How We Do Business
We strive to be a good public citizen.
Partnering With Responsible Suppliers and Business Partners
We pride ourselves on the quality and integrity of our products and only partner with suppliers that share our values and our commitment to ethical and responsible business practices. We will not knowingly do business with suppliers or business partners who employ individuals under the local minimum working age, engage in human trafficking, employ forced labor or use corporal punishment to discipline employees, regardless of whether the practices are permitted by local law. The L Brands Supplier Code of Conduct more completely outlines our standards for suppliers.
We act responsibly with respect to the environment. We comply with all applicable environmental laws and strive to minimize our impact on the environment.
We strive to sell merchandise that complies with all applicable product safety laws.
International Trade, Fair Dealing and Fair Competition
We comply with all laws that govern international trade, including laws intended to prevent money laundering and cooperating with unsanctioned boycotts and laws that regulate imports and exports.
We compete vigorously but fairly and ethically. It is important that we follow all applicable competition laws and avoid practices that interfere with fair and open competition. This means, for example, that you must not enter into any agreement (whether formal or informal) with our suppliers, vendors or other external parties to restrain trade. Agreements cannot include:
- fixing prices in our stores or those of our competitors; or
- boycotting certain vendors.
Avoid discussions with external parties about these topics, even if they suggest it or if it comes up at a trade event. Global competition laws are complex, and the penalties for violations are severe - for both companies and individuals. Partner with the Office of the General Counsel for guidance.
We do not engage in unfair or fraudulent business practices either directly or indirectly through an external party to help L Brands’ business or to hurt a competitor’s business. Do not be dishonest, misrepresent or use other illegal or unethical means to learn competitors’ trade secrets or obtain confidential information about other companies.
We advertise honestly and follow applicable advertising laws and standards. Our advertising and marketing must not be deceptive, unfair or contain misrepresentations. Be honest and accurate when discussing our merchandise and services. In addition, don’t say anything untrue, unfounded or misleading about our competitors, their merchandise or their services.
Bribery and Corruption
We are committed to using honest and ethical business practices. That means that we do not tolerate bribery or corruption anywhere we do business worldwide. We follow all applicable anti-corruption laws.
Among other things, anti-corruption laws and company policy prohibit all instances of offering, giving, authorizing, accepting, receiving, requesting or promising a bribe or anything of value with the intent to improperly influence someone or gain an improper advantage.
Additional review may be required to ensure that external parties are reputable and the contract or agreement with them must include appropriate anti-corruption provisions. It’s important to remember we cannot ask an external party to take any action we are prohibited from taking ourselves.
If you think you will interact with government officials or have questions about anti-corruption, seek guidance from the Office of the Chief Compliance Officer, or refer to the L Brands Global Anti-Corruption Policy.
Conflicts of Interest
We avoid conflicts of interest. A conflict of interest is a personal activity, interest or relationship that interferes (or may appear to interfere) with an associate’s objectivity on behalf of the company. A conflict of interest can create a situation that makes it difficult to do our work effectively or harms the company’s business. Your own actions, financial interests or relationships may create conflicts of interest. Unless disclosed to and authorized by the company, you cannot have and must avoid conflicts of interest.
Conflicts of interest can be created by anyone with whom you have a close personal relationship. For the purposes of this policy, a close personal relationship includes your spouse, partner, relative (by blood, marriage or adoption), person you’re romantically or intimately involved with or others you live with. Don’t allow a close personal relationship or friendship to create an uncomfortable or unfair work environment or negatively affect job performance. In addition:
- You may not supervise or report to anyone with whom you have a close personal relationship.
- You may not oversee, review, or influence the job evaluation, pay or benefits for anyone with whom you have a close personal relationship.
A financial conflict of interest can arise when your actions are influenced, or appear to be influenced, by possible financial gain. The gain could be for 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 competitor (other than certain investments in a publicly traded company).
- You receive money, services or favors from anyone other than the company for doing work for the company.
The company owns the design, concept, invention, formation or similar creation that you develop while working with the company. You may not compete with L Brands while employed by the company including:
- taking for yourself or directing others to take any business opportunity discovered through your work on behalf of the company;
- working for, or on behalf of, a competitor unless approved by the company; and
- serving as a director, manager or advisor of any company or organization engaged in a business that competes or plans to compete with L Brands, unless approved by the company.
The company must know about potential conflicts of interest as and when they arise. Contact the Office of the Chief Compliance Officer if you:
believe you have a conflict of interest or a financial conflict of interest;
want to get involved in an outside business or job opportunity while working with the company; or
want clarification of our conflicts of interest policy.
Business Gifts and Hospitality
We are careful when giving or receiving business gifts or hospitality. Avoid making, or appearing to make, business decisions based on unethical influences. All exchanges (giving or receiving) of business gifts or hospitality must comply with applicable laws and company policy.
Gift examples include cash or cash equivalents (gift cards, gift certificates, rebates and discounts), merchandise, personal favors, transportation, travel or vacation accommodations or business or employment opportunities. Hospitality includes business meals and tickets to sporting events, concerts, theater, golf and other events.
Examples of allowable gifts and hospitality include:
- business meals provided they are not extravagant;
- an occasional event if the associated expense is reasonable, customary and culturally appropriate, the external party will attend with you, and you have notified your manager (such expense is considered a gift if the external party does not attend with you); and
- gifts valued at USD50 or less.
Some types of gifts and hospitality are always prohibited. You may not give or receive (unless noted as an exception below):
- cash or cash equivalents;
- gift cards redeemable for our company merchandise;
- lai see/red envelopes (red packets containing cash given during holidays or special events like Chinese New Year). The company does not offer lai see/red envelopes to external parties; however, associates in our Asia offices may accept one lai see/red envelope valued at USD15 or less from a person, company or vendor group outside of L Brands for a single holiday or event.
- anything as “quid pro quo” (part of an agreement to do anything in return for the gift or hospitality);
- any solicited gift;
- gifts valued at more than USD50;
- perishable gifts (food, flowers, candy, etc.), which must be shared with other associates or donated to a legitimate charitable organization (for donations, contact Community Relations);
- a gift that is pre-approved in writing by the Office of the Chief Compliance Officer;
- gifts or hospitality that would violate other provisions of the Code or applicable law; and
- anything that would cause other people to violate their employer’s standards.
Any gift or hospitality you give must be accurately disclosed in detail on a travel and expense reimbursement report.
Anything you give to government officials must comply with all applicable laws and the terms of the company’s Global Anti-Corruption Policy.
Interactions with Governments
We are truthful and straightforward with government entities. If you are contacted by a government or regulatory representative and asked to provide information or submit to an inspection as a representative of the company, inform your manager immediately. Never knowingly provide false or misleading information to any government official or representative or destroy records related to an investigation. Similarly, never direct or encourage another associate to do so.
We believe that involvement in political activities in the communities we serve is important to our 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 pre-approve any use or commitment of money or other company resources for political activities on behalf of the company.
Getting involved in the political process is entirely your own personal and voluntary decision. If you choose to participate, you can do so only on your own time using your own money or resources. Unless authorized by the company, you are not acting on behalf of it and you cannot use company resources or services for your personal political activities.
The company communicates with government officials and agencies around the world about public policy issues that may affect our business. Because lobbying is strictly regulated at all levels, the Office of the Chief Compliance Officer and the Government Affairs department must pre-approve lobbying activities on the company’s behalf.
We are committed to doing well to do good. To be fair and consistent, the Office of the Chief Compliance Officer and Community Relations must pre-approve all charitable contributions committed to or made with company assets on behalf of L Brands, a brand or a particular function. This includes money, product and the use of our space or resources, to list a few. We will not give charitable contributions as a condition of or in order to improperly influence a business decision.
Check with your manager before giving business gifts and hospitality on behalf of the company.
Make business decisions free from improper influences.
Consult with the Office of the Chief Compliance Officer and Community Relations before committing company assets for a charitable donation.