Code of Business Conduct and Ethics
Amended and Restated on:
November 19, 2014
At Nordstrom, we believe in hiring great people to provide the highest levels of service to our customers. It has always been our practice to conduct ourselves with the highest standards of ethical behavior when it comes to taking care of our customers, interacting with each other and protecting our company's interests.
This document, the Nordstrom Code of Business Conduct and Ethics or ‘Code of Conduct,' covers a wide range of business practices and procedures. It serves as a framework to help you understand the core philosophies of Nordstrom business and to guide you as you make on-the-job decisions.
As a Nordstrom employee, you are expected to comply with the Code of Conduct and any other applicable laws, regulations, expectations, policies, procedures and guidelines that apply to your position. Failure to do so may result in disciplinary action up to and including termination of employment.
USE GOOD JUDGMENT IN ALL SITUATIONS
We expect you to use good judgment when it comes to taking care of our customers and in your interactions with other Nordstrom employees and vendors. The following pages contain important information and guidelines we have created to help you use good judgment. When we talk about using good judgment, it's really about how we treat our customers, how we treat each other and how we do business. If you have questions about what using good judgment means, talk with your manager, Human Resources or store manager.
OUR DOOR IS ALWAYS OPEN
We value and encourage open and honest discussion, which is why our Open Door philosophy is such an important part of our culture. Clear, open, honest, and respectful communication is essential. We want you to feel confident in discussing any issue with the person or people directly involved.
The following individuals are among those who can help you with any questions or concerns you may have:
- Your manager
- Human Resources
- Store manager
- Diversity Affairs
- Loss Prevention manager
- Regional manager
You can find contact information for these individuals through Outlook or any store operator. You may also use the AskHR feature on mynordstrom.com or call 855.NORDYHR (667-3947).
In the event you become aware of illegal or unethical behavior, immediately report it to one of the above individuals. You may also anonymously report your concerns by calling .888.832.8358 or by visiting ethicspoint.com. Please keep in mind that while you have the option to make your report anonymously, we will need sufficient details about your concern in order to adequately investigate it and take any appropriate action.
RETALIATION IS NOT PERMITTED
We do not permit any retaliation of any kind against employees who report possible misconduct, raise a concern regarding a violation of this Code, participate in an investigation or otherwise engage in legally protected activity. Anyone who retaliates will be subject to disciplinary action, up to and including termination of employment. If you feel you have been subject to retaliation, immediately contact Human Resources or a manager
WE TAKE CARE OF OUR CUSTOMERS
OUR CUSTOMER SERVICE COMMITMENT
We have a long-standing commitment to provide our customers with the best possible service every time they shop with us. We do everything we can to make them feel welcome, respected and comfortable. Our focus is and always will be to provide our customers with a great experience and to continually maintain a strong and lasting relationship with them. We ask that you always use good judgment and treat customers in the manner that you would like to be treated.
Personal information includes names, mailing and email addresses, phone numbers, dates of birth, Social Security numbers, prosthesis information, purchase and return information, and cardholder or other account data or Personal Book information or other customer lists.
- Access and use personal information only when appropriate for authorized Nordstrom-related purposes.
- Ensure you capture and record customer information accurately once you have the customer's permission.
- Use Personal Book in an ethical and appropriate manner; only enter accurate information that is voluntarily given to you by the customer specifically to enter into Personal Book, another preapproved data device or other applications.
- Contact your manager to learn to properly use and manage Personal Book.
- Return all customer information in any format that you have in your possession should your employment with Nordstrom end for any reason. You may not retain or use any customer information you gained while employed at Nordstrom for any purpose.
- Comply with all Nordstrom policies and procedures for handling personal information and access to systems to ensure that we meet our legal obligation, protect our reputation and protect our investment in proprietary information.
- Report individuals who seem out of place or unfamiliar to Loss Prevention or Building Security
- Verify with Strategic Sourcing or your manager that an appropriate contract is in place before sharing or releasing any information to an approved Nordstrom third party service provider
Remember Not To:
- Enter customer information into any unauthorized personal address book, physical or electronic document or list, cell phone or other device.
- Remove printed customer lists, forms or other information obtained directly from our customers, Personal Book, or any other Nordstrom source from the store.
- Download or remove any customer information from Nordstrom applications, salesperson "Apps" or Nordstrom enabled systems.
- Share or release any customer information to unauthorized third parties (via social media, vendors, insurance companies, investigators, friends or family members of the customer).
If you witness or become aware of or suspect a situation where sensitive, personal or confidential information is or may be lost, stolen or disclosed outside the company in an unauthorized manner — whether it's deliberate or accidental — immediately notify your manager, Human Resources or Loss Prevention.
For more information or further assistance please visit the Privacy site on mynordstrom.com, Nordnet, or contact the Privacy Department at email@example.com
Technology is an important part of how we serve our customers and we encourage you to leverage the technology available to you. It is also important you are aware that the Nordstrom technology tools you use to perform Nordstrom work - including Nordstrom-provided devices or applications that allow you to connect to the Nordstrom network or access data from your personal device - are company resources and are provided for business purposes only. All employees are expected to use good judgment when using technology, including but not limited to:
• The Internet.
• Social networking/media tools.
• Software and software tools such as Point of Sale (POS) devices, mobile applications and Personal Book.
• Communication methods such as email, texting, secure e-mail and voice mail.
• Approved personal or Company issued devices, including smart phones and other mobile devices that access the Nordstrom Network.
• Private web-based email accounts such as Hotmail, Gmail, Yahoo, etc. that employees may access through company-provided technologies.
• Information that is retrieved and stored in company-owned hard drives or in temporary intranet files.
You may only use authorized tools and processes to store personal information. Should you have questions about what is considered appropriate, contact the Privacy Department at firstname.lastname@example.org.
We have a legitimate business need (including to ensure compliance with Nordstrom policies, including this Code of Conduct) to access, review, copy, move or delete the content and information carried by these technologies at any time and without notice, and by using these technologies, employees understand and agree that Nordstrom retains the right to do so. Employees are permitted to use these technologies for limited and reasonable personal use provided such use does not interfere with their duties. However, any such personal use is governed by all applicable Nordstrom policies including this Code of Conduct. Employees should not expect privacy when using these resources.
You are representing Nordstrom when using these resources and are expected to use them in a manner that reflects our professional and customer service standards.
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It is critical for you to understand that all Nordstrom guidelines also apply to the use of technology. Whether it is Nordstrom-owned or your own personal technology, these guidelines include, but are not limited to our expectations regarding harassment, discrimination, retaliation, sexual harassment, violence in the workplace, privacy and company information. Discriminatory, unethical and/or inappropriate behavior when using these technologies or social media will not be tolerated.
Specific Information Security and Privacy standards, guidelines and resources have been published on Nordnet and other internal sites regarding the appropriate use, protection and control of Nordstrom information and technological resources, as well as the retention of email and other records. Please ensure that you are familiar with these standards and expectations, because users of these resources will be held accountable for knowing and following these standards.
Nordstrom manages our business records and information, both written and electronic, as part of our normal course of business in compliance with Nordstrom's policies and applicable regulatory and legal requirements.
Technology Use While Driving
Nordstrom expects employees to exercise good judgment at all times including when driving on company time or conducting business while driving. Cell phone or other types of mobile device usage while driving can increase the likelihood of an accident causing injury to oneself or others. Use of a cell phone or other mobile devices in any capacity while driving is not required by Nordstrom. Nordstrom expects employees to avoid unnecessary use of such devices while driving, even where use is not restricted by law. To the extent possible, employees should only make and receive calls when safely parked. When an employee must make a call while driving, Nordstrom expects employees to use hands-free devices, keep the calls brief and exercise extreme caution.
If you use social media accounts to talk about Nordstrom or its products, we expect you to use good judgment and follow these additional guidelines:
- Only specifically approved employees who have completed Nordstrom Privacy training can use Nordstrom-owned social media accounts, the Nordstrom logo, and Nordstrom.com photos and video, and blog on behalf of Nordstrom. Please contact the Social Media team to learn more.
- Disclose your Nordstrom affiliation on your personal social bios and note that the views expressed are your own.
- Don't post sensitive, private or confidential company information (e.g., unannounced product launches and promotions, internal sales results, company strategy, pricing information or comparisons).
- Never give out personal customer or co-worker information (e.g., personal addresses, phone numbers, or credit card information) or add information you receive from social networking to Personal Book or other Nordstrom tools.
- Respect every customer's privacy; do not share details about their visit. This expectation applies equally to private and public figures
- Do not post pictures of customers or co-workers without their permission.
- Do not post information about customers or co-workers that could be perceived as harassing, retaliatory, or discriminatory in nature.
- Know that you may be legally responsible for the content you post. Respect brands, trademarks and copyrights.
- Comply with the Endorsement Guidelines if you are receiving benefits or incentives for posts on social media. Even if you are not receiving a benefit, you must still disclose your Nordstrom affiliation and note that the views expressed are your own if you comment on social media about Nordstrom or its products; people need to understand you work for the company and that may influence your views.
- Ensure your posts do not create a real or perceived conflict of interest; for example, do not accept direct advertising or compensation from competitors.
- Get approval from the Privacy Department for contests or promotions directed toward Nordstrom customers or employees.
Nordstrom pays for all time worked, which includes approved social media activities on behalf of Nordstrom, even if it is just a few minutes.
Our ultimate objective is to make sure our customers are satisfied with their purchases. We stand behind our goods and services and want customers to be satisfied with them. We'll always do our best to take care of customers. Our philosophy is to deal with them fairly and reasonably; we hope they will be fair and reasonable with us as well.
When making returns, we ask that you always use good judgment. As you serve customers, treat them the way you would like to be treated. Respect, dignity and the best possible service should remain at the forefront of every decision you make. We have a zero tolerance policy when it comes to discrimination of any kind. If you are working with a customer and have a question about not accepting a return, please contact your manager or store manager.
In our continuing effort to ensure employees are being compensated properly, the following procedures need to be followed when Full-line store employees ring returns, exchanges and rewrites:
If the customer has an exchange to make, either in style or size, an even exchange on the original salesperson's employee number should be rung. If, however, the customer chooses different items and needs or requests assistance, the original salesperson should be charged for the return, and the new salesperson assisting the customer is given credit for the sale.
• At no time should a salesperson ring a return on his/her employee number for merchandise he/she did not originally sell.
WE TREAT EACH OTHER WITH RESPECT
EQUAL EMPLOYMENT OPPORTUNITY PHILOSOPHY
Our people are the foundation of who we are as a company. Attracting, hiring and retaining diverse talent enables us to be more innovative and better serve our employees, customers and communities.
We uphold our tradition of valuing our employees and are an equal opportunity employer committed to recruiting, hiring, training and promoting qualified people of all backgrounds, regardless of sex; race; color; creed; national origin; religion; age; marital status; pregnancy; nursing mother status; physical, mental or sensory disability; sexual orientation; gender identity or expression; military or veteran status; or any other basis protected by federal, state and/or local laws.
Please contact Human Resources if your ability to perform the expectations of your job is impacted by your pregnancy, disability, or religion. We will partner with you to determine if there is a reasonable accommodation we can provide, such as an accommodation to enable you to perform the essential functions of your job or a leave of absence. If you are unable to perform the essential functions of the job, even with a reasonable accommodation, we encourage you to ask Human Resources for support in identifying other available positions at Nordstrom for which you may be qualified or any other reasonable accommodation options. Information is also available on mynordstrom.com.
CREATE A POSITIVE WORK ENVIRONMENT
WE DO NOT PERMIT HARASSMENT OR DISCRIMINATION
At Nordstrom we strive to create an inclusive, supportive environment. To that end, we do not permit discrimination or harassment of any kind. This includes discrimination or harassment based on sex; race; color; creed; national origin; religion; age; marital status; pregnancy; nursing mother status; physical, mental or sensory disability; sexual orientation; gender identity or expression; military or veteran status; or any other basis protected by federal, state and/or local laws. Any unwanted and/or unwelcome behavior — whether it is physical, verbal, in person, written, or through email, social media, or other technological means — that creates an intimidating, hostile or offensive environment is prohibited.
If you experience or observe any behavior you believe is discriminatory or harassing, you must report it immediately to Human Resources or any manager. Complaints will be investigated as promptly and as confidentially as is reasonable and Nordstrom will take corrective action when appropriate, up to and including termination of employment.
SEXUAL HARASSMENT IS A SERIOUS MATTER
We do not permit harassment of any kind and that includes sexual harassment by or against employees, vendors or customers. Sexual harassment is unlawful and may include threats or insinuations that an employee's refusal to submit to sexual advances will adversely affect that person's employment, evaluation, wages, advancement opportunities, assigned duties or any other conditions of employment or career development.
Sexual harassment can also be sexual advances, requests for sex, or verbal or physical conduct of a sexual nature that creates an intimidating, hostile, humiliating, or sexually offensive work environment. While it is impossible to list all types of behavior that could be sexual harassment, some examples are:
• Unwanted and/or unwelcome sexual comments, advances, flirtations or propositions.
• Verbal abuse of a sexual nature, including sexually oriented jokes or comments or questions regarding one's sexual experience, activity or prowess.
• Comments about an individual's sexual attractiveness.
• Display of sexually suggestive objects or pictures or making sexually suggestive gestures.
Nordstrom prohibits these acts and any other acts that constitute sexual harassment. For additional information on this topic, visit mynordstrom.com or see the postings in your workplace.
KEEP OUR WORKPLACE FREE FROM VIOLENCE
As part of our goal to provide a safe environment for our employees and customers, Nordstrom prohibits any kind of threat, intimidation or act of violence in the workplace.
Threats — either direct or implied — may be in the form of words, gestures, phone calls, emails, text messages, social networking/media messages or posts, drawings, etc.
Intimidation, threats and violence may also arise out of non-work situations, for example, domestic abuse or relationship breakups. These situations may impact our workplace, including your safety or the safety of coworkers, customers or vendors. Nordstrom is committed to working with employees who are victims of domestic violence to prevent abuse and harassment from occurring in the workplace. Nordstrom is also committed to managing the risk these situations may pose to other employees and customers.
As an employee, you play a critical role in maintaining a culture of safety. You must immediately notify Human Resources or a manager of any threats, intimidation and/or acts of violence (including threats to harm oneself) as soon as possible so that we can evaluate and implement appropriate safety procedures at the store to help ensure a safe and secure workplace. Nordstrom will address any threats or concerns as promptly and confidentially as is reasonable. Remember, we cannot take steps to help create a violence-free workplace unless we are aware of situations that could lead to the risk of violence in the workplace. You are also responsible for:
• Cooperating with an investigation into any risk of violence in the workplace.
• Providing Human Resources with a copy of any temporary or permanent restraining/protection orders that identify you, any Nordstrom employee or any Nordstrom location as protected.
• Not bringing potentially dangerous items — including weapons — into the workplace with you. Weapons of any kind are not allowed in our workplace for any reason.
Nordstrom cares about the well-being and safety of our employees. Resource information for those that may be involved in domestic abuse situations can be found on mynordstrom.com
We all share responsibility for our own safety and the safety of our coworkers and customers. You are responsible for making safety a priority and performing your duties according to general safety practices outlined in our Injury and Illness Prevention Program. You are also responsible for complying with all job-specific safety best practices provided to you by your manager and/or store manager. We will communicate safety performance openly with you, and we expect you to inform the appropriate manager anytime you come across a situation or condition you believe might jeopardize your safety or the safety of others. Failure to follow safety practices or to report safety violations may result in discipline up to and including termination of employment.
DRUGS, ALCOHOL AND TOBACCO LIMITATIONS IN THE WORKPLACE
We believe Nordstrom should be a safe, efficient and productive place to work. For that reason, employees must work free from the effects of drugs and alcohol.
Nordstrom prohibits having, using, or being under the influence of drugs (including drug paraphernalia) during your shift (including meal and rest periods), while attending company events, or while otherwise representing the company. For the purposes of this policy, "drugs" includes: (1) any illegal drug; (2) any over-the-counter or prescription medication that is obtained illegally or is used contrary to its prescribed dosage or purpose; and (3) marijuana.
In addition, Nordstrom also prohibits employees from consuming or being under the influence of alcohol during their shift (including meal and rest periods), while attending customer events, or while otherwise representing the company. However, Nordstrom employees of legal age are permitted to order and consume alcoholic beverages in Nordstrom Restaurants on their days off or after their shift ends.
If Nordstrom determines that an employee has violated this policy or if an employee is perceived to be under the influence of drugs or alcohol during a shift (including meal and rest periods), while attending customer events, or while otherwise representing the company, Nordstrom may take disciplinary action, up to and including termination of employment.
Some areas of our company require employees to successfully complete drug and/or alcohol testing. Testing positive for drugs and/or refusing to cooperate with required testing, or failing to comply with applicable drug and alcohol guidelines, will result in disciplinary action up to and including termination of employment.
Should you have a substance abuse issue our Employee Assistance Program is available to provide confidential support and appropriate resources. These resources are available on mynordstrom.com. Talk with Human Resources if you need time away from work to attend a rehabilitation program. However, please also be aware that if a problem with your job performance exists, we will address it with you, regardless of any substance abuse issue you may have.
Finally, Nordstrom is a smoke-free environment. Nordstrom employees are prohibited from smoking of any kind. This includes the use of lighted, battery-operated or electronic smoking devices or delivery systems on Company property.
THEFT AND OTHER CRIMINAL BEHAVIOR
Criminal behavior and theft of Nordstrom merchandise, money, sales or other property is prohibited. It affects us all — diminishing our ability to meet our customers' needs and reducing our profitability.
Nordstrom has a formal loss prevention program. This program uses a variety of resources — including Loss Prevention agents, camera and video systems, special tags, fixtures, technologies and other means — to prevent shoplifting, apprehend shoplifters and prevent crime and employee theft. Public areas of the store, Employee Only areas and offices may be monitored at any time. In addition, Nordstrom may inspect packages, handbags, lockers and their contents and other belongings at any time and without notice. In order to avoid creating a perception of possible employee theft, you must purchase any Nordstrom merchandise you wear, unless your store manager has authorized an expense transfer for promotional purposes. Employees are also expected to comply with rules regarding Employee Owned Goods.
Each Nordstrom store has a designated employee entrance and an Employee Service Area (ESA) or Self Service Area (SSA). You are required to use the employee entrance when arriving for or leaving from work. Any purchases you make during your shift — as well as your handbag, briefcase or other bags — may be checked at the ESA/SSA. If you are unable to use the employee entrance for any reason, please immediately notify Human Resources.
The Merchandise Discount is a benefit provided to Nordstrom employees and their eligible family members and dependents. It is important that you follow the guidelines:
• Your discount may only be used to purchase merchandise for yourself, your eligible dependents or as a gift. In the case of a gift, it must be paid for entirely by you if you use your discount. In addition, you may not ring your own transactions on merchandise purchased with your discount, nor are you eligible for commissions on merchandise purchased with your discount. This applies to purchases made either by you or your eligible dependents.
Merchandise purchased with your discount may not be resold for profit.
It's important you understand all expectations regarding appropriate use of your discount. More information can be found on mynordstrom.com.
Nordstrom is committed to respecting your privacy. We take great care to protect your personal information and require that you do the same by protecting the personal information of other employees as well as the confidential business information of Nordstrom. Personal information about employees includes Social Security numbers, dates of birth, mailing and email addresses and sales information. We have safeguards in place to limit access to your personal and health information, and we retain records in accordance with our Records Retention policy posted on Nordnet and mynordstrom.com.
The federal privacy regulation under the Health Insurance Portability and Accountability Act (HIPAA) controls the use and disclosure of protected health information. We take these privacy standards seriously, to ensure your rights regarding your health information, and comply with this regulation. The Nordstrom Health Plan's Notice of Privacy Practices further explains your rights as they relate to the protection of your health information. It lists Nordstrom's responsibilities to you, as well as whom you should contact in the event you have a privacy concern. You will find a copy of the Notice in your Employee Benefits Summary Plan Description (SPD), available online at mynordstrom.com.
WE DO BUSINESS WITH INTEGRITY
PROTECT NORDSTROM, ITS INTERESTS AND PROPERTY
To protect Nordstrom, its interests and its property, you must comply with all applicable governmental laws, rules and regulations when you are conducting business on behalf of Nordstrom. You also must avoid engaging in conduct that, even though legal, is inconsistent with Nordstrom's policies or ethical principles. This means that you must ensure that you do not use Nordstrom's property, funds, personnel, time, facilities or equipment for your own personal use or gain. This also means that you must return to Nordstrom at the end of your employment any Nordstrom property, equipment or sensitive, personal or confidential information as defined in these guidelines that is in your possession or control.
You should also be aware that any business processes or opportunities you discover through your work at Nordstrom belong to Nordstrom, not you, and may not be disclosed or used for personal gain. Similarly, Nordstrom shall be the exclusive owner if you make a discovery, develop or create any invention, design, process, concept, formula, tangible work of design or authorship, or similar creation using Nordstrom's resources or confidential information in the course of your employment.
Information about company performance that has not been made public must also be kept confidential. Be especially alert if someone asks you about the current pace of business, sales, our profitability or our strategies. Participating in these discussions can result in an inadvertent but nevertheless damaging, disparaging or illegal disclosure of information.
If you have any questions at all about what constitutes sensitive, personal or confidential information or how to protect that information, please contact your manager, Human Resources or store manager. In addition, the Privacy site on mynordstrom.com and Nordnet contains additional privacy resources and information regarding our privacy expectations.
MEDIA, INVESTOR AND MARKET RESEARCH ORGANIZATION QUESTIONS
You can help us ensure that when we speak as a company, we speak with one voice, with a consistent message and through appropriate channels. Only approved Nordstrom spokespeople may serve as a Nordstrom representative when speaking to the investment community, market research organizations or the news media (including newspapers, television, radio, magazines, blogs or online publications). This means non-approved employees may not respond to inquiries nor reach out to the investment community, market research organizations or the news media on behalf of or as a representative of the company. No Nordstrom employee should accept compensation for providing information about the company. If you are contacted, please work with Corporate Affairs (Public Relations). Your store manager or Human Resources can help you locate the right person.
PAY FOR TIME WORKED
Nordstrom pays you for all time worked, including time you spend outside of work on work-related social networking, emailing, phone calls, etc. Therefore, you are expected to accurately and completely submit all the time that you work.
Nordstrom is committed to paying employees accurately, including only making legally permissible deductions from employees' pay. Despite this commitment, mistakes can happen. We encourage you to review your payslips each pay period to ensure they are correct. Please notify Human Resources via the AskHR feature on mynordstrom.com or call 855.NORDYHR (667-3947) immediately if you believe an error has occurred with respect to your pay, including if you believe an improper deduction has been taken from your salary or other pay. Nordstrom will investigate all concerns and will promptly make any required adjustments.
Should you choose to end your employment with Nordstrom, you must timely notify Human Resources and your manager so we can ensure accurate and timely pay.
Record All Time Worked
The Time Entry system is your means of recording and verifying the time you work. It is your responsibility to use Time Entry each time you arrive or leave work or when you take a meal period. If Time Entry is not available, or you end up working during a meal period or while punched out, you must complete and submit a Special Activity Timesheet (SAT) online at mynordstrom.com before the end of the pay period. You are periodically asked to certify that you have submitted all of your time worked and are expected to provide an accurate answer when asked.
You should not record time in which you were not actually working for Nordstrom. In addition, you may not ask someone else to record your work hours for you on Time Entry, nor may you record work hours for someone else. It is important that you understand that your recorded time may be reviewed by Nordstrom.
Working Scheduled Shifts
You are also responsible for working your scheduled shifts or, if you are unable to work your scheduled shift or will be late, you must contact your manager. You are also responsible for taking your meal and rest breaks.
ACCURATE AND ETHICAL ACCOUNTING
Nordstrom works hard to earn the trust of our customers, employees, vendors and other business partners by being honest and forthright in all aspects of our business, including compliance with all applicable financial reporting and accounting rules and regulations. This trust is one of our most valuable assets. We want to assure you that we approach our accounting the same way we do the rest of our business.
It is possible that company directors, officers and employees may be called on to provide necessary information to ensure that Nordstrom's public reports and communications are complete, fair, accurate and understandable. If requested of you, Nordstrom expects you to take this responsibility very seriously, with the same integrity expected of you on a daily basis. We also expect you to share in this responsibility for accurate and ethical accounting procedures by properly recording all transactions in accordance with Nordstrom procedures and by retaining or disposing of records in accordance with Nordstrom record retention policies.
You should have confidence that we hold ourselves to strict standards and are committed to maintaining your trust. By telling you our expectations up front, we rely on you to do your part to help us maintain these standards.
The Nordstrom Audit Committee has established procedures to respond to possible employee concerns about accounting-related practices. You are welcome to submit a complaint regarding accounting matters to the Audit Committee of the Nordstrom Board of Directors or to a manager. Examples of concerns you should report are errors, fraud or misrepresentation in our accounting-related practices. Retaliation against you for making a complaint will not be tolerated. As with all other matters, our door is always open. Should you have questions or concerns regarding accounting, internal audit controls or auditing matters, contact:
- your manager
- store manager
- Human Resources
- 885-NordyHR (667-3947)
- Audit Committee
If you feel more comfortable communicating on an anonymous basis, you may call 1.888.832.8358 or visit ethicspoint.com. The toll-free number and website are administered by an independent third party called EthicsPoint.
AVOID CONFLICTS OF INTEREST
Nordstrom values fair and honest dealings with our customers, coworkers, vendors, competitors and other business partners. We expect employees to uphold these values by avoiding conflicts of interest.
A conflict of interest exists if you have an interest outside of your work at Nordstrom that interferes with your job responsibilities or affects your judgment on behalf of Nordstrom. For example, a conflict of interest may exist if a member of your family is associated with a vendor or you work for a competitor within the retail sector — this could affect independent judgment on behalf of Nordstrom. Similarly, a conflict of interest may exist if you or a member of your family is associated with one of Nordstrom's institutional investors or a financial analyst covering Nordstrom stock.
You may work for another employer as long as it does not cause a conflict of interest or interfere with your job performance at Nordstrom.
You must report any potential conflicts of interest to your manager, Human Resources or store manager. Officers should report actual or potential conflicts of interest to the Corporate Secretary, and members of the Board of Directors should report actual or potential conflicts of interest to the Corporate Governance and Nominating Committee.
IMPROPER GIFTS AND PAYMENTS
. Accepting gifts, loans, trips or other items of value from a customer, vendor, competitor or others with whom we do business — or may potentially do business — could create the impression that the gift improperly influenced our decision to do business with the gift giver. As a result, neither you nor your family members may accept gifts from customers, vendors or a competitor except for non-cash gifts of nominal value. You may also accept a gift or prize as long as it is considered to be an authorized promotional prize provided by a vendor to stimulate business. You can learn more about this in the Participate Fairly in Contests section and in the Employee Complimentary Goods Guidelines on Nordnet or mynordstrom.com.
Participating in business-related functions, including meals with a vendor, customer or competitor is an acceptable form of entertainment and is generally allowed. This also includes accepting vendor-sponsored business trips to view merchandise with prior supervisor approval. In all of these situations, however, we expect you to use good judgment and to ensure that the value and frequency of these functions do not become excessive.
Offering or giving money or anything else of value, directly or indirectly, to foreign government officials, parties or candidates for the purpose of obtaining or retaining business or to secure any improper advantage is illegal. Nordstrom employees must not offer or accept bribes or use other inappropriate means to obtain an undue or improper advantage, or engage in any other actions that violate U.S. or international anticorruption laws and regulations. If you have additional questions, please contact the Corporate Secretary.
You should avoid relationships or behaviors that create a real or perceived conflict of interest with your job performance or judgment at Nordstrom.
Any employee who has a close, personal relationship with an employee they supervise, or any relationship that could create a real or perceived conflict of interest, must immediately disclose the relationship to Human Resources or the store manager so that appropriate action may be taken, which may include transfer to a different department or location. Failure to promptly disclose such relationships or other related poor judgment may lead to disciplinary action up to and including termination of employment.
Store Managers, Human Resources and Loss Prevention employees may not work in or support a store that employs their immediate family member or those with whom they have a romantic/sexual relationship, except in limited circumstances, which must be approved by the Executive Vice President of Human Resources or an approved designee.
As a Nordstrom employee, you may be eligible to participate in exciting and rewarding contests sponsored either by Nordstrom or a vendor. Contests may include merchandise awards from Nordstrom inventory, merchandise awards from our vendors, trips or other incentives. Should your productivity be rewarded through one of these contests, you are expected to comply with contest guidelines, which are located on Nordnet and mynordstrom.com.
YOUR FINANCIAL RESPONSIBILITY
We expect you to use good judgment when it comes to writing personal checks to Nordstrom, using your Nordstrom debit card and keeping your Nordstrom credit account(s) current and in good standing. Issues of concern include a check that is written off, a Nordstrom debit card transaction that is returned by the bank as unpaid or being delinquent on your Nordstrom account(s).
If you are issued a Nordstrom Corporate Card, you must keep that account current and in good standing as well. This means you should only use your card for business related expenses and you should follow all terms and conditions of your card including reconciling your expenses in a timely and accurate manner. Use of this card is a privilege and you are trusted to use good judgment when purchasing goods and services.
We are firmly committed to competing fairly and ethically in the marketplace. We do not enter into or try to enter into agreements, understandings or communications with competitors on matters such as prices, markups, markdowns and any other terms or conditions on which we do business. If you have any additional questions or concerns, please contact the Corporate Secretary.
CALL MONITORING AND RECORDING
In an effort to ensure that our customers are receiving the best possible customer service, and also for legal and security-related reasons, we have a practice of recording phone calls at our Credit division locations, including the Credit division's affiliate Nordstrom Bank, as well as calls to Nordstrom Direct Contact Center locations. Authorized representatives of Nordstrom, Inc. and/or Nordstrom Bank may, from time to time, monitor (listen in on), record and later review your telephone calls to the above locations.
Monitoring and recording of these calls may occur at any time during the workday, for any length of time and without notification to you. Please also be aware that you do not have the option to prevent phone calls you make to the locations listed above from being monitored and/or recorded.
TRADING IN NORDSTROM SECURITIES
Using confidential or material nonpublic information to trade in stock is called "insider trading" and is unethical and illegal. Employees, officers and directors who have knowledge of confidential or material nonpublic information from or about Nordstrom are not permitted to buy, sell or otherwise trade in Nordstrom securities, except during limited time periods as defined by Nordstrom, whether or not they are using or relying on that nonpublic information. This prohibition extends to sharing or tipping off others about such information, especially because the individuals receiving such information might use it to trade in Nordstrom securities. In addition to customary market trades in Nordstrom stock, this prohibition against insider trading also applies to trades made based on investment decisions in the 401(k) Plan and the Employee Stock Purchase Plan. We expect our employees, officers and directors to be vested financially in the company's success, and accordingly, they should not participate in any short sales and other hedging activities related to Nordstrom securities (other than exercising employee stock options). If you have any questions about trading in our company's securities, please contact the Corporate Secretary.
TALKING ABOUT WAGES, HOURS AND WORKING CONDITIONS (move to above AT-WILL EMPLOYMENT)
You are free, though not required, to discuss your wages, hours and working conditions and those of other employees that they disclose voluntarily. Nothing in this Code of Conduct changes that and Nordstrom will not discipline, retaliate, or terminate your employment for doing so. However, wage information of other employees that you may have access to as part of your job is proprietary information and should not be made public or shared with co-workers or Nordstrom competitors. For more information, see the section of this Code entitled "Protecting Nordstrom, Its Interests and Property."
Nothing in this information constitutes an employment contract. Your employment with Nordstrom remains at-will, which means that both you and Nordstrom reserve the right to end the employment relationship at any time, with or without notice, with or without reason.
Nordstrom takes compliance with the principles laid out in this Code of Conduct very seriously, and any waivers of strict compliance will be made in limited, special circumstances. For Nordstrom's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, any waiver will require prior approval of either the Board of Directors or the Corporate Governance and Nominating Committee, along with prompt disclosure to shareholders.
IN CLOSING …
You are part of a legacy of talented individuals who work together to provide the highest level of customer service. Throughout your career at Nordstrom, you'll face many new challenges and opportunities. As you rise to meet the challenges and take advantage of the opportunities, we ask that you follow the philosophy Nordstrom was founded upon: use good judgment in all situations. Doing so will empower you to provide outstanding customer service every day, one customer at a time. Use the information included in the Code of Conduct and other position-specific expectations to guide your decisions. You are expected to comply with the Code of Conduct and all other Nordstrom policies. Because Nordstrom is constantly growing and changing, this Code of Conduct may be revised from time to time without notice. For this reason, employees should access the Code of Conduct from mynordstrom.com to ensure they are receiving the most current information about the Code. And if you are ever in doubt or see something that doesn't look like good judgment, reach out to your resources, including your manager, Human Resources and store manager — we are here to help.