Our Company and You
The relationship between you and the company is one of trust.
Protecting Business Information
Our business information is a valuable asset, and we protect it. Business information includes confidential, proprietary, privileged or secret information. It can be written or electronic, or it can be information you know or learn that is not formally documented. Some examples of business information are:
- trade secrets;
- intellectual property;
- sales figures, including comparable stores sales;
- information about our ideas and know-how, processes and procedures;
- unannounced product launches and promotions;
- marketing and images;
- private information about customers or associates such as credit card numbers or banking information; and
- vendor lists.
Business information must not be shared with anyone without a legitimate business or law enforcement reason and in accordance with all applicable laws and regulations. Do not share business information with anyone outside the company unless authorized to do so and in accordance with company policies.
The company’s business information is classified according to level of sensitivity. Certain levels of business information may have safeguard requirements for collecting, handling, storing, transmitting, accessing, securing, retaining and destroying. See the company’s Information Security Policy for details.
You are responsible for keeping the business information you work with secure even after you leave the company. In no event should you use our business information for personal benefit or gain, for either yourself or another person or company, even if you are no longer working for the company.
We do not use proprietary or non-public business information of others without permission. You must respect the confidentiality of other companies’ business information. Do not bring business information from another company to L Brands. Do not intentionally misrepresent or use other improper means to obtain another company’s business information. Respect other associates’ obligations to protect the confidentiality of former employers. Do not download, distribute, keep or produce unauthorized copies from books, magazines, newspapers, films, videos, music recordings, websites, products or computer programs.
If you are not sure about sharing or safeguarding business information, check with your manager.
In addition to protecting business information, we comply with insider trading laws. Inside information is information (about our company or another company) that is not public and is also material – that is, a reasonable investor would consider the information important in deciding whether to buy, sell or hold stock. Company policies and the law strictly limit what we can do while we hold inside information.
Material information could include:
- earnings and other financial results;
- sales and comparable stores sales data;
- inventory levels;
- significant gains or losses of business;
- plans for a company acquisition, sale or merger;
- management changes; and
- business strategies.
You are prohibited from trading L Brands stock and other securities while you possess material, non-public information about the company. This applies to all associates of L Brands as well as their families and entities they control. Trading includes buying, selling and shifting account balances, investment allocations and investment directions in company plans.
Do not share inside information with anyone unless they have a business need to know, and never share inside information outside of L Brands. Refer to the company’s Insider Trading Policy for additional details.
Financial Integrity and Accurate Records
We ensure that company records are accurate, timely, and fairly and completely reflect actual transactions and events. Our shareholders, customers, fellow associates, the public and government entities are entitled to accurate and truthful business records. We ensure that we are using company assets appropriately, and we are properly reflecting all expenditures, transactions, assets and liabilities in our financial records. It is each associate’s responsibility to create accurate and complete records and follow internal controls. If you are unsure about what is required, talk to your manager.
We also ensure that we follow company policy and applicable law for retaining, storing and destroying company records, information and electronic data. Each of us is responsible for information and records under our control. We must be familiar with the recordkeeping procedures that apply to our jobs. Information and records may only be destroyed in accordance with the company’s Records Retention Policy and never in response to or in anticipation of an audit, investigation or lawsuit.
Audits and Investigations
We cooperate fully with internal and external audits and investigations of possible violations of company policies. Do not destroy or alter any documents that may be requested as part of an investigation or audit on behalf of the company. Do not lie, make intentionally false or misleading statements, or fail to provide accurate information to internal or external auditors or investigators, or cause others to do so.
Use of Company Property
We use work time and company property for the benefit of the company. Company property includes our premises, information, equipment, documents, data, software, technology assets, supplies, merchandise, samples and support services. On occasion, we can use company property for limited, incidental personal use. Do not be careless or negligent with company property. In addition, do not participate in theft or unauthorized removal of company property or the property of others. This includes removing supplies, samples, tools or equipment without authorization.
Improper use of company property can expose the company to legal or financial risk. For example, follow the company’s Information Security Policy when downloading software and protect computer passwords and information stored on our systems.
Unless otherwise regulated by applicable law, you should have no expectation of privacy on our premises or while using our systems or networks. The company retains the right to search any and all company property at any time, including, but not limited to offices, desks, email, instant and mobile messages, voicemail and any other company-provided communications and computing devices, services and applications. Please be aware that your activities, business or personal, carried out on our premises or using our systems or networks may become known to us.
You are not restricted from sharing information about your own employment with others or cooperating with any fair employment practices agency. Nor are you restricted from reporting possible violations of law to any government agency or entity or making any other disclosure that is protected under applicable law or regulation. You do not need prior authorization from the company to make such reports and you are not required to notify the company that you have made such reports.
We safeguard the company’s trademarks and intellectual property because they are some of our most valuable assets. We all have the responsibility to protect these assets, including reporting counterfeit merchandise or the improper distribution of our products by others. Our intellectual property includes legally protected creations, such as copyrights, trademarks, patents, brands, design rights and trade secrets. It also includes inventions, designs, know-how and innovations that you conceive or devise when they:
- arise out of or are suggested by the company’s business information or any work you performed for the company;
- result from your use of the company’s time, facilities or assets, or
- otherwise arise from your work on behalf of the company.
For the company’s protection as well as your own, it is critical to show proper respect for the laws governing copyright, fair use of copyrighted material owned by others, trademarks and other intellectual property, including the company’s own copyrights, trademarks and brands. If you are unsure about your proper use of our intellectual property, check with your manager or the Legal department.
Create and maintain accurate, complete and fair business records.
Protect L Brands’ business information.
Respect intellectual property – both the company’s and others.
The company releases information related to its financial performance and position on significant issues and strategies only through associates who are authorized to speak publicly on behalf of the company.
The company will respond to investors and the media only through a designated spokesperson. If you’re ever asked to make a comment to investors or the media on behalf of the company, politely direct the request to Communications. See Contacts section.
All requests to speak externally as a representative of the company at occasions such as industry conferences, education presentations and panel discussions must be approved by Communications. Participation in case studies, white papers, other published pieces or award entries also must be pre-approved. Requests for use of the company’s logos or inclusion of the company’s name in press releases, on websites or at trade shows by external parties, including the media, must be referred to Communications.
Using Digital Media
We use digital media responsibly. Customers, competitors and associates all over the world can easily access information posted on digital media channels. Use common sense when posting and remember that our company policies apply even if your online activities are not related to our business. For example, just as you wouldn’t discriminate against or insult a customer or fellow associate in person, it is unacceptable to do so online.
Don’t post business information, including the company’s financial position, sales trends, forecasts, future product launches and promotions, vendor lists, private information about customers or other associates such as credit card numbers or banking information or other information that could compromise your safety or that of others. Respect all copyright and intellectual property laws.
Solicitation and Distribution
There are times when we all feel the need to contribute to something we believe strongly in. But it’s important to protect our associates’ work activities and relationships with business partners from those who promote personal causes, products or viewpoints. That’s why we have guidelines for solicitation of money, time or resources, or distribution of literature. These guidelines apply equally to associates who are soliciting and those being solicited. Unless you are authorized by the Office of the Chief Compliance Officer and Community Relations:
- Do not solicit during working time.
- Do not distribute literature during working time or in working areas. Cafes and break areas are not considered working areas. Rest, meal and other authorized breaks are not considered working times.
- Do not use company telephones or letterhead to solicit other associates, vendors or business partners or to distribute literature of any kind.
- Do not solicit vendors or business partners on behalf of the company. Never solicit a vendor or business partner if there is a stated or implied understanding, suggestion or expectation that supporting a personal cause or charitable effort will benefit the vendor’s or other party’s business relationship with the company.
In addition, please be aware that:
- Noncompany-sponsored activities are not permitted on company property, even in nonworking areas or during nonworking hours. Examples include:
- book fairs, magazine drives, candy sales, cookie sales, gift-wrap sales, flower sales or other outside promotional sales; and
- posting or advertising items or services for sale.
- Nonassociates are prohibited from soliciting or distributing literature on company property.
Occasionally, the company may solicit associates as part of a company-sponsored campaign for organizations supported by L Brands, such as United Way or Pelotonia. Any communications, solicitation or promotion as part of a company-sponsored campaign to associates can only be made in accordance with company policies and must be approved in advance by Community Relations and Communications.
Refer media inquiries for comments on behalf of the company to Communications.
Use digital media responsibly.
Maintain a workplace consistent with company policies.