Commitment and Accountability

We follow the basic guidance of our Code of Conduct: Do what’s right.

Leading with Values

We are committed to living by our values, doing what’s right and acting with integrity everywhere we do business regardless of the circumstances. Each of us has the responsibility to understand and follow the Code and other company policies. We follow the law in all countries where we do business. Violations will result in disciplinary action up to and including termination of employment.

Managers and senior leaders have additional duties:

  • lead by example;
  • ensure your teams understand and follow the Code and complete all training;
  • create an open environment so associates can ask questions and raise concerns;
  • actively support and follow the no retaliation policy;
  • take quick corrective action where appropriate; and
  • get help from Human Resources or the Office of the Chief Compliance Officer when needed.

Open Door Policy

We encourage you to talk openly with us about work-related ideas, questions, problems and concerns so they can be resolved. If there is something about your job or the company that concerns you, or you see something that you think is wrong, we encourage you to communicate it to your manager, next level manager, Human Resources partner or the Ethics Hotline.


  • Use our open door policy and talk to the appropriate partner; and
  • If you are uncomfortable talking to your manager, next level manager or Human Resources partner, or you feel your questions or concerns have not been resolved, you can contact the Office of the Chief Compliance Officer or the Ethics Hotline. See Contacts section.


Our Open Communications Advantage

We are one of the world’s best specialty retailers with a tradition of success built primarily on agility and teamwork. We believe we are more productive, more efficient and better able to deliver on our brand promises when our associates have a close, collaborative relationship with one another. 

Over the course of our long history, our associates have grown their careers and the business on a platform of collaboration and cooperation and by retaining the power to work freely and directly with each other. This collaborative spirit is the foundation of our enduring success. We pledge to maintain this collaborative atmosphere.

As part of our commitment to you, associates are assured:

  • equal opportunity and treatment;
  • career-advancement opportunities;
  • equitable and competitive wages;
  • excellent benefits;
  • open and honest communication; and
  • a rewarding and safe work environment.


Our open door policy has always meant associates could address issues honestly with anyone – at any level.

Getting Help and Sharing Concerns

The Code cannot anticipate every situation. But, most problems can be avoided by checking the Code, using good judgment and asking for help.

No Retaliation

In no event will any associate be subject to reprisals, retribution or any career disadvantage for raising a concern. We strictly prohibit retaliation for reporting under the Code. Anyone who retaliates (or tries to retaliate) will be subject to disciplinary action up to and including termination of employment.


     If you’re not sure if something raises an integrity question, ask yourself:
  • Does it align with our values?
  • Is it the right thing to do?
  • Is it legal and am I authorized to do it?
  • Is it consistent with our Code and other policies?
  • Is it professional and businesslike?
  • Would I want to see it reported in the media?

What Happens When Someone Contacts the Ethics Hotline?

The Ethics Hotline is operated and staffed by an outside company. When you raise a concern through the Ethics Hotline, it’s only shared with the departments that need to know (such as Human Resources, Legal, Compliance & Ethics or Loss Prevention/Safety Services) for prompt and timely follow up and action. Our investigations process includes:

  • conducting a timely and fair investigation by a qualified person;
  • documenting and tracking progress of the investigation;
  • ensuring due process;
  • achieving a reasonable conclusion based on evidence collected; and
  • implementing appropriate options for corrective actions.

You can contact the Ethics Hotline by telephone (link to Contacts below) or online at If you choose to telephone the Ethics Hotline, a live operator will answer and ask you a series of questions about your concern. Interpreters are available. If you make a report through the Ethics Hotline website, it will prompt you for more information about your concern.