Neiman Marcus 2009 Annual Report Download - page 481

Exhibit 14.1
A LETTER TO ASSOCIATES OF
THE NEIMAN MARCUS GROUP, INC.
We are writing to tell you about the Code of Ethics and Conduct ("Code") and how it applies to you. We also want to remind you of
certain fundamental ethical principles that guide how we conduct our business.
One unwavering rule lies at the core of our business philosophy: we conduct all business in strict compliance with both the letter and
the spirit of the law, and with a scrupulous commitment to the highest standards of business and personal ethics. Our policies and
standards of conduct reflect these basic principles, but words alone cannot create a moral conscience or guarantee adherence to these
standards. Each associate plays an important part in maintaining these high standards.
Through its operating units, The Neiman Marcus Group, Inc. ("NMG" or the "Company") does business in many communities
throughout the world. All associates are ambassadors of the Company, and their conduct has a direct and significant impact on the
Company's business and reputation. The Company's objective is to be respectful and tolerant of different values and customs and to
be a model corporate citizen in all of the communities in which we do business.
This is not just bureaucratic talk. We mean it. As part of our compliance efforts, we have implemented a program to ensure that
all associates have a clear understanding of their legal and ethical responsibilities, have access to management in order to obtain
guidance when difficult questions arise, and have a full and fair opportunity to advise the Company if they feel illegal or unethical
actions have been committed or will be committed by vendors, suppliers, or other associates. The Company supports the efforts of
associates who report violations or suspected violations of the Code in good faith. The Company will not tolerate any form of
retaliation against such individuals, even if upon investigation their suspicions prove to be incorrect.
The Company is committed to a comprehensive compliance program that includes many elements. The Code reiterates and
emphasizes the Company's long-standing policies on matters such as antitrust, insider trading, product safety, and equal employment
opportunities, and sets forth procedures to ensure compliance. Educational programs enable each associate to recognize and respond
appropriately to legal and ethical issues that may arise. The Compliance Committee, headed by the Company's General Counsel,
oversees the training and compliance program. Associates are encouraged to discuss concerns with whomever they feel most
comfortable: a supervisor, an NMG attorney, the Human Resources Department, the Associate Relations Department, or the
Compliance Committee. Associates may also report issues using EthicsPoint, an independent online program that permits both
identifiable and anonymous reporting.
We need your help. While we realize that the length of the Code may seem somewhat overwhelming, much of it is based on
common sense. We ask you to read the Code carefully to ensure that you understand both the important legal and ethical
responsibilities that we all share, along with the consequences for non-compliance. Each associate will be required to certify that he
or she understands the Code and will abide by it. We must rely on each associate's good judgment and recognition that only associates
who abide by the Code and the Company's policies have a place with us. Working together, we can take personal pride in being part of
an organization that is second to none in its pursuit of excellence through commitment to the highest legal and ethical values.