CODE OF CONDUCT FOR ASSOCIATES - L Brands

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CODE OF CONDUCT FOR ASSOCIATES - L Brands
CODE OF
CONDUCT
  FOR ASSOCIATES
CODE OF CONDUCT FOR ASSOCIATES - L Brands
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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
CODE OF CONDUCT FOR ASSOCIATES - L Brands
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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
CODE OF CONDUCT FOR ASSOCIATES - L Brands
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 Conduct
LEADING 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   7
don’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 Conduct
LEADING 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   11
is 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 Conduct
Improper 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   13
Using 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 Conduct
ACKNOWLEDGMENT
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   17
UNITED 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 Conduct
HOW 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   19
Leaving 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 Conduct
care 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   21
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