attract
can include physical actions, spoken or written remarks and pic- the best talent possible.
tures or videos. In any case, harassment is offensive and may
expose the individuals involved and Walgreens to legal liability.
Therefore, our company will not tolerate harassment of any kind.
If you experience or witness any act of discrimination or harassment,
you should report it immediately. You will not face retaliation for
making a report in good faith.
We strive to create a safe and healthy work environment
Certain safety laws and standards are in place to ensure each
of us enjoys a healthy work environment. It is up to all of us to
uphold these laws and standards, and to follow any safety
guidelines specific to our jobs. In addition, we should report any
concerns we have about misconduct or hazardous conditions
that may threaten the safety of our workplace.
Violence and threats of violence are prohibited. Walgreens will not
stand for any threatening behavior, even if made in a seemingly
joking fashion. In that regard, we must never bring any weapons
into the workplace.
Drugs and alcohol impair judgment and in the workplace can
affect everyone’s safety. You may not possess, distribute or
be under the influence of alcohol or drugs, including certain pre-
scription drugs, while on the job or while conducting company
business. If you have any questions or need assistance with a
substance abuse problem, please contact Employee Relations.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
11A Foundation of Trust for Our Company and Our Fellow Team Members
My team leader has asked me not to report a minor disabilities, leaves of absence, prescription drug history, and
injury that recently occurred at work. I didn’t miss any online purchases (i.e. Walgreens.com, drugstore.com).
work as a result of the incident, and my team’s safety
We may only use such data for relevant and appropriate business
award depends on our incident rate going down. Is it
purposes. We must not share this information with anyone inside
okay not to report it?
or outside our company who does not need to know it. If your job
No, this is never okay. You must report all work- entails having access to this type of information, you must take
related injuries, no matter how minor. Tracking injuries, special precautions to keep the data private in accordance with
including those where no one was seriously hurt or Walgreens policies and the law. You can be assured that our
missed work, helps us spot trends that could lead to company is committed to keeping our personal information
incidents that are more serious. secure at all times, whether on paper or in electronic format.
We work to protect our company’s assets I know that some of the information I work with is
Our shareholders trust us to protect our company’s assets—both confidential. Does this mean I can’t talk about it with
physical and intangible. Our physical assets include computers, anyone, even other team members?
products, equipment and the like. We must be considerate
Confidential means that you should keep the infor-
while utilizing these assets, and protect them at all times from
mation secure. You should discuss such information
loss, damage, theft and misuse. Intangible assets include our
only with those who need to know about it for company
reputation, the Walgreens brand and any sensitive or confidential
business purposes. If you have any questions about
information about our company. Your obligation to protect this
who you can discuss the information with, you should
information continues even after your employment ends.
ask your team leader.
Our company’s intellectual property is an equally valuable asset.
“Intellectual property” includes copyrights, patents, trademarks, We use our computer systems appropriately
trade secrets, logos and other intangible industrial or commercial While limited personal use of our computer and network systems
property. These creations are protected by law, and we are obli- is acceptable, it should not detract from our work for Walgreens.
gated to protect them. Also, keep in mind that—to the extent We should also never use our company computers or network
permitted by law—the rights to all intellectual property are systems for inappropriate conduct, such as viewing obscene or
assigned to Walgreens. This applies to any such materials we sexually explicit materials, spreading profanity or derogatory remarks
create on our company’s time and expense or within the scope or communicating harassing or discriminatory statements.
of the duties we perform for Walgreens. Walgreens reserves the right to block access to inappropriate
sites. Please also be aware that our company may monitor all
We are also expected to protect the intellectual property of
data and communications to the extent permitted by local law.
our vendors and suppliers, which we may encounter during
Walgreens also retains the right to report any suspected or
the normal course of our business dealings. We are able to pro-
actual violations of the law to the appropriate authorities.
vide top-quality products because we have cultivated strong
relationships with our vendors and suppliers. It is therefore
We always need to use our computer and network systems
critical that we maintain those relationships by honoring our
appropriately. This means composing e-mails and other electronic
vendors’ and suppliers’ proprietary information and protecting
communications professionally. All business communications
it from unauthorized disclosure or misuse.
may later be reviewed and interpreted by other parties, so take
We safeguard each other’s personal information care in how you compose your thoughts because electronic
In keeping true to our values of trust and integrity, Walgreens messages can be forwarded without your consent. In addition,
strives to safeguard the private personal information of all we may not post our company’s confidential information to
team members. During the course of our employment, we each Internet chat rooms, message forums or any other public forum.
provide sensitive personal, medical and financial information to It is important to keep in mind that none of us should have any
our company. Additionally, some of us may have access to infor- expectation of privacy when using company computers or
mation regarding our colleagues’ salaries, performance reviews, network systems.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
12A Foundation of Trust for Our Company and Our Fellow Team Members
By working for Walgreens, we are committed to
treating each other with respect.
13A Foundation of Trust
for Our Investors
14A Foundation of Trust for Our Investors
We keep honest, accurate financial books and records We avoid conflict of interest situations
We are committed to making accurate, timely, complete, fair To uphold our company’s reputation, we must be alert to any
and clear disclosures in our reports to the U.S. Securities and situations that may create a conflict of interest, whether real or
Exchange Commission and other regulatory bodies. It is our perceived. A conflict of interest occurs when there is an actual
duty to ensure that our business records reflect an honest and or apparent interference with our ability to make objective busi-
accurate picture of our financial standing. For this reason, it is ness decisions because of our personal relationships or loyalties.
important to keep accurate records of receipts, sales, expenses, Certain situations are more likely to hinder our capabilities in
corporate assets and corporate liabilities. If you become aware making good judgment calls, and we must take care to avoid
of any accounting or auditing irregularity, you have a duty to those circumstances. If you have knowledge about a situation
report it immediately so that Walgreens can take the appropriate that may be a conflict of interest, you should immediately dis-
steps to resolve the matter. close it to your team leader, the chief compliance officer or the
general counsel, or call the company hotline.
Furthermore, each of us must cooperate with requests by
auditors or government investigators. If management, auditors Conflicts of interest could include:
or government authorities request information, we must not • Serving as an officer or director of or having ownership
conceal, alter or destroy any of those requested records. interest in another company that does business or competes
Falsifying business records can lead to termination and even with Walgreens
criminal prosecution. If you become aware or suspect that our
• Having a family member that has ownership interest in another
company is under investigation, you are required to involve the
company that does business or competes with Walgreens
general counsel immediately.
• Using Walgreens information for your own personal gain,
to benefit a family member or another company for which
I worked quite a bit of overtime last week. My team
you serve as an officer or director, or in which you have
leader told me that I could miss a day of work this week
financial interest
if I don’t record last week’s overtime on my timesheet.
This seems like a good solution because Walgreens • Participating in business transactions for your own personal
won’t have to pay me for overtime, and I can get some gain based on information or relationships developed as a
extra time with my family. Is this okay? Walgreens team member
No. You need to ensure that all of the records you • Failing to disclose that you are closely related to someone,
submit are complete and accurate. Team leaders such as a vendor or customer who has sought or is seeking
should never place pressure on their team members a financial relationship with Walgreens
to do otherwise. You should report the situation to • Having a romantic relationship with a team member that you
Employee Relations. supervise or that is in your line of supervision
If a team member wishes to engage in a transaction or activity,
We maintain records in compliance with the law and which is, or potentially may be a conflict, the team member must
company policy first make a full written disclosure to the general counsel, who,
There are many laws and regulations that govern how we along with the chief compliance officer, will evaluate the written
maintain company documents, including business, financial and disclosure and make a determination. Following this procedure
healthcare records. Each of us is responsible for ensuring that will ensure that conflict of interest provisions are not violated.
company records are retained and disposed of in accordance
Below are additional common conflict of interest situations, as
with all applicable laws and regulations, as well as licensing and
well as guidelines you should follow in dealing with them. Please
accreditation requirements. Records include information stored
remember that these guidelines also apply to members of your
in various formats, including paper, electronic, audio and video.
“immediate family.” This includes your spouse, domestic partner,
The length of time to retain records depends on the content and parents, children, siblings, in-laws and anyone who resides in
type of record involved. We are each responsible for understand- your home.
ing the retention schedule for our records.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
15A Foundation of Trust for Our Investors
Gifts and entertainment approval of the general counsel. Gifts to foreign businesses
cannot be made without prior notice and approval by the chief
A vendor has offered me tickets to a local sporting
compliance officer.
event that they cannot use. Can I accept?
Additional information regarding gifts and entertainment can be
No. Accepting tickets to a sporting event or other
found in our Gift Policy. If your role involves gifts in any way, you
recreational activity is inconsistent with our Code and
should become familiar with this policy. If you have any ques-
gift policy.
tions, please contact the general counsel.
Doing business with friends and relatives
Business gifts and entertainment are common courtesies in many
Another common conflict of interest can occur when doing
business circles. They can, however, also become inappropriate
business with or while supervising family or friends. We are not
if the gifts or entertainment are too lavish or too frequent, or if the
permitted to directly oversee immediate family members. If you
courtesies are used to influence a business decision.
are put in such a situation, you should disclose it to your team
Our policy is that team members may not accept any gifts leader immediately so that reassignments can be made. In addi-
from individuals or companies doing or seeking to do business tion, you may not enter our company into a business relationship
with Walgreens. with a friend or family member or a business owned or operated
by a friend or family member without the prior approval of the
With prior approval of the responsible corporate vice president,
general counsel. You must avoid any scenario where you stand
however, meals and entertainment may be offered or accepted
to gain personally from Walgreens-related dealings or where
when both the team member and the representative of the other
there may be any appearance of favoritism.
company are present, and a substantial business discussion
takes place directly before, during or after the activity. When this
My department is in the process of choosing a
type of activity is related to your attendance at a company
vendor. One of my team members recommended a
approved trade show, convention or seminar, prior approval
company owned by his sister. I have heard good things
by a corporate vice president is not required.
about this company from other sources. Can I consider
As a general rule, do not offer a business gift or courtesy if doing this company even though one of my team members is
so would give the appearance that you are attempting to influence related to the owner?
a business decision. You may offer a gift, favor or entertainment to The vendor can compete for the work, but the team
others at company expense if it meets all of the following criteria: member who is related to the owner cannot be involved
• Nominal in value in decisions about choosing the supplier. Nor can the
• Consistent with accepted business practice team member be involved in managing the supplier, if
• Not against the law or in violation of our company’s high chosen. Your team member should also understand that
he cannot provide any confidential company information
standards of integrity
to his sister that would help her company be selected.
• Not against the policies or standards of the recipient’s company
• Not in a form that could give the appearance of a bribe
Outside positions
(i.e., no cash or cash equivalent)
We may have outside business interests or employment, as long
• Not something that would embarrass our company if it
as those interests do not interfere or conflict with our current
was disclosed
position and responsibilities for Walgreens. In general, this
Keep in mind that rules governing the giving of gifts, favors and means we may not work for or have a significant financial interest
entertainment to any U.S. or foreign public government official in a competitor, supplier or customer. A conflict of interest may
(or their family members), or healthcare providers/referral sources also exist if any member of your immediate family is, or has
(or their family members) are much stricter than those set forth in ownership interest in, a competitor, supplier or customer of the
this section. No gifts, favors, or entertainment can be given to company. We must immediately disclose any such situations to
any domestic or foreign government official without prior written the general counsel.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
16A Foundation of Trust for Our Investors
There are many laws and regulations that govern
how we maintain company documents, including
business, financial and healthcare records. Each of
us is responsible for ensuring that company records
are retained and disposed of in accordance with all
applicable laws and regulations, as well as licensing
and accreditation requirements.
You may not serve as a director, trustee or officer of another company or one of our publicly traded suppliers or competitors.
company, or in a similar paid or unpaid position, other than with Insider information is not generally available to the public and
Walgreens, without prior approval of the general counsel. This could, if publicly known, reasonably influence a person’s decision
rule does not apply to public, political, non-profit or social organi- to buy or sell that company’s securities. Insider information can
zations, or to residential boards whose activities do not conflict be shared only after it has been officially disclosed to the public
with our company’s interests. and a reasonable waiting period has passed to allow the informa-
tion to be absorbed by the marketplace.
You may join industry or trade associations with the approval of
your team leader, as long as you ensure that any related activities Using this type of information in determining whether to buy or
are consistent with our company’s interests. sell a stock (also known as “insider trading”) is illegal. This applies
to stock, shares, options or other securities of Walgreens or
Business opportunities another company, as well as to transfers into or out of stock-
We may not accept business opportunities, commissions or based retirement plans. If you have any question about whether
advantageous financial arrangements from a customer, supplier the nonpublic information you possess is material, do not make
or business partner of our company. In addition, we may not trades based on that information. Rather, seek guidance from
purchase the goods or services of our company’s vendors for the general counsel.
personal use on terms other than those available to the general
public or established by company policy. We must also refrain from disclosing insider information to
others—including friends and family—to use for their own
If you become aware of any business opportunities in which financial benefit (also known as “tipping”). The consequences
Walgreens might be interested, you are required to bring them for violating insider-trading laws are severe, and punishment
to the attention of your team leader and not take advantage of may include fines and imprisonment, as well as termination.
those prospects for your personal gain.
Team members who have access to “insider information” are
We uphold insider trading laws required to be familiar with our Insider Trading Policy.
While working for Walgreens, it is possible that you could become
aware of insider information. This information could be about our
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
17A Foundation of Trust
for Our Communities
18A Foundation of Trust for Our Communities
We follow healthcare laws
Because we are a healthcare provider, many of our services are The auditors have requested a certain range of files,
heavily regulated by various governmental and regulatory agencies. and when I was scanning them, I realized there are
We are all responsible for ensuring compliance with any clinical some documents missing. I don’t think the documents
and regulatory standards that apply to our work. In addition, as are critical, but I know the auditors will look for them.
a healthcare company, we are regulated by many laws that are Can I recreate the missing documents for the audit?
designed to prevent, detect and punish fraud, waste and abuse. No. Recreating records might be viewed as an
This includes laws and regulations such as the Federal Anti-Kick- improper attempt to alter existing records. Speak to
back Statute, Stark Law, Federal Civil False Claims Act (FCA) and your team leader about this situation so it can be
Federal False Statements Act. In general, these laws seek to: properly disclosed to the auditors.
• Prevent any false or fraudulent claims to federal healthcare
programs, such as Medicare and Medicaid If you have any questions or concerns involving the various health-
• Ensure that decisions made by healthcare providers about care laws that apply to your area of work, please consult your team
patient treatment or product use are not influenced by leader, the compliance office or the Health Law Department.
personal gain
We work to build sustainable supply chains
• Reduce the cost of healthcare to support patients and
We want to ensure that people doing work for Walgreens around
promote the quality of healthcare services
the world are being treated fairly—not only by our company, but
We comply with the Federal False Claims Act also by our suppliers. We expect our suppliers to follow the same
The Federal False Claims Act prohibits knowingly submitting a high standards that we have set for ourselves. Therefore, we only
false or fraudulent claim for payment to the Federal government. purchase from suppliers who respect basic human rights wher-
The Act is intended to reduce fraud, waste and abuse of federal ever they operate. In addition, we only work with suppliers who
funds. Many states have enacted similar laws. The Act allows maintain our company’s commitment to freedom of association
individuals to file suit on behalf of the government against people and fair wages and hours for all workers. If you suspect or know
or businesses alleged to have committed fraud. The Act also of any of Walgreens suppliers who do not act in accordance with
provides whistleblower protection for those who report violations. our standards, you have a duty to our company to report it.
Walgreens will never retaliate against team members who exercise
We follow international trade laws
their rights under the Federal False Claims Act—or any other federal
The United States has a number of laws controlling the importa-
or state anti-fraud laws. We must all comply with the Federal False
tion of goods. For example, it is illegal to trade with certain
Claims Act, and any applicable state false claims acts. We must
countries specified by the U.S. government or with individuals
never make false claims or statements to the Federal government
and organizations against which the United States has imposed
or to any state government.
embargoes. U.S. customs laws also place restrictions on the
importation of goods into the United States. If your job entails
I noticed an unusually high incidence of a certain trade with other countries, you need to be familiar with the
reimbursement code for a particular item. It’s possible processes and requirements that apply to your work. Each of
that these are legitimate claims, but I’m suspicious. us must be vigilant to ensure that we comply with trade laws and
What should I do? regulations—both in the United States and in the countries where
we do business. Consequences for violations of these laws are
Report your suspicions to your team leader, the
severe for both our company and the team members involved.
chief compliance officer or the general counsel. Disre-
garding this situation could make you and our company In addition, we are prohibited from engaging in or appearing to
liable under the False Claims Act. If you ever suspect support boycotts against certain countries or companies. We
that a claim is incorrect or fraudulent, you must report it. are required by law to report any requests to participate in an
unsanctioned boycott to the U.S. government. For that reason,
if you believe you have received a boycott request or have any
questions about boycott activities, it is crucial that you notify the
general counsel immediately.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677
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