Neiman Marcus 2008 Annual Report Download - page 805

THE CODE
The Code contains a great deal of information that is important to you as an employee of the Company. While you
are expected to read the Code in its entirety and sign the Certification From, the Code's primary purpose is to serve as a guide
for you as situations arise. Keep in mind the general contents of the Code, refer to it periodically to refresh your memory, and
ensure that your conduct is in compliance with applicable laws and Company policies. For purposes of this Code, (i) all
references to the employees of The Neiman Marcus Group, Inc. or the "Company" shall also include all employees of Neiman
Marcus Stores, Neiman Marcus Direct, Neiman Marcus Online, Bergdorf Goodman, Inc., Bergdorf Graphics, Inc., Kate
Spade LLP, Gurwitch Products, L.L.C., Horchow, and Chef's Catalog, and (ii) all references to employees shall specifically
include but shall not be limited to the officers and directors of the Company and its subsidiaries.
CONSEQUENCES OF NON-COMPLIANCE
The Company's activities and those of its employees and others acting on behalf of the Company must always be ethical and
in full compliance with applicable laws, regulations, policies, and the Code. Because the Company feels so strongly about maintaining
the highest level of business ethics, the Code establishes standards of conduct which, in some instances, go beyond the minimum
requirements of the law. Failure to comply with the Code can have severe consequences for both the individuals involved and for the
Company. Employees who violate the Code may be subject to disciplinary action up to and including termination of employment. In
addition, supervisors who disregard or should have reasonably detected and reported a violation of the Code may be disciplined. Of
course, an employee suspected of such a violation will be given an opportunity to explain his or her actions before any disciplinary
action is taken.
Employees who violate the Code also may have violated the law. Accordingly, such employees may be subject to
prosecution, imprisonment or fines, and may have an obligation to reimburse the Company, the government or any other person or
entity for any losses or damages resulting from such violations. Additionally, the Company may be subject to prosecution and/or
significant fines for the improper conduct of its employees.
DUTY TO REPORT
Employees must report violations or suspected violations of the Code, or of any laws applicable to the Company's business,
to their supervisor, any attorney in the Legal Department, their designated Compliance Officer, the Compliance Committee, or
Associate Relations. Employees also should seek guidance before engaging in conduct they believe may violate the Code. Contact
information for the Compliance Committee members, Compliance Officers, and attorneys in the Legal Department is available in the
attached Appendices. Supervisors and Compliance Officers should respond to inquiries and/or notify and seek advice from the
Compliance Committee or from an attorney in the Legal Department. Supervisors and Compliance Officers who learn of any matter
that might expose the Company to potential liability must immediately report it to
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