ethics

always true to Target.

Target Corporation

Code of Ethics

enter >

table of contents.

a message from our CEO

defining ethics at Target

our purpose, culture and values

putting ethics into action

how to use our Code ......................................

reporting concerns ..........................................

how to comply with our Code .........................

making ethical choices ....................................

working together

appreciate our diversity

and demonstrate inclusivity ..........................

show respect at work ....................................

promote health and safety ............................

record time honestly.....................................

maintaining trust

provide safe food and products .....................

select business partners carefully ................

avoid conflicts of interest..............................

be truthful in marketing and advertising.........

keep privacy in mind .......................................

manage financial products ............................

conducting business fairly

prevent bribery ..............................................

follow international trade rules......................

provide accurate financial information ............

trade securities fairly and legally ...................

prevent money laundering..............................

compete fairly ...............................................

safeguarding what’s ours

secure our assets. .........................................

protect non-public information ......................

respect and preserve intellectual property ..

manage records ............................................

communicate responsibly .............................

caring for our world

respect human rights .....................................

engage responsibly in political activities .......

care for our planet .........................................

invest in our communities ..............................

summing it up

policy and resource look-up ..........................

essential resources.......................................

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Code of Ethics

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Target Corporation Code of Ethics Handbook — page 3

defining ethics at Target.

Target’s commitment to ethical standards is reflected in

the way we conduct business and through our actions.

As team members, at any level, we must always

consider the impact on our guests, team members,

stakeholders, community and the Target brand when

making business decisions.

We must each demonstrate a commitment to building

a strong ethical culture by:

• Modeling Target’s culture and values through our

decisions and actions

• Exhibiting honesty, respect and concern for

others through every interaction

• Understanding and following Target policies

and procedures

• Complying with all laws

• Seeking guidance when you have ethical questions

• Reporting any suspected violations or concerns

By holding ourselves and each other accountable to

these standards, we deliver on our brand promises

while deepening the trust of our guests, team

members, stakeholders and communities.

As a purpose-driven company, we know how important it is to

draw on our shared values and behaviors to bring that purpose

to life. To help you do that each and every day, we’ve created a

Code of Ethics that can help you make choices and decisions

that uphold our values and make good on the promises we

make to our guests, team, stakeholders, communities and our

culture.

No matter what job you hold or where you work, it’s up to you to

know and follow our Code. I encourage you to read it carefully

and ask questions if something isn’t clear. Use it to identify

anything that might violate our policies and report any concerns.

Consider it an essential resource for making ethical choices –

the choices that matter to our guests, our communities and

our Company.

In our daily work, we’re building connections with the people

and communities we serve. Every good decision strengthens

those bonds and gives us all a company we can be proud of

every day. Thank you for making ethical decisions and staying

true to our values.

Sincerely,

Brian Cornell

Chairman and Chief Executive Officer

a message from our CEO.

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Target Corporation Code of Ethics Handbook — page 4

our purpose, culture and values.

purpose

to help all families

discover the joy of

everyday life

Our guests are the reason

Target exists. They place their

trust in us as team members.

In return, we are accountable

to them.

culture – care, grow and win together

We care by showing up for each other and treating one another with respect; we grow by investing in our

people, their development and opportunities to reach their fullest potential; and we win together by leaning

into our collective power to accomplish more, striving to make things better for each other and our guests.

values – how we bring our purpose to life

Our values represent how we present ourselves to the world as Target team members. These values stand

out at Target as the elements that make us distinctly who we are. They are deeply ingrained principles that

guide our actions and our decisions.

inclusivity

valuing diverse voices and approaches, being authentic and respectful and creating equitable

experiences.

connection

building trusted relationships, collaborating across business functions and recognizing and celebrating

progress.

drive

doing what’s right for Target, our team and our guest(s), delivering results that matter, choosing

progress over perfection and continually learning.

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Target Corporation Code of Ethics Handbook — page 5

putting ethics

into action.

Target’s Code of Ethics,

“the Code,”

is your

resource for making ethical decisions.

how to use our Code .......................................

reporting concerns ..........................................

how to comply with our Code .........................

making ethical choices ....................................

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Target Corporation Code of Ethics Handbook — page 6

why we need it

We make countless decisions at work

each day. Our Code can help you navigate

challenging situations and align your

decisions and behaviors with Target’s values.

The Code also helps you comply with

laws, Target policies and procedures. Any

reference to “laws” in this Code includes any

applicable external rules and regulations that

apply to our business.

The Code covers a wide variety of situations

that you may encounter as a team member

to help you understand how you’re expected

to handle them. Whenever you have a

question, go to the Code first for guidance.

The Code can’t cover every possible work

situation, but it’s a good starting point and

the Ethics team is here to help you when

you’re not sure about what to do.

each topic in the Code covers

our commitment

what we believe as an organization

and why this topic is important

how it’s done

the way we work to fulfill

our commitment

in your daily work

the actions you should take

to make ethical decisions

consider this

determine the impact to Target

before making decisions and

taking action

what if

common scenarios that may arise

and guidance on what to do

policy spot

learn more about specific policies

or resources that impact your work

the Code applies to all team

members

As a team member at Target Corporation,

“Target” or “our Company”, the Code

applies to you, no matter what job you hold.

Whether you work in the stores,

supply chain

locations

, headquarters, global offices or

any other Target location, you will be held

accountable for understanding and following

the Code, Target policies, procedures and

the laws that apply to Target.

when the Code is violated

If someone violates our policies, ignores

another team member’s misconduct or

pressures someone to violate our Code, the

impact could damage Target’s reputation,

compromise guest and team member safety,

jeopardize our financial health and decrease

guest trust.

As a team member, you are obligated to

follow the Code and report any violations

or potential violations.

Any action Target

takes will be prompt, fair and consistent and

may involve disciplinary action, including

immediate termination. If your actions violate

the law, additional legal consequences may

impact Target and result in civil penalties,

criminal prosecution, fines and even jail time

for you, other team members and leaders.

Our Board of Directors has its own separate

Code of Ethics within in our Corporate

Governance Guidelines that is similar to this

Code but tailored to the responsibilities that

are unique to Board members.

how to use our Code.

your rights as a team member

You have rights as a team member under

specific labor laws within each country. Nothing

in this Code is meant to interfere with those

rights, including which include, among other

things, your right to communicate about:

•

Wages or hours

•

Other terms and conditions of your

employment

Nothing in this Code or any other Target

policy or agreement prohibits you from

reporting any potential legal violations to

a government authority.

All team members have the right to be

heard when they have an issue or a concern.

Target provides a variety of outlets for team

members to express their concerns. Refer to

the

Open Door Culture

guidelines for more

information.

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Target Corporation Code of Ethics Handbook — page 7

If you see or suspect any activity that

violates our Code, policies or laws, you

have a responsibility to promptly report in

good faith using one of the reporting

options. You also have a responsibility to

report any suspected violations shared

with you by another team member.

There are times when you may need to

seek guidance on what action to take,

as the Code cannot include every topic.

The Ethics team is here to help you make

the right ethical decisions.

The Ethics team will work to ensure the

appropriate teams are engaged to evaluate

any reported matters.

What should I do if …

I have questions or

need guidance

I observe, experience or suspect

unethical conduct

There is a problem

that may put

Target, the team or our reputation

in jeopardy.

Target does not tolerate retaliation

of any kind against someone who

reports a concern in good faith.

Voice a concern, ask a

question or report a violation.

Talk

Talk to your leader or Human

Resources partner.

ethics@target.com

Visit

www.TargetIntegrityHotline.com

Call

Integrity Hotline, anonymous

option available 24 hours a day

U.S.:

1-800-541-6838

India:

000-800-

100

1657

Other non-U.S. locations:

place a collect call to the U.S.

at: 1-470-219-7116

Write

Corporate Compliance & Ethics

Target Corporation

1000 Nicollet Mall #3110

Minneapolis, MN 5540

What happens when

you contact Ethics?

The Ethics team or third-party

hotline representative creates a

report of your concern.

Every allegation received is

appropriately investigated and only

the necessary partners are involved.

If your report is substantiated, Target

will act promptly and appropriately.

The outcome may be kept

confidential.

reporting concerns.

Point your smartphone camera

at this QR code, then tap the

pop-up notification to go to the

Integrity Hotline website.

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Code of Ethics

putting ethics into action

how to comply with our Code

how to comply with our Code.

Know your responsibilities.

Open your door

Create a safe environment and

encourage team members to come

to you when they need to talk. Listen,

offer guidance, and follow-up. Contact

ethics@target.com

promptly to

report employee concerns or if

you need additional guidance.

Take action

Watch for misconduct. If you become

aware of a violation, a potential

violation or any other concern,

voice your concerns immediately

Never retaliate or allow others to retaliate.

Be a good example

Make ethical decisions, model

Target values and demonstrate them

in everything you do.

Encourage team

members to always do what’s right for

Target and use the reporting options to

share concerns. Never pressure or direct

any team member to knowingly falsify,

misstate, manipulate, or inaccurately

represent any information that could

violate Target’s Values, Code of Ethics,

Policies, procedures or the law.

Set expectations

Talk openly about ethics in your

business and let team members know

that you expect them to make ethical

business decisions.

Talk up the Code

Refer to the Code often and know

where to go for resources and answers

to team member questions.

Leaders have additional responsibilities:

As team members, you’re expected to:

Follow the law

Get to know the laws that apply

to Target and your job. Follow them

consistently and ask questions

if something isn’t clear.

Stay alert and voice

your concerns

Watch for potential violations of our

Code, our policies or any laws and

voice your concerns immediately

Live Target values

Make sure every action you take

is professional and ethical and that

your behaviors align with our values.

Understand and follow

the Code

Read the Code carefully and refer

to it often, along with the policies

that apply to your work.

Prioritize Target’s

business interests

Always look out for Target’s best

interests when making business

decisions or taking action.

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Target Corporation Code of Ethics Handbook — page 9

consider the impact and risk to Target when

making decisions

We must proactively identify and manage risks, always

looking out for Target’s best interests.

understand your impact

Each decision you make has an impact on our Company.

That’s why you must always be mindful of making decisions

that reflect the very best in ourselves and our Company.

Sometimes it’s hard to know “what is the right thing to do?”

So, consider the ethical decision-making tool before making

decisions or taking action.

If you’re ever in a situation where the ethical choice isn’t clear,

ask yourself:

ethical decision-making tool

making ethical choices.

If you answered “

” to any of these questions, the answer is simple – “

don’t do it

” – and

voice your concern

if someone else is doing it. If you’re not sure, stop and reconsider the

impact of your actions. Ask for advice by contacting

ethics@target.com

– that’s always the

right choice.

Is it legal?

Is it in line with our values,

policies and our Code?

Does it enhance

our reputation?

If my decision or action

was reported in the media,

would it reflect positively on Target?

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Target Corporation Code of Ethics Handbook — page 10

working

together.

Together we build trust by taking

personal accountability for our

behaviors and actions.

appreciate our diversity and

demonstrate inclusivity ...................................

show respect at work .....................................

promote health and safety ..............................

record time honestly.......................................

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Target Corporation Code of Ethics Handbook — page 11

Discrimination based on protected status

is illegal and it goes against everything

Target stands for.

That means we don’t

discriminate against team members,

applicants or business partners based

on characteristics like:

• Race, national

origin or ancestry

• Color

• Sex

• Pregnancy status

• Gender

• Religion or

religious creed

• Age

• Medical condition

or disability

• Sexual orientation

• Gender identity

or expression

Voice your concerns.

If you ever experience,

see or suspect behavior that violates our

commitment to inclusion or equality, don’t

ignore it.

Voice your concerns immediately

so we can take action to protect our guests,

each other, and our workplace.

our commitment

We value and support each other and work

to ensure a diverse, welcoming and inclusive

culture. At Target, we know every team

member has something to contribute. When

we are inclusive and do our best to create

opportunities for everyone, we all benefit from

the richness of different perspectives and

enhanced points of view across our team.

how it’s done

We aim to champion a more inclusive society

and deliver inclusive guest experiences by

embracing diversity and making Target an

inclusive and welcoming place to work. Our

aspiration is to have a team that represents

the spectrum of guest perspectives and a

workplace that supports and enables those

perspectives to exist within our business

objectives. That is what will help us deliver

on behalf of our guests.

At Target, embracing diversity means

understanding and recognizing that each of

us is unique and our dimensions of difference

are one of our greatest strengths. Inclusion

is about creating an environment where

everyone feels welcome, valued and

respected. It means that all individuals enjoy

a sense of belonging and level of support

that allows them to do their best work.

in your daily work

Strengthen inclusion acumen.

strengthening your inclusion acumen,

you can help everyone around you feel

welcomed, respected and valued.

Examples of inclusion acumen include:

• Seeking to understand the viewpoints

of others and advocating on their

behalf

• Creating a safe environment for the

team where all perspectives are

welcome

• Being aware of societal issues that can

impact the team and our business

Promote equal employment opportunities.

We believe that every individual deserves an

opportunity to succeed, so we follow laws that

promote equal employment opportunities.

policy spot

Equal Employment Opportunity and

Harassment-Free Workplace Policy

appreciate our diversity and demonstrate inclusivity.

We embrace diversity and strive to give everyone access to the same opportunities.

• Marital status

• Citizenship status

• Military or

veteran status

• Genetic

information

or characteristics

(or those of a

family member)

• Perceived

membership in a

protected class

• Any other

characteristic

protected by

applicable laws

what if

I believe a job applicant may have

been disqualified because of a

disability, but since I wasn’t actually

involved in the hiring process, should

I just let this go?

No, you shouldn’t. If discrimination did

occur, it could violate the law and our

commitment to equal opportunity.

Voice your concerns immediately

consider this

If you witness or experience behavior that

you believe is discriminatory, always

remember that you can reach out to any

leader with your concerns, even if that leader

is not your direct supervisor. You have multiple

reporting options to

voice your concerns

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Target Corporation Code of Ethics Handbook — page 12

our commitment

Harassment based on protected status in

any form, is illegal and will not be tolerated.

It’s your responsibility as a team member to

prevent any type of harassment at Target.

Examples of harassment include, but are

not limited to, intimidation, bullying, stalking,

verbal or physical aggression, harassment or

coercion.

Harassment and other intimidating or abusive

behavior can do widespread damage, harming

those who are targeted and our work

environment. That is why we won’t tolerate

harassment by anyone at Target and work

to ensure that everyone feels comfortable

and respected at work.

how it’s done

One of the best ways to prevent harassment

is through awareness – team members

watching out for each other and using care in

their own interactions. Treat each person you

encounter with respect and fairness, including:

• Coworkers

• Leaders

• Business partners

• Guests

show respect at work.

Target believes that each individual deserves respect and a workplace that’s free from harassment.

policy spot

Equal Employment Opportunity and

Harassment-Free Workplace Policy

Violence-Free Workplace Policy

what if

A coworker often insults me, then turns

around and says, “Just kidding.” This has

been going on for a long time, and it’s

really upsetting me. Am I overreacting if

I voice my concerns?

No, you’re not. Harassment can be a

matter of perception. If it’s hurtful to

you, it shouldn’t be tolerated, and we

need to know about it.

Voice your

concerns immediately

in your daily work

Recognize signs of harassment.

When

behavior interferes with someone’s work or

creates a hostile or offensive environment,

it may be harassment, particularly if it’s

based on a person’s race, color, sex, gender,

national origin, citizenship status, religion, age,

disability, sexual orientation, gender identity or

expression, genetic information or any other

protected class. Harassment can take a variety

of forms and can be visual, verbal, physical or

sexual in nature.

Stay alert for sexual harassment.

This type

of harassment includes asking someone out

repeatedly, sexual advances or requests for

sexual favors, inappropriate touching, sharing

of sexual materials/jokes, continuing to make

sexual advances after being refused or any

other inappropriate verbal or physical conduct.

Sexual harassment can occur unintentionally,

so be aware of your own behavior.

Help stop bullying.

Sometimes harassment can

involve bullying or persistent mistreatment that

threatens someone’s physical or emotional well-

being. Bullying can be targeted at a single person

or a group and could involve singling someone out

for ridicule, exclusion or other harmful treatment.

Stay alert for violence.

Target has a

Violence-

Free Workplace Policy

and prohibits any acts or

threats related to violence.

Voice your concerns.

If you have seen, heard or

experienced, harassing or intimidating behavior,

don’t let it continue – you have a responsibility

to report your concerns.

Voice your

concerns immediately

consider this

Harassment takes many forms and might

look like:

• Jokes, slurs or gestures

• Threats or intimidation

• Stalking

• Sharing offensive material

• Coercion

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Target Corporation Code of Ethics Handbook — page 13

our commitment

We want to maintain a safe and secure

work environment for our team members,

contractors and business partners and a

safe shopping environment for our guests.

This requires each team member to commit

to being a safety advocate at all times

and to follow all laws, safety procedures

and the Occupational Safety and Health

Administration (OSHA) standards.

how it’s done

When you stay alert and follow our safety

procedures, you’re better able to protect

yourself, your coworkers and our guests.

Recognize your responsibility to help maintain

a safe and healthy workplace and take action

when potentially unsafe situations come up.

in your daily work

Prevent substance use.

Working under the

influence of drugs or alcohol is risky – for you

and everyone else. The use, consumption,

or possession of any drug or controlled

substance that isn’t used or obtained legally

(including prescription drugs that have been

prescribed to someone else) is prohibited.

Always keep a clear head and don’t bring

these substances into our workplace. Don’t

try to work if your judgment or abilities

are impaired (even by legally-obtained

prescription drugs).

Voice your concerns

immediately

if you become aware of

substance abuse in the workplace.

Additionally, Target maintains a tobacco-free

workplace, so tobacco in any form (including

electronic cigarettes) is prohibited outside of

designated areas.

Follow safety rules.

Our health and safety

programs and procedures are here for you,

so follow these closely, with no exceptions

and no short-cuts. Use personal protective

equipment (PPE) as required, and report

incidents, injuries and near misses right away.

Talk to your leader if you become aware of a

safety hazard or unsafe behavior, so it can be

addressed immediately.

Stay alert for violence.

We don’t permit team

members to possess weapons of any kind in

our workplace, and we won’t tolerate threatening

behavior against any team member or guest.

Target has a

Violence-Free Workplace Policy

and prohibits any acts or threats related to

violence. If you ever see or suspect harmful

behavior or weapons, immediately contact one

the following:

• Your leader

• Human Resources partner

• Corporate Security (HQ)

• Assets Protection (Stores/

Supply Chain

locations)

Store and team members.

Be sure to

reference the Stores and

Supply Chain

Emergency Procedures Flipchart often to

ensure you are prepared to respond to any

number of situations, including assault and

active shooter scenarios.

promote health and safety.

We look out for each other and do our part to maintain a safe, healthy and secure environment.

policy spot

Safety Policy

Violence-Free Workplace Policy

Visitor Management Policy

what if

While unloading the trailer a few pallets

and carts are pulled into the fire aisle

to give the team more room in the

backroom. You just learned that leaving

anything in the fire aisle is a violation of

OSHA, fire code and Target policy, but

the items will only be in the aisle a short

time, and team members will be nearby

to remove them quickly if needed. Is this

something I should report?

Yes. Remove the items from the fire

aisle immediately and remind leaders

and team members that “nothing in

the fire aisle” means just that – even

if items are there only “temporarily.”

Voice your concerns immediately

consider this

Injuries can happen to anyone and can be

life-altering events that could affect what

you, your team and our guests are able to

do at work, home or at play. Always follow

safety best practices to:

• Call out and resolve hazards

• Act in a safe manner

• Stop any unsafe action or condition

Help make sure that you, your team and our

guests leave each of our locations safely.

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Target Corporation Code of Ethics Handbook — page 14

our commitment

Target follows all employment laws, including

those involving wages earned and hours

worked. Violating these laws goes against our

values. It’s not just a legal issue – it’s an issue

of what’s right.

how it’s done

Being paid for all time worked is our promise

to our team members, but to make sure it

happens, we depend on hourly (non-exempt)

team members to record the time they work

honestly and accurately and follow our

requirements for meals and break periods.

in your daily work

Don’t work off the clock.

It is illegal and

against Target’s policy for non-exempt or

hourly team members to work (or be paid for

work) outside of scheduled work time. This

is considered “working off the clock” and is

illegal. If you lead a team, make sure non-

exempt team members are provided time to

take required duty-free meal periods and rest

breaks and account for all of the time they’ve

worked.

Record responsibly.

If you are a non-exempt

or hourly team member, accurately record

the time you start and stop work, and submit

a punch correction if you missed recording

your time. Only record your own time – never

record a coworker’s time in or out under any

circumstances. If you see an error on your

paycheck, talk to your leader right away, and

voice your concerns immediately

about

wage and hour issues.

Submit time off.

Promptly submit actual time

off honestly and accurately.

record time honestly.

We value our team members and compensate them for all time worked.

policy spot

Team Member Handbooks

consider this

Working off the clock happens when someone:

• Starts work before punching in

• Works during a meal break or rest

period

• Works or is asked to work after

clocking out

Code of Ethics

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record time honestly

what if

I am a non-exempt team member and

on a busy day, my leader has asked

me to work an extra half hour without

recording the time. I really don’t mind,

but is this OK?

No, it’s not. Your leader is prohibited

from asking or requiring you to work

outside your regular hours or to be

dishonest with your time record.

Voice your concerns immediately

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Target Corporation Code of Ethics Handbook — page 15

maintaining

trust.

The everyday choices we make matter

to those we work with and our guests.

provide safe food and products ......................

select business partners carefully ..................

avoid conflicts of interest ................................

be truthful in marketing and advertising ..........

keep privacy in mind .......................................

manage financial products ..............................

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Code of Ethics

maintaining trust

provide safe food and products

our commitment

Our guests expect the products they purchase

from Target, regardless of brand, to function

properly and be safe to consume or use.

Anything less could harm guests, damage our

reputation and jeopardize guest trust. We’re

committed to protecting our reputation for

quality and safety by setting high expectations

for ourselves and our business partners.

how it’s done

It’s up to team members to take pride in

our Company and the products we offer by

initiating conversations with business partners

to ensure they understand and comply with all

applicable laws and meet safety and product

quality standards.

in your daily work

Monitor business partners.

If you work with

our business partners, ensure they have the

expertise, experience and capacity to provide

the type of products we are purchasing from

them. Ask questions about what product

quality and safety programs they have in place.

Seek guidance from the appropriate teams to

understand all applicable requirements.

Insist on safe products.

We expect our

products to comply with all applicable product

laws. Make sure the business partners we work

with are aware of compliance requirements and

Target requirements to ensure that we offer safe,

reliable and quality products. Seek guidance

from the appropriate teams so you understand

all applicable requirements before any product

reaches our guests.

Insist on safe food.

Our

Supply Chain locations,

Import Warehouses and Stores must comply

with all applicable health and food safety laws

and standards with no exceptions. Make sure

they are clean, sanitary and well-maintained.

You should also understand and follow all safe

food handling procedures. Food and beverages

for humans or animals should not be offered for

sale past their expiration dates. Perishable foods

should be stored, transported and displayed at

the proper temperatures.

provide safe food and products.

We are committed to providing our guests with safe, reliable and quality products.

what if

I noticed a team member who was in

a hurry to stock produce. They finished

eating their lunch, then immediately

went out to the floor and started

handling the fruit they were stocking. Is

this OK?

No, it isn’t. Personal hygiene is critical

when it comes to food safety, including

hand washing after touching your face,

hair, clothing or equipment.

Voice your

concerns immediately

If you are a leader, ensure proper training.

Make sure any team member who handles

food receives the proper training. If you see

anyone, including a team member, leader or

vendor compromising our safety or cleanliness

standards, don’t ignore it.

Voice your concerns

immediately

Know how to handle product removals.

Issues with products may arise and pose a risk

to our guests and Target’s reputation. If this

happens, the Product Investigations and Removal

(PIR) team within Product Safety and Quality

Assurance (PSQA) for General Merchandise

or the Food and Essentials Safety and Quality

Assurance (FESQA) team for Food and Essentials

will investigate and may work with stores and

supply chain locations

to execute a market

withdrawal or consumer level recall. Promptly and

carefully follow instructions to quickly stop sale

and remove product from the shelves and supply

chain. The authorized teams may notify guests of

a product safety issue.

consider this

If your job impacts product or food safety

or quality, understand and follow:

• All applicable laws

• Applicable product safety standards

• Internal compliance requirements

•

Third Party Risk Policy Requirements

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Button 10.Page 16

Target Corporation Code of Ethics Handbook — page 17

our commitment

The actions of any business partner (including

vendors, suppliers, third-party sellers,

manufacturers, contractors, subcontractors,

locations and their agents) who work with

us, or on our behalf, may have a direct effect

on our reputation. There’s a lot at stake: an

unethical act, breach of trust or a law violation

can have serious consequences for us. So, we

take care in choosing our business partners.

how it’s done

We rely on team members to choose and

manage business partners wisely. This

includes monitoring each business partner

throughout the business relationship life

cycle beginning with proper selection and

onboarding in accordance with our

Vendor

Risk Management Policy

in your daily work

Choose wisely.

If you’re responsible for a

business partner relationship, make your

selections carefully by weighing criteria

such as ethics, quality, service, price,

reputation, availability, experience, equity

and inclusion.

Set the standard.

All business partners

must follow our

Business Partner Code

of Conduct

and

Standards of Vendor

Engagement (SOVE)

, which describes

what we expect from them. Examples of

these expectations include, but are not

limited to:

• Meeting our quality, compliance and

security standards

• Complying with all laws and Target

policies applicable to their business

and products

• Maintaining a safe and healthy

workplace

•

Treating workers fairly and not

tolerating discrimination, harassment

or unlawful labor practices

• Prohibiting underage or child labor

• Prohibiting the use of forced labor

or human trafficking in their

operations and within the operations

of their suppliers

select business partners carefully.

We are committed to doing business ethically and legally and seek to work with business partners who share the same commitment.

policy spot

Standards of Vendor Engagement (SOVE)

Vendor Risk Management Policy

Conflicts of Interest Policy

Anti-Bribery Policy

what if

I visited a third-party work site recently and

heard my point-of-contact instructing their

employees to “stay until the work is done.”

Their comments raised concerns that they

may be violating wage and hour laws. Do I

have a responsibility to say something?

Yes. We hold our business partners

accountable to our high standards and

expect them to follow the law. Target does

not tolerate illegal employment practices.

Take note of the situation and

voice your

concerns immediately

Stay involved.

If you work with business

partners, initiate conversations to confirm

they understand the importance of complying

with the laws that apply to their products

or services and align to our commitments.

Monitor their performance under their contract

to ensure they are meeting their obligations. If

you see or suspect any activity that could put

our Company or our guests at risk,

voice your

concerns immediately

Code of Ethics

maintaining trust

select business partners carefully

consider this

There is information throughout our Code

that speaks to our relationships with

business partners. If you work with business

partners, make sure you understand what’s

required by type of business partner and

initiate conversations with your partners

to ensure they understand the following

requirements:

• Promote product safety

• Protect third-party information

• Avoid conflicts of interest

• Uphold ethical business practices

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Business Partner Code of Conduct

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Button 10.Page 17

Target Corporation Code of Ethics Handbook — page 18

our commitment

We never allow our personal interests to

impact the business decisions we make as

Target team members. When our outside

activities conflict or even appear to conflict

with our responsibilities as a Target team

member, we avoid and disclose any activity

that could be considered a conflict of interest.

how it’s done

The best way to avoid a conflict of interest

is to know and avoid the types of situations

where conflicts typically arise between

personal and business interests and

relationships. Seek guidance immediately if

you see, hear or suspect a potential conflict.

Always prioritize Target’s business interests

when making decisions.

in your daily work

Be alert to the activities of family members

or close personal relationships.

Conflict of

interest situations extend beyond your own

activities – they also apply to the activities

of your family members/close personal

relationships. Always disclose any personal

or family relationships or activities that have

the potential to influence decisions you make

on the job. If you’re not sure if a particular

situation creates a conflict, always ask for

guidance by contacting

ethics@target.com.

Know when to say “No.”

Offers of gifts,

entertainment or accommodations that do

not further a legitimate business purpose or

don’t comply with our policies can also create

a conflict of interest and cause others to

question your objectivity. Know what’s allowed

– and what isn’t – and turn down anything that

is, or could be perceived as a violation of our

policy.

Consider your influence.

Never misuse the

authority of your position for personal benefit.

Your role should never be used to acquire

anything of value or pressure a business

partner for personal gain.

Disclose potential conflicts.

Despite your

efforts, conflicts of interest can still arise,

even if you’re careful to avoid them. Promptly

disclose any actual, potential or perceived

conflict to your leader, Human Resources

partner or the Ethics team so it can be

addressed and resolved. Depending on the

job you hold, you may be required to complete

an annual Conflicts of Interest Disclosure

Statement.

Be aware.

It’s not possible to list every

situation that could pose a conflict, but here

are some that often arise:

avoid conflicts of interest.

We have interests and relationships outside of work, but we act in Target’s best interest and avoid even the appearance of a conflict of interest.

•

A business partner offering to pay for

a meal, gift or entertainment that does

not further a legitimate business purpose

or does not meet a Target business

objective.

• Investing in a company that competes

with, does business with or seeks to do

business with Target

• Transacting business on behalf of Target

with a company in which you or a family

member has a substantial financial interest

• Using your position or authority at

Target, or company property, resources

or information, for personal gain instead of

putting Target first

• A family member performing services for

a current or prospective business partner

or for an entity that competes with Target

• Becoming a member of an outside board

of directors or advisory board

Code of Ethics

maintaining trust

avoid conflicts of interest

policy spot

Conflicts of Interest Policy

Conflicts of Interest Business

Amenities Table

Travel and Expense Policy

consider this

Not sure if there’s a conflict of interest?

Ask yourself:

• Could it affect my objectivity?

• Could it influence the decisions I make

on behalf of Target?

• Could an outside observer view it as

a possible conflict?

If the answer to any question is “yes,” or

“I’m not sure,” seek guidance.

what if

A business partner that works with Target

asked if I would be willing to do a little

work for them “on the side.” Is this OK?

It depends. If the work is unrelated to

Target’s business, it may be OK. If the work

competes with our business, or interferes

with your ability to do your job or could

influence your judgment, you should

not accept it. It is also a conflict if you

are responsible for managing or making

decisions about that business relationship

on behalf of Target. The best course of

action is to contact

ethics@target.com

and

ask for guidance before proceeding.

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Button 10.Page 18

Target Corporation Code of Ethics Handbook — page 19

our commitment

Our guests make decisions about where

they’ll shop and what they’ll buy based

on what they see in stores, online or what

they learn about us. We have an obligation

in our promotions, advertising and guest

communications to follow all laws and

provide guests with accurate information.

how it’s done

Honesty really is the best policy. When you

communicate clearly and accurately about

our products, you keep our guests happy

and promote Target’s brand. You also

preserve the reputation we’ve earned as

a Company that does what’s right.

in your daily work

Maintain trust.

If your work involves

promotions, advertising or guest

communications, observe responsible

advertising practices and comply with all

applicable laws. Make sure that any claims

you make:

• Are true

• Have been adequately substantiated

• Accurately state prices

Always make sure that product attributes

accurately represent the quality, features and

availability of our products.

Engage responsibly.

Before engaging

and compensating an influencer who will

reference or endorse Target, you must obtain

pre-approval from

Business.Affairs@target.

com

Honor guest expectations.

We strive to have

advertised merchandise available for guests

to buy. If a product doesn’t live up to guest

expectations, we honor our return policy.

be truthful in marketing and advertising.

In promoting our business, we communicate accurately and honestly.

what if

My team has been working on an

advertising campaign for a new apparel

line, and we want to generate excitement

about it. Can we suggest that wearing

the gear will help burn calories as long

as we don’t say it directly?

No. All claims must be accurate and

comply with any applicable laws, and

we must have substantiation from our

vendor or supplier for the claims before

we make the claim in our ads – whether

the claim is expressed or implied.

policy spot

Social Media Policy

consider this

Laws related to truth-in-advertising and

marketing apply on our product packaging

and hangtags, and anywhere we place an ad.

Examples include, but are not limited to:

• A newspaper or magazine

• The internet

• Postal mail

• Billboards or buses

Always know and comply with the law.

Code of Ethics

maintaining trust

be truthful in marketing and advertising

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Target Corporation Code of Ethics Handbook — page 20

our commitment

As part of our day-to-day operations, we

come into contact with the personal

information of our guests, team members

and business partners. We understand the

critical obligation we have to collect, use and

share this information in an appropriate way

and follow the laws that prevent improper

disclosure or use.

how it’s done

We expect you to protect the privacy of

guests, team members and business partners,

and take precautions to keep all personal

information safe. Follow all applicable data

privacy laws and our Enterprise policies

for collecting, storing, using, sharing and

disposing of personal information.

in your daily work

Be able to recognize personal information.

Personal information is any information that

alone, or in combination with other data,

can identify an individual, either directly

or indirectly.

Examples of personal information include,

but are not limited to:

• Name

• Address

• Mobile device ID

• Date of birth

• Social security number

• Credit card number

• Email address

• Phone number

Handle personal information responsibly.

Use personal information only for legitimate

business purposes. Responsible handling

of personal information includes, but is not

limited to:

• Share personal information only with

others authorized to see it and who

have a business need to know it

• Share personal information externally

only if you have appropriate contract

language in place or if required

or permitted by law

• Collect, use and share the minimum

amount of personal information

necessary for your project

• Use guest personal information only for

purposes disclosed in the applicable

privacy policies or consent form

• Use team member personal information

only for employment-related purposes,

unless you receive consent from the team

member to use it for another purpose

• Keep personal information only to fulfill the

reasonable business purposes for which it

was collected or for legal compliance

• Destroy personal information when no

longer needed or remove details that could

identify someone

keep privacy in mind.

We are committed to handling personal information responsibly.

Code of Ethics

maintaining trust

keep privacy in mind

policy spot

Privacy Compliance Policy

Target Privacy Policy

consider this

Understand where you encounter data in

your role and help protect guest and team

member personal information by:

• Recognizing personal information and

following all laws to protect it

• Handling and protecting personal

information with care

• Using personal information only for

legitimate business purposes

what if

I am on a marketing team and would

like to email a merchandise coupon to

a list of guests who have purchased an

item on Target.com. What should I do?

If you don’t normally send guest emails

as part of your work, contact the Privacy

team at

privacy@target.com

before you

proceed. Marketing emails are subject to

federal law that, if violated, may have

serious legal and reputational consequences

for Target. They must have specific

content and include a link to unsubscribe.

Additionally, marketing email lists must

come from Target’s Email Marketing

Universe and exclude guests who have

opted out of email marketing.

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Button 10.Page 20

Target Corporation Code of Ethics Handbook — page 21

our commitment

We comply with the laws that relate to our

consumer financial products, the way we

offer financial products and how we manage

guest data. Each guest interaction gives us the

opportunity to build and deepen guest trust,

so we take great care in offering payment

options that work for our guests and handle

all personal information responsibly to protect

that trust.

how it’s done

Each of us has an obligation to follow the laws

that relate to how we manage and promote

financial products, disclose product terms

and collect on past-due payments. We also

have a responsibility to safeguard all personal

information that our guests share with us.

in your daily work

Stay up to date.

If you are involved in

creating, marketing or managing any of

our financial products (such as the Target®

Mastercard®, Target Credit Card™, Target

Debit Card™, Target GiftCard™ or prepaid

cards offered by other issuers), complete

your required training and follow all

laws and policies that apply to these

payment responsibilities.

Handle guest personal information with

care.

If you manage financial products,

payment terms or collect data, there are

many laws you need to follow to protect our

guests and lawfully manage our financial

business. It is up to you to secure guest data

by following all applicable laws, policies and

procedures, as this is a critical component of

managing our financial products.

manage financial products.

We want our guests to have a good experience using our guest services and financial products.

Code of Ethics

maintaining trust

manage financial products

consider this

Laws are far-reaching and govern our work.

Financial Retail Services team members

must understand how we:

• Advertise our financial products and

disclose product terms

• Manage cardholder accounts and

collect on past-due balances

Store team members must understand

the following:

• The proper way to open a Target

RedCard™ account for a guest: only

with their knowledge and consent

• How to display Target GiftCards™ and

prepaid cards

• Follow all point of sale (POS)

prompts (refer to Target’s

Anti-

Money Laundering

Policy

for more

information)

We count on you to know what’s required

and to ask questions when you don’t know

what is required.

policy spot

RedCard Sales Practices Policy

Anti-Money Laundering Policy

TD Bank Privacy Policy for

Target Credit Card

Target Debit Card Privacy Policy

what if

A coworker told me if they haven’t received

a RedCard™ application in a while, they

reapply with their own information to help

increase the store’s RedCard™ application

totals. What should I do?

You should use one of the ethics reporting

options to

voice your concern

. Entering

applications in your own name or in

someone else’s name is a violation of

the

RedCard Sales Practices Policy

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Target Corporation Code of Ethics Handbook — page 22

conducting

business fairly.

Our everyday actions focus on our honesty

and accountability in our work.

prevent bribery ................................................

follow international trade rules ........................

provide accurate financial information .............

trade securities fairly and legally .....................

prevent money laundering ...............................

compete fairly .................................................

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Code of Ethics

conducting business fairly

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Target Corporation Code of Ethics Handbook — page 23

our commitment

There’s only one way we win in business –

by acting ethically. We neither rely upon nor

tolerate unethical or illegal business practices.

This activity damages our Company and the

communities where we operate.

how it’s done

We comply with all anti-bribery laws. You

may never authorize, offer or pay a bribe

to a government official. You must watch

business partners closely to make sure

they don’t pay bribes.

in your daily work

Remember, a bribe can take many forms.

A bribe can be anything of value. Examples

include, but are not limited to:

• Cash, a gift card or merchandise

• A meal, gift or entertainment

• Travel

• A charitable or political contribution

• An offer of employment or an internship

Get to know the law.

Bribery laws around

the world, including the U.S. Foreign Corrupt

Practices Act (FCPA), apply to our business.

In addition to prohibiting bribery, the FCPA

requires companies to keep accurate books

and records and maintain effective financial

controls. Ask for guidance if you need help

understanding how to comply with these laws

by contacting

ethics@target.com

Be vigilant.

Work with the Compliance team or

the

Third Party Risk and Compliance

team to

complete the required due diligence process

prior to using any vendor that will be interacting

with government officials on Target’s behalf.

Closely monitor the activities of all business

partners, even after they are hired.

Voice your

concerns immediately

if you suspect a bribe.

prevent bribery.

We work honestly, without resorting to bribery in any area of our business.

Use extra care with government officials.

If you work with government officials or hire

a business partner to work with government

officials on Target’s behalf, make sure you

understand your responsibilities for ensuring

compliance with Target’s

Anti-Bribery Policy

Code of Ethics

conducting business fairly

prevent bribery

what if

I would like to pay for a government

official’s meal. Can I do that?

Generally, no. However, if the meal serves

a permissible business purpose, is modest

and customary in nature and does not

violate any applicable law, you may seek

approval from the Vice President of Ethics

by emailing ethics@target.com. Consult the

Anti-Bribery Policy

for additional details.

consider this

Someone in another country might tell you

a bribe is customary there. It may seem like

the easiest way to get something done, but

it’s always wrong. Don’t ever pay it or allow

anyone else to pay it.

policy spot

Anti-Bribery Policy

Vendor Risk Management Policy

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Code of Ethics

conducting business fairly

follow international trade rules

home

our commitment

As an importer of significant size, Target is

committed to following all trade laws that

apply to our business. International trade

rules regulate where, how and with whom we

can conduct business across borders. We

follow these rules to comply with the law, to

avoid incurring penalties or sanctions, and to

preserve Target’s status as a trusted trader.

We strive to maintain positive relationships

with the U.S. government agencies that have

oversight of international trade.

how it’s done

If your work in the supply chain involves

international trade compliance, we expect

you to know, understand and follow the laws

that apply to your work and the movement of

our goods. Initiate discussions to understand

how your internal and external supply

chain partners are also complying with the

international trade laws that apply to their

business and operations.

in your daily work

Respect trade regulations.

There may

be times when it is unclear what laws,

customs and practices govern a particular

international trade transaction. If questions or

potential conflicts arise and you’re not sure

how to proceed, always ask for guidance by

contacting

ethics@target.com

. If you have

reason to believe that a supply chain business

partner is violating an applicable law,

voice

your concerns immediately

Comply with government sanctions.

We don’t

conduct business with countries or entities that

are subject to trade embargoes or economic

sanctions, and we don’t participate in or

promote boycotts that the U.S. government

doesn’t support. If you work in the supply chain

and uncover or hear about any circumstances

that potentially violate those commitments,

voice your concerns immediately

follow international trade rules.

We import goods from around the world and follow the rules that apply.

Do your due diligence.

Remember that third

party business partners in the supply chain

represent us, and if they violate the law, Target

could be held responsible. If you work with

business partners in the supply chain, monitor

their performance and never overlook or ignore

any concerns that could indicate unlawful or

unethical activity.

If you work with merchandise business

partners, initiate conversations to ensure

your partners can validate that all product

information they supply is complete,

accurate and sufficient to satisfy applicable

trade law requirements.

what if

After determining the proper duty

classification for a new import item with

an origin of China, the classification

specialist informs the Sourcing Manager

(SM) that the product is subject to anti-

dumping duties at a rate of 250%. The SM

shares this information with the vendor,

who encourages the use of Taiwan as the

country of origin to evade the additional

duties. How should the SM proceed?

The SM should inform the business

partner that the proposal is illegal and

unethical. The SM should then escalate

the issue to their manager or

voice any

concerns immediately

consider this

Conducting business across borders is

complex and involves many laws enforced

by numerous agencies, which are often

subject to change. If you have responsibilities

for import compliance:

• Complete all required trainings

• Seek help if you have any questions

by contacting

ethics@target.com

Understand and follow the below:

•

Global Sanction Policy

•

Country of Production Governance

Policy

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Target Corporation Code of Ethics Handbook — page 25

consider this

Examples of financial records include, but are

not limited to:

• Payroll records

• Purchase orders or invoices

• Expense reports

• Sales or inventory data

• Regulatory filings

home

Code of Ethics

conducting business fairly

provide accurate financial information

our commitment

The U.S. Securities and Exchange Commission

and other governing bodies have strict rules

about the accuracy of our financial statements

and disclosures and the strength of our

internal controls over financial reporting. Our

financial and operational records must remain

accurate, so we can make sound business

decisions, keep our operations running

efficiently and meet our goals and obligations.

how it’s done

As team members, we have an obligation

to follow all internal control procedures to

maintain our financial records – this includes

submitting an expense report, reviewing or

approving financials and handling any other

business record. Accurate recordkeeping

helps us provide complete, accurate, timely

and understandable information in our public

disclosures.

in your daily work

Insist on accuracy.

Always record information

such as costs, expenses, time records and

contracts accurately. Follow our procedures

and never falsify a record or transaction,

including those required by regulatory

authorities or auditors. Save supporting

documentation in accordance with our records

management procedures and obtain any

needed approvals before submitting complete

and accurate expenses for reimbursement or

making payments on our behalf.

Review team member expenses.

If you are

a leader, you are responsible for reviewing all

expenses submitted by your team members

before approving expenses to ensure they are

accurate and truthful.

Know your responsibilities.

Keep in mind

that, our internal audit team and external

auditors periodically test our internal controls

and the accuracy of our financial statements

and disclosures. It is your responsibility to

know and follow all accounting standards for

your area. If anyone ever asks you to falsify

a financial record, or you become aware of

any violation of our accounting standards or

inaccuracy in our financial records,

voice your

concerns immediately

provide accurate financial information.

We present an honest and accurate financial image of our business.

what if

I work in accounting and recently

noticed some odd invoices from a

contractor. Every time they come in

the same coworker always says they’ll

handle it. Could this be a warning sign

of record falsification?

Yes, it could be. If you suspect invoices

are being paid to an unauthorized

organization, person or team member,

voice your concerns immediately

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Target Corporation Code of Ethics Handbook — page 26

our commitment

Trading securities of a company based on

inside information (information that is both

material and non-public) is illegal and unfair.

When we take steps to prevent it, we uphold

our Company’s reputation for dealing honestly

wherever we do business.

how it’s done

As part of your job, you may be exposed

to inside information about our Company

or another company, such as one of our

business partners. It is unfair and illegal to

use inside information to buy or sell securities

for personal gain. We should trade only when

information is lawfully and publicly available.

We should also not tip others by sharing inside

information with them to trade.

in your daily work

Recognize inside information that could be

material.

If you have access to information

that isn’t publicly accessible, you’re an insider.

Although you’re always obligated to maintain

the confidentiality of any non-public information

you learn as part of your job you should be

sensitive to information that could potentially

be used for insider trading purposes. Examples

of inside information include, but are not

limited to:

• Sales and earnings figures

• Projections and reaffirmations of

projections of future sales and earnings

• Dividend or share repurchase actions

• Significant mergers, acquisitions or

divestitures

• Significant new contracts or lawsuits

• Changes in key suppliers

• Key management changes

• Labor negotiations

• Pricing or marketing strategy changes

• Significant cybersecurity events

trade securities fairly and legally.

We promote trust in the marketplace by supporting fair and open securities markets.

what if

Another team member just told me that

a significant acquisition by Target of

one of its largest business partners has

gone public. Is it safe for me to buy more

shares of Target stock now?

It depends. Before trading, confirm

that the information has been publicly

announced by checking Target’s investor

relations website or another publicly

available source, such as an industry

website or journal. Additionally, you

should confirm that at least 24 hours

have passed since that information was

publicly announced. Finally, you should

evaluate any other information you know

and confirm that nothing is material and/

or non-public before you decide to trade.

Limit sharing accordingly.

Don’t share inside

information with anyone else at Target unless

that person reasonably needs the information

to perform their job. Information must never be

shared with anyone outside of Target, including

your family and friends. Always be aware of your

surroundings so that you don’t inadvertently share

information with anyone you shouldn’t.

Watch what you say.

Never recommend, instruct,

or suggest that anyone else buy or sell securities

of any company when you have inside information

about that company. This is called tipping, and the

consequences can be severe.

consider this

Even if you recommend that someone

else buy or sell securities of a company and

don’t give a reason for the recommendation,

you are still violating the law and our policy

when you have inside information about a

company. If you’re not sure if trading is

allowed, always seek guidance by contacting

ethics@target.com

policy spot

Securities Trading Policy

Acceptable Use of Information

Resources Policy

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Code of Ethics

conducting business fairly

trade securities fairly and legally

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Button 13.Page 26

Target Corporation Code of Ethics Handbook — page 27

our commitment

Money laundering is the process of moving

around money made from criminal activity

so that the proceeds appear legitimate.

Money laundering is illegal and can be

connected to almost any criminal activity,

including terrorist activities and drug

transactions. We conduct business carefully

to help prevent money laundering and other

financial crimes. Remaining alert, cautious

and inquisitive also helps protect Target,

our values and the economy.

how it’s done

We comply with anti-money laundering and

anti-terrorism laws in all countries where we

do business. We rely on you to monitor your

business closely so we can take the necessary

action to help prevent or report suspected

financial crimes.

in your daily work

Stay alert with gift cards.

Prepaid gift

cards are easy to resell and difficult to track,

making them an appealing tool for money

laundering. Our point of sale system is set

up to control this activity. If you are a store

team member, always follow register

prompts when assisting a guest with a gift

card transaction, never complete back-to-

back gift card transactions, and consult a

leader when prompted.

Be vigilant with large cash RedCard™

payments.

Large payments made with

cash are risky because the source of the

funds can be difficult to determine.

•

Store team members:

If a guest

makes a payment on their RedCard™

with a large sum of cash, notify

fraud.tips@target.com

after the

payment is made

•

Headquarters team members:

If you identify a large cash payment,

or several payments which equal a

large cash payment on a guest

account, notify

fraud.tips@target.com

prevent money laundering.

We remain alert, cautious and inquisitive to help prevent money laundering or other financial crimes.

consider this

Money laundering warning signs to watch for

include, but are not limited to:

• Large cash payment made to

a RedCard™

• Overpayment of RedCard™ followed by

a credit balance request

• Merchandise purchased with large

sums of cash

• Large purchases of gift cards or

prepaid products

• Attempts to avoid recordkeeping

requirements

• Payments to individuals not involved

in the transaction

• Attempts to disguise or withhold

identification information

what if

A guest is trying to purchase a large

amount of gift cards in a store. While

ringing up the sale, a register prompt

pops up to prevent the transaction from

being completed. What should I do?

Follow the point of sale (POS) prompts,

never attempt to override the pop

up and contact the Store Leader

immediately.

policy spot

Anti-Money Laundering Policy

Take a stand.

Remember that by preventing

money laundering, you’re not just protecting

Target – you may also be preventing a serious

crime. If any transaction, by either a business

partner or a guest, seems suspicious,

voice your concerns immediately

home

Code of Ethics

conducting business fairly

prevent money laundering

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Target Corporation Code of Ethics Handbook — page 28

our commitment

Acting ethically is core to our culture.

Competition and antitrust laws promote free

and fair competition between companies.

By complying with these laws, we contribute

to a thriving marketplace and compete

for business based on the quality of our

products and services.

how it’s done

Target acts with integrity and in the spirit

of fair dealing. To do your part, follow

antitrust laws and don’t make agreements

with competitors or others that restrain

competition. Use legitimate sources when

acquiring business information and when

doing business with others, avoid practices

that are unfair, manipulative or deceptive.

in your daily work

Follow antitrust laws.

Never discuss or

reach an agreement with a competitor on

price, terms of sale, assortment, margins,

promotions, business partner relationships

or the division or allocation of markets,

territories or channels where Target does

business. Avoid even the appearance that

any of our pricing, promotional or assortment

decisions are influenced by information

exchanged with a competitor.

Gather competitive information fairly.

If you

gather information about our competitors, use

honest methods. Never encourage anyone

to give you information that should be kept

confidential, and always refuse information you

suspect was improperly obtained. It is never

OK to share confidential information from a

previous employer.

compete fairly.

We compete vigorously, but always fairly and legally.

what if

We just hired someone who previously

worked for one of our competitors. Is

it OK if I ask them about some of the

secret new services their company was

developing before they left?

No. It’s never appropriate to ask

someone to disclose confidential

business information of a former

employer. We have a responsibility to

gather information ethically.

consider this

Before any interaction with a competitor,

consult with Target’s Law Department. If you

are engaging in a legitimate interaction with

a competitor (for example, a Target-approved

trade association), and the topic of an improper

agreement comes up (for example, aligning

retail pricing on a product), make sure you

immediately:

Stop the conversation

Make it clear you don’t want

to participate

Remove yourself from the situation

Voice your concerns immediately

policy spot

Antitrust Policy

home

Code of Ethics

conducting business fairly

compete fairly

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Target Corporation Code of Ethics Handbook — page 29

safeguarding

what’s ours.

Target’s reputation is in our hands, so we

carefully protect our resources.

secure our assets ............................................

protect non-public information........................

respect and preserve intellectual property .....

manage records ..............................................

communicate responsibly ...............................

home

Code of Ethics

safeguarding what’s ours

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Button 16.Page 29

Target Corporation Code of Ethics Handbook — page 30

our commitment

Target’s resources are provided to help us

manage our business effectively and efficiently

while serving our guests. If we use these

resources inappropriately, we inadvertently

risk financial loss, reputational damage and

our ability to grow and thrive.

how it’s done

Each of us is expected to care for Target’s

assets and use them responsibly, along with

any assets or information belonging to our

business partners. You are responsible for

the resources provided to you, which means

taking care of all resources to prevent any

loss, damage, theft, fraud, misuse, waste or

unauthorized disclosure.

in your daily work

Know what to protect.

Our assets take

different forms. Examples of assets include,

but are not limited to:

•

Physical assets

– merchandise,

samples, buildings, fixtures, office

furniture, tools, equipment, phones,

credit cards or cash

•

Technology

– computers, phones,

tablets, handheld devices, hardware,

software, network systems and access

to systems

Secure our assets.

Follow our security

procedures to secure Target assets. Unless

you’re authorized, physical assets should

never be removed from Target property

without permission or used for personal gain

or benefit. Protect and use Target equipment

and systems primarily for Target business., and

return immediately upon request or change of

work arrangement. If you see someone acting

suspiciously or engaging in dishonest activity,

contact either:

•

Assets Protection (Stores and Supply

Chain locations)

•

Corporate Security (HQ)

If you see this type of behavior,

voice

your concerns immediately

, as it is your

responsibility to protect Target’s physical

assets and ethical culture.

secure our assets.

We keep track of our physical property and assets, only using them for legitimate Target business.

consider this

One of the easiest ways to prevent a vehicle

break-in is to keep all valuables out of sight.

This is important when you are traveling

with a company-issued device such as a

laptop or iPad. If you leave company assets

in your vehicle, protect them by removing

them from sight. All company-issued

devices contain confidential information

and intellectual property that you are

responsible for protecting.

what if

I noticed a fellow team member taking

home returned merchandise. They said

it was damaged, so it didn’t matter. Can

they do that?

No, they may not. Even if merchandise

is damaged or to be disposed of, it’s

still Target property and needs to be

accounted for and properly processed

for inventory purposes.

Voice your

concerns immediately

policy spot

Acceptable Use of Information

Resources Policy

Conflicts of Interest Policy

Visitor Management Policy

home

Code of Ethics

safeguarding what’s ours

secure our assets

Hybrid Work Policy

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Target Corporation Code of Ethics Handbook — page 31

our commitment

Target’s non-public information can be a critical

business asset. Our top priority is keeping this

information protected and safe for our guests

and team members. If non-public information is

mishandled or disclosed, it can compromise trust,

negatively impact our business and damage our

reputation.

how it’s done

Everyone, at every level of Target, has a

responsibility to protect our non-public

information by following our

Acceptable Use

of Information Resources Policy

and the

Information Security Policy

. All team members

must also complete the required training to

understand the required behaviors and technical

requirements to help safeguard information

resources at Target.

in your daily work

Know what’s non-public.

Examples of

information not publicly available include, but

are not limited to information about Target’s

procedures, systems, operations, finances,

merchandising, contracts, strategies, product

development and guests.

Target’s information is classified as:

•

Public

•

Internal

•

Confidential

•

Secure Handling Required (SHR)

Share information wisely.

If you have access

to information that isn’t publicly available, handle it

with care.

•

Access only the information you need

to do your job, share and store it using

Target-approved tools and never share it with

anyone that is not authorized to access the

information

•

External business partners must have a non-

disclosure agreement or contract in place

prior to accessing any non-public Target

information

•

When discussing non-public information, pay

attention to your environment (for example:

elevator, breakroom, coffee shop, or home

office) and be mindful of others who could

overhear your conversations

•

Confidential or SHR information should never

be attached or included in meeting invites

as calendars are often accessible to team

members or contractors who may not be

authorized to access the information

•

Verify email addresses prior to sending, so

that information isn’t shared with the wrong

recipients

•

Protect your Target user ID and passwords

and never share this information with anyone

protect non-public information.

We handle our information with the utmost care, protecting it from misuse, disclosure and attacks.

what if

My business partner set up a file-

sharing site and asked me to send

Target documents to that location for

review. Since we have a contract, is this

OK?

No, it’s against Target’s

Acceptable Use

of Information Resources Policy

store or share Target information using

unapproved, external tools. Instead,

give the business partner access to the

documents through an approved Target

file-sharing tool. Refer to the

Where to

Share guide

for detailed direction.

Use strong security practices.

•

Review your emails carefully

Never click on any unfamiliar links

or respond to unusual requests

Report suspicious emails immediately

security@target.com

•

Never use your Target login information

or passwords on personal accounts. If

a personal password is compromised, it

can endanger all applications/websites

•

Only install and use authorized software

on Target devices.

consider this

policy spot

Acceptable Use of Information

Resources Policy

Information Security Policy

Vendor Risk Management Policy

Contact

security@target.com

with

questions that come up to help

determine what is best for Target, our

guests and team members. Examples

of common situations that often arise

include, but are not limited to:

•

I received a suspicious e-mail and

want to have it evaluated.

•

What can I do, or not do, when

handling non-public information?

•

What should I consider from a

security perspective when building

or buying a new app?

•

My password may have been

compromised. What should I do?

home

Code of Ethics

safeguarding what’s ours

protect non-public information

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Button 16.Page 31

Target Corporation Code of Ethics Handbook — page 32

consider this

What you develop while you’re employed

by Target may belong to Target. In some

instances, you may not use it for your own

benefit or share with another entity, even

after you leave Target.

our commitment

Anything we create at Target may be considered

intellectual property, including new brands,

marketing campaigns, artwork, product designs

and business innovations. We respect and treat

our intellectual property as a valuable Company

asset. We also respect valid intellectual property

owned by others and comply with the laws that

protect intellectual property.

how it’s done

We must always protect Target’s intellectual

property and respect intellectual property

owned by others. Intellectual property can

exist for:

•

Brands and logos (trademarks)

•

Literary and artistic works, such as

graphics, product designs, pictures,

artwork, music, videos, text and other

artistic elements (copyrights)

•

Marketing campaigns

•

Inventions and business innovations

(patents)

respect and preserve intellectual property.

We value our strong brand and carefully protect intellectual property.

Work with the Target Brands team, to review

and avoid any potential intellectual property

issues. Obtain the necessary permission

required by third parties before using anyone’s

intellectual property. If you have concerns

about someone not following intellectual

property policies, always

voice your

concerns immediately

Code of Ethics

safeguarding what’s ours

respect and preserve intellectual property

in your daily work

Understand your responsibilities.

Follow all

policies and procedures in place for developing,

protecting and enforcing Target’s intellectual

property rights.

Respect all intellectual property.

Deal fairly

with the intellectual rights of others when

working with music, logos, written materials,

software, videos, lyrics, images, designs and

even a person’s name or likeness.

Follow the laws governing:

•

Intellectual property (creative or

proprietary items that support our

brand and make us unique)

•

Trademarks (brands, logos and slogans –

think of our famous bullseye)

•

Copyrights (creative designs, software,

photos and images)

•

Patents (covering our innovations

and inventions)

•

Trade secrets (non-public information

that makes us competitive)

what if

Who do I contact if I have a question

regarding intellectual property?

Email the Target Brands team at

target.brands@target.com

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Target Corporation Code of Ethics Handbook — page 33

our commitment

We understand the importance of protecting,

storing, managing and disposing of our

information in a way that will help us comply

with the law and address our operational

needs. We keep accurate records to

demonstrate compliance with the law

and operate more efficiently by effectively

managing our information.

how it’s done

Each of us has a role in managing records,

whether you create records in your job or

develop technology that automates a business

process. It is up to you to understand and

follow the recordkeeping laws and Target’s

policies so you can manage information

properly in your business.

in your daily work

Know what’s required.

Work with your

leader to understand what records your team

needs to create and manage manually or

electronically. Make sure records can be easily

retrieved when needed.

Think of others.

You may no longer need

the record in your day-to-day role, but others

may rely on it in the future. A record-retention

period is established to meet the needs of all

business areas.

Hold on to records.

Although retention

should always comply with the Records

Retention Schedule, your law or tax partners

may occasionally contact you to put records

on “hold.” In this case, do not destroy those

records until the hold is released.

Let it go.

Not all documents and data need to

be kept as records. If you only have a copy, or

it’s not considered a record, purge it when you

are done with it unless it is on hold.

manage records.

We create and maintain records that accurately reflect our business activities, commitments and decisions.

what if

The retention period listed for records

I keep seems far too short. I’d like to

keep them a few years longer, just in

case I might need them. Is this OK?

No, record retention periods are

determined by an inter-departmental

team to ensure we are meeting legal

and operational objectives while

managing risk and expense. If you

believe a retention period is too short

or too long, you should contact

records.management@target.com

to have it reviewed.

Code of Ethics

safeguarding what’s ours

manage records

consider this

Accurate records management can be

achieved if you:

•

Create complete and accurate records

part of your normal business process

telling a story – include who, what,

when,

where and why

•

Provide truthful information, never

knowingly falsify, misstate, manipulate

or inaccurately represent business

information (operational data,

performance

metrics, etc.)

•

Store records in a sustainable location

where you and others can easily find

when needed

•

Retain records according to the Records

Retention Schedule for your area

•

Destroy or purge records when the

retention period has been reached–

unless on legal, tax, or investigative hold

policy spot

Records and Information

Management Policy

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Button 16.Page 33

Target Corporation Code of Ethics Handbook — page 34

Request:

Comments to

the media

Guest

complaints

Invitations to

make a speech

Donations

Financial or

investment

inquiries

Email:

Public

Relations

Guest

Relations

Presentations

Corporate

Responsibility

Investor

Relations

our commitment

As team members, we love our Company

and enjoy talking about it – to each other and

everyone. We designate authorized individuals

who are trained to speak on behalf of Target

because we can damage our reputation in just

a few words with an untrue statement.

how it’s done

Our reputation is one of our greatest assets,

and it’s up to each team member to protect

it. We refer all outside inquiries about Target’s

business to our Enterprise Communications

team to ensure that all information conveyed

to the public, regulatory authority and others is

accurate, complete and consistent.

in your daily work

Post responsibly on social media

. Posting on

social media helps you connect with others,

but use care when posting on social media

channels. Make it clear that any opinions you

express are your own and do not reflect those

of Target. If you speak about Target goods

or services, you must disclose that you are a

Target team member. Never share proprietary

or other non-public information. Of course,

discriminatory or harassing remarks or threats

of violence will not be tolerated.

Communicate accurately with government

authorities.

If your work authorizes you to

communicate with or respond to government

or regulatory entities, it’s important to be

accurate. Anything you say or report to these

entities should be accurate, complete and

consistent. Never mislead, provide incorrect

information or omit important details.

Help us speak with one voice.

You can

make sure official messaging about our

Company is accurate and complete by

allowing only authorized individuals to speak

for Target. They get the right messages out

to protect our Company and our reputation.

Never speak for Target if you’re not

authorized, and remember, if you are asked

to speak about your role as a Target team

member, outside of Target, you must receive

approval from

press@target.com

communicate responsibly.

We understand the impact our words can have, so we communicate thoughtfully and responsibly.

Code of Ethics

safeguarding what’s ours

communicate responsibly

consider this

what if

While online, I came across a post from a

guest who was upset with the service they

received at a store. It would be so easy for

me to reply and help them out. Is that OK?

No. Unless you are authorized to speak

on Target’s behalf, you may not reply,

as your response could be misinterpreted.

Notify Guest Services or Guest Relations

about the post so appropriate action can

be taken.

policy spot

Social Media Policy

Delegation of Authority Policy

External Presentation Decision Filter

Never post anything online that:

•

Would compromise non-public

business information (guest and

business partner communication)

•

Appears to be on Target’s behalf

without authorization

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Button 16.Page 34

Target Corporation Code of Ethics Handbook — page 35

caring for

our world.

We invest in our communities.

respect human rights ......................................

engage responsibly in political activities .........

care for our planet ...........................................

invest in our communities ................................

home

Code of Ethics

caring for our world

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Target Corporation Code of Ethics Handbook — page 36

our commitment

Target is committed to prioritizing and

protecting human rights across our global

operations – from our team members,

guests, supply chain, and our communities

because we believe every person deserves

to be treated with dignity and respect. We

are continuously working to do better and

our approach is to effectively respond when

concerns are raised.

how it’s done

We expect every team member and business

partner to show respect for human rights

and follow all laws that protect human

rights, including those that prohibit forced

or compulsory labor, child labor and human

trafficking.

in your daily work

Protect human rights.

Human rights are

embedded in all aspects of our business.

Every team member has a role to prioritize and

protect human rights across our global supply

chain operations and hold business partners

accountable to those same standards. Some

of our priorities include, but are not limited to:

Ensure positive partnerships.

Choose

business partners who share our values and

demonstrate an ongoing commitment to

human rights. It’s up to you to hold business

partners accountable to our high ethical

standards.

Once a merchandise business partner

is selected, the Responsible Sourcing &

Sustainability team may monitor and audit

the business partner as part of our oversight

and due diligence process to make sure

they comply with our

Standards of Vendor

Engagement (SOVE)

and follow all applicable

laws.

respect human rights.

We’re dedicated to making a positive impact on our communities through the actions we take.

what if

A business partner I’m considering

working with had an employment law

violation a few years ago that I read

about in the news. They shared that the

company is under new management and

now has a good recent record. Do we

have to consider this past violation?

Yes, we do. Even though their current

record is good, it’s important that we

consider any past violations by business

partners when we become aware of

them. Talk to your leader about this

vendor’s past before making any

vendor selection decisions.

Code of Ethics

caring for our world

respect human rights

consider this

All business partners are expected to follow

our SOVE. We also expect all business

partners we work with to treat workers fairly

with dignity and provide safe and healthy

work conditions. If you work with business

partners and have concerns or hear about

any human rights issues,

voice your

concerns immediately

policy spot

Human Rights Statement

Business Partner Code of Conduct

Standards of Vendor Engagement (SOVE)

Equal Employment Opportunity and

Harassment-Free Workplace Policy

Target’s Integrity Hotline

Global Sanctions Policy

Country of Production Policy

• Ensuring safe and sanitary working

conditions

• Providing legal compensation for all hours

worked or services performed

• Striving to give everyone access to the

same opportunities through inclusive

guest experiences, work environments,

workforce diversity, and societal impact

• Working to validate that supply chain

workers have clean, drinkable water and

sanitation on site

• Preventing Owned Brand manufacturing

facilities from discharging untreated

wastewater into the communities

• Striving to accelerate economic

development and vitality in the

communities where we operate

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Target Corporation Code of Ethics Handbook — page 37

our commitment

The Government Affairs team works to make

sure that Target has a voice in decisions

made by government officials. Target also

encourages team members to participate

in the civic process.

how it’s done

When you engage in advocacy on behalf of

Target, you must always follow the policies

and laws that apply. You must also keep your

personal political activities separate from

your role at Target.

in your daily work

Understand Target’s policy.

Before you

contact a government official on behalf

of Target, always obtain approval from

Government Affairs. This ensures that

Target’s advocacy is consistent,

coordinated and in compliance with the

law. Only Government Affairs is authorized to

promise or make political contributions

on behalf of Target.

You must also obtain pre-approval from

Ethics prior to providing anything of value to a

government official. Examples include, but are

not limited to

• Meals

• Gifts

• Entertainment

• Travel

If you’re ever unsure, ask for guidance by

contacting

ethics@target.com

engage responsibly in political activities.

Our community gets stronger when everyone is engaged and invested in making it a better place.

Act on your own behalf.

If you want to

contribute your personal time or money

to political activities, be clear that you’re

acting on your own behalf and not on

Target’s behalf. You may not use Target’s

name to suggest that Target sponsors or

endorses your personal politics, nor may you

use your position to pressure other team

members to make political contributions or

to support or oppose particular candidates.

More generally, you may not use any Target

resources or services (except as permitted

by Government Affairs) for political purposes.

Code of Ethics

caring for our world

engage responsibly in political activities

consider this

If you are considering becoming a candidate

for political office or accepting an appointment

to a government position, contact Government

Affairs first. Government Affairs can help you

identify and navigate any potential conflicts of

interest and understand the applicable policy

requirements.

what if

I’m a team leader, and I support a political

candidate in our community. I’d like

everyone on my team to support that

candidate, too. May I ask them to donate

or volunteer?

No. You may not use your position at

Target to pressure others into supporting

any candidate or cause, or to make a

political donation.

policy spot

Political Activities, Lobbying, and

Government Ethics Policy

Conflicts of Interest Policy

Anti-Bribery Policy

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Target Corporation Code of Ethics Handbook — page 38

our commitment

We operate our business by using resources

responsibly and following environmental

laws that impact Target. Having a good

environmental record matters to our guests,

team members and communities, and that

commitment is ingrained throughout our

business.

how it’s done

We comply with the environmental laws that

apply to Target and follow all policies and

procedures in place. We use and conserve

resources by recycling and reusing when

possible and disposing materials properly. By

doing so, we also reduce our carbon footprint.

in your daily work

Take responsibility.

Follow Target’s best

practices to comply with environmental laws

by properly disposing of waste and handling

and storing chemicals and other hazardous

materials safely. If your work with business

partners involves sustainability practices,

make sure you initiate discussions to confirm

they understand our expectations to comply

with all laws, act responsibly and follow the

environmental standards as outlined in the

Standards of Vendor Engagement (SOVE)

Watch for hazards.

Watch for environmental

hazards like improper waste disposal or

release of pollutants. If you see a potential

hazard, don’t ignore it –– report it immediately

through the stores My Help App or contact

ethics@target.com.

Be aware of your impact on the

environment.

Help us achieve our

environmental goals by:

• Following Target policies and procedures

that focus on proper disposal of waste

and unsellable items, improving water

quality, optimizing water efficiency and

managing chemicals

• Increasing efforts to offer sustainable

products and ensuring sustainable

operations

• Conserving resources such as water

and paper

• Reusing plastics and metal whenever you

can to minimize our carbon footprint

care for our planet.

We are good stewards of our resources and do our part to protect the planet.

Code of Ethics

caring for our world

care for our planet

consider this

Target recycling and salvage programs

have a significant impact on decreasing our

carbon footprint by removing waste properly.

If you have questions regarding recycling,

you can follow and ask questions on the

#knowthespace

community on Yammer.

Store team members

– make sure all materials

are properly placed, labeled and disposed of

by carefully following all procedures.

what if

I noticed several team members

dumping chemicals improperly. It may

have only happened once, so I’m not

sure if I should say something. Should I?

Yes, you should. We should follow all

applicable environmental laws and do

what we can to properly dispose of

materials that could harm people and

the environment

Voice your concerns

immediately

policy spot

Standards of Vendor Engagement (SOVE)

Corporate Responsibility Reports

Corporate Responsibility

Planet Overview

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Target Corporation Code of Ethics Handbook — page 39

our commitment

Our Company was founded on a deep belief

that the enduring success of our business

relies on the strength and vitality of the

communities we serve. By investing in the

places where we live and work, we create

more resilient and vibrant communities

for future generations of guests and

team members.

how it’s done

No matter what job you hold or where you

work, you have a responsibility to maintain

our reputation, make honest decisions that

reflect our values and act responsibly in

our communities.

in your daily work

Seek pre-approval.

All of Target’s

charitable donations or cause marketing

campaigns must be pre-approved by the

Corporate Responsibility team. Contact

corporateresponsibility@target.com

with

questions.

Act on your own behalf.

We encourage you

to become involved in your community.

However, unless approved, do not make

donations or speak on behalf of Target. Contact

the Enterprise Communications team with

questions.

invest in our communities.

We are committed to bringing about positive impact in the communities we serve.

what if

I’m on a team that wants to donate

Target clothing or money to a nonprofit.

Can we do this?

While Target is committed to addressing

needs within our communities, teams

must follow Target’s

Waste Minimization

Donation Process

. In certain instances,

the Corporate Responsibility team and the

Waste Minimization team

may approve in-

kind donations tied to a corporate strategic

initiative.

Always contact Corporate Responsibility

before engaging in any discussion with a

nonprofit to ensure tax, legal and governance

requirements are considered. International

donations have additional requirements

including pre-approval of all charities by the

Corporate Responsibility team.

Code of Ethics

caring for our world

invest in our communities

consider this

Team members carry out Target’s legacy of

volunteerism by donating time and talent

in the communities where we do business.

Corporate volunteer opportunities can be

found at

myGiving

, and additional resources

are provided below to understand the

limitations placed on volunteering.

• Target’s charitable donations and

cause marketing campaigns must

be pre-approved by the

Corporate

Responsibility team

• The

No Solicitation

and

Distribution

Policy

provides all team members the

ability to work free from distraction

and the pressure of solicitation, as

team members are prohibited from

asking others to make contributions

• When volunteering on work time,

always keep your leader informed

policy spot

Delegation of Authority Policy

No Solicitation and Distribution

Policy

Volunteering at Target FAQs

Waste Minimization Donation Process

Charitable Donations

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Target Corporation Code of Ethics Handbook — page 40

summing

it up.

How will we stay true to Target?

That depends on you.

Reading this Code is a great first step. The next step is taking what

you’ve learned from the Code and turning it into actions that make

our Company the best it can be. Never forget the impact you have on

Target and our guests. The decisions you make, no matter how small,

should reflect what’s most important to us, our values and doing

what’s right for our guests.

If you have any questions about our Code or policies or need additional

guidance, please don’t hesitate to ask. Keep in mind that we may modify

or update the Code as needed, so refer to it often. In rare cases, it

might be appropriate for Target to waive a part of the Code. Any waiver

applicable to our executive officers, chief accounting officer or controller

may be made only by Target’s Board of Directors (or a committee of the

Board) and will be promptly disclosed to our shareholders.

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Code of Ethics

summing it up

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Target Corporation Code of Ethics Handbook — page 41

policy and resource look-up.

Want to know more?

Here is an alphabetical list of all the policies and resources referenced in our Code.

Enterprise Policies

can also be accessed through our Ethics Site. If you

have questions about them or how they apply to you or your role, please contact your leader or your Human Resources partner.

Policy or

Resource Name:

Policy or

Resource Name:

Acceptable Use of Information

Resources Policy

Anti-Bribery Policy

Corporate Responsibility Reports

Corporate Responsibility

Planet Overview

Anti-Money Laundering Policy

Delegation of Authority Policy

Drug and Alcohol Policy

Antitrust Policy

Conflicts of Interest Business

Amenities Table

Equal Employment Opportunity and

Harassment-Free Workplace Policy

Describes:

Defines the information classification levels and

establishes requirements for handling information

securely to protect Target’s information resources.

Outlines requirements for team members who work

with government officials or supervise vendors that

work with government officials.

Updates stakeholders on Target’s progress against our

corporate responsibility commitments on an annual

basis. The report represents Target’s global operations

for each fiscal year.

Overview of Target’s commitment to better our planet.

Outlines requirements for accepting cash payments

for merchandise transactions or to fund gift cards.

Outlines requirements regarding who can authorize

and execute contracts, make charitable or political

contributions and represent Target at external

speaking engagements.

Outlines requirements that prohibit business practices

that interfere with a competitive, free marketplace.

This Policy establishes requirements for Target

team members in the workplace. Alcohol and Drugs

can have a harmful effect on the health, safety, and

productivity of team members, and to the security of

the company’s equipment and facilities.

Outlines limits for accepting gifts, meals, entertainment

and/or travel offered by a vendor, prospective vendor

or competitor.

Prohibits discrimination and harassment of team

members on the basis of any protected characteristic,

as well as retaliation against individuals who complain

of or participate in an investigation related to

discrimination or harassment.

Referenced

on page:

Referenced

on page:

Conflicts of Interest Policy

Outlines requirements for accepting gifts, meals, entertainment

and/or travel offered by a current or prospective business

partner, or competitor. Also includes information regarding

outside employment, financial investments and business

dealings with former team members.

Charitable Donations

Outlines what charitable donations are allowed and

when to contact Corporate Responsibility.

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Code of Ethics

policy and resource look-up

Business Partner Code of Conduct

Outlines standards and expectations for

merchandise vendors.

Country of Production Governance

Policy

Establishes requirements necessary to ensure that

Target is sourcing from countries in compliance with

all legal, regulatory, and Target requirements.

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Target Corporation Code of Ethics Handbook — page 42

Information Security Policy

Outlines requirements to ensure the confidentiality,

integrity and availability of Target’s information

resources and information assets.

External Presentation

Decision Filter

Decision-making tool to determine if acceptable to

speak at an external engagement.

Global Sanctions Policy

Sets forth requirements for team member conduct

regarding compliance with applicable economic trade

sanctions laws (“Sanctions”).

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Code of Ethics

policy and resource look-up

policy and resource look-up continued.

Policy or

Resource Name:

Policy or

Resource Name:

myGiving

No Solicitation and Distribution

Policy

Safety Policy

Retail Privacy Policy

Open Door Culture

Securities Trading Policy

Social Media Policy

Political Activities, Lobbying,

and Government Ethics Policy

Records and Information

Management Policy

Describes:

A site for team members to find volunteer

opportunities.

Prohibits team members from soliciting others during

their own or another team member’s work time, and

from distributing literature during working time or in

work areas.

Outlines requirements for team members regarding

safety, compliance and claims.

Discloses how Target collects, uses, shares

and protects guest information.

Encourages team members who have a job-related idea

or concern to share with their leader. If a satisfactory

resolution isn’t reached, team members can go to

another higher level leader within the organization.

Prohibits trading in our securities and certain other

companies’ securities by Insiders (all team members

and members of the Board of Directors) when they

are aware of material, non-public information.

Outlines requirements for Company and Political Action

Committee (PAC) political contributions, personal political

activity by team members, lobbying, the provision of hospitality

to government officials and limits on the activities of team

members who were formerly government officials.

Outlines guidelines about what can and cannot be

shared by team members on social media outside

of Target.

Outlines requirements to ensure records and non-

record information assets are managed effectively.

Referenced

on page:

Referenced

on page:

RedCard Sales Practices Policy

Outlines requirements for team members who solicit and

process Target Credit and Debit Card applications.

Privacy Compliance Policy

Outlines requirements to ensure the proper collection,

use, sharing and deletion of Target Guest and Team

Member Personal Information.

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Target Corporation Code of Ethics Handbook — page 43

Standards of Vendor Engagement

(SOVE)

Outlines social, labor and environmental expectations

for merchandise vendors and factories.

Target Debit Card Privacy Policy

Discloses how Target collects, uses, shares and

protects Debit Card personal information.

TD Bank Privacy Policy for

Target Credit Card

Discloses how TD Bank collects, uses, shares and

protects Credit Card personal information.

home

policy and resource look-up continued.

Code of Ethics

policy and resource look-up

Policy or

Resource Name:

Policy or

Resource Name:

Team Member Handbooks

Travel and Expense Policy

Describes:

Provides team members with expectations.

Outlines requirements for team members traveling

for Target business and seeking business expense

reimbursement.

Referenced

on page:

Referenced

on page:

Volunteering at Target FAQs

Visitor Management Policy

Waste Minimization

Donation Process

Violence-Free Workplace Policy

FAQs for volunteering and team member giving.

Outlines requirements for hosting visitors, vendors or

guests to ensure safe and secure environments

at Target locations.

Overview of donation process by location.

Defines conduct considered to be workplace

violence, prohibits that conduct and describes the

consequences for violating the Policy. Also addresses

the use and possession of weapons, explosives and

other dangerous items in the workplace.

Vendor Risk Management Policy

Outlines requirements to manage the strategic,

operational, reputational, compliance and financial

risks that may arise when working with vendors.

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Target Corporation Code of Ethics Handbook — page 44

ethics@target.com

Enterprise Policies

Team Member Handbooks

Issues or Concerns:

To ask questions, report

potential misconduct or

other ethical concerns

For questions on the Code of Ethics

To view Enterprise policies

To view information about

Company Benefits

Contact:

Talk

Talk to your leader or Human

Resources partner.

ethics@target.com

Visit

www.TargetIntegrityHotline.com

Call

Integrity Hotline, anonymous

option available 24 hours a day

U.S.:

1-800-541-6838

India:

000-800-

100

1657

Other non-U.S. locations:

place a collect call to the U.S.

at: 1-470-219-7116

Write

Corporate Compliance & Ethics

Target Corporation

1000 Nicollet Mall #3110

Minneapolis, MN 5540

notes.

home

essential resources.

Have a question?

Target offers a variety of resources for more help and to report concerns:

Code of Ethics

essential resources

June 2021 #1

Point your smartphone camera at this QR

code, then tap the pop-up notification to

go to the Integrity Hotline website.

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Target Corporation Code of Ethics Handbook

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