Neiman Marcus 2003 Annual Report Download - page 348

Loans and/or guarantees for any financial obligations granted to any employee, including but not limited to officers and
directors are of special concern and must be disclosed to and approved by the Board of Directors.
In general, no employee should: (a) accept a gift from; (b) be employed by, consult, serve as a director, volunteer or
otherwise render services to; (c) own or have an ownership interest in; (d) be a creditor of; or (e) obtain confidential information for
personal benefit from any person, firm or entity that supplies goods or services to, purchases goods or services from, or is a competitor
of the Company, its subsidiaries or affiliates. The only exceptions to this general rule are that it is not a conflict for employees to own
insubstantial amounts of stock in publicly-held companies with whom the Company does business or competes, or to accept non-cash
gifts and/or entertainment more specifically described below.
Employees, officers and directors are also prohibited from (a) taking for themselves personally opportunities that are
discovered through the use of Company property, information or position; (b) using Company property, information, or position for
personal gain; and (c) competing with the Company. Employees, officers and directors owe a duty to the Company to advance its
legitimate interests when the opportunity to do so arises.
GIFTS
Employees are prohibited from soliciting gifts, gratuities, or any other personal benefit or favor of any kind from vendors or
potential vendors. Gifts include not only merchandise and products, but also personal services, theater tickets, tickets for sports events,
and any other tangible or intangible items, services or favors that are valuable and not available to all employees on an equal basis.
Except as provided below, employees are discouraged from accepting unsolicited gifts, and are prohibited from accepting gifts of
money and gifts in any form which would induce or obligate them to give special consideration to the person or company making the
gift.
During any calendar year, employees may accept unsolicited, non-monetary gifts provided: (1) they are items of nominal
intrinsic value ($150.00 or less in aggregate retail value); or (2) they are product samples, clearly marked with company or brand
names, and distributed to a large group of our employees on an equal basis. Any gift of more than nominal intrinsic value must be
reported to Marita O'Dea, Lee Roever or Nina Fabian in the Human Resources Department to determine whether it can be accepted.
Whether or not the gift is accepted, employees should tactfully discourage the person or company making the gift from making similar
gifts in the future.
ENTERTAINMENT
Employees shall not encourage or solicit entertainment from any individual or company with whom our Company does
business. Entertainment includes, but is not limited to, activities such as dinner parties, theater parties and sports events. From time to
time, employees may accept unsolicited entertainment, but only under the following conditions:
(1) the entertainment occurs infrequently;
(2) the entertainment arises out of the ordinary course of business;
(3) the entertainment involves reasonable, not lavish, expenditures (the amounts involved should be ones employees are accustomed to
spending normally for their own business or personal entertainment);
(4) the entertainment takes place in settings that also are reasonable, appropriate and fitting to our employees, their hosts and the
business at hand; and
(5) the employee is not tempted to give and does not feel obligated to give to the individual or company providing the entertainment
any special consideration.
An employee who becomes involved in a situation that creates a conflict of interest, or the appearance of one, should notify
his or her supervisor and seek guidance from the Compliance Committee or the Legal Department. The Company ordinarily will
expect the conflict of interest to be eliminated, but there are occasions when apparent conflicts may be acceptable