Neiman Marcus 2009 Annual Report Download - page 482

Burton M. Tansky Karen Katz Brendan Hoffman Jim Gold
President and President and President and President and
Chief Executive Officer – The
Neiman Marcus Group, Inc. Chief Executive Officer – Neiman Marcus Stores Chief Executive Officer – Neiman Marcus Direct Chief Executive Officer – Bergdorf Goodman, Inc.
THE CODE
The Code contains important information about the Company's ethics, legal principles, and standards of conduct. All associates are
expected to read the Code thoroughly and refer to it as a guide to ensure strict compliance with all laws and policies. Many of the
obligations (for example, the duty not to share information with a competitor) will continue after an associate has left the Company.
Department heads are responsible for Code enforcement in their departments and supervisors are accountable for the associates who
report to them. Throughout this document, we will refer to The Neiman Marcus Group, Inc, as "NMG" or the "Company," and both
terms should be treated interchangeably. All references to the "associates" means all full time, part time, temporary and seasonal
associates of NMG, Neiman Marcus Stores, Neiman Marcus Direct, Neiman Marcus Online, Bergdorf Goodman, Inc., Bergdorf
Graphics, Inc., Horchow, Cusp and their respective subsidiaries.
CONSEQUENCES OF NON-COMPLIANCE
All associates are expected to exercise sound discretion and good judgment based upon the highest level of business ethics. Violations
of policy may result in disciplinary action up to and including termination of employment. In some cases, an associate will have the
opportunity to provide an explanation before disciplinary action is taken. Violations of a criminal nature may subject an associate to
criminal prosecution, imprisonment or fines. An associate may also be obligated to reimburse the Company, the government or any
other person or entity for resulting losses or damages.
DUTY TO REPORT
Each associate has a duty to report actual or suspected violations of the Code and all illegal activity applicable to our business.
Reports must be made to either their supervisor, an NMG attorney, the Human Resources Department, the Associate Relations
Department, or to the Compliance Committee. The Company prefers that associates identify themselves when reporting violations or
suspected violations, however, reports may also be made anonymously through EthicsPoint website www.ethicspoint.com, or by
calling 1-800-573-2022. Contact information for the Compliance Committee is available in Appendix 1. If a report is made to a
supervisor, the supervisor must immediately contact the Human Resources Department, the Associate Relations Department, or an
NMG attorney before conducting any investigation or providing a formal response.
When reporting any violation, associates will be asked to provide detailed information, including the identities of all witnesses, and all
documents supporting the claim. The Company will do its best to conduct a thorough investigation based on the information
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