Neiman Marcus 2009 Annual Report Download - page 498

CONFLICTS OF INTEREST
The Company relies on the objectivity, integrity and undivided loyalty of its associates in performing their duties. Associates are
expected and have a duty to avoid any situation in which their personal interests conflict, or have the appearance of conflicting, with
those of the Company. By way of example only, a conflict of interest exists in the following situations: (1) when an associate engages
in an activity that detracts from or interferes with the associate's objectivity, effectiveness, duty of loyalty, or timely performance of
duties or services; (2) when an associate or a member of his or her family has a financial or other interest which might influence the
associate's judgment while acting on behalf of the Company; or (3) when an associate or a member of his or her family purchases
goods or services from a supplier of the Company at less than retail price (other than the normal discount available to all associates of
the Company or to the general public). In addition, an associate has a conflict if he or she, or a member of his or her family, may
benefit from the associate's position at the Company's expense. The Company uses the phrase "member of the associate's family"
broadly to include, without limitation, a spouse, domestic partner, child, spouse or domestic partner of a child, parent, in-law, sibling,
dependent, aunt, uncle, or any adult supported by the associate or sharing the associate's residence.
In general, associates shall not:
• compete with the Company;
• own or have an ownership interest in any vendor, distributor, supplier, customer, or competitor of the Company;
• be employed by, consult, serve as a director, volunteer or otherwise render services to any vendor, distributor, supplier,
customer, or competitor of the Company;
• be a creditor of any vendor, distributor, supplier, customer, or competitor of the Company;
• use Company property, information, or position for personal gain;
• take advantage of opportunities learned or made available through one's position with the Company or through the use of
Company information;
• obtain confidential information for one's personal benefit from any vendor, distributor, supplier, customer, or competitor of
the Company;
• employ a relative where the associate directly supervises, has audit or approval function, or directly or indirectly influences
the status of such relative; or
• accept any gift or entertainment from a vendor, distributor, supplier, customer, or competitor of the Company, except as
permitted in this policy.
Associates are required to disclose all actual or potential conflicts of interest to their supervisor. Loans and/or guarantees for any
financial obligations granted to any associate, including but not limited to officers and directors are of special concern and must be
disclosed to and approved by the Company's Board of Directors. It is not a conflict for associates to own insubstantial amounts of
stock in publicly held companies with whom the Company does business or competes, or to accept non-cash gifts and/or entertainment
in the situations described below.
GIFTS
Associates are prohibited from soliciting gifts, gratuities, favors, or any other personal
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