Neiman Marcus 2003 Annual Report Download - page 344

absence, should be prepared to handle such inspections. The manager should ask the visitor seeking to conduct an official inspection
to produce credentials and to cite the statutory authority for the inspection. The inspector should be asked to state the specific purpose
of the inspection, the matters to be investigated, and the persons to whom the inspector wishes to speak.
If the inspection is unannounced and is not a routine one (such as an annual licensing inspection), the visitor should be
told that Company policy requires you to contact the Legal Department, and he or she should be invited to wait until a
Company attorney authorizes the inspection.
CONTACTS WITH THE MEDIA AND THE FINANCIAL COMMUNITY
The Company has a legal responsibility to provide its shareholders and the public with periodic reports concerning its
financial condition (e.g., annual reports and quarterly earnings statements) and to issue periodic press releases with regard to important
corporate developments. To ensure that all such reports and press releases concerning the Company are supplied to the public in an
authoritative and consistent manner, no employees are to provide such information to anyone outside the Company without the prior
approval of the Company's Chief Financial Officer, Vice President of Finance, or General Counsel.
Only the Chief Executive Officer, the Chief Financial Officer, the Vice President of Finance, and the General Counsel are
authorized to respond to requests for copies of public reports, including financial reports filed with the Securities and Exchange
Commission, reports regarding meetings with members of the financial community and previously issued press releases. Employees
are to refer any such requests to the Chief Financial Officer, Vice President of Finance or General Counsel.
Additionally, no one other than employees authorized by the Company's Chief Executive Officer, Chief Financial Officer, or
Vice President of Finance may respond to inquiries made by the media, investment analysts or other third parties (e.g., financial
writers or editors) concerning the Company or any of its subsidiaries or divisions. This includes inquiries concerning finances,
operations, marketing plans, industry issues, litigation or investigations. Such inquiries must be referred to the Vice President of
Finance or the Chief Financial Officer, who will decide whether or not to provide the requested information. In addition, no employee
is to issue a press release to the general, financial or trade media without the approval of the Vice President of Finance.
Officers and employees who are authorized to discuss matters disclosed in the Company's published statements or publicly
filed reports should limit their discussion to the information contained in the printed report, and should refer any inquiries for
additional information to the Vice President of Finance or the Chief Financial Officer.
ADVERTISING
Employees shall not create, approve or disseminate any advertising or promotional materials that are false or
deceptive, are not adequately substantiated, or otherwise violate applicable laws and regulations.
Fair and accurate advertising and sales practices are critically important in preserving the Company's goodwill and reputation
with its customers and the general public. Federal and state laws, Federal Trade Commission regulations, and Company policy
prohibit false, misleading or deceptive advertising and related activities in the promotion and sale of products sold or offered by the
Company. Therefore, all advertising claims and other representations to customers and potential customers must be truthful and have a
reasonable basis. In addition, all advertising claims made in any print or non-print medium, including, for example, catalogues,
brochures, posters, newspapers, magazines, radio, television, e-mail or the Internet, must be substantiated before publication or
dissemination.