Walgreens Code of Business Conduct - October 2014
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Walgreens Code of Business Conduct
October 2014
Table of Contents A message from President and CEO Greg Wasson ................................................. 1 A message from Chief Compliance Officer Diane Nobles....................................... 2 Our Code and Your Responsibilities The purpose of our Code of Business Conduct ....................................................... 3 Key principles ........................................................................................................... 4 Publication and amendments................................................................................... 4 We are all accountable ............................................................................................. 4 Team leaders have additional responsibilities .......................................................... 4 Where we can seek help........................................................................................... 4 No retaliation policy .................................................................................................. 5 Open Door Policy ..................................................................................................... 5 What happens if we violate our Code?..................................................................... 5 A Foundation of Trust for Our Customers ................................................................. 6 We uphold our trustworthy reputation through product safety ................................ 7 We provide quality, dependable services our customers can count on ................... 7 We market our products and services honestly ....................................................... 7 We expect our suppliers to uphold our values ......................................................... 8 We protect the private information and intellectual property of others .................... 8 We uphold the competition and antitrust laws that apply to our work..................... 8 We obtain competitive information fairly .................................................................. 9 We work on government contracts and programs lawfully and ethically ................. 9 We maintain appropriate relationships with healthcare professionals...................... 9 A Foundation of Trust for Our Company and Our Fellow Team Members ............. 10 We foster diversity and inclusion in our workplace .................................................. 11 We respect each other and do not tolerate harassment .......................................... 11 We strive to create a safe and healthy work environment ........................................ 11 We work to protect our company’s assets ............................................................... 11 We safeguard each other’s personal information ..................................................... 12 We use our computer systems appropriately ........................................................... 12 Individual social networking and blogging ............................................................... 12 A Foundation of Trust for Our Investors .................................................................... 14 We keep honest, accurate financial books and records........................................... 15 We maintain records in compliance with the law and company policy .................... 15 We avoid conflict of interest situations ..................................................................... 15 Gifts and entertainment ............................................................................................ 16 Doing business with friends and relatives ................................................................ 16 Outside positions...................................................................................................... 16 Business opportunities ............................................................................................. 17 We uphold insider trading laws ................................................................................ 17 A Foundation of Trust for Our Communities ............................................................. 18 We follow healthcare laws ........................................................................................ 19 We comply with the Federal False Claims Act ......................................................... 19 We work to build sustainable supply chains ............................................................ 19 We follow international trade laws ............................................................................ 19 We do our part to protect the environment .............................................................. 21 We support our local communities ........................................................................... 21 We communicate with a single voice ....................................................................... 21 Asking Questions and Raising Concerns.................................................................. 22
A Message from President and CEO Greg Wasson
To all our team members:
Walgreens culture of accountability rests firmly on our foundation of a strong
commitment to ethics, honesty and integrity. As a trusted healthcare provider,
community presence, employer and strategic partner, that commitment has always
been an integral part of how we do business. Compliance guides our business
relations both internally and externally, and plays a critical role in all compensation
and employment decisions.
As we expand our horizons and move into the global arena, it is perhaps more
important than ever that we uphold that commitment. We are building our brand
in parts of the world that have not grown up with Walgreens for the last century.
Greg Wasson
Their first acquaintance and lasting relationship should be with a company that
continuously puts ethics at the top of its list of requirements for all its team
members and all its business dealings.
This Code of Business Conduct has been designed to help you understand your role
in supporting compliance and the critical business behaviors each of us must adhere
to. It was created to answer questions you may have regarding ethics at Walgreen
Co. and guide you in your work. Please be sure to read through the entire booklet
and consider it a primer on our business conduct.
The ongoing dedication to ethics and compliance on the part of team members
past and present is what has kept Walgreens a trusted destination in this country
for health and happiness for more than 113 years. We’re ready to take our business
and commitment to compliance worldwide.
Thank you for being a trusted member of our team.
Be well,
Greg Wasson
“As we expand our horizons and move
into the global arena, it is perhaps more
important than ever that we uphold our
commitment to compliance, ethics,
honesty and integrity.”
Greg Wasson
OCTOBER 2014 1
A Message from Chief Compliance Officer Diane Nobles
Dear Team Members:
Welcome to the 2014 edition of Walgreens Code of Business Conduct. This important
document is both a primer and a guidebook created to help ensure Walgreens maintains
its trusted reputation with our customers and patients, communities, healthcare
professionals and organizations, clients, shareholders and all with whom we do business.
One of the things I’ve seen since my earliest days at Walgreens is how tuned in our team
members are when it comes to ethics, a strong sense of responsibility and integrity. The
importance of our cultural beliefs in our everyday work certainly attests to that. We are all
about doing the right thing, in the right way—the essence of integrity. I see it in meetings,
Diane Nobles in conversation, when setting strategies—and it is just this kind of mindset that has kept
Walgreens going strong through its 113-year history. We hold ourselves accountable for
Walgreens success—just as we should. And the reality is, accountability is a critical factor
in how Walgreens does business here and around the world, and how each and every one
of us does business. In fact, holding ourselves accountable is the very basis on which the
success of all our endeavors rests.
Who hasn’t seen the fall of individuals, companies and organizations due
“When you demonstrate to the loss of reputation or misconduct? Just as Walgreens reputation
has been built one decision at a time over more than a century, it can be
ethical behavior, you’re destroyed one decision at a time. Each of us is a representative of
playing the ultimate role Walgreens, which is why each of us is accountable for behaving ethically
of the team member— and being compliant with regulations. And that’s the key behind this
keeping our company publication: to ensure we’re all working off the same page—literally—
safe and our reputation when it comes to ethics and integrity at Walgreens. Please be sure to read
through the Code of Business Conduct beginning to end. Each year, our
intact, and safeguarding code is refreshed to keep up with changing policies, regulations and laws.
our customers, patients,
clients, shareholders— From our open door policy and reporting violations with no fear of
retaliation to ethical principles and practical guidance, our Code covers
and each other.” the ethical behaviors our team members need to demonstrate on the job.
Diane Nobles
Your Compliance Office is always ready to answer questions or discuss
Chief Compliance Officer
issues—just call 847-964-6519 or email compliance@walgreens.com
for a confidential conversation.
When you demonstrate ethical behavior, you’re playing the ultimate role of the team
member—keeping our company safe and our reputation intact, and safeguarding our
customers, patients, clients, shareholders—and each other.
Thank you, and be well.
Diane Nobles
2 OCTOBER 2014
at the corner of ETHICS and COMPLIANCE
The purpose of our Code of Business Conduct Our Code of Business Conduct is a guide to the ethical and legal
responsibilities we share as members of the Walgreens Family of Companies (collectively “Walgreens”). We use this Code for
guidance and direction to resources to help us make the right decisions. It helps us choose the right action to take. We all
encounter situations that force us to make decisions at work, and sometimes the most ethical response is not always the
most obvious choice. As we cannot address every decision you must make, our Code is not a summary of all laws and
policies that apply to Walgreens business. Instead, it is a starting point to help us determine when and where to seek help
when we are unsure. We have a solid foundation today and many things we don’t want to lose, like the desire to win, our
innovative mindset and looking out for each other. Our key strategic components include our core values and cultural beliefs.
Evolving our culture is about respecting what’s here and welcoming the new.
OUR CODE A Foundation of Trust
AND YOUR for Our Company
and Our Fellow
RESPONSIBILITIES
Team Members
A Foundation of Trust A Foundation of Trust
for Our Customers for Our Investors
A Foundation of Trust Each of us is
for Our Communities responsible for
following the principles
outlined in our Code.
OCTOBER 2014 3
Our Code and Your Responsibilities
Each of us is responsible for following the principles outlined usual high standards, to lead by example and act as role models.
in our Code. We are all expected to be familiar with and follow If you are part of leadership, you can do this by:
company policies, as well as the laws and regulations in every • Reinforcing the Code and ensuring it is consistently applied
location where we do business. By reviewing and understanding
• Making sure each team member has completed all
our Code and policies, we become better prepared to handle
required training
ethical issues as they arise. ®
• Communicating relevant policies to team members and helping
Key principles them to understand the policies
Each of us is responsible for: • Encouraging all team members to raise any questions
or concerns
Integrity and compliance – Achieving our goals with
integrity and in compliance with company policy and • Dealing with reports of misconduct promptly and properly
legal requirements • Never ignoring any type of misconduct or retaliation against a
Open communication – Encouraging open, honest and team member
full discussion about our policies and procedures • Never retaliating against a team member for raising questions or
Raising questions – Raising and resolving questions about issues, in good faith, to those outside your chain of command
ethical business conduct (for example the confidential hotline, Asset Protection Solutions,
or HR Shared Services).
Reporting violations – Reporting actual or perceived Code,
Team leadership must strive to create a positive work environment
policy or legal violations to management, the chief compliance
where team members feel comfortable asking for help and raising
officer or the company hotline
concerns about this Code. Team leadership must also be alert to
Cooperation – Assisting with any audit, compliance assess-
any situations or actions that may violate the letter or spirit of the
ment, legal or other internal inquiry with candid, accurate
Code or company policy or that may damage our company’s repu-
and complete information
tation. It is important that, as team leadership, you take immediate
Non-retaliation – Ensuring that no punishment or retaliation action to address such situations.
occurs against anyone for raising a good-faith concern
When team leadership receive reports of a situation that may be
unethical or potentially damaging to our company’s reputation,
Publication and amendments or suspect that one exists, he or she must promptly notify the
The current version of the Code of Business Conduct is posted chief compliance officer, company hotline, or HR Shared Services
and maintained on the Walgreens website at www.walgreens.com and work to resolve the issue. Team leadership who know about,
>Investor Relations >Corporate Governance >Code of Business or should know about, misconduct and do not act promptly to
Conduct. Amendments are also posted on the website, as required report it and cooperate with any investigation to correct the
by applicable law. Because the Code is revised periodically, please situation will be subject to disciplinary action.
check the website for the most recent version.
Where we can seek help
We are all accountable If you are ever unsure about the best course of action, however,
Whatever our role is with Walgreens, our actions represent the there are many company resources available to help you.
company, and we must always do our best to uphold Walgreens If you become aware of or even reasonably suspect any violations
reputation. Our success as a company depends on each of us of our Code or company policy, you are required to report your
accepting personal responsibility for always doing the right thing. concerns to your direct team leadership, the chief compliance
We must accept the obligation to stop or prevent actions that officer, HR Shared Services or the company hotline. Speaking up
could harm our customers or our company’s reputation and to when you sense any activity that could violate our core values
report any such actions as soon as we learn of them. helps maintain Walgreens culture of trust and integrity and our
Team leadership has additional responsibilities responsibility to uphold our company’s high moral standards.
Performing honestly and with integrity is an obligation we all share. There are a number of ways to raise issues. If you believe that a
Team leadership, however, are expected to perform beyond our law has been violated or an ethical violation has occurred, contact
This icon has been placed throughout the guide to indicate the availability of additional information. Simply click on the icon for a link to find out more
®
about specific policies and topics. (These links are internal and can only be accessed by Walgreen team members.)
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
4 OCTOBER 2014
Our Code and Your Responsibilities
the chief compliance officer immediately. For other matters, you can No retaliation policy ®
talk to your team leadership or any other member of management. Walgreens does not tolerate retaliation against anyone who
Sometimes, just talking to your team leadership will help clarify the participates in an investigation, raises a legal or ethical concern,
situation and answer your questions. or reports misconduct in good faith. “Good faith” means that the
If you still have concerns after talking with your team leader, you report was made out of genuine concern for the company or
can always contact the chief compliance officer, company hotline team members involved.
or HR Shared Services.
Here are some examples of retaliation:
Chief compliance officer • schedule changes that are outside of the business need
• Phone: 847-964-6519 and/or the team members request after reporting an issue
• Email: compliance@walgreens.com • unreasonably denied or delayed promotions
• Web: www.tnwgrc.com/walgreens • excluded from meetings, making decisions, denial of
• Hotline: 1-855-WAG-CODE (1-855-924-2633) administrative support, or reassigning job duties
HR Shared Services • excluded from training that contributes to
• Phone: 847-315-4455 professional advancement
• reprimanded for contacting the hotline or Asset
The Walgreens hotline (1-855-WAG-CODE) is a toll-free
Protection Solutions
telephone line reserved specifically for team member calls
on ethics and compliance issues. This hotline is an option • verbal abuse by a supervisor or someone else
that is made available to you to report your concerns if you in management
feel uncomfortable doing so in person.
Open Door Policy ®
The hotline is staffed 24 hours a day, seven days a week, 365
Our Open Door Policy is a key part of our culture. It encourages
days a year by an outside firm experienced in handling sensitive
us to present ideas, raise concerns and ask questions—including
calls and accepting calls in many languages. Callers may report
those of a legal or ethical nature—without fear of retaliation. You
anonymously. Anonymous callers should know, however, that
are encouraged to address situations first with your team leader,
it is sometimes more difficult to follow up on issues raised by
who is often best able to resolve the issue. You can avoid many
individuals who don’t identify themselves.
potential violations by simply asking for guidance before acting.
Our company is committed to reviewing, evaluating and responding In certain cases, you may feel uncomfortable discussing a matter
to all reports of misconduct—big or small. To the extent practical, with your team leader, or you might be unable to reach a satisfac-
considering our need to investigate and comply with company tory solution. If this is the case, you may speak with any other
obligations, Walgreens will make every effort to protect the confi- member of management, the chief compliance officer, HR Shared
dentiality of any person who comes forward with information, as Services or you may call the company hotline. You will never be
well as the information itself. punished or retaliated against for making good faith use of our
Open Door Policy.
My team leadership asked me to do something that
I don’t believe is in compliance with the law. Should I What happens if we violate our Code?
follow his/her instructions? To maintain the highest standards of integrity, we must dedicate
ourselves to complying with our Code, company policies and
No. We must all obey the law. Regardless of the posi- procedures and applicable laws and regulations. Violations
tion of the team leader within the company, if you think of our Code not only damage our company’s standing in the
you have been asked to do something that is against the communities we serve—they may also be illegal. Team members
law, you have a duty to report the situation. You can involved in violating our Code will likely face negative conse-
use the Open Door Policy or go to another member of quences. Walgreens will take the appropriate disciplinary action
team leadership, the chief compliance officer, HR Shared in response to each case, up to and including termination. In
Services or call the Walgreens hotline. Remember that all addition, team members involved may be subject to government
good faith reporting is protected from retaliation. fines or criminal or civil liability.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
OCTOBER 2014 5
A FOUNDATION OF TRUST
for Our Customers
Be Bold
Be Real
Love Customers
Be One
Build Trust
Own It
Live It
A FOUNDATION OF TRUST for Our Customers
Walgreens team members must always follow the highest
standards of integrity and ethics when interacting with our
customers and patients. Even team members who do not
interact with customers must be aware that the decisions they
make and the work they perform ultimately affect our customers.
We uphold our trustworthy reputation through product safety
Our customers count on us to sell safe reliable products that
meet the highest quality and safety standards. In our company’s
long history, we have earned our customers’ trust by sticking to
this principle.
As part of our commitment to exceeding our customers’ expecta-
tions, we must also ensure that we purchase only the highest
quality products from our suppliers. If you become aware of any
defective products or other issues that could pose a health or safety
risk, you have a responsibility to report the matter immediately. ®
Our marketing materials and company communications are
meant to inform our customers about our products and services.
They are expected to meet all industry standards that govern
As a store manager, I received a communication from
advertising and promotion. As such, we must follow all relevant
the company that a certain product is being pulled and
laws and regulations regarding the marketing of our products,
quarantined due to quality concerns. I have some other
services and the Walgreens brand. In addition, we must never
tasks that I’d like to complete before pulling the product
falsely represent any of our competitors’ products or services or
from the sales floor. Is that okay?
engage in any deceptive marketing practices.
No. Our customers trust us to provide safe, quality
products. The pull and quarantine items should be pulled
I’m having trouble meeting my sales goals. I’ve tried
from the floor immediately. You must focus on maintaining
many selling techniques, but I still can’t meet the com-
our customers’ safety and complete the other tasks later.
pany’s expectations. My team leader said that we should
“do what it takes” to meet sales targets. My team leader
We provide quality, dependable services our customers becomes eligible for incentives with sales success, and
can count on team members earn rewards for sales results. I’ve heard
Due to our unique standing as both a retailer and a healthcare that some team members in other areas have been meet-
provider, we must maintain our commitment to the integrity of ing sales goals by overstating the benefits of our services
our products and services. Many of our customers rely on our or issuing unauthorized discounts to offset costs for the
pharmacists and other healthcare providers for advice and customer. I feel I’m on the verge of disciplinary action for
dependable service. Those professionals are required to maintain my lack of success in sales. What should I do?
current licenses, certifications or registrations and follow standards
You should not engage in any improper sales
of ethics that correspond with their occupations. Further, you may
practices to meet these goals. You also should never
not give any type of medical, pharmaceutical or other professional
misrepresent products or services to a customer or issue
advice unless you are licensed to do so.
unauthorized discounts. You have a number of alterna-
We market our products and services honestly tives available to you. For instance, you can speak to your
We must preserve Walgreens principles of integrity and honesty colleagues or team leader for help in meeting your goals.
when we market our products—whether in any advertising, You can also review sales training or practice your use of
promotions, packaging, or labeling. Our customers’ trust is one sales techniques, maybe with a team leader or colleague.
of our most valuable assets, and we are committed to maintaining You should also report the rumors you have heard about
that confidence. other team members using improper sales techniques
to the chief compliance officer or the company hotline.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
OCTOBER 2014 7
A FOUNDATION OF TRUST for Our Customers
We expect our suppliers to uphold our values I often communicate with our healthcare providers by
We rely on our suppliers’ and other business partners’ integrity e-mail. If they request patient information that is private
in all our dealings, and we expect them to assure the safety and and confidential, is it okay to send it electronically?
performance of their products and services. We pursue legally
Patient information may be sent by e-mail to healthcare
compliant ways to make the most reliable purchasing decisions
providers, but only if the e-mail is encrypted. In some
based on cost, product and quality, so that we can deliver quality
situations, be sure the provider has signed any necessary
goods at competitive prices to our customers.
agreements to receive protected health information. If
Walgreens develops lasting relationships with suppliers who meet you have questions as to when signed agreements are
our high standards of business ethics. Our standing in the commu- required, contact the chief compliance officer. In addition,
nities we serve is based on the trust that those communities place send only the information requested.
with us. To maintain that trust and continue to deliver the best
products to our customers, we follow all company procurement We must never knowingly violate the intellectual property rights of
policies in our purchasing interactions. We will not purchase prod- others. Those of us with marketing or advertising responsibilities
ucts from a supplier who uses involuntary labor, prison labor or should be particularly careful when preparing advertising or
child labor. We respect all applicable laws establishing a minimum promotional materials that use the name, printed materials, or
age for employment to support the end of child labor worldwide trademarks of another company. As a general rule, we may not
and we expect our suppliers to do the same. make unauthorized copies of any copyrighted material. Further,
Our company expects its vendors to comply with the standards we may not install or distribute software products on company-
outlined in the Walgreens Vendor Responsibility Standards and owned computers without an appropriate license.
Supplier Code of Conduct. Any team member who becomes
®
In addition, you should not disclose the confidential information
aware of a supplier operating unethically must immediately report or trade secrets of others, including your former employers (e,g.,
the supplier to our chief compliance officer. If the report is verified, picture care plus data or balance rewards data). If anyone at
Walgreens will notify the vendor and require that it take steps Walgreens asks or pressures you to do so, you should report
to immediately comply with our standards. If the vendor fails the matter to your direct team leadership, another member of
to comply with our standards, or its conduct or rehabilitation management or the chief compliance officer. Never use or share
efforts are not in Walgreens best interests, we will terminate any information divulged to you by a third party—whether inten-
the business relationship. tionally or unintentionally—unless you know it is not confidential
or a trade secret. If you are unsure of how to use information you
We protect the private information and intellectual property
have received, contact your direct team leader, another member
of others
of management or the chief compliance officer.
Our relationship with customers is one of our most valuable assets.
It is vital to our success as a company that we treat customers with We uphold the competition and antitrust laws that apply
the highest amount of respect. As healthcare providers, our cus- to our work
tomers entrust us with health information, which is protected under Throughout our history, Walgreens has been dedicated to robust
state and federal law. It is essential that we keep this private data— competition. However, we believe in competing solely on merit—
including names, addresses, dates of birth, social security numbers, never through deceptive or dishonest practices. In this regard, we
phone numbers, prescription histories and health condition—secure must always be accurate and truthful in our dealings with suppliers
and confidential consistent with company policy. It is important to and other business partners, and we expect the same from them.
use good judgment when handling this type of data and to ensure While we compete actively, we do not misrepresent, manipulate, or
any disclosure of a customer’s protected health information to a conceal any material information to gain a competitive advantage.
third party complies with company policy. Our customers value We promote our products and services based on their high stan-
our discretion with their legally protected information. ® dards, and never by making disparaging or false allegations about
our competitors.
There are strict competition and antitrust laws in place to ensure
Our customers’ trust is one of our most valuable fair competitive business practices. Walgreens counts on each
assets, and we are committed to maintaining of us to obey these laws. Specifically, we never discuss with
that confidence. competitors any information about pricing, suppliers, promotional
strategies, territories or any other sensitive marketing information.
We never discuss or make agreements about boycotting third
parties or allocating markets or customers.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
8 OCTOBER 2014A FOUNDATION OF TRUST for Our Customers
If a competitor tries to engage you in a discussion on any of We work on government contracts and programs lawfully
the above-mentioned topics, even informally, you must end the and ethically
conversation immediately and report the incident to the chief Many of our customers rely on our ability to provide the services
compliance officer. We should be especially mindful during trade they need through government-backed healthcare programs such
association meetings or conferences where we are likely to have as Medicare, Medicaid and other federal and state programs.
more frequent interactions with our competitors. Remember, we When working on potential or existing government contracts or
must avoid even the appearance of unethical business practices. funded programs, it is critical that we adhere to all of the laws,
Antitrust laws can be challenging to grasp, and violations carry regulations and procedures that apply to these contracts and
serious penalties—both civil and criminal—for the team members programs. These rules are often much stricter and more complex
involved and our company. If your job involves sales, marketing than those that govern our other contracts.
or procurement, you must know and understand these laws as If your work involves government contracts, government-funded
they apply to your work. For further guidance, please contact programs, or complying with government program parameters,
the chief compliance officer or compliance@walgreens.com. you have a duty to familiarize yourself with the relevant laws and
regulations that affect your job. To seek help in doing so, contact
DOs and DO NOTs of antitrust and competition laws: the chief compliance officer. Please note that violations of these
• Do NOT discuss pricing or the terms of our bid with rules can result in substantial penalties, the loss of future govern-
a competitor. ment contracts, exclusion from government funded programs
• Do NOT agree with competitors to target certain customers, and even civil liability and/or criminal prosecution for the team
products, services or geographic territories. members involved and our company.
• Do NOT agree to boycott a customer, supplier, licensor
or licensee. We maintain appropriate relationships with healthcare
• Do NOT agree with a vendor on the prices at which a professionals
product will be resold to a third party. Our relationships with healthcare professionals are heavily regu-
• Do obtain the chief compliance officer’s review before: lated and the rules are strictly enforced. A healthcare professional
– Communicating with our competitors or participating in is any individual or entity, directly or indirectly involved in the deliv-
trade association activity ery of healthcare who can purchase, prescribe, lease, recommend
– Teaming with our competitors or use our healthcare products or services. The federal and state
– Entering into joint bidding or supply arrangements or laws that govern paying, providing or offering anything of value to
forming a joint venture healthcare professionals such as gifts, meals, entertainment or
– Acquiring assets or voting securities grants are complex and highly regulated.
– Agreeing to contracts containing exclusivity provisions.
The consequences for failing to comply with these laws can result
in significant monetary and even criminal penalties. It is important
We obtain competitive information fairly that you understand and comply with these laws and company
Remaining current on market practices and developments is policy when dealing with healthcare professionals. If you have
vital to the continued success of Walgreens. While we recognize questions or need assistance determining whether a particular
the importance of obtaining information we must only do so in relationship is appropriate, contact the chief compliance officer.
a lawful and ethical manner. This means we obtain information
only through publicly available resources. We also protect any A local physician hinted that if I made a donation
information provided to us in confidence by our suppliers and to his foundation, he would increase the number of
other business partners. prescriptions directed to my location. What should I do?
We must not ask our colleagues to disclose any confidential
Decline the physician’s offer and inform your team
information about their previous employers. If we lawfully obtain
leader or the chief compliance officer. Our relationships
confidential information from suppliers or other business partners,
with healthcare professionals prohibit us from making
we must take care to protect it as we would our company’s own
improper payments that influence business decisions.
proprietary data.
This prescriber is putting our company at risk by solicit-
ing for donations, and making this type of donation could
subject us to serious consequences.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
OCTOBER 2014 9A FOUNDATION OF TRUST
for Our Company and
Our Fellow Team Members
Be One
Be Real
Build Trust
Live It
Be Bold Own It
Love CustomersA FOUNDATION OF TRUST for Our Company and Our Fellow Team Members
We foster diversity and inclusion in our workplace joking fashion. In that regard, we must never bring any weapons
We believe fostering diversity and promoting inclusive hiring into the workplace. ®
practices in the workplace encourages a wider range of abilities Drugs and alcohol impair judgment and in the workplace can
and experiences, and helps us attract the best talent possible. affect everyone’s safety. You may not possess, distribute or
Diversity helps inspire the innovation that drives our business and be under the influence of alcohol or drugs, including certain pre-
helps enhance the ideas that provide our competitive advantage as scription drugs, while on the job or while conducting company
we serve consumers from all walks of life. Our hiring decisions are business. If you have any questions or need assistance with a
based solely on merit. We never make any employment-related substance abuse problem, please contact HR Shared Services
decisions based upon a person’s race, color, gender, age, religion, or the company hotline. ®
disability, sexual orientation, veteran status, marital status or any
Certain safety laws and standards are in place to ensure each
other basis protected by law. Diversity and inclusion are key aspects
of us enjoys a safe and healthy work environment. We all have
of Walgreens strong value system and culture, which have carried
a responsibility to uphold these laws and to follow any safety
us through more than a century of service to our communities.
standards and guidelines specific to our jobs. We should always
We respect each other and do not tolerate harassment report any concerns about misconduct or hazardous conditions
By working for Walgreens, we are committed to treating each that may threaten the safety of our workplace. Our leadership
other with respect. Each of us is responsible for ensuring that our is committed to the safety, health, and well-being of our team
workplace is free from any type of harassment. Harassment is any members, our business partners, and our customers.
unwelcome conduct that creates an intimidating or offensive work
environment—whether it is of a sexual nature or not. Harassment
I noticed activities that may be creating a safety and
can include physical actions, spoken or written remarks and
environmental hazard, but it is not in my area, and I do
pictures or videos. In any case, harassment is offensive and may
not want to get involved. I do not have to report it, do I?
expose the individuals involved and Walgreens to legal liability.
Therefore, our company will not tolerate harassment of any kind. This is not the best way to handle your concern.
If you experience or witness any act of discrimination or harassment, Safety and the environment are every team member’s
you should report it immediately. You will not face retaliation for “area.” Report your concern to your leadership. If you
making a report in good faith. are uncomfortable doing so, then you should contact
®
the chief compliance officer or the company hotline.
What is harassment?
It includes: We work to protect our company’s assets
• Unwanted physical contact Our shareholders trust us to protect our company’s assets—both
• Display of offensive material physical and intangible. Our physical assets include company
records, computers, products, equipment and the like. We must be
• Threat of dismissal or failure to promote based on sex,
considerate while utilizing these assets, and protect them at all times
race, age, color, national origin, disability, religion or
from loss, damage, theft and misuse. Intangible assets include our
sexual orientation
reputation, the Walgreens brand and any sensitive or confidential
• Conduct of a sexual, racial or other nature that unreasonably
information about our company. Your obligation to protect this
interferes with a team member’s work performance or creates
information continues even after your employment ends.
an intimidating, hostile or offensive working environment
• Bullying, humiliation or intimidation Our company’s intellectual property is an equally valuable asset.
• Threatened or actual violence “Intellectual property” includes copyrights, patents, trademarks,
trade secrets, logos and other intangible industrial or commercial
• Offensive jokes
property. These creations are protected by law, and we are obli-
• Abuse
gated to protect them. Also, keep in mind that—to the extent
permitted by law—the rights to certain intellectual property are
We strive to create a safe and healthy work environment assigned to Walgreens. This applies to any such materials we
Violence and threats of violence are prohibited. Walgreens will not create on our company’s time and expense or within the scope
stand for any threatening behavior, even if made in a seemingly of the duties we perform for Walgreens. ®
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
OCTOBER 2014 11A FOUNDATION OF TRUST for Our Company and Our Fellow Team Members
We are also expected to protect the intellectual property of data and communications to the extent permitted by local law.
our vendors and suppliers, which we may encounter during Walgreens also retains the right to report any suspected or
the normal course of our business dealings. We are able to actual violations of the law to the appropriate authorities.
provide top-quality products because we have cultivated strong
We always need to use our computer and network systems
relationships with our vendors and suppliers. It is therefore
appropriately. This means composing e-mails and other electronic
critical that we maintain those relationships by honoring our
communications professionally. All business communications may
vendors’ and suppliers’ proprietary information and protecting
later be reviewed and interpreted by other parties, so take care in
it from unauthorized disclosure or misuse.
how you compose your thoughts because electronic messages
We safeguard each other’s personal information can be forwarded without your consent. In addition, we may not
In keeping true to our values of trust and integrity, Walgreens post our company’s confidential information to Internet chat
strives to safeguard the private personal information of all rooms, message forums or any other public forum. It is important
team members. During the course of our employment, we each to keep in mind that none of us should have any expectation of
provide sensitive personal, medical and financial information to privacy when using company computers, mobile devices, or
our company. Additionally, some of us may have access to infor- network systems.
mation regarding our colleagues’ salaries, performance reviews,
Individual social networking and blogging ®
disabilities, leaves of absence, prescription drug history, and
Walgreens family of companies recognizes that team members
online purchases (i.e., Walgreens.com, drugstore.com). ®
may use social media to participate in discussions. If an individual
We may only use such data for relevant and appropriate business chooses to identify as a team member of the company or includes
purposes. We must not share this information with anyone inside other identifying information concerning the company while
or outside our company who does not need to know it. If your job participating in social media discussions, they must do so
entails having access to this type of information, you must take within the guidelines of Walgreens policy, which can be found
special precautions to keep the data private in accordance with on Walgreens intranet sites.
Walgreens policies and the law. You can be assured that our
company is committed to keeping our personal information Nothing in the policy is intended to interfere with team members’
secure at all times, whether on paper or in electronic format. Section 7 rights under the National Labor Relations Act. However,
team members should be aware that the improper and inappropri-
ate use of social media can pose tremendous risks to Walgreens
I know that some of the information I work with is
family of companies, including:
confidential. Does this mean I can’t talk about it with
• Disclosure of Walgreens family of companies confidential and
anyone, even other team members?
proprietary information
Confidential means that you should keep the infor- • Infringement of third-party intellectual property rights
mation secure. You should discuss such information • Harassment
only with those who need to know about it for company • Privacy violations
business purposes. If you have any questions about
• Potential damage to reputation and brand
who you can discuss the information with, you should
ask your team leadership. Social media refers to the external online tools used to share
content, profiles, opinions and experiences. Social media tools
include, but are not limited to:
We use our computer systems appropriately ®
• Professional networking sites (e.g., LinkedIn)
While limited personal use of our computer and network systems • Social networking sites (e.g., Facebook, Tumblr)
is acceptable, it should not detract from our work for Walgreens. • Video and photo sharing websites (e.g., YouTube)
We should also never use our company computers or network
• Micro-blogging sites (e.g., Twitter)
systems for inappropriate conduct, such as viewing obscene or
• Personal websites and blogs
sexually explicit materials, spreading profanity or derogatory remarks
• Forums and discussion boards (e.g.,Yahoo! Groups,
or communicating harassing or discriminatory statements.
GoogleGroups, Yelp)
Walgreens reserves the right to block access to inappropriate
sites. Please also be aware that our company may monitor all
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
12 OCTOBER 2014A FOUNDATION OF TRUST for Our Company and Our Fellow Team Members
By working for
Walgreens, we are
committed to treating
each other with respect.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
OCTOBER 2014 13A FOUNDATION OF TRUST
for Our Investors
Own It
Be One
Build Trust
Live It
Be Bold
Love Customers
Be RealA FOUNDATION OF TRUST for Our Investors
We keep honest, accurate financial books and records a Legal Hold Notice could result in disciplinary action up to and
We are committed to making accurate, timely, complete, fair and including termination.
clear disclosures in our reports to the U.S. Securities and Exchange
We avoid conflict of interest situations ®
Commission and other regulatory bodies. It is our duty to ensure
To uphold our company’s reputation, we must be alert to any
that our business records reflect an honest and accurate picture
situations that may create a conflict of interest, whether real or
of our financial standing. For this reason, it is important to keep
perceived. A conflict of interest occurs when there is an actual or
accurate records of receipts, sales, expenses, corporate assets
apparent interference with our ability to make objective business
and corporate liabilities. If you become aware of any accounting or
decisions because of our personal relationships or loyalties. Certain
auditing irregularity, you have a duty to report it immediately so that
situations are more likely to hinder our capabilities in making good
Walgreens can take the appropriate steps to resolve the matter.
judgment calls, and we must take care to avoid those circum-
Furthermore, each of us must cooperate with requests by auditors stances. If you have knowledge about a situation that may be a
or government investigators. If management, auditors or govern- conflict of interest, you should immediately disclose it to the chief
ment authorities request information, we must not conceal, alter or compliance officer or call the company hotline.
destroy any of those requested records. Falsifying business records
can lead to termination and even criminal prosecution. If you become
Conflicts of interest could include:
aware or suspect that our company is under investigation, you are
• Serving as an officer or director of or having ownership
required to involve the chief compliance officer immediately.
interest in another company that does business or competes
with Walgreens
I worked quite a bit of overtime last week. My team • Having a family member that has ownership interest in another
leader told me that I could miss a day of work this week company that does business or competes with Walgreens
if I don’t record last week’s overtime on my timesheet.
• Using Walgreens information for your own personal gain, to
This seems like a good solution because Walgreens
benefit a family member or another company for which you serve
won’t have to pay me for overtime, and I can get some
as an officer or director, or in which you have financial interest
extra time with my family. Is this okay?
• Participating in business transactions for your own personal
No. You need to be paid for all time worked and to gain based on information or relationships developed as a
ensure that all of the records you submit are complete Walgreens team member
and accurate. Team leaders should never place pressure • Failing to disclose that you are closely related to someone,
on their team members to do otherwise. You should report such as a vendor or customer who has sought or is seeking
the situation to HR Shared Services or the company hotline. a financial relationship with Walgreens
• Having a romantic relationship with a team member that you
supervise or that is in your line of supervision
We maintain records in compliance with the law and
company policy
• Having a relationship with a commercial entity that administers
There are many state and federal laws and regulations that govern or delivers Medicare or Medicaid benefits which may include
how we maintain company documents, including business, financial producing, marketing, reselling, distributing, or providing
and healthcare records. Each of us is responsible for ensuring healthcare related products and/or services
that company records are retained and disposed of in accordance
with all applicable laws and regulations, as well as licensing and If a team member wishes to engage in a transaction or activity,
accreditation requirements. Records include information stored in which is, or potentially may be a conflict, the team member must
various formats, including paper, electronic, audio and video. first make a full written disclosure to the chief compliance officer.
®
Following this procedure will ensure that conflict of interest
The length of time to retain records depends on the content and
provisions are not violated.
type of record involved. We are each responsible for maintaining
records in compliance with the Walgreens Enterprise Records Additional common conflict of interest situations are described on
Retention Schedule. If you are a person with knowledge of records the next page, as well as guidelines you should follow in dealing
related to litigation, an investigation or other dispute, you may with them. Please remember that these guidelines also apply to
receive a “Legal Hold Notice.” Each person who receives a Legal members of your “immediate family.” This includes your spouse,
Hold Notice is responsible for retaining original records related to the domestic partner, parents, children, siblings, in-laws and anyone
dispute, as directed in the Legal Hold Notice. Failure to comply with who resides in your home.
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
OCTOBER 2014 15A FOUNDATION OF TRUST for Our Investors
Gifts and entertainment ®
way, you should become familiar with this policy. If you have
any questions, please contact the chief compliance officer.
My supplier offered me tickets to a concert. The Doing business with friends and relatives ®
tickets have a face value of $200, however the supplier Another common conflict of interest can occur when doing
indicates that he only paid $75 for the tickets. Can I business with or while supervising family or friends. We are not
accept the tickets? permitted to directly oversee immediate family members. If you
Acceptance of entertainment from a supplier or are put in such a situation, you should disclose it to your team
vendor is only permissible if the entertainment is offered leader immediately so that reassignments can be made. In addi-
for legitimate business purposes and the provider is in tion, you may not enter our company into a business relationship
with a friend or family member or a business owned or operated
attendance. The face value of the tickets could appear
by a friend or family member without the prior approval of the
excessive and thus would need to be approved by the
chief compliance officer. You must avoid any scenario where
Walgreens chief compliance officer and appropriate
you stand to gain personally from Walgreens-related dealings
business unit Vice President.
or where there may be any appearance of favoritism.
Outside positions ®
Business gifts and entertainment on a modest scale are commonly
We may have outside business interests or employment, as long
used to build goodwill and strengthen working relationships among
as those interests do not interfere or conflict with our current
suppliers and other business associates. Providing or accepting
position and responsibilities for Walgreens. In general, this means
occasional meals, small company mementoes and tickets to
we may not work for or have a significant financial interest in a
sporting and cultural events may be appropriate in certain circum-
competitor, supplier or customer. A conflict of interest may also
stances. However, if offers of gifts or entertainment are frequent
exist if any member of your immediate family is, or has ownership
or of substantial value, they may create the appearance of, or an
interest in, a competitor, supplier or customer of the company.
actual conflict of interest or illicit payment.
We must immediately disclose any such situations to the chief
When deciding on the appropriateness of giving or receiving compliance officer.
a business gift or entertainment, consider:
You may not serve as a director, trustee or officer of another
• the value of the gift or entertainment (should be of minimal value) company, or in a similar paid or unpaid position, other than
• the sum of gifts or entertainment to or from an entity over with Walgreens, without prior approval of the chief compliance
time (normally over a one year period) officer. This rule does not apply to political, non-profit or social
• the suitability of the gift or entertainment given your position organizations, or to residential boards whose activities do not
at Walgreens conflict with our company’s interests.
• the impact of the gift or entertainment on building positive You may join industry or trade associations with the approval
business relations with the recipient and of your team leader, as long as you ensure that any related
• how the gift or entertainment might look to an outsider activities are consistent with our company’s interests.
Team members must always report receipt/giving of gifts using the
gift and entertainment registry form, which can be found within the Some examples of possible conflicts of interest:
policy and at WalNet> Company>Compliance Office>Policies). • A purchasing agent hires his brother-in-law to provide
vending services to the company lunch areas.
Keep in mind that rules governing the giving of gifts, favors and
entertainment to any U.S. or foreign public government official • A team member who is a member of a company employee
(or their family members), or healthcare providers/referral sources selection team fails to disclose that he is related to a job
(or their family members) are much stricter than those set forth candidate whom the company is considering for a position.
in this section. No gifts, favors, or entertainment can be given • A member of team leadership provides paid consulting
to any domestic or foreign government official without prior services on the weekend to a company customer or supplier.
written approval of the chief compliance officer. Gifts to foreign • A team member works part time in the evening for a
businesses cannot be made without prior notice and approval company that makes a product that competes with the
by the chief compliance officer. products of his full time employer.
Additional information regarding gifts and entertainment can be • A store team member has secondary employment as a
found in our Gift and Entertainment Policy. If your role involves pharmacy technician at another retailer.
providing or receiving business gifts or entertainment in any
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to compliance@walgreens.com.
16 OCTOBER 2014You can also read
