Neiman Marcus 2003 Annual Report Download - page 350

IMPLEMENTATION OF THE CODE
THE COMPLIANCE COMMITTEE
The Company's General Counsel is the Chairman of the Compliance Committee, with ultimate responsibility for all matters
overseen or addressed by the Committee, including the Company's compliance with applicable laws and the Code. The General
Counsel has appointed several officers of NMG to serve on the Compliance Committee, as listed in Appendix 1. In consultation with
management, the Compliance Committee has appointed Compliance Officers for each operating division and subsidiary of the
Company who are accessible at a local level and to whom employees may address questions and report violations.
DISSEMINATION OF INFORMATION
All employees receive a copy of the Code and are required to sign a Certification representing that they have received and
reviewed it, understand their obligation to comply with the Code's requirements and to report any violations. Periodically, employees
may be asked to re-certify their understanding and compliance with the Code. Signed Certifications are submitted to the appropriate
Human Resources Department for inclusion in the employee's personnel file.
The Company retains the right to update, amend, or modify the Code at any time without prior notice. The Compliance
Committee and Compliance Officers are available to answer all employee questions concerning the meaning and application of the
Code and its related policies. Employees also may ask their supervisors to relay questions or concerns to a Compliance Officer, a
member of the Compliance Committee, or to the Legal Department.
TRAINING AND EDUCATION
The Compliance Committee oversees and coordinates the training of designated employees regarding the Code and its
policies. The Legal Department may conduct periodic compliance meetings and distribute guidelines to further educate employees
regarding the Code's contents.
The Code summarizes certain key laws, policies and ethical principles under which difficulties may arise so that an employee
can bring possible problems to the Company's attention before illegal or unethical activities occur. The Company recognizes,
however, that the materials contained in the Code and those distributed to supplement the Code cannot possibly anticipate all potential
problems that employees may encounter. To a significant extent, the Company must rely upon each individual employee to act with
integrity, to use his or her best judgment, to seek guidance when necessary and to do the right thing in any given situation.
DISCIPLINE FOR VIOLATIONS
Employees are expected to follow the letter and the spirit of the law and the Code. Supervisors are responsible for the
behavior of employees under their direction and control.
The Company will follow whatever procedures and take whatever disciplinary action it deems appropriate under the
particular circumstances. In addition to disciplinary action that the Company may impose in the ordinary course of conducting its
business, the Code provides specific disciplinary guidelines. Under the Code, disciplinary action up to and including termination of
employment may be taken against the following: