Neiman Marcus 2003 Annual Report Download - page 331

appreciates efforts on the part of its employees to communicate possible wrongdoing to the Compliance Committee. Any
employee responsible for reprisals against coworkers or subordinates for reporting in good faith known or suspected
violations will be subject to disciplinary action. On the other hand, any employee who submits a report that the employee
knows or suspects may be false will be subject to disciplinary action.
While the Company will not retaliate against an employee because of his or her good faith report of a suspected violation of
the Code, an employee who reports a violation or suspected violation of the Code may still be disciplined for misconduct or for any
unrelated reasons. In other words, an employee is not exempt from disciplinary action simply because he or she has made a report
under the Code. For example, an employee who makes a good faith report of a violation of the Code and who is on probation due to
unsatisfactory job performance may still be disciplined based on his or her job performance.
The Company prefers that employees identify themselves when reporting violations or suspected violations because this will
better enable the Compliance Committee to investigate the alleged wrongdoing. However, the Company recognizes that in some cases
employees may feel it desirable to remain anonymous. The Compliance Committee will investigate anonymous reports, but requests
that such reports be described in as much detail as possible with regard to the alleged misconduct, the individuals involved, and the
basis for the allegations so that a thorough investigation can be conducted.
COMPLIANCE WITH LAWS AND RELATED POLICIES
Certain laws, policies and ethical principles that are of particular importance to the Company are described below. In addition
to the Code, the Company periodically distributes more detailed guidelines regarding compliance with individual policies and laws to
employees for whom such guidelines are particularly relevant. Employees are bound by such guidelines and should retain a copy for
their reference.
GENERAL OBLIGATION TO DEAL FAIRLY
Employees shall endeavor to deal fairly with the Company's customers, suppliers, competitors, and other employees. No
employee shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair dealing practice.
ANTITRUST LAWS
Employees are prohibited from making any agreements with competitors in restraint of trade, and shall not engage in
price fixing, resale price maintenance, unlawful boycotts, price discrimination or other acts that violate applicable antitrust
and trade practice laws.
Federal and state antitrust laws are intended to preserve and to promote fair and open competition, which lies at the
foundation of a free enterprise system. While the Company should compete aggressively and creatively, its commitment is to compete
in strict compliance with the