CODE OF CONDUCT FOR ASSOCIATES - L Brands
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CODE OF CONDUCT FOR ASSOCIATES
Table of 1 Letter from the Chairman
contents
2 OUR COMMITMENT AND ACCOUNTABILITY
2 Leading With Values
2 Open Door Policy
3 Our Open Communications Advantage
3 Getting Help and Sharing Concerns
3 No Retaliation
4 YOU AND THE WORKPLACE
4 Equal Opportunity and No Discrimination or Harassment
4 Accommodating Disabilities
4 Honesty
4 Merchandise Discount
5 Recording Time
5 Workplace Health and Safety
6 No Weapons or Firearms
6 Drug- and Alcohol-free Workplace
6 No Workplace Violence
6 Conduct Off The Job
6 Travel and Expense Reimbursement
7 HOW WE DO BUSINESS
7 Partnering with Responsible Suppliers and Business Partners
7 International Trade, Fair Dealing and Fair Competition
8 Bribery and Corruption
8 Conflicts of Interest
9 Business Gifts and Hospitality
10 Interactions with Governments
10 Political Activities
10 Charitable Contributions
11 OUR COMPANY AND YOU
11 Protecting Business Information
11 Inside Information
12 Financial Integrity and Accurate Records
12 Audits and Investigations
12 Use of Company Property
13 Intellectual Property
13 External Communications
14 Using Digital Media
14 Solicitation and Distribution
15 acknowledgment
17 contacts
19 HOW WE SUPPORT OUR CODE
Letter Dear associate,
from
As our company has grown, our values have remained a part of everything we do —
they are a connection to our heritage and a guide to our future. Our values are the
the
measure of success for how we do things, and we hold each other accountable for
living them each day.
Chairman The customer rules! Everything we do must begin and end with an insatiable
drive to anticipate and fulfill our customers’ desires.
Passion leads to success. We pursue excellence because we are emotionally,
intellectually and spiritually engaged in our work ... and that makes our talent
formidable and our results extraordinary.
Inclusion makes us stronger. We cherish our diversity, because embracing
others’ thoughts, experiences, hopes and dreams makes our own more
complete and connects us to our customers.
It matters how we play the game. Doing what is right means following
our beliefs — and the rules — even when no one is watching. Winning means
very little unless how we get there is fair, collaborative, rooted in our values
and contributes to the greater good.
As a shopkeeper, I learned early on that good, strong values help us make the
best choices — especially when the right decision isn’t always clear. Our Code
of Conduct is based on our values and is a resource where associates can find
information that defines behaviors that are acceptable and those that are not.
All of our policies, whether in the Code of Conduct, in our standard operating
procedures or from other sources in our business, are based on our values.
There are tremendous benefits of working together in an innovative, creative
and entrepreneurial environment like ours. With these benefits also comes
responsibility — to each other and to ourselves. Part of that responsibility
includes reviewing the Code and company policies, understanding and upholding
the Code, and asking questions if we’re unsure about something. It’s a personal
promise. And it’s fundamental to all that we stand for. If you ever see anything
that seems inconsistent with our values or Code of Conduct, be sure to talk to
your manager or Human Resources partner.
Thank you for sharing in the responsibility.
Regards,
Les
L Brands Code of Conduct 1
LEADING WITH VALUES:
OUR
We follow the basic guidance of our
Code of Conduct: Do what’s right.
COMMITMENT
AND
Leading With Values Open Door Policy
We are committed to living by our We encourage you to talk openly
values, doing what’s right and acting with us about work-related ideas,
ACCOUNT-
with integrity everywhere we questions, problems and concerns
do business regardless of the so they can be resolved. If there
ABILITY
circumstances. Each of us has the is something about your job or the
responsibility to understand and follow company that concerns you, or you
the Code and other company policies. see something that you think is wrong,
We follow the law in all countries where we encourage you to communicate it
we do business. Violations will result in to your manager, next level manager,
disciplinary action up to and including Human Resources partner or the
termination of employment. Ethics Hotline.
Managers and senior leaders have
additional duties: DO
• lead by example; • Use our open door policy and
• ensure your teams understand and talk to the appropriate partner.
follow the Code and complete all • If you are uncomfortable talking
training; to your manager, next level
• create an open environment where manager or Human Resources
associates can ask questions and partner, or you feel your
raise concerns; questions or concerns have not
• actively support and follow the been resolved, you can contact
no retaliation policy; the Office of the Chief Compli-
• take quick corrective action where ance Officer or the Ethics Hotline.
appropriate; and See Contacts section.
• get help from Human Resources or
the Office of the Chief Compliance
Officer when needed.
2 L Brands Code of Conduct
Our Open Communications Getting Help and Sharing
Advantage Concerns What Happens
We are one of the world’s best
specialty retailers with a tradition of
The Code cannot anticipate
every situation. But, most problems
When Someone
success built primarily on agility and can be avoided by checking the Code, Contacts the
teamwork. We believe we are more using good judgment and asking Ethics Hotline?
productive, more efficient and better for help.
able to deliver on our brand promises The Ethics Hotline is operated
when our associates have and staffed by an outside
a close, collaborative relationship No Retaliation company. When you raise a
with one another. In no event will any associate be concern through the Ethics
subject to reprisals, retribution Hotline, it’s only shared with the
Over the course of our long history, or any career disadvantage for departments that need to know
our associates have grown their raising a concern. We strictly prohibit (such as Human Resources,
careers and the business on a platform retaliation for reporting under the Code. Compliance & Ethics, Legal
of collaboration and cooperation Anyone who retaliates (or tries to or Loss Prevention/Safety
and by retaining the power to work retaliate) will be subject to disciplinary Services) for prompt and timely
freely and directly with each other. This action up to and including termination follow up and action. Our inves-
collaborative spirit is the foundation of of employment. tigations process includes:
our enduring success, and we pledge • conducting a timely and fair
to maintain this atmosphere. investigation by a qualified
DO person;
As part of our commitment to you, If you’re not sure if something raises • documenting and tracking
associates are assured: an integrity question, ask yourself: progress of the investigation;
• equal opportunity and treatment; • Does it align with our values? • ensuring due process;
• career-advancement opportunities; • Is it the right thing to do? • achieving a reasonable
• equitable and competitive wages; • Is it legal and am I authorized to conclusion based on
• excellent benefits; do it? evidence collected; and
• open and honest communication; • Is it consistent with our Code and • implementing appropriate
and other policies? options for corrective actions.
• a rewarding and safe work • Is it professional and businesslike?
environment. • Would I want to see it reported in You can contact the Ethics
the media? Hotline by telephone (see the
Our open door policy has always meant Contacts section) or online
associates could address issues honestly If the answer to any of these ques- (www.lb.ethicspoint.com). If you
with anyone – at any level. tions is “no,” you should discuss the choose to telephone the Ethics
situation with your manager, Human Hotline, a live operator will
Resources partner or the Office of answer and ask you a series of
the Chief Compliance Officer. questions about your concern.
Interpreters are available. If you
make a report online through
the Ethics Hotline website, it will
prompt you for more informa-
tion about your concern.
L Brands Code of Conduct 3
LEADING WITH VALUES:
YOU
We provide a harassment-free workplace
with equal employment opportunities.
AND THE Equal Opportunity Honesty
WORKPLACE and No Discrimination
or Harassment
We treat everyone with respect and
We are committed to honesty in the
workplace. Do not engage in dishon-
est business practices, such as theft,
dignity. We are an equal opportunity fraud, merchandise discount abuse or
employer. We do not base employ- intentionally making false or misleading
ment-related decisions on an individu- statements. Dishonest conduct can
al’s race, color, religion, gender, gender also be lying on company records
identity, national origin, citizenship, age, and documents (including time, payroll
disability, sexual orientation, marital or conversion records), intentionally
status or any other legally protected excluding information, or misusing
status under applicable laws. company property and assets, such
as our computer systems, for your
We also do not tolerate discrimination own or someone else’s benefit.
or harassment. It doesn’t matter if the
conduct is in person, shared electroni-
cally or occurs off company property or Merchandise Discount
off-the-clock. Harassment may include While we consider the merchandise
slurs and any other offensive remarks, discount to be a beneFIt, it is also
jokes and other verbal, non-verbal, sex- considered a discretionary privilege
ually oriented, graphic, written or elec- and there are guidelines to use it.
tronic comments or physical conduct. You may use the merchandise discount
to purchase items for your own personal
use, bona fide (real) gifts for others
Accommodating without being compensated with
Disabilities money, services or other items, or to
We are committed to providing make a personal donation to a charita-
accessible facilities and services to ble organization. Your spouse and your
our job applicants, associates and dependents (children through age 22
customers with disabilities. We will while still in school and dependent
attempt to provide reasonable accom- on you) are also eligible to use the
modations to applicants and associates discount. You receive your discount at
with disabilities, as needed or required all company-owned stores world-wide
by applicable law. If you believe you and Victoria’s Secret online. The
need an accommodation to perform discount is not valid in third-party
your job, even for a short period operated stores or kiosks. The discount
of time, inform your manager or is taken from the full ticket price of each
Human Resources partner. item. It is not valid on promotional or
permanently marked down (red-lined)
merchandise. Like any customer, you
may return or exchange merchandise
purchased with your discount in accor-
dance with the brands’ return policies.
4 L Brands Code of Conduct
There are additional things you • work without getting paid
should know about proper use of (off-the-clock);
the merchandise discount: • record time for another associate
• You can purchase gift cards with or ask another associate to record
your discount; however, you cannot time for you;
make a purchase online using a • intentionally report inaccurate time
discounted gift card or receive your worked; or
merchandise discount in store when • edit your own time record.
redeeming a discounted gift card.
• Unless otherwise stated, you are In addition, associates must follow
not eligible for Friends and Family applicable laws and company policies
discounts. regarding travel time pay and rest and
• Generally, you cannot combine your meal periods.
discount with special offers or
coupons either in store or online.
Check the terms and conditions for Workplace Health
each offer to confirm eligibility. and Safety
• Merchandise purchased with your We provide safe, clean and accessible
discount or at a special associate- facilities for our customers and
only sale, or given to you by the associates. We comply with all
company (gratis), cannot be re-sold applicable workplace safety laws and
anywhere else, including flea we have global safety policies and
markets, auction websites or procedures to protect us from
rummage sales. avoidable injury in the workplace.
• You and your dependents must Whether you work in a store, a
identify yourselves as eligible to distribution center or an office,
receive the merchandise discount. it’s important to:
You may be asked to provide valid • know the safety and emergency
photo ID or other documentation procedures (refer to your brand/
such as a discount card or employee function standard operating
ID number. procedures or talk to your manager);
• It is both your responsibility and • watch for potential hazards and
the store’s responsibility to follow report them immediately to your
the discount policy. Do not put manager;
yourself or another associate in a • immediately report any accident
questionable or uncomfortable or injury, no matter how minor, to
position of “bending the rules.” your manager and the Emergency
Associates cannot ring transactions Operations Center (See Contacts
for themselves, friends or family. section); and
• report incidents of obscene or
threatening phone calls or electronic
Recording Time posts related to work to the
We follow all applicable wage Emergency Operations Center.
and hour laws and regulations.
All hourly associates (and some salaried
associates depending on role and
location) must accurately record all
the time they work. When recording
your time, you should never:
L Brands Code of Conduct 5
No Weapons or Firearms Conduct Off The Job
DO Weapons or fIrearms are not permit- The company is generally not
• Treat everyone with respect ted on company property or in our concerned with an associate’s conduct
and dignity. stores. Only authorized associates and off the job unless it gets in the
• Follow applicable wage and those in law enforcement can carry way of job performance or is
hour rules. weapons and firearms on company unprofessional. While the company
• Know health and safety property and in stores. respects your privacy, illegal activities
procedures for your workplace. or conduct violating the Code may be
• Submit accurate travel and ex- subject to disciplinary action up to
pense reimbursement requests. Drug- and Alcohol-free and including termination even if the
• Report suspected violations of Workplace conduct occurs off the property or
the Code immediately. We are committed to providing a off-the-clock.
drug- and alcohol-free workplace.
Associates must work entirely free of
the effects of alcohol and illegal drugs, Travel and Expense
as well as the adverse effects of any Reimbursement
other legal substance. You may not If you travel on company business
possess or use illegal drugs or alcohol or purchase items on behalf of
on company premises, and you may not the company, you are entitled to
report to work after consuming alcohol reimbursement of qualiFIed expenses
or illegal drugs. For example, you may including meals and transportation
not go to lunch, drink alcohol and then expenses such as mileage over and
return to work. above your normal commute.
You are expected to ensure that
No Workplace Violence expenses submitted for reimbursement
We take violence and threats are legal, reasonable and customary,
of violence very seriously. Any asso- business-related and appropriate. All
ciate who threatens or causes harm to expenses must be recorded accurately
anyone may be terminated regardless and completely, with the appropriate
of whether the threat was made on- supporting documents (such as detailed
or off-the-clock, as a “joke” or in receipts) to ensure that the company
the “heat of the moment.” maintains accurate books and records.
Refer to the company’s travel and
expense reimbursement policies for
complete details.
6 L Brands Code of ConductLEADING WITH VALUES:
We strive to be a good public citizen.
HOW WE
Partnering with We compete vigorously but fairly and
ethically. It is important that we follow
DO BUSINESS
Responsible Suppliers and
Business Partners all applicable competition laws and
We pride ourselves on the quality and avoid practices that interfere with fair
integrity of our products and only and open competition. This means,
partner with suppliers that share our for example, that you must not enter
values and our commitment to ethical into any agreement (whether formal or
and responsible business practices. informal) with our suppliers, vendors or
We will not knowingly do business other external parties to restrain trade.
with suppliers or business partners Agreements cannot include:
who employ individuals under the • fixing prices in our stores or those
local minimum working age, engage in of our competitors; or
human trafficking, employ forced labor • boycotting certain vendors.
or use corporal punishment to discipline
employees, regardless of whether the Avoid discussions with external parties
practices are permitted by local law. about these topics, even if they suggest
The L Brands Supplier Code of Conduct it or if it comes up at a trade event.
more completely outlines our standards Global competition laws are complex,
for suppliers. and the penalties for violations are
severe – for both companies and indi-
We act responsibly with respect to viduals. Partner with the Office of the
the environment. We comply with all General Counsel for guidance.
applicable environmental laws and
strive to minimize our impact on the We do not engage in unfair or fraudulent
environment. business practices either directly or
indirectly through an external party to
We strive to sell merchandise that help L Brands’ business or to hurt a
complies with all applicable product competitor’s business. Do not be dis-
safety laws. honest, misrepresent or use other illegal
or unethical means to learn competitors’
trade secrets or obtain confidential
International Trade, information about other companies.
Fair Dealing and Fair
Competition We advertise honestly and follow
We comply with all laws that govern applicable advertising laws and stan-
international trade, including laws dards. Our advertising and marketing
intended to prevent money laundering must not be deceptive, unfair or
and cooperating with unsanctioned contain misrepresentations. Be honest
boycotts and laws that regulate imports and accurate when discussing our
and exports. merchandise and services. In addition,
L Brands Code of Conduct 7don’t say anything untrue, unfounded Conflicts of Interest
or misleading about our competitors, We avoid conflicts of interest.
their merchandise or their services. A conflict of interest is a personal
activity, interest or relationship that
interferes (or may appear to interfere)
Bribery and Corruption with an associate’s objectivity on behalf
We are committed to using honest of the company. A conflict of interest
and ethical business practices. That can create a situation that makes it
means that we do not tolerate bribery difficult to do our work effectively or
or corruption anywhere we do business harms the company’s business. Your
world-wide. We follow all applicable own actions, financial interests or
anti-corruption laws. relationships may create conflicts of
interest. Unless disclosed to and autho-
Among other things, anti-corruption rized by the company, you cannot have
laws and company policy prohibit and must avoid conflicts of interest.
all instances of offering, giving, autho-
rizing, accepting, receiving, request- Conflicts of interest can be created by
ing or promising a bribe or anything anyone with whom you have a close
of value with the intent to improperly personal relationship. For the purposes
influence someone or gain an improp- of this policy, a close personal relation-
er advantage. ship includes your spouse, partner, rel-
ative (by blood, marriage or adoption),
Additional review may be person you’re romantically or intimately
required to ensure that involved with or others you live with.
external parties are reputable Don’t allow a close personal relationship
and the contract or agree- or friendship to create an uncomfortable
ment with them must or unfair work environment or negatively
include appropriate affect job performance. In addition:
anti-corruption • You may not supervise or report to
provisions. It’s import- anyone with whom you have a close
ant to remember we personal relationship.
cannot ask an external party • You may not oversee, review or influ-
to take any action we are pro- ence the job evaluation, pay
hibited from taking ourselves. or benefits for anyone with whom
you have a close personal
If you think you will interact with relationship.
government officials or have
questions about anti-corruption, A financial conflict of interest can arise
seek guidance from the Office of when your actions are influenced, or
the Chief Compliance Officer, or appear to be influenced, by possible
refer to the company’s Global financial gain. The gain could be for
Anti-Corruption Policy. yourself or someone with whom you have
a close personal relationship. This kind of
conflict of interest may happen when:
• You have a financial interest in a
vendor, supplier, landlord or competi-
tor (other than certain investments in
a publicly traded company).
8 L Brands Code of Conduct• You receive money, services or favors Examples of allowable gifts and
from anyone other than the company
for doing work for the company.
hospitality include:
• business meals provided they are
DO
The company must know about
not extravagant;
potential conflicts of interest as
The company owns the design, concept, • an occasional event if the associated
and when they arise. Contact the
invention, formation or similar creation expense is reasonable, custom-
Office of the Chief Compliance
that you develop while working with ary and culturally appropriate, the
Officer if you:
the company. You may not compete external party will attend with you,
• believe you have a conflict of
with L Brands while employed by the and you have notified your manager
interest or a financial conflict
company including: (such expense is considered a gift if
of interest;
• taking for yourself or directing others the external party does not attend
• want to get involved in an outside
to take any business opportunity with you); and
business or job opportunity while
discovered through your work on • gifts valued at USD50 or less.
working with the company; or
behalf of the company;
• want clarification of our conflicts
• working for, or on behalf of, a Some types of gifts and hospitality are
of interest policy.
competitor unless approved by always prohibited. You may not give or
the company; and receive (unless noted as an exception
• serving as a director, manager or ad- below):
visor of any company or organization • cash or cash equivalents;
engaged in a business that competes Exceptions
or plans to compete with L Brands, – gift cards redeemable for our
unless approved by the company. company merchandise
– lai see/red envelopes (red packets
containing cash given during
Business Gifts and holidays or special events like
Hospitality Chinese New year). The company
We are careful when giving or does not offer lai see/red enve-
receiving business gifts or hospitality. lopes to external parties; however,
Avoid making, or appearing to make, associates in our Asia offices may
business decisions based on unethical accept one lai see/red envelope
influences. All exchanges (giving or valued at USD15 or less from a
receiving) of business gifts or hospitality person, company or vendor group
must comply with applicable laws and outside of L Brands for a single
company policy. holiday or event.
• anything as “quid pro quo” (part
Gift examples include cash or cash of an agreement to do anything in
equivalents (gift cards, gift certificates, return for the gift or hospitality);
rebates and discounts), merchandise, • any solicited gift;
personal favors, transportation, travel • gifts valued at more than USD50;
or vacation accommodations or Exceptions
business or employment opportunities. – perishable gifts (food, flowers,
Hospitality includes business meals and candy, etc.), which must be
tickets to sporting events, concerts, shared with other associates or
theater, golf and other events. donated to a legitimate charitable
organization (for donations
contact Community Relations)
L Brands Code of Conduct 9– a gift that is pre-approved in pre-approve any use or commitment
DO writing by the Office of the Chief
Compliance Officer
of money or other company resources
for political activities on behalf of
• Check with your manager before
• gifts or hospitality that would violate the company.
giving business gifts and hospital-
other provisions of the Code or
ity on behalf of the company.
applicable law; and Getting involved in the political
• Make business decisions free from
• anything that would cause other process is entirely your own personal
improper influences.
people to violate their employer’s and voluntary decision. If you choose
• Consult with the Office of the
standards. to participate, you can do so only on
Chief Compliance Officer and
your own time using your own money
Community Relations before
Any gift or hospitality you give must be or resources. Unless authorized by the
committing company assets for
accurately disclosed in detail on a travel company, you are not acting on be-
a charitable donation.
and expense reimbursement form. half of it and you cannot use company
resources or services for your personal
Anything you give to government of- political activities.
ficials must comply with all applicable
laws and the terms of the company’s The company communicates with
Global Anti-Corruption Policy. government officials and agencies
around the world about public policy
issues that may affect our business.
Interactions with Because lobbying is strictly regulated at
Governments all levels, the Office of the Chief Compli-
We are truthful and straightforward ance Officer and the Government Affairs
with government entities. If you are department must pre-approve lobbying
contacted by a government or regulato- activities on the company’s behalf.
ry representative and asked to provide
information or submit to an inspection
as a representative of the company, in- Charitable Contributions
form your manager immediately. Never We are committed to doing well
knowingly provide false or misleading to do good. To be fair and consistent,
information to any government official the Office of the Chief Compliance
or representative or destroy records re- Officer and Community Relations must
lated to an investigation. Similarly, never pre-approve all charitable contributions
direct or encourage another associate committed to or made with company
to do so. assets on behalf of L Brands, a brand
or a particular function. This includes
money, product and the use of our
Political Activities space or resources, to list a few. We
We believe that involvement in will not give charitable contributions as
political activities in the communities a condition of or in order to influence
we serve is important to our a business decision.
success. The company engages in public
policy issues and may make political
contributions as laws allow. The Office
of the Chief Compliance Officer and the
Government Affairs department must
10 L Brands Code of ConductLEADING WITH VALUES:
OUR
The relationship between you
and the company is one of trust.
COMPANY
AND YOU
Protecting Business ting, accessing, securing, retaining and
Information destroying. See the company’s Informa-
Our business information is a valuable tion Security Policy for details.
asset and we protect it. Business
information includes confidential, pro- You are responsible for keeping the
prietary, privileged or secret informa- business information you work with
tion. It can be written or electronic, or secure even after you leave the company.
it can be information you know or learn In no event should you use our business
that is not formally documented. Some information for personal benefit or gain,
examples of business information are: for either yourself or another person
• trade secrets; or company, even if you are no longer
• intellectual property; working for the company.
• sales figures, including comparable
stores sales; We do not use proprietary or nonpublic
• information about our ideas and business information of others without
know-how, processes and proce- permission. You must respect the confi-
dures; dentiality of other companies’ business
• unannounced product launches and information. Do not bring business
promotions; information from another company to
• marketing and images; L Brands. Do not intentionally misrep-
• private information about custom- resent or use other improper means
ers or associates such as credit card to obtain another company’s business
numbers or banking information; and information. Respect other associates’
• vendor lists. obligations to protect the confidentiality
of former employers. Do not download,
Business information must not be distribute, keep or produce unautho-
shared with anyone without a legitimate rized copies from books, magazines,
business or law enforcement reason newspapers, films, videos music record-
and in accordance with all applicable ings, websites, products or computer
laws and regulations. Do not share programs.
business information with anyone
anywhere outside the company, unless If you are not sure about sharing or
authorized to do so and in accordance safeguarding business information,
with company policies. check with your manager.
The company’s business information is
classified according to level of sensitivi- Inside Information
ty. Certain levels of business information In addition to protecting business
may have safeguard requirements for information, we comply with insid-
collecting, handling, storing, transmit- er trading laws. Inside information
L Brands Code of Conduct 11is information (about our company or We also ensure that we follow company
Material another company) that is not public and
is also material – that is, a reasonable
policy and applicable law for retain-
ing, storing and destroying company
information investor would consider the information records and electronic data. Each of
could include: important in deciding whether to buy, us is responsible for information and
• earnings and other financial sell or hold stock. Company policies and records under our control. We must be
results; the law strictly limit what we can do familiar with the record keeping proce-
• sales and comparable stores while we hold inside information. dures that apply to our jobs. Information
sales data; and records may only be destroyed in
• inventory levels; You are prohibited from trading accordance with the company’s Records
• significant gains or losses L Brands stock and other securities Retention Policy and never in response
of business; while you possess material, nonpublic to or in anticipation of an audit, investi-
• plans for a company information about the company. This gation or lawsuit.
acquisition, sale or merger; applies to all associates of L Brands as
• management changes; and well as their families and entities they
• business strategies. control. Trading includes buying, Audits and Investigations
selling, and shifting account balances, We cooperate fully with internal and
investment allocations and investment external audits and investigations of
directions in company plans. possible violations of company policies.
DO Do not destroy or alter any documents
• Create and maintain accurate, Do not share inside information with that may be requested as part of an
complete and fair business anyone unless they have a business investigation or audit on behalf of the
records. need to know and never share inside company. Do not lie, make intentionally
• Protect L Brands’ business information outside of L Brands. Refer false or misleading statements, or fail to
information. to the company’s Insider Trading Policy provide accurate information to internal
• Respect intellectual property – for additional details. or external auditors or investigators,
both the company’s and others. or cause others to do so.
Financial Integrity
and Accurate Records Use of Company Property
We ensure that company records We use work time and company
are accurate, timely and fairly property for the benefIt of the
and completely reflect actual company. Company property includes
transactions and events. Our share- our premises, information, equipment,
holders, customers, fellow associates, documents, data, software, technology
the public and government entities assets, supplies, merchandise, samples
are entitled to accurate and truthful and support services. On occasion, we
business records. We ensure that we can use company property for limited
are using company assets appropri- and incidental personal use. Do not be
ately, and we are properly reflecting careless or negligent with company
all expenditures, transactions, assets property. In addition, do not participate
and liabilities in our financial records. in theft or unauthorized removal of
It is each associate’s responsibility to company property or the property of
create accurate and complete records others. This includes removing supplies,
and follow internal controls. If you are samples, tools or equipment without
unsure about what is required, talk to authorization.
your manager.
12 L Brands Code of ConductImproper use of company property For the company’s protection as well
can expose the company to legal or
financial risk. For example, follow the
as your own, it is critical to show proper
respect for the laws governing copy-
You are not
company’s Information Security Policy right, fair use of copyrighted material restricted
when downloading software and owned by others, trademarks and other from sharing information about
protect computer passwords and intellectual property, including the your own employment with
information stored on our systems. company’s own copyrights, trademarks others or cooperating with
Unless otherwise regulated by applica- and brands. If you are unsure about your any fair employment practices
ble law, you should have no expectation proper use of our intellectual property, agency. Nor are you restricted
of privacy on our premises or while check with your manager or the Legal from reporting possible viola-
using our systems or networks. The department. tions of law to any government
company retains the right to search any agency or entity or making
and all company property at any time, any other disclosure that is
including, but not limited to offices, External Communications protected under applicable law
desks, email, instant and mobile The company releases information or regulation. You do not need
messages, voicemail and any other related to its financial performance and prior authorization from the
company-provided communications position on significant issues and strat- company to make such reports,
and computing devices, services and egies only through associates who are and you are not required to
applications. Please be aware that your authorized to speak publicly on behalf notify the company that you
activities, including personal, carried of the company. have made such reports.
out on our premises or using our
systems or networks may become The company will respond to investors
known to us. and the media only through a designat-
ed spokesperson. If you’re ever asked
to make a comment to investors or the
Intellectual Property media on behalf of the company, politely
We safeguard the company’s trade- direct the request to Communications.
marks and intellectual property See Contacts section.
because they are some of our most
valuable assets. We all have the All requests to speak externally as a
responsibility to protect these assets, representative of the company at
including reporting counterfeit mer- occasions such as industry conferences,
chandise or the improper distribution of education presentations and panel
our products by others. Our intellectual discussions must be approved by
property includes legally protected cre- Communications. Participation in case
ations, such as copyrights, trademarks, studies, white papers, other published
patents, brands, design rights and trade pieces or award entries must also be
secrets. It also includes inventions, pre-approved. Requests for use of the
designs, know-how and innovations that company’s logos or inclusion of the
you conceive or devise when they: company’s name in press releases,
• arise out of or are suggested by the on websites or at trade shows by
company’s business information external parties, including the
or any work you performed for the media, must be referred to
company; Communications.
• result from your use of the compa-
ny’s time, facilities or assets; or
• otherwise arise from your work on
behalf of the company.
L Brands Code of Conduct 13Using Digital Media Compliance Officer and Community
solicitation We use Digital media responsibly. Relations:
• Do not solicit during working time.
as part of Customers, competitors and associates
all over the world can easily access • Do not distribute literature during
a company- information posted on digital media working time or in working areas.
sponsored channels. Use common sense when Cafés and break areas are not con-
campaign posting and remember that our com- sidered working areas. Rest, meal
pany policies apply even if your online and other authorized breaks are not
Occasionally, the company
activities are not related to our business. considered working times.
may solicit associates as part
For example, just as you wouldn’t • Do not use company telephones or
of a company-sponsored cam-
discriminate against or insult a customer letterhead to solicit other associates,
paign for organizations support-
or fellow associate in person, it is vendors or business partners or to
ed by L Brands, such as United
unacceptable to do so online. distribute literature of any kind.
Way or Pelotonia. Any commu-
• Do not solicit vendors or business
nications, solicitation or promo-
Don’t post business information, includ- partners on behalf of the company.
tion as part of a company-spon-
ing the company’s financial position, Never solicit a vendor or business
sored campaign to associates
sales trends, forecasts, future product partner if there is a stated or implied
can only be made in accordance
launches and promotions, vendor lists, understanding, suggestion or expec-
with company policies and must
private information about customers tation that supporting a personal
be approved in advance by
or other associates such as credit card cause or charitable effort will benefit
Community Relations and
numbers or banking information or oth- the vendor’s or other party’s business
Communications.
er information that could compromise relationship with the company.
your safety or that of others. Respect all
copyright and intellectual property laws. In addition, please be aware that:
• Noncompany-sponsored activities
DO are not permitted on company
• Refer media inquiries for property, even in nonworking areas
Solicitation and
comments on behalf of the or during nonworking hours.
Distribution
company to Communications. Examples include:
There are times when we all feel the
• Use digital media responsibly. - book fairs, magazine drives,
need to contribute to something we
• Maintain a workplace consistent candy sales, cookie sales,
believe strongly in. But it’s important
with company policies. giftwrap sales, flower sales or
to protect our associates’ work activities
and relationships with business partners other outside promotional sales;
from those who promote personal caus- and
es, products or viewpoints. That’s why - posting or advertising items or
we have guidelines for solicitation for services for sale.
money, time or resources, or distribu- • Nonassociates are prohibited from
tion of literature. These guidelines apply soliciting or distributing literature
equally to associates who are soliciting on company property.
and those being solicited. Unless you
are authorized by the Office of the Chief
14 L Brands Code of ConductACKNOWLEDGMENT My signature below indicates that I have received the L Brands Code of Conduct: I acknowledge that: • It is my responsibility to comply with all company policies, including those in the Code of Conduct, and any revisions made to them. • The company may modify the Code of Conduct from time to time as it deems necessary and that I will be notified of these changes. • The Code of Conduct is not an employment contract and does not alter my at will employment status. Either the company or I can terminate my employment, with or without cause, at any time in the U.S. and in all other locations where permissible by law. • I cannot disclose the company’s business information without a legitimate business or law enforcement reason (and in accordance with applicable laws and regulations). • The company can collect and retain my personal information for employment purposes, in accordance with the company’s privacy policies. • The company may access, collect, intercept, use, disclose, move, communi- cate and/or transfer (including across borders) any information communicated through the company’s computer and/or communications network. • The company may release my personal information as it deems necessary to the appropriate workers’ compensation authorities or other appropriate party should I suffer a workplace injury or occupational disease. • Violation of any company policy, including those contained in the Code of Conduct, may be grounds for disciplinary action, up to and including termination of employment. I understand that: • I can share information about my own employment with others and can cooperate with any fair employment practices agency. • I can report possible violations of applicable laws or regulations to any gov- ernmental agency or entity and can make other disclosures that are protected under applicable law or regulation. I do not need to get permission from the company to make such reports and am not required to notify the company of such reports or disclosures or any related investigations. Note: An electronic signature may serve as acknowledgment when the form is completed online. _____________________________________________________________________ Associate name (please print) _____________________________________________________________________ Brand or division name _____________________________________________________________________ Associate signature (required) _________________________ Date REV 12_2016 L Brands Code of Conduct 15
16 L Brands Code of Conduct
CONTACTS
UNITED STATES CANADA OUTSIDE OF NORTH AMERICA
Ethics Hotline www.lb.ethicspoint.com www.lb.ethicspoint.com www.lb.ethicspoint.com
To report unethical +1.888.884.7218 +1.866.892.4241 Mainland China
behavior or suspected Southern: 10.800.120.1239
violations of our Northern: 10.800.712.1239
code of conduct
Hong Kong
800.964214
India
000.800.100.1071
000.800.001.6112
Indonesia
001.803.011.3570
007.803.011.0160
Israel
1.809.21.4405
Korea
00798.14.800.6599
00308.110.480
00798.1.1.009.8084
Philippines
1.800.1.114.0165
Singapore
800.120.4201
Sri Lanka
Direct Access Code + 1.888.884.7218
112.430.430 (outside Colombo)
2.430.430 (Colombo)
Taiwan
00801.13.7956
United Arab Emirates
Direct Access Code + 1.888.884.7218
8000.555.66
United Kingdom
Direct Access Code + 1.888.884.7218
0.500.89.0011 (C&W)
0.800.89.0011 (British Telecom)
Vietnam
120.11067
Associate Information/ HR Direct HR Direct HRAccess
Human Resources +1.866.473.4728 +1.855.770.8707 Employee Self Service
https://hraccess.lb.com
HRAccess HRAccess
Employee Self Service Employee Self Service Mast Far East
https://hraccess.lb.com https://hraccess.lb.com HR Service Center
+852.2734.4000
United Kingdom
Human Resources
+44(0) 207.557.6670
Associate Intranet http://www.gettingtonext.com http://www.gettingtonext.com Mast Far East
http://msthrfeweb/
United Kingdom
http://www/gettingtonext.com
Communications communications@lb.com communications@lb.com communications@lb.com
+1.800.945.5088 +1.800.945.5088 +1.800.945.5088
L Brands Code of Conduct 17UNITED STATES CANADA OUTSIDE OF NORTH AMERICA
Community Relations makeadifference@lb.com makeadifference@lb.com makeadifference@lb.com
Emergency +1.800.765.7465 +1.800.765.7465 +1.800.765.7465
Operations Center emergencyoperationscenter@ emergencyoperationscenter@ International Toll Free
lb.com lb.com 08.082340479
emergencyoperationscenter@lb.com
Employment The Work Number® All Canada Brands/Functions Mast Far East
Verification www.theworknumber.com Local Human Resources partner Local Human Resources partner
+1.800.996.7566
United Kingdom
+1.800.367.5690 + company
+44(0) 207.557.6670
code 10217 (non-members)
UKHR@victoria.com
Expense +1.877.415.7168 +1.877.415.7168 Mast Far East
Reimbursement aer@lb.com aer@lb.com Local finance teams
Department
United Kingdom
+1.877.415.7168
aer@lb.com
Government Affairs governmentaffairs@lb.com governmentaffairs@lb.com governmentaffairs@lb.com
+1.614.415.7078 +1.614.415.7078 +1.614.415.7078
Office of the Chief Ethics & Compliance Ethics & Compliance Ethics & Compliance
Compliance Officer Jennifer Estey, Director Jennifer Estey, Director Jennifer Estey, Director
L Brands Inc L Brands Inc L Brands Inc
P.O. Box 16000 P.O. Box 16000 P.O. Box 16000
Columbus, OH 43216 Columbus, OH 43216 Columbus, OH 43216
USA USA USA
ethics@lb.com ethics@lb.com ethics@lb.com
+1.614.415.2721 +1.614.415.2721 +1.614.415.2721
Global Anti-Corruption Global Anti-Corruption Global Anti-Corruption
Dan Click, AVP Dan Click, AVP Dan Click, AVP
L Brands Inc L Brands Inc L Brands Inc
P.O. Box 16000 P.O. Box 16000 P.O. Box 16000
Columbus, OH 43216 Columbus, OH 43216 Columbus, OH 43216
USA USA USA
daclick@lb.com daclick@lb.com daclick@lb.com
+1.614.415.6311 +1.614.415.6311 +1.614.415.6311
Compliance & Ethics Counsel Compliance & Ethics Counsel Compliance & Ethics Counsel
James Ervin, Jr. James Ervin, Jr. James Ervin, Jr.
L Brands Inc L Brands Inc L Brands Inc
P.O. Box 16000 P.O. Box 16000 P.O. Box 16000
Columbus, OH 43216 Columbus, OH 43216 Columbus, OH 43216
USA USA USA
jervin@lb.com jervin@lb.com jervin@lb.com
+1.614.415.7367 +1.614.415.7367 +1.614.415.7367
General Counsel General Counsel General Counsel
L Brands Inc L Brands Inc L Brands Inc
P.O. Box 16000 P.O. Box 16000 P.O. Box 16000
Columbus, OH 43216 Columbus, OH 43216 Columbus, OH 43216
USA USA USA
generalcounsel@lb.com generalcounsel@lb.com generalcounsel@lb.com
Chief Compliance Officer Chief Compliance Officer Chief Compliance Officer
L Brands Inc L Brands Inc L Brands Inc
P.O. Box 16000 P.O. Box 16000 P.O. Box 16000
Columbus, OH 43216 Columbus, OH 43216 Columbus, OH 43216
USA USA USA
generalcounsel@lb.com generalcounsel@lb.com generalcounsel@lb.com
Office of the generalcounsel@lb.com generalcounsel@lb.com generalcounsel@lb.com
General Counsel
18 L Brands Code of ConductHOW WE
Your Associate File Pay and the Law
Your associate file contains information Nothing in the Code of Conduct or
required by law and may also contain other company policies is intended
information about your work history,
salary or pay rate, performance eval-
to prohibit discussion of pay rates or
any rights protected by applicable
SUPPORT
OUR CODE
uations, and other information related law (including labor or employment
to your job. These files are considered standards).
company property and may not be
removed from our premises or released
to anyone without proper authorization. Your Career OTHER COMPANY
All requests for access to or copies of Career Opportunities POLICIES ABOUT
associate files must be referred to HR Our company provides the opportu- YOUR EMPLOYMENT
Direct or your Human Resources part- nity for growth. We try to promote
ner. To see your own file, contact your from within. Promotion decisions are
Human Resources partner. Store associ- based on many factors, including your
ates should contact their store manager performance and your ability to assume
or district manager. additional responsibilities.
Performance Evaluations
References The company believes in providing
Generally, the company does not associates with consistent and
provide employment references and constructive feedback to promote
associates, including managers, may not professional growth and development.
provide job references on behalf of the Job performance, business results and
company. If you receive a request for a economic conditions are the primary
reference, please refer the request to factors in determining any potential in-
your Human Resources partner for crease. Typically, you will participate in a
a response. performance evaluation once a year and
may also participate in periodic prog-
In response to an external inquiry for ress evaluations throughout the year.
information about a current or former
associate, the company will verify Resignations
only employment dates, employment You are free to resign your position at
status (part or full time), job title and any time; however, we encourage you
department and work location. See to give two weeks’ notice as a matter
the Contacts section for employment of courtesy (or the amount of time
verification contact information. specified in your employment agree-
ment). The company may choose to
release you prior to your two-week
notice date. In this case, you will be paid
for all hours worked or to satisfy con-
tractual obligations, where applicable.
L Brands Code of Conduct 19Leaving the Company
If you leave the company, your man-
STORE ASSOCIATES
ager or Human Resources partner can
Our labor management tools sched-
answer your questions about final pay
ule to the needs of the business and
arrangements and the termination of
associate availability. Schedules are
benefits. To learn more about what
posted in advance of each work week
happens to key benefits, please refer
electronically (where available) and in
to your benefits materials, HR Direct or
the back room. Availability and time off
contact your Human Resources partner.
requests must be submitted through the
Before leaving the company, you will
online scheduling system (or in writing if
have to return all company property,
no online scheduling system is avail-
including electronic equipment, compa-
able) before the schedule is created;
ny credit cards, your employee ID card,
talk to your manager to understand the
store keys, discount card, etc. If you are
timeline for your store. Management will
a U.S. associate and have a payroll card,
do its best to approve requests while
you should keep it in the event you are
allowing us to meet the needs of the
rehired by the company.
business. Once a schedule has been
published, store management will com-
municate schedule changes to you only
Scheduling through verbal conversations.
and Attendance
Your hours are dependent on where you
work and the needs of the business.
Be On Time
You must report to work on time,
whether you’re just starting the day or
HOME OFFICE ASSOCIATES returning from rest or meal periods. If
While hours may vary office to office,
you will be late, inform your manager as
our standard hours are 8:30 a.m. to
soon as possible before the beginning
5:30 p.m., Monday through Friday.
of your workday/shift. Chronic lateness,
Depending on the department,
for whatever reason, will affect your per-
geographic location and/or time of
formance and may result in disciplinary
year, your work schedule may differ.
action, up to and including termination.
Talk to your manager about specific
If you must leave work early, talk with
work hours for your position.
your manager. Leaving work during
a workday/shift without your manag-
er’s permission or taking unauthorized
CUSTOMER CARE CENTER, breaks is not permitted.
DISTRIBUTION CENTER
AND SHIPPING BUILDING When You Can’t Make It
ASSOCIATES If you have a day when you must be
Work schedules in the customer
absent, call your manager at your first
care centers, distribution centers and
opportunity (texting, emailing, instant
shipping facilities are determined by
messaging and other electronic commu-
business needs. Specific attendance
nications are not acceptable forms
guidelines are provided during
of notification for store, distribution
orientation.
center/shipping building and customer
20 L Brands Code of Conductcare center associates). Please call as our facilities. For more information on
soon as possible but no later than two
hours before the beginning of your
the dress code for your job, refer to
your orientation materials or brand
WHEN YOU
workday/shift. Your manager is respon- standard operating procedures, or talk CAN’T MAKE IT
sible for finding coverage for your shift. to your manager.
• If you are absent five or more con-
STORE ASSOCIATES
Call the store and speak to
secutively scheduled workdays/shifts
the manager on duty. Store
due to injury or illness, you must get Associate Contact
managers should call the store
a note from your doctor. (We also Information
and district manager.
reserve the right to request a note Please ensure your contact information
from your doctor for absences less is up-to-date so we can contact you
than five consecutively scheduled in case of an emergency. To protect
DISTRIBUTION
workdays/shifts.) associate safety and privacy, associate
CENTER/SHIPPING
contact information is not to be posted
BUILDING ASSOCIATES
Call the call-off line for your
• For all absences lasting more than in the store backrooms or other com-
location listed in your orienta-
five consecutively scheduled work- mon areas in our facilities.
tion materials.
days/shifts, please contact HR
Direct in addition to contacting your
manager to determine if you are Personal Property
eligible for leave time. (See Associate Keep your personal possessions locked
Information in the Contacts section in your assigned locker, desk drawer
for location-specific contact details.) or other designated area. Do not leave
your personal possessions unsecured.
Failure to contact your manager while The company does not assume liability
you are out (unless you are on an ap- for any lost, stolen or damaged
proved leave of absence) could affect personal items.
your employment. We reserve the right
to terminate the employment of any
associate absent for three consecutively Smoking and Using
scheduled workdays/shifts without call- Tobacco Products
ing in to report the absence. You will be Smoking and using tobacco products
deemed to have voluntarily abandoned (including cigarettes, electronic ciga-
your employment with the company rettes, pipes, cigars, snuff or chewing
and you will be designated as “not to tobacco) are not permitted in any of our
be rehired” by Human Resources. facilities, distribution centers or stores,
including back rooms. If you smoke or
use other tobacco products, please do
Dressing for Success so only in designated areas. You are
Our dress code requirements vary required to follow the smoking/tobacco
from job to job. The company does policy in the mall or facility in which
not require associates to purchase you work.
and wear L Brands’ merchandise. You
may be asked to modify your dress or
remove accessories to comply with our
brand policies or safety protocols in
L Brands Code of Conduct 21You can also read
