Corporate Governance - Conduct

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Download Corporate Governance DocumentationCode of Conduct
As of: 
February 2014

Code of Business Conduct and Ethics

Amended and Restated on:
February 26, 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 those customers, interacting with each other and protecting our company’s interests.

Our expectation is that you will uphold the guidelines detailed on the following pages and comply with all applicable laws and regulations. This document, the Nordstrom Code of Business Conduct and Ethics or ‘Code of Conduct,’ covers a wide range of business practices and procedures. Our Code of Conduct is 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 expectations, policies, procedures and guidelines that apply to your position. Failure to do so may result in disciplinary action up to and including termination.

At Nordstrom, 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 in all situations. 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.

Each of us has the responsibility to speak up to create a safer and supportive work environment where each of us can realize our potential and contribute to our company’s goal of providing excellent customer service. If you have any questions about the Code of Conduct or have a concern about any employee or customer conduct, we want to hear from you. The expectation is that you will immediately raise any concern that you or others may have. We cannot address concerns unless we are aware of them. The following individuals are among the managers who can help you with any questions or concerns you may have:

  • Department manager
  • Human Resources manager
  • Store manager
  • Human Resources director
  • Regional manager
  • Diversity Affairs director
  • Loss Prevention manager

You can find contact information for these individuals through Human Resources or any store operator. If you prefer, you can use the AskHR feature on or call 855.NORDYHR (667-3947).

Also, in the event you observe illegal or unethical behavior, you have a responsibility to speak to one of the above individuals. If you feel more comfortable communicating on an anonymous basis, you may call 1.888.832.8358 or visit The toll-free number and website are administered by an independent third party called EthicsPoint, which will report your concern to Nordstrom, who will determine next steps. Please keep in mind that we will need sufficient details about your concern in order to adequately investigate it and take action if necessary.

Nordstrom will not permit any retaliation 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, contact Human Resources or any manager.


We must respect the privacy and confidentiality of customer, employee (personal information) and business information. Adhere to the Nordstrom Privacy Policy, Privacy training, the Code of Conduct, and other Nordstrom guidelines and expectations.

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.

Personal information about employees includes Social Security numbers, dates of birth, mailing and email addresses and sales information.

Remember To:

  • Only access and use personal information 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 department 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 that an appropriate contract is in place before sharing or releasing any information to an approved Nordstrom third party service provider


  • Enter customer information into any unauthorized personal address book, physical or electronic 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 department manager, Human Resources or Loss Prevention.

For more information or further assistance please visit the Privacy site on Nordnet or contact the Privacy Department at

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 that 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 Gmail, Yahoo, Comcast, 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.

Nordstrom has 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.

You are expected to follow applicable state and federal laws and regulations and the Travel & Expense Policy regarding the use of cell phones and other mobile devices while on company time or when conducting business while driving. Safety must come before all other concerns.

It is critical for you to understand that all current and future Nordstrom guidelines also apply to the use of technology. These include, but are not limited to our expectations regarding harassment and discrimination, retaliation, sexual harassment, violence in the workplace, privacy and company information. Discriminatory, unethical and/or inappropriate behavior when using these technologies will not be tolerated.

Specific Information Security and Privacy standards have been published on Nordnet regarding the use of Nordstrom information and technological resources, and 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. These standards, expectations and policies can be found on Nordnet.

If you use social media accounts to connect and share about Nordstrom, we ask that you use good judgment and follow these additional guidelines:

  • Follow Nordstrom guidelines and expectations, including the Privacy Policy, Privacy Trainings, the Code of Conduct and other Nordstrom guidelines. Follow terms and conditions for social networking sites.
  • Comply with the Endorsement Guidelines if you are receiving benefits or incentives for posts on social media.
  • 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 (i.e., unannounced product launches and promotions, internal sales results, company strategy, pricing information or comparisons).
  • Never give out personal customer or co-worker information (i.e. 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.
  • Always ask for permission to post pictures of customers or co-workers.
  • Know that you may be legally responsible for the content you post. Respect brands, trademarks and copyrights.
  • 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 Social Media, Legal and Privacy Teams for contests or promotions directed toward Nordstrom customers or employees.

Only specifically approved employees who have completed additional training can use Nordstrom social media accounts, the Nordstrom logo, photos and video, and blogs on behalf of Nordstrom. Please contact the Social Media team to learn more.

Nordstrom pays for all time worked, which includes approved social media activities on behalf of Nordstrom, even if it is just a few minutes. Nothing in these Social Media guidelines is intended to prevent employee discussions or activities involving wages, hours and working conditions. We expect you to comply with these guidelines and use good judgment. Failure to comply may result in disciplinary action up to and including termination of your employment.

We do not have a return policy in our Full-line stores. Our ultimate objective is to make sure our customers are satisfied with their Nordstrom purchases; we handle returns on a case-by-case basis. Rack employees are expected to use good judgment with respect to all returns and to follow the Rack Return Policy.

Nordstrom customers expect and should receive the best in new and up-to-date clothing. As a result, we do not allow the sale of used merchandise except at our Last Chance and Nordstrom Rack stores. Merchandise is considered “used” if any portion of it has been consumed, altered, reconditioned, refurbished or worn. The only exception is merchandise, other than cosmetics, that has been tried on for approval in the store or elsewhere.

After you have completed a return or exchange for a customer, thoroughly examine the returned item(s) for any signs of previous wear (aside from being gently tried on) and ensure that it meets our standards before returning it to the sales floor. If you determine that an item does not meet this standard, it must not to be returned to the Full-line sales floor. All returned swimwear and intimate apparel/undergarments without attached tags may not be placed back on the sales floor. Your department manager can help you determine how to handle any used merchandise.

Specific to Cosmetics, please use good judgment to determine whether merchandise is used or damaged in any way based on how the product appears when it is returned (e.g., status of packaging, seals, cellophane, etc.) and properly process this merchandise.

Only returned items that are closely inspected and determined to be unused and not tampered with may be returned to the sales floor and resold. Returned product should never be used for samples.

In our continuing effort to ensure employees are being compensated properly, the following procedures need to be followed when Full-line stores employees ring returns and exchanges and rewrites within all selling departments.

  • If a customer brings in merchandise to exchange and the original salesperson is present and available, the original salesperson should take care of the customer’s needs.
  • If the original salesperson is not present or available, follow the procedure based on whether the customer needs assistance in selecting a new size or style.
  • If the customer does not need or request assistance to exchange or return a size or style, then the original salesperson’s employee number should be used for both the return and the sale.
  • If a customer has an exchange to make, either in style or size, and the customer does need or request 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. There is an exception to this approach for Fine Jewelry diamond upgrades. See your Fine Jewelry department manager or Human Resources for more information about how diamond upgrades are handled.


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; or any other basis protected by federal, state and/or local laws.

Please contact Human Resources if you have a disability that may impact your ability to perform the expectations of your job. This includes disabilities caused or contributed to by pregnancy. 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.


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; 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 or other technological means — that creates an intimidating, hostile or offensive environment is prohibited.

We do not permit harassment of any kind and that includes sexual harassment. Sexual harassment may include but is not limited to any of the following:

  • 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.
  • Unwanted and/or unwelcome sexual comments, advances, flirtations or propositions.
  • Verbal abuse of a sexual nature, including sexually oriented jokes or comments.
  • Display of sexually suggestive objects or pictures or making sexually suggestive gestures.
Nordstrom prohibits these behaviors and any other behaviors that constitute sexual harassment.

We all share the responsibility to create an inclusive environment where employees and customers feel welcome.

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. Nordstrom will not permit any retaliation against employees who report concerns regarding discrimination or harassment.

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. Therefore, it is critical that you talk to Human Resources or a manager about these issues. Remember, we cannot take steps to help create a violence-free workplace unless we are aware of situations that could lead to violence in the workplace.

As an employee, you play a critical role in maintaining a culture of safety. You are also responsible for immediately reporting any real or potential threats, intimidation and/or acts of violence against you or others, including threats to harm oneself, to Human Resources or any manager. You are also responsible for:

  • Cooperating with an investigation into any real or potential violence in the workplace.
  • Reporting to and providing Human Resources with a copy of any temporary or permanent 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.

Any threat or concern you report will be investigated as promptly and as confidentially as reasonable. In addition, Nordstrom will not permit any retaliation against employees who report concerns regarding violence in the workplace.

We see the commitment to a safe work environment as a partnership. Though we all have different responsibilities, we share the overall responsibility for our own safety and the safety of our coworkers and customers. You will be given the tools and training necessary to safely perform your job. You are responsible for making safety a priority and performing your duties according to general safety practices and other established job-specific best practices outlined in our Injury and Illness Prevention Program. As a part of our Open Door philosophy, and this safety partnership, 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.

We believe Nordstrom should be a safe, efficient and productive place. For that reason, employees must work free from the effects of drugs and alcohol.

“Drugs” refers to any drug, including marijuana, and over-the-counter medication and prescription medication that is obtained illegally or is used contrary to its prescribed dosage or purpose.

Nordstrom prohibits using, being under the influence of, possessing, distributing, selling or buying drugs (including drug paraphernalia) on company property or time, including rest and meal periods. Nordstrom also prohibits employees from consuming or being under the influence of alcohol or legal and illegal drugs including marijuana during their shift. If Nordstrom determines that an employee has engaged in these prohibited behaviors, it may result in disciplinary action up to and including termination of employment.

Moreover, if you are perceived to be under the influence of alcohol, legal or illegal drugs during a shift, it may also result in disciplinary action up to and including termination of employment.

It is acceptable for employees of a legal age to order and consume alcoholic beverages in Nordstrom Restaurants on their day off or after their shift ends.

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.

You are accountable for the performance of your job duties and your personal conduct at all times. Be aware that if a problem with your job performance exists, we will address those issues with you, regardless of any substance problem you may have. Our Employee Assistance Program is available to provide confidential support and appropriate resources should you need them. You may also talk with Human Resources if you need time away from work to attend a rehabilitation program.

It is also important that Nordstrom employees and customers enjoy a smoke-free environment.

Criminal behavior and theft of Nordstrom merchandise, money or other property is prohibited. It affects us all — diminishing our ability to meet our customers’ needs and reducing our profitability.

Providing excellent customer service is the best way to minimize shoplifting, crime and employee theft. As an added measure, Nordstrom also has a formal loss prevention program. This program uses a variety of resources — including Loss Prevention agents, camera and video systems, special tags, fixtures, technology 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 work. Any purchases you make during your shift — as well as your handbag, briefcase or other bags — will 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 these guidelines:

  • Your discount may be used to purchase merchandise for yourself, your eligible dependents or as a gift.
  • You must present a temporary discount shopping pass or a Nordstrom Rewards card that shows your employee number and discount percentage at point of sale as proof of your employment. You can get a temporary pass from Human Resources.
  • In order to apply your discount, you must pay for merchandise with a valid House Account card, Nordstrom gift card, Nordstrom debit card, personal check (personal checks are not accepted for payment in the Nordstrom Restaurants or Specialty Coffee Bars), cash or a debit card with your Personal Identification Number (PIN).
  • Any gift purchased with a merchandise discount must be paid for entirely by you. If several employees are buying a gift together, the lowest discount percentage of those employees will be applied. If the gift is subsequently exchanged, it must be for merchandise of equal or lesser value in one transaction. If the gift is exchanged for an item of greater value, no discount may be applied to that item.
  • You may not ring your own transactions or those of your family members or eligible dependents.
  • You are not eligible for commission on merchandise purchased with your discount. This applies to purchases made either by you or your eligible dependents.
  • You may use your discount on regular and sale-priced merchandise; however, you are not allowed to receive a sale price adjustment on items that have already been purchased.
  • If you are ringing a discounted transaction, you must ask for proof of discount eligibility.
  • Reimbursement in any form cannot be accepted for purchases made with your discount.
  • Nordstrom purchases may not be resold for profit.

We expect you to comply with these guidelines and use good judgment.

Employee theft of merchandise, sales or other Nordstrom property, or any other failure to comply with these procedures may result in disciplinary action up to and including termination of employment, as well as possible criminal prosecution.

For more information about the Merchandise Discount Plan, refer to the Employee Benefits Summary Plan Description (SPD) on

Nordstrom is committed to respecting your privacy. We take great care to protect your personal information such as your address and Social Security number as required by law. We have safeguards in place to limit access to your personal and health information and retain records in accordance with our Records Retention policy posted on Nordnet.

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


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 witness or become aware of or suspect an actual or potential situation where sensitive, personal or confidential information is lost, stolen or disclosed outside the company in an unauthorized manner — whether it’s deliberate or accidental — immediately notify your department manager, Human Resources or Loss Prevention. If you have any questions at all about what constitutes sensitive, personal or confidential information or how to protect that information, please contact your department manager, Human Resources manager or store manager. In addition, the Privacy at Nordstrom website on Nordnet contains additional privacy resources and information regarding our privacy expectations.

Other than authorized Nordstrom spokespersons, employees may not respond to inquiries on behalf of Nordstrom from the investment community or the news media, including newspapers, television, radio, magazines, blogs or online publications. Any inquiries from outside groups or outreach on behalf of Nordstrom should always be referred to our Corporate Affairs department; your store manager or Human Resources manager can help you locate the right person. 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.

We create, retain, and dispose of 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. If you have any questions about those requirements, please ask Human Resources.

Nordstrom is committed to paying its employees accurately. This includes paying employees for all the time they work and only making legally permissible deductions from employees’ pay. Despite Nordstrom’s commitment to paying its employees accurately, mistakes can happen. We encourage you to review your payslips each pay period to ensure they are correct. Please notify Human Resources or, if you prefer, you can use the AskHR feature on 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.

Nordstrom pays you for all time worked. Therefore, you are expected to record your time accurately and completely. 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 your work takes you where Time Entry is not available, or you end up working during a meal period or while punched out, you must complete a Special Activity Timesheet (SAT) online at, and submit the form 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 are not allowed to work without recording your time. This includes but is not limited to any time you spend outside of your scheduled shift on work-related social networking, emailing, phone calls, etc.

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.

In addition, you are responsible for contacting your department manager as soon as possible before the start of your shift if you are unable to report to work, will be late for your scheduled shift, or need to leave work early.

While we hope you’ll choose to build your career at Nordstrom, we ask that you timely notify Human Resources and your department manager should you choose to leave the company.

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.

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 or to management. 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.

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.

As with all other matters, our doors are always open. Should you have questions or concerns regarding accounting, internal audit controls or auditing matters, contact your department manager, store manager or Human Resources manager. If you would prefer, you may contact the Audit Committee of the Nordstrom Board of Directors. If you feel more comfortable communicating on an anonymous basis, you may call 1.888.832.8358 or visit The toll-free number and website are administered by an independent third party called EthicsPoint.

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 department manager, Human Resource manager 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.

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 the Human Resources manager, Human Resources director or Store manager so that appropriate action may be taken, which may include transfer to a different store. Failure to promptly disclose such relationships or other related poor judgment may lead to disciplinary action up to and including termination of employment.

In addition, 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.

It is important that we all uphold Nordstrom’s reputation for acting professionally, fairly and honestly. 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 — may create the impression that the gift may have improperly influenced our decision to do business with the gift giver. As a result, neither you nor your family members may accept these gifts 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 BIZWeb>Stores>Contests on Nordnet.

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.

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, free 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 include the following highlights:

  • The merchandise or award you receive for a contest is considered earned wages per the Internal Revenue Service. As a result, you may be taxed for the award by the vendor, through your paycheck or through self-reporting on your annual tax return.
  • You are not allowed to return awarded merchandise for cash, a gift card or credit, and in some divisions you may only exchange the merchandise for a different size.
  • Once the decision has been made to accept the award and the taxing process is completed, it will not be reversed.

For more information about contests and other forms of complimentary goods, refer to the Contest section on BIZWeb>Stores>Contests on Nordnet.

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 and/or Corporate Card 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).

Based on your position, you may be issued a Nordstrom Corporate Card for your business expenses. Use of this card is a privilege, and you are trusted to use good judgment when purchasing goods and services. Your card should be used only for business-related expenses. Nordstrom expects you to follow all terms and conditions of your card, including reconciling your expenses in a timely and accurate manner.

We are firmly committed to competing fairly and ethically. 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, please contact the Corporate Secretary.

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 in place regarding calls to 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.

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, 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 Nordstrom’s 401(k) Plan & Profit Sharing 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.

The Code of Conduct should not be interpreted in a way that interferes with the rights of employees to engage in concerted activity that is protected under the National Labor Relations Act or that applies to discussions and activities involving your wages, hours and working conditions.

The information provided here is designed to help you be successful with our company. It is subject to change at any time without prior notice. In addition, nothing in this information constitutes an employment contract. Your employment with Nordstrom remains at-will, (unless you are a party to a collective bargaining agreement that provides otherwise) 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 document 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.

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. And if you are ever in doubt or see something that doesn’t look like good judgment, reach out to your resources — we are here to help.