Neiman Marcus 2009 Annual Report Download - page 499

benefits of any kind from current or prospective vendors, suppliers, customers, or other third parties. Gifts include, but are not limited
to, cash, merchandise, services, or any other thing of value that is not available to all associates on an equal basis. Associates are
generally discouraged from accepting unsolicited gifts, and are specifically prohibited from accepting gifts of money or gifts in any
other form which would induce or obligate them to give special consideration to the person or company making the gift.
During any calendar year, associates may, as a limited exception, accept unsolicited, non-monetary gifts that: (1) are items of nominal
intrinsic value (i.e. $150.00 or less in aggregate retail value); or (2) are product samples, clearly marked with company or brand
names, and distributed to a large group of associates on an equal basis. Associates are prohibited from returning conclave or vendor
gifts for cash or credit. Associates are also prohibited from selling or bartering gifts received from vendors. Any gift having more
than nominal intrinsic value must be reported to the Human Resources Department to determine whether it can be accepted. Whether
or not the gift is accepted, associates should tactfully discourage the person or company giving the gift from giving similar gifts in the
future.
The Company does permit vendors to provide reasonable amounts of free merchandise or "gratis" merchandise to associates in our
stores, subject to the General Manager's approval. "Gratis" is for the sole purpose of helping our store associates promote the products
the Company sells and to better serve all customers.
ENTERTAINMENT
Associates are prohibited from encouraging or soliciting entertainment from any current or prospective vendor, government agency,
supplier, or customer. Entertainment includes, but is not limited to, activities such as dinner parties, theater parties and sporting
events. From time-to-time, associates may accept unsolicited entertainment, but only under the following conditions:
• the entertainment occurs infrequently;
• the entertainment arises out of the ordinary course of business;
• the entertainment involves reasonable, not lavish, expenditures (e.g., the amounts involved should be amounts that associates
are normally accustomed to spending for their own business or personal entertainment);
• the entertainment takes place in settings that are reasonable, appropriate and fitting for associates, their hosts and the
business at hand; and
• associates are not tempted to give and do not feel obligated to give any special consideration to the individual or company
providing the entertainment.
An associate who becomes involved in a situation that creates a conflict of interest, or the appearance of one, should notify his or her
supervisor and seek guidance from either their supervisor, an NMG attorney, the Human Resources Department, the Associate
Relations Department, or the Compliance Committee. The Company reserves the right, in its sole discretion, to take all necessary
actions to eliminate any conflicts of interest or to grant exceptions to the policy.
SUBSTANCE ABUSE AND DRUG TESTING POLICY
It is the Company's intention to provide a safe and productive work environment for all associates.
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