The Home Depot | Business Code of Conduct and Ethics

THE

HOME

DEPOT

Business Code of

Conduct and Ethics

The Home Depot

DOING THE RIGHT THING

Guidance for making decisions that align with The Home Depot's values and

ethical and legal obligations.

Business Code of Conduct and Ethics

Applicable to directors, officers and associates of The Home Depot.

The Home Depot | Business Code of Conduct and Ethics

Table of Contents

Introduction

Our Core Values; Complying with the Code and the Law; Open Door Policy;

Zero Tolerance for Retaliation; Waivers; Getting Answers or Reporting a

Concern

Doing the Right Thing for Our

Associates

Respect for All People; Labor and Employment; Workplace Safety;

Workplace Violence; Alcohol and Drugs; Weapons; Workplace Conduct

Doing the Right Thing for Our

Customers

Antitrust and Fair Competition; Confidentiality, Privacy and Information

Protection; Customer and Associate Information

Doing the Right Thing for Our

Shareholders

Conflicts of Interest; Financial Interests; Supplier Relationships; Gifts and

Entertainment; Corporate Opportunities; Insider Trading

Doing the Right Thing for Our

Company

Protecting Company Assets; Intellectual Property; Information Systems;

Accurate Records; Records Retention; Communications

Doing the Right Thing for Our

Communities

Environmental Responsibility; Human Rights; Responsible Sourcing;

Government Contracting; Political Activity; FCPA and Anti-Bribery

Compliance and Reporting

Corporate Compliance; AwareLine; Investigation Cooperation;

Non-Retaliation; Consequences of Violations

The Home Depot | Business Code of Conduct and Ethics

Introduction

The Business Code of Conduct and Ethics provides associates with straightforward guidance for making

decisions that align with The Home Depot's operating principles and legal obligations. The Code applies

worldwide to associates, including business operating units, subsidiaries and members of the Board of

Directors.

Our Core Values

• Excellent Customer Service

• Building Strong Relationships

• Entrepreneurial Spirit

• Respect for All People

• Creating Shareholder Value

• Doing the Right Thing

• Giving Back

• Taking Care of Our People

Complying with the Code and the Law

Associates are expected to comply with the Code and all applicable laws and regulations. When local law

imposes a different requirement, associates should seek guidance from Corporate Compliance or the Legal

Department.

The Open Door Policy

The Home Depot encourages associates to voice concerns, express doubts, discuss problems and ask

questions through management, Human Resources and Corporate Compliance channels.

The Home Depot | Business Code of Conduct and Ethics

Doing the Right Thing for Our Associates

Respect for All People

The Home Depot states that it is an equal opportunity employer and does not tolerate discrimination or

harassment prohibited by applicable law. Associates are expected to treat one another with respect and

professionalism.

• Do not discriminate or harass another associate, applicant, customer, supplier or other person covered by

applicable law and policy.

• Raise workplace concerns through the Open Door Policy or other reporting channels.

• Do not retaliate against someone who raises a concern in good faith.

• Follow applicable standards for workplace conduct, safety and security.

Labor and Employment

Associates are expected to follow wage-and-hour, employment and timekeeping requirements applicable to

their role and location. Accurate records of hours worked are required, and associates should not knowingly

work outside approved timekeeping processes.

Workplace Safety

Safety is a core Home Depot value. Associates must follow applicable safety procedures, training

requirements and operating standards for stores, distribution facilities, offices and field operations.

The Home Depot | Business Code of Conduct and Ethics

Workplace Safety and Security

The Code identifies safety as an ethical and operational responsibility. Detailed equipment procedures are

established through the Company's Standard Operating Procedures and safety policies rather than being

fully reproduced in the Code.

Safe Work Practices

• Follow required safety training and Standard Operating Procedures.

• Use equipment only as authorized and trained.

• Report unsafe conditions, injuries, incidents and potential hazards promptly.

• Follow emergency procedures and cooperate with safety investigations.

• Do not bypass safety controls to save time or meet a performance target.

Workplace Violence

Threatening or violent behavior is inconsistent with The Home Depot's workplace expectations. Associates

who observe a potentially violent situation should report it through the appropriate management, Human

Resources or AwareLine channel.

Alcohol, Drugs and Weapons

Associates must comply with Company rules and applicable law concerning alcohol, controlled substances,

impairment and weapons in the workplace.

The Home Depot | Business Code of Conduct and Ethics

Doing the Right Thing for Our Customers

Antitrust and Fair Competition

The Home Depot expects associates to compete honestly and fairly. Associates should not enter

agreements or arrangements with competitors that could violate antitrust or competition laws.

• Do not discuss prices, bids, market allocation or other competitively sensitive subjects with competitors

unless approved and lawful.

• Consult Legal or Corporate Compliance when a business interaction creates competition-law uncertainty.

• Do not use improper means to obtain a competitor's confidential information.

Confidentiality, Privacy and Information Protection

Associates may handle customer, associate, vendor and Company information. Such information must be

accessed, used, stored and disclosed only as authorized.

• Protect payment-card, customer, associate and other personal information.

• Use information only for legitimate business purposes.

• Follow information-security and privacy procedures.

• Report suspected privacy or security incidents promptly.

The Home Depot | Business Code of Conduct and Ethics

Conflicts of Interest

Associates have a responsibility to make decisions based on the interests of The Home Depot without regard

to personal benefit. A conflict may exist when private or professional interests interfere, or appear to

interfere, with Company interests.

Financial Interests

• Disclose actual or potential conflicts promptly.

• Be especially careful about financial interests in current or prospective suppliers, vendors or service

providers.

• Obtain Corporate Compliance guidance when a financial interest could affect business decisions.

• Remember that the appearance of a conflict can be as important as an actual conflict.

Relationships with Suppliers, Vendors and Service Providers

Social or romantic relationships with suppliers, vendors or service providers can create an appearance of

conflict when the associate has direct responsibility for the relationship. Such situations should be disclosed

and reviewed when required.

Corporate Opportunities

Associates should not take for themselves opportunities discovered through their position or Company

property when doing so would conflict with the interests of The Home Depot.

The Home Depot | Business Code of Conduct and Ethics

Gifts and Entertainment

The acceptance of gifts and entertainment from current or potential suppliers, vendors or service providers

can create a conflict of interest or the appearance that personal interests are being placed ahead of The

Home Depot.

General expectations

• Do not accept gifts or entertainment when they could improperly influence, or appear to influence, a

business decision.

• Follow the Company's Gifts and Entertainment Policy for permitted exceptions, thresholds and approval

requirements.

• Disclose questionable offers rather than attempting to resolve uncertain situations alone.

• Never request personal benefits from suppliers, vendors or service providers because of your Home Depot

position.

Supplier integrity

Suppliers, vendors and service providers are expected to act ethically and in a manner consistent with the

standards set by The Home Depot. Business decisions should be based on legitimate Company interests, not

personal incentives.

The Home Depot | Business Code of Conduct and Ethics

Insider Trading and Company Information

Associates may learn material nonpublic information about The Home Depot or another company through

their work. Securities laws restrict trading and sharing material nonpublic information in certain

circumstances.

Protecting Material Nonpublic Information

• Do not trade securities while in possession of material nonpublic information when prohibited by law or

Company policy.

• Do not disclose material nonpublic information to another person for the purpose of enabling a securities

transaction.

• Follow applicable trading-window, pre-clearance and other Company requirements.

• Contact Legal or Corporate Compliance when uncertain.

Protecting Company Assets

Company assets include merchandise, cash, equipment, systems, intellectual property, confidential

information and other resources. Associates are expected to protect assets from loss, theft, misuse and

unauthorized access.

The Home Depot | Business Code of Conduct and Ethics

Information Systems and Records

Information Systems

• Use Company systems responsibly and in accordance with applicable policies.

• Protect passwords, credentials and access rights.

• Do not introduce unauthorized software or devices into Company systems.

• Report suspected cybersecurity incidents through the required process.

Accurate Records and Financial Reporting

The Home Depot expects accurate and complete business and financial records. Associates must not create

false records, conceal information or make misleading entries.

Records Retention

Business records must be retained, protected and disposed of according to Company requirements and

applicable law. Associates should preserve records subject to a legal hold or investigation.

Intellectual Property

Company intellectual property, including trademarks, copyrighted material, proprietary processes and other

protected information, should be used and disclosed only as authorized.

The Home Depot | Business Code of Conduct and Ethics

Doing the Right Thing for Our Communities

Environmental Responsibility

The Code recognizes environmental responsibility as part of The Home Depot's ethical and legal

expectations. Associates should follow environmental procedures relevant to their work and location.

Human Rights

The Home Depot's responsible business materials describe respect for human rights and responsible

sourcing as part of its broader business standards. Associates involved in sourcing and supplier relationships

should follow applicable Company requirements.

Responsible Sourcing

• Follow supplier and responsible-sourcing requirements applicable to your role.

• Escalate concerns involving labor practices, human rights or supply-chain integrity.

• Maintain appropriate supplier documentation and due diligence.

Community Responsibility

The Home Depot's value of Giving Back supports community involvement while associates remain

responsible for following Company approval, resource-use and conduct requirements.

The Home Depot | Business Code of Conduct and Ethics

Government Contracting and Anti-Bribery

Government Contracting

Business with government entities can be subject to specialized procurement, pricing, recordkeeping, ethics

and disclosure requirements. Associates involved in government contracting should follow the applicable

Company policies and obtain Legal or Compliance guidance.

FCPA and Anti-Bribery Compliance

The Home Depot's Code addresses compliance with the Foreign Corrupt Practices Act and anti-bribery

requirements. Associates must not offer, promise, authorize or provide improper payments or anything of

value to influence a business decision or government action.

• Use approved third parties and follow due-diligence procedures.

• Maintain accurate books and records.

• Do not disguise or mischaracterize improper payments.

• Seek guidance before providing anything of value to a government official or other high-risk recipient.

Regulatory cooperation

Associates must provide truthful information and cooperate appropriately with authorized government

inquiries, audits and investigations.

The Home Depot | Business Code of Conduct and Ethics

Political Activity

The Home Depot maintains standards governing Company and associate participation in the political

process. Personal political activity should not be represented as Company activity, and Company resources

must be used only as permitted by applicable policy.

• Follow the Company's Political Activity Policy.

• Do not imply that The Home Depot endorses your personal political views.

• Use Company time, facilities and resources for political activity only when specifically permitted.

• Obtain required approvals before political activity conducted on behalf of the Company.

• Remember that personal political affiliation should not affect employment decisions.

Government and public officials

Communications intended to influence government action may constitute lobbying and can trigger

registration, disclosure and approval requirements. Consult the appropriate Public Affairs or Legal resources

before acting on behalf of The Home Depot.

The Home Depot | Business Code of Conduct and Ethics

Getting Answers and Reporting a Concern

Associates are encouraged to speak up when ethical or legal standards may not be met. Concerns can be

raised through several channels, including management, Human Resources, Corporate Compliance and the

AwareLine.

Channel

Use

Immediate manager or

supervisor

Questions or concerns that can appropriately be addressed locally.

Human Resources partner

Workplace, employment and associate-relations concerns.

Corporate Compliance

Ethics, compliance and policy questions or concerns.

AwareLine

Anonymous reporting of ethical or legal concerns, available 24/7.

Associate AwareLine

1-800-286-4909

thdawareline.com

Reports may be made anonymously. The Home Depot states that retaliation for making a

report is prohibited.

The Home Depot | Business Code of Conduct and Ethics

Zero Tolerance for Retaliation

The Home Depot states that retaliation for making a good-faith report is prohibited. Associates should be

able to raise questions, concerns and suspected violations without fear of adverse treatment because they

spoke up.

Protected actions

• Raising a good-faith concern.

• Asking a compliance or legal question.

• Participating honestly in an investigation.

• Providing information requested by authorized investigators.

• Using the AwareLine or another approved reporting channel.

Handling a concern

Reports may be reviewed and investigated by the appropriate Company function. Associates should

preserve relevant information, provide truthful information and avoid interfering with an investigation.

Consequences

Violations of the Code, Company policies or applicable law may lead to corrective or disciplinary action, up

to and including termination, depending on the circumstances and applicable requirements.

The Home Depot | Business Code of Conduct and Ethics

Value Wheel and Inverted Pyramid

The Home Depot's culture is reinforced by its values and servant-leadership philosophy. The Company's

inverted pyramid places customers and frontline associates at the top, with senior management at the base

in a supporting role.

CUSTOMERS

Primary focus

FRONT LINE ASSOCIATES

Direct customer impact

FIELD SUPPORT

Support stores and associates

CORPORATE OFFICE

Enable operations

CEO

Support the organization and culture

Core values

Excellent Customer Service • Building Strong Relationships • Entrepreneurial Spirit • Respect for All People •

Creating Shareholder Value • Doing the Right Thing • Giving Back • Taking Care of Our People

The values are intended to guide everyday decisions and the way associates serve customers, work with

one another and conduct Company business.

The Home Depot | Business Code of Conduct and Ethics

Associate Reference and Acknowledgment

Quick Reference

• Do the right thing, even when no one is watching.

• Know and follow the Code, Corporate Compliance Policies and Standard Operating Procedures relevant to

your role.

• Treat people with respect.

• Protect customers, associates, Company assets and information.

• Disclose conflicts and seek guidance.

• Compete fairly and follow anti-bribery requirements.

• Keep accurate records.

• Speak up when something is wrong.

• Use the AwareLine when you prefer anonymous reporting.

• Never retaliate against a person who raises a concern in good faith.

Associate acknowledgment

Associate name

____________________________________________

Associate ID

____________________________________________

Location / department

____________________________________________

Manager

____________________________________________

Date

____________________________________________

Signature

____________________________________________

This handbook is a practical representation of the public Business Code of Conduct and Ethics framework. Associates should always

follow the current Code, Corporate Compliance Policies and Standard Operating Procedures applicable to their role and location.

The Home Depot Business Code of Conduct and Ethics Handbook

Prompt to Clone This The Home Depot Business Code of Conduct and Ethics Handbook

Apply this example's core structure, strategic pacing, and structural hierarchy directly to your own topic.

What are you generating today?

KPMG Real Estate Revenue Handbook

Similar Examples