Neiman Marcus 2009 Annual Report Download - page 493

foreign made goods with U.S. content. Associates must consult with the Legal Department before exporting any goods.
ANTIBOYCOTT LAWS
The Company will not participate in any economic boycott unless sanctioned by the U.S. government. The Company will not provide
information that could be construed to further unsanctioned boycotts. Any requests to do so must be reported to the U.S. Department
of Commerce. If an associate receives any such request by a third party, it must be reported immediately to the Legal Department.
U.S. EMBARGOES
Associates must comply with trade restrictions imposed under the International Emergency Economic Powers Act and the Trading
with the Enemy Act. Both laws impose restrictions that affect exports, imports, travel, currency transactions, assets and accounts with
certain countries, whether directly or through third parties. Associates must confirm that no trade restrictions are in effect with any
country with whom the Company does or intends to do business.
POLITICAL ACTIVITIES AND CONTRIBUTIONS
Associates must comply with all campaign finance and ethics laws, including those prohibiting the use of Company funds, assets,
facilities, or services to: (1) support or oppose political parties or candidates; or (2) reimburse associates who make donations to
support or oppose political parties or candidates.
Associates, who make personal political contributions, or who participate in the political process or political activities to express their
personal views on legislative or political matters must conduct such activities on their own time and at their own personal expense.
Unless authorized by the Company, associates who engage in such activities or make any public political statements must avoid any
references to their affiliation with the Company.
Occasionally, the Company may retain the services of a lobbyist whose sole function is to communicate with legislative or regulatory
officials on behalf of the Company. Since lobbyists are often subject to specific registration, reporting, and financial disclosure
requirements, associates are prohibited from engaging in any lobbying activities without pre-approval by the Legal Department.
IMPROPER OR UNRECORDED PAYMENTS / EXCESSIVE GIFTS
It is the Company's policy to maintain accurate and reliable financial records. Associates are therefore required to retain all supporting
documentation necessary to support all payments made or received by the Company. In support of this policy, associates shall not:
• falsely report any payment in accounting records;
• omit any payment from accounting records;
• create or maintain secret or unrecorded funds or assets;
• make false or fictitious entries in the Company's books or records so as to conceal such funds or assets;
• make, facilitate or accept any bribes, kickbacks or other improper payments,
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