Neiman Marcus 2009 Annual Report Download - page 492

antiboycott laws, and embargos mandated by the U.S. State Department. Associates must also be respectful and tolerant of the values
and legally permissible customs of the communities and countries in which the Company does or seeks to do business. Illegal
activities are strictly prohibited, even if a particular community or country does not enforce certain laws.
THE FOREIGN CORRUPT PRACTICES ACT
The FCPA prohibits making or offering bribes, kickbacks, or payments of money or anything of value to government or public
officials, political parties, candidates for political office, or to any third party for any purpose in connection with the Company's
business operations. This includes giving money or anything of value to a third party where there is reason to believe that it will be
passed on to a government official for this purpose. This prohibition applies regardless of whether the source is from personal or
Company funds. To ensure compliance with the FCPA, all payments to such parties must be pre-approved by the Legal Department.
IMPORT AND CUSTOMS CONTROLS
Associates are required to comply with all U.S. laws, U.S. Customs Services regulations ("Customs"), and all regulations created by
federal agencies relating to, or governing, the importation or exportation of goods and technology to and from the United States.
Associates are required to report all violations or questionable transactions of U.S. Customs laws to either their supervisor, an NMG
attorney, the Human Resources Department, the Associate Relations Department, or to the Compliance Committee.
Customs and trade laws provide that all imported goods must enter the United States with the appropriate quota or export/import
licenses, labels, markings, bills of lading, and commercial invoices. All goods must be adequately and correctly described and all
payments and/or charges related to the importation must be disclosed to Customs. In addition, certain types of products (e.g.,
consumer products and textiles) are subject to special laws and regulations. All import transactions are subject to strict recordkeeping
requirements and mandate that records be retained for a period of at least five (5) years from the date of the transaction.
Both Customs and Company policy forbid the importation of goods produced by illegally employed underage workers, convicts or
forced labor. The importation of transshipped goods is also prohibited. Transshipped goods are goods which are misrepresented on
entry to the United States as the product of a second country in order to avoid additional duties or quantity limitations imposed on the
country actually producing them. The Company should ascertain that product manufacturers are not on the Customs list of
transshippers, and that they observe appropriate labor practices. Where on-site factory visits are made, associates should be on alert
for any indications of these prohibited activities and report them immediately to the Legal Department. Where possible, the Company
should secure in writing a representation and warranty that the product manufacturer will not supply any goods to the Company where
the originating country is not legally identified or which is produced by underage or involuntary labor.
EXPORT CONTROLS
Associates are responsible for understanding how export controls laws apply to their jobs and for conforming to such requirements.
Under Export Administration Regulations, the export of goods and services from the United States may require a specific export
license from the U.S. Commerce Department. The same may apply both to transshipment of U.S. origin goods from the country of
original destination to a third country, and to exports of
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