Neiman Marcus 2009 Annual Report Download - page 501

Chairman of the Compliance Committee, with ultimate responsibility of overseeing compliance with all applicable laws and with the
Code.
DISSEMINATION OF INFORMATION
The Code summarizes certain key laws, policies and ethical principles which aid associates in identifying and preventing possible
problems. The Company recognizes that the materials contained in the Code and those distributed to supplement the Code cannot
possibly anticipate all potential problems that may be encountered. To a significant extent, the Company must rely upon each
individual associate to act with integrity, to use his or her best judgment, and to seek guidance when necessary in any given situation.
All associates will receive a copy of the Code and are required to sign a Certification. The Certification represents that an associate
has received and reviewed the Code and understands the obligation to comply with all of its requirements. It is imperative that all
associates read and thoroughly understand each provision. Associates will be asked to re-certify their understanding and compliance
on an annual basis. Signed Certifications will be inserted into an associate's personnel file.
The Company retains the right to update, amend, or modify the Code at any time without prior notice. Associates will be bound by
such changes. The Company may also periodically distribute additional guidelines regarding compliance with individual policies.
TRAINING AND EDUCATION
The Compliance Committee oversees and coordinates the training of designated associates regarding the Code and its related policies.
The Legal Department may conduct periodic compliance meetings and distribute guidelines to further educate associates regarding the
Code's content.
DISCIPLINE FOR VIOLATIONS
Associates are obligated to comply with all requirements set forth in the Code. In enforcing these requirements, the Company will
undertake all necessary actions based upon the facts and circumstances of each situation. The Code provides additional disciplinary
guidelines for the following situations:
• associates who authorize, condone or participate in actions that violate the law or the Code;
• associates who attempt or encourage others to retaliate, directly or indirectly, against individuals who report violations or
potential violations of the law and/or the Code;
• associates who fail to report a violation of the law and/or the Code, or who withhold relevant and material information
concerning a violation of which they are aware or should be aware; and
• associates who submit reports of violations or suspected violations which are knowingly false, made in bad faith, or
submitted with a reckless disregard for the truth or accuracy of the alleged violations.
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