Neiman Marcus 2003 Annual Report Download - page 351

• Employees who authorize or participate directly in actions that violate the law or the Code;
•
Employees who fail to report a violation of the law or the Code, or who withhold relevant and material information
concerning a violation of which they are aware or should be aware;
•
The violator's supervisor(s), to the extent that the circumstances of the violation reflect inadequate supervision or lack
of diligence by the supervisor(s);
•
Employees who attempt or encourage others to retaliate, directly or indirectly, against individuals who report
violations of the law or the Code; and
•
Employees who submit reports of violations or suspected violations which the employees know or should know are
false.
INVESTIGATING AND RESPONDING TO ALLEGATIONS OF VIOLATIONS
All reported violations of the law or the Code will be investigated promptly and will be treated confidentially to the extent
reasonable and possible under the circumstances. The Compliance Committee coordinates all investigations of wrongdoing and
confers with Company management regarding any recommended corrective action.
Employees are expected to cooperate in the investigation of alleged violations of the law or the Code. It is imperative,
however, that employees not conduct even a preliminary investigation of any possible violations without first obtaining the approval
of the Compliance Committee. Investigations may raise complicated legal issues, and if conducted without the approval, advice and
supervision of the Compliance Committee could result in adverse consequences.
RETENTION OF OUTSIDE LEGAL COUNSEL
Periodically, the Company will retain outside counsel to provide advice regarding legal compliance, assist in conducting internal
investigations, or represent the Company in litigation or governmental investigations. Only the Legal Department may decide when to
retain outside counsel to represent or to advise the Company, and it will select, hire and supervise outside counsel. No one other than
the Legal Department may retain outside counsel with respect to any Company matter.