Code of Conduct Associate Guide (EP.001.rev )

Code of Conduct Associate Guide (EP.001.rev5.02.07) The Home Depot and its affiliates are dedicated to being an Employer of Choice and provide numerous programs to provide a safe, employee-centered work environment. These programs include the InFocus safety program, the Homer Fund and Care Solutions for Life. From the very beginning, The Home Depot has been committed to doing right by our associates, our customers, our vendors, our communities and our shareholders. Acting with integrity and doing the right thing are the driving forces behind the Company's extraordinary success. "Doing the right thing" is a relatively easy concept to understand. Yet, actually doing the right thing is not always that simple. Because The Home Depot and its affiliates want our associates to be equipped to conduct themselves and the Company s business in the most ethical and appropriate manner possible, we have developed a Code of Conduct. The Code of Conduct is a means to ensure that we work in an environment that is in line with our Values. This Code of Conduct provides you with guidelines to better understand standards of professional conduct in the workplace in order to maintain a safe and productive environment. Standards of Conduct The Home Depot and its affiliates ( Home Depot or Company ) are committed to the highest standards of ethical and professional conduct. The Company recognizes that as associates, you expect to be informed of what is expected of you and the consequences that will result if those expectations are not met. As a result, standard, common sense rules of conduct that are necessary for orderly and efficient operations have been established. The following provides examples of two types of prohibited conduct: (1) Major Work Rule Violations, which are considered to be so severe in nature that they would normally result in termination for a first offense; and (2) Minor Work Rule Violations, which are considered to be unacceptable behavior in the workplace that would normally result in discipline and may individually or cumulatively result in termination depending on the seriousness of the offense(s). The rules, regulations, and policies contained in this Standard Operating Procedure (SOP) apply to all associates regardless of position with the Company. As an associate, you have certain responsibilities to the Company, your supervisor, your fellow associates, our customers and our vendors. These rules, regulations, and policies also apply at all times that associates are on Company premises including all buildings, grounds, vehicles, and parking areas used by the Company to conduct its business, whether owned or rented by the Company, during any period 1

of time when associates are performing duties for The Home Depot and may also apply to offduty, off-premises conduct. Anyone violating these rules of conduct may be disciplined up to and including termination. The reasons listed for discharge or discipline are examples only and are not meant to, and do not, include all reasons for which an associate may be disciplined or discharged. The Code of Conduct is a part of the Company s Business Code of Conduct and Ethics Compliance Policy, and may be amended from time to time. This Code of Conduct does not create a contract between Home Depot and any Home Depot associate. No promise of any kind is made by Home Depot in this Code of Conduct. Home Depot is free to change the terms of this Code of Conduct, or the terms of an associate s employment, without having to consult with or obtain the agreement of the associate. Home Depot and the associate each continue to have the absolute authority to terminate the employment relationship at will. The employment relationship may be terminated with or without cause, and with or without prior notice. This at will status can only be modified if such modification is in writing and signed by both the associate and the CEO of the Company. Act with Integrity and Honesty The Home Depot expects all associates to act with integrity and honesty in all matters related to Company business. Associates may not obtain or use any property or services of the Company, fellow associates, our customers, visitors or vendors in a manner other than that authorized by Company policy or by federal, state or local laws. Associate Behavior Associates must perform their assigned duties to the best of their ability and in the best interest of the Company, fellow associates, our customers, visitors, vendors and shareholders. Associates must not take any action that creates a risk, harm or damage to oneself, another person, the Company, or the property of the Company or others. Associates must adhere to and fully comply with all Company policies and procedures, as contained in the Standard Operating Procedures and Compliance Policies, which can be found in the Code of Conduct brochure or on the Company s intranet site and obtained by request to a Human Resource Manager. This includes policies not specifically outlined in the Code of Conduct Salaried managers must be conscious of the fact that as agents of the Company their actions may be attributed to the Company under certain circumstances even while off duty. Therefore, they should avoid situations that place the Company at risk and/or call their professionalism into question. For example, situations to be avoided are repeatedly fraternizing with hourly associates in places where alcohol is served such as bars and restaurants or repeatedly having lunch, dinner or breaks with some hourly associates but not others. Attendance and Punctuality To provide the level of service that the Company s customers expect and deserve, all associates are expected to report for work at the assigned time, ready to perform their assigned duties and work their assigned scheduled hours. (Refer to Attendance & Punctuality Guidelines.) 2

Background Checks The Background Investigation Program (BIP) supports the strategy of evaluating each candidate s individual fitness for the requirements of the position sought by the candidate. Consistent and thorough background checks are a component of our selection process that will aid in our mission to hire the best. All new hires, promotions, and some lateral moves (depending on the background check requirements for the position) will undergo a background investigation. Some positions will receive a criminal investigation only. Other positions based on job responsibilities will undergo an expanded investigation that may include credit and motor vehicle checks. After making a conditional offer, a Background Investigation Consent Form must be completed by the candidate before the background check is conducted. The Background Check (and drug screen) is only to be initiated after a conditional offer has been made. Associates cannot be hired, start working (including Orientation refer to the Orientation section of Staffing SOP), or be moved into a new position until after they have successfully completed the Background Check and Drug Test processes Customer Service All associates are expected to provide a consistently satisfying customer experience by thinking and acting with a customer perspective, anticipating and responding to customer needs, and by providing customers a total solution that meets their needs. Following Instructions Associates are expected to follow the directions and instructions of supervisors and managers, unless doing so would clearly violate the law or Company policy. Information Systems Use and Security Associates may not use the Company s equipment to send or receive information in violation of federal or state law, in violation of Company policy, (ex. Solicitation and Distribution SOP), or in violation of the property rights of another. Associates who violate this SOP are subject to discipline, which could include termination of employment. Associates may also be prosecuted if they are in violation of state or federal law. Personal use is subject to all Home Depot policies, including Respect, Harassment and Non Discrimination and Solicitation and Distribution. (Refer to Information Systems Use and Security SOP) Possession of Weapons and Explosives The Company does not permit associates to possess or use any kind of weapon, explosive or other dangerous implement while associates are at the workplace or otherwise performing duties on behalf of the Company. This policy applies whether or not a weapon is armed, loaded, or properly secured and whether or not it is concealed on an associate s person or contained in an associate s personal property such as a purse, briefcase, or vehicle. Pepper spray, mace and teargas, where legal, may be carried on Company premises only while going to and from work (i.e., at the beginning and end of shift). Such products should not be carried in an associate's apron or while the associate is working. Use of such products to defend yourself against physical attack on Company premises or time, while going to and from work, may be acceptable if otherwise deemed appropriate. Use of such products to initiate a confrontation on Company premises or while performing duties on behalf of the Company is prohibited, even while going to and from work. Associates bear complete legal responsibility for their use of such products. (Refer to Workplace Violence SOP) 3

Respect Respect for All People is one of Home Depot's core values. The Company is committed to providing an environment of mutual respect, free of harassment and discrimination for our associates, customers and vendors. Associates are expected to treat fellow associates, customers and vendors with courtesy and to resolve any differences in a professional, nonabusive, non-inflammatory and non-threatening manner. Associates are responsible for their own behavior and for understanding how others may perceive their conduct in the workplace. Conduct that may be acceptable outside of the work environment may be unacceptable in the workplace. Safety Policy It is important to maintain a safe work and shopping environment for associates, customers and vendors. Associates must follow the Company s safety standards to ensure the safety and well being of all customers, associates and vendors. Every associate must take personal responsibility and ownership for safety. All associates are required to immediately address safety issues and report unsafe conditions or behaviors to your manager. Staffing and Selection The Home Depot is an employer of choice wherever we do business. The Company strives to attract, motivate and retain a high performing, diverse workforce. Making good hiring decisions is crucial to the Company s success. All hires, transfers and promotions must be done using the Company's Standard Operating Procedures, Promotion & Employment Standards and the Store Level Entry System (SLE), where available. The Store Manager is responsible for all hiring, transfer and promotion decisions regardless of which members of the management team assist in the process. (Refer to Staffing- Internal Selection SOP) NOTE: Store Support Centers, Contact Centers and Home Depot Supply might not have access to the SLE hiring system. Substance Abuse Policy The Company strives to provide a safe, productive environment for its associates, customers and vendors. This includes a safe workplace, free of the problems associated with the use and abuse, including having detectable levels based on the Company's testing standards, of alcohol, illegal or non-prescribed controlled substances. All use (including having detectable levels based on the Company's testing standards), sale, distribution, possession or transfer of alcohol, or illegal drugs, or illegal use of prescription drugs when on the job, on Company premises (the store and adjacent parking lots), or in Company owned or rented vehicles is strictly prohibited. Associates choosing to consume alcohol at Home Depot events or functions (not on the job and not on Home Depot property) must limit their intake to moderate amounts. Whether consuming alcohol or not at off-site social events, all Home Depot associates must display appropriate behavior, consistent with Company values and respectful of all others and their property. Illegal substance use and abuse subjects the Company to unacceptable risks of workplace accidents, errors or other behaviors that would undermine the Company's ability to operate safely, effectively and efficiently. Therefore, to maintain an alcohol, drug and substance abuse free workplace, the sale, offering, possession or use of alcohol or illegal or non-prescribed controlled substances is prohibited. (Refer to Drug Testing Overview-Substance Abuse in the Workplace SOP) 4

Workplace Activity Staying focused and providing the best service to our customers is critical to the Company s success. For this reason, it is important that the workplace be primarily for authorized Company activities. Associates on Company premises should be engaged in work activity except during lunches and breaks. Workplace Violence/Threats of Violence An associate who becomes aware of a display of violent, abusive or threatening behavior, or a threat to engage in such behavior by another associate, former associate, customer or vendor, is to report such behavior to his or her immediate supervisor, manager or to Human Resources. (Refer to Workplace Violence SOP) Major Work Rule Violations This section provides examples of prohibited conduct that will normally result in termination for a first offense, which include, but are not limited to, the list below. Managers should always consider whether an offense is of such a serious nature that termination for a first offense is appropriate (see investigation process). When in doubt, contact your Human Resources partners. Violation of Discrimination or Harassment Policy Discriminating against an associate, customer, or vendor on the basis of race, color, gender, sexual orientation, age, religion, national origin, disability, or any characteristic protected by applicable law Engaging in any activity that violates the Company's sexual harassment or general harassment policies or other behavior prohibited by the harassment policy towards an associate, customer, or vendor. Harassment or disrespectful behavior can be verbal, nonverbal or physical. Examples of conduct that could be considered harassment or disrespectful behavior include, but are not limited to, directing abusive or obscene language to fellow associates, customers or vendors, offensive jokes, threats of termination, or other willful creation of circumstances that would make the workplace intolerable Treating a fellow associate, customer or vendor in an abusive, threatening or inflammatory manner Making intentional false reports of harassment or other false statements about associates Retaliating against an associate who makes a good faith complaint of discrimination or harassment or who participates in an investigation of such complaint (Refer to the Harassment and Non-Discrimination SOP) Failure to Act with Integrity and Honesty Stealing or attempting to steal the property of a customer, fellow associate, the Company or a vendor, whether retail or non-retail, and regardless of purpose, the amount involved or the method used to remove the property from the premises; knowingly possessing any such stolen property Creating a transaction for oneself, friend(s) or family; performing or authorizing a transaction for oneself, friend(s) or family including but not limited to the following: Ringing, modifying or authorizing any POS sale or refund transaction 5

Creating, modifying or completing Special Services or SOSI transactions including special orders, will calls, quotes, measures and installations Authorizing markdowns (all reason codes), donations or even exchanges Creating, modifying or authorizing pricing associated with generic clearance SKUs, Manager s Competitor Adjustments, Manager s Clearance Price Changes, reconditioned merchandise Creation of discount coupons that are not sponsored or authorized by corporate (i.e., Friends and Family 10% off coupons) Store-to-store transfers of merchandise (regular, special order or clearance) for personal benefit Selling, buying or distributing merchandise or services at other than the authorized prices Fraudulent reporting of travel or business expenses (also see Falsifying a Company document below) Using corporate credit cards for unauthorized purposes Failing to pay past due balances on corporate credit cards Falsifying a Company document or a document relied upon by the Company, by including false information or by knowingly omitting relevant information. The following are examples: Falsifying reports, medical excuses, applications, etc. Making false reports or claims Using another Cashier s log number Manipulating inventory Clocking in or out for another associate or allowing another associate to clock you in or out Computer Room Associates making their own punch changes or changes for other associates without manager verification and approval Improperly using an associate's social security number or employment ID Removing documents/counseling notices/performance evaluations from a file without proper authorization from your HR representative Altering, falsifying, destroying, or misusing any employment documentation including computerized materials and time clock records Misusing funds from Matching Gift Program, Homer Fund or Employee Fund Participating in or inappropriately influencing a transaction between Home Depot and another individual or organization when self-interest is involved; any situation where a conflict of interest exists between the Company's interests and an associate's personal interests (i.e., soliciting work from customers for personal gain) Working off the clock Asking an associate to commit a fraudulent or illegal act including working off the clock Holding merchandise off of the sales floor for personal benefit Associate Behavior/Conduct Unbecoming Initiating or participating in physical altercations or assault, attempted assault or offensive, aggressive and/or threatening conduct (i.e., threats of bodily harm to a person or family, etc.) Vandalizing Company, associate, vendor or customer property or willfully attempting to cause harm, damage, or injury to another person, to the property of that person, or to the property of the Company, whether or not the harm, damage, or injury actually occurs. 6

Being convicted of, or pleading guilty or no contest to, a serious criminal offense which substantially relates to the job including crimes involving violence or dishonesty (i.e., theft, fraud, sexual assault, possession of illegal drugs, etc.) Taking any action that creates a security or loss prevention risk, whether or not such risk results in financial loss or causes harm or damage to oneself, another person, the Company, the property of the Company or others. Assigning work that places associates at risk of serious harm, significant damage to Company property or financial loss to the Company whether or not such harm or damage occurs; knowingly allowing associates to perform work or assignments under unsafe conditions. Disclosing confidential or proprietary information without specific authorization. Such information includes, but is not limited to: financial records, sales information or events, confidential products or promotional lines, customer account information, vendor pricing agreement, and marketing or forecasting information. Company personnel records remain confidential and subject to the Code of Condut. Using equipment to videotape, audiotape or take photographs on Home Depot property unless the associate has been specifically authorized to do so by a manger in connection with the performance of his or her work. Participation in gambling activity, either with other associates or with a third party, while on Home Depot property and/or during working time. The nature of the gambling activity will determine if the offense is a Major Work Rule Violation and subject to immediate termination of employment or a Minor Work Rule Violation. Attendance/Punctuality Failing to report to work for two consecutive scheduled days without calling a salaried manager and/or without satisfactory explanation to give notice of the absence. When possible, associates must provide sufficient prior notice to a salaried manager. ( Refer to Attendance & Punctuality Guidelines) Failure to Provide Customer Service Blatantly disregarding a customer s needs Being flagrantly rude to a customer Treating a customer in an abusive, threatening or inflammatory manner including initiating arguments with a customer Disregarding safety standards that result in placing a customer at risk of serious harm Disregarding safety standards that result in considerable damage to a customer s vehicle, property or merchandise. Obtaining personal or confidential information regarding a customer without authorization. Failure to Follow Instructions/Insubordination Being flagrantly insubordinate Refusing to perform assigned work tasks or follow directions unless doing so would clearly violate Company policy or the law Refusing to submit to a search of personal belongings by an authorized manager while on Company property Impeding, refusing or failing to cooperate with an internal investigation Violation of Staffing and Selection Policy (Refer to Staffing Internal -Selection and Staffing External- Selection SOPs) 7

Assigning an associate to a position before the associate has qualified for the position and passed any appropriate test Failing to interview the correct number of candidates Intentionally allowing new hires to begin work prior to receiving all required preemployment paperwork, such as results of a negative drug screen or background screening or before the hire is processed in the AIMS system Paying new hire salary outside of the appropriate payroll system due to failure to process appropriate pre-employment paperwork Violation of Safety Policy Every associate must take personal responsibility and ownership for safety. All associates are required to immediately address safety issues and report unsafe conditions or behaviors to your manager. Refer to SOP s Critical Operating Safety Standards, Safe Work Practices and Hazardous Materials and the Safety Training class materials for detailed information on safety policies and guidelines. Violation of Loss Prevention Policy (Refer to Manager s Loss Prevention Internal/External Guide and Training Class materials for detailed information on Loss Prevention policies and guidelines) Pursuing or apprehending a subject without being authorized as described in the Loss Prevention External Policy Guidelines. Failing to report a Non-Recovery Incident in violation of the Loss Prevention External Policy Guidelines. Conducting or participating in any surveillance of company property without appropriate prior approval. Violation of Substance Abuse Policy (Refer to Drug Testing Overview- Substance Abuse in the Workplace) Violating the Alcohol Policy as outlined under Standards of Conduct Selling, distributing, offering, possessing, transferring or using alcohol or illegal/controlled substances during working time or on Company premises Engaging in the illegal use of prescription drugs during working time or on Company premises Having detectable levels of alcohol, drugs, or non-prescribed controlled substances as determined by a drug/alcohol test Failing to produce a valid prescription when testing positive for prescription drug use Refusing or failing to take a required drug and/or alcohol test within the defined period of time Tampering with or adulterating a drug or alcohol test Failing to notify a manager before beginning work of any drug or medication taken that may inhibit the associate s ability to work or to operate equipment safely Possession of Weapons and Explosives Possessing or using any kind of weapon, explosive or other dangerous implement while on Company premises or while performing duties for the Company, whether or not it is armed, loaded, or properly secured and whether or not it is concealed on an associate s person or contained in an associate s personal property such as a purse, briefcase, or vehicle. (Refer to Workplace Violence SOP) Workplace Violence/Threats of Violence (Refer to Workplace Violence SOP) 8

Direct threats or acts of violence made by an associate against another associate, customer or vendor. Failure to report threats or acts of violence by an associate, former associate, customer, or vendor, to a member of management. Information Systems Use and Security Disclosing Company Information by associates on any internet discussion forum. Installing or running any pirated, copied or illegally obtaining software on any Home Depot computer system. Using the Internet to access inappropriate websites as determined by Home Depot. (Ex. adult content, gambling, weapons and hate speech.) Inappropriate use of the email or telephone as determined by Home Depot. (Ex. messages relating to sexual activity, hate speech or threats of violence). Background Checks Requesting background check without knowledge or consent of the associate. Requesting a background check prior a conditional offer of employment Hiring and working an associate prior to the completion of all relevant background checks. Hiring an associate with a red alert without HRVP approval. Discipline Guidelines for Major Work Rule Violations Major Work Rule Violations are so serious in nature as to normally warrant termination for a first offense. Minor Work Rule Violations Examples of prohibited conduct include, but are not limited to, the following conduct. Violations may result in disciplinary action up to and including termination. Managers should always consider the seriousness of the offense to determine if it is a major or minor work rule violation (see investigation process). When in doubt, contact your Human Resources partners. Violation of Respect Failing to treat associates, customers, or vendors with respect or engaging in other inappropriate conduct toward others Failing to notify a Home Depot manager, a member of Human Resources management or a designated Company resource of discrimination or harassment Failure to Provide Customer Service Failing to engage a customer regarding products, services or sales Arguing or bickering with a customer Disregarding a customer s needs Intentionally failing to assist a customer with merchandise selection or purchase Failure to Act with Integrity and Honesty Having three (3) returned checks to Home Depot in 12 months Performing unauthorized work off of Company premises Failing to perform assigned work after clocking in 9

Associate Behavior/Conduct Unbecoming Smoking in other than designated areas or in Company vehicles or on Company property (unless in a designated area as described in Smoking and Tobacco Use SOP). Violating the Dress Code (Dress Code SOP) Reporting to work in an unfit condition to perform assigned work Unintentionally destroying, losing, or misusing property of a minor nature Failing to maintain proper accounting for the Employee Fund (Associate Committees) Participating in or inappropriately influencing a transaction between The Home Depot and another individual or organization when there is no self interest involved; other appearances of a conflict of interest between Company interests and personal interests Violating the No-Solicitation policy (Solicitation and Distribution SOP) Arguing or bickering with customers, vendors or their representatives Violating the Company's policies and procedures as contained in SOP, the Loss Prevention Internal and External Policy Guidelines, Manager s Safety Reference Guide and Compliance Policies that are not otherwise considered a major work rule violation Participation in gambling activity, either with other associates or with a third party, while on Home Depot property and/or during working time. The nature of the gambling activity will determine if the offense is a Major Work Rule Violation and subject to immediate termination of employment or a Minor Work Rule Violation. Attendance/Punctuality (Refer to Attendance & Punctuality Guidelines) Failing to work as scheduled without sufficient prior notice to or authorization by salaried management Having unexcused absences Having excessive unexcused tardiness Having excessive missed punches Following Instructions/Insubordination Failing to perform a specifically assigned work task or follow directions unless doing so would clearly violate Company policy or the law Violation of Safety Policy Associates must follow the Company s safety standards to ensure the safety and well being of all customers, associates and vendors. Refer to SOP s Critical Safety Operating Standards and Safe Work Practices and the Safety Training class materials for detailed information on safety policies and guidelines. Workplace Activity Conduct during working hours that demonstrates a significant lack of attention to assigned duties and responsibilities (example: loafing, sleeping, reading for personal pleasure, etc.) Discipline Guidelines for Minor Work Rule Violations Coaching Session Counseling Session A Coaching Session is used to bring to light an inappropriate behavior and/or action by an associate. A Counseling Session is used to call attention to a behavior and/or action that the associate has demonstrated in violation of Company policy or 10

Final Counseling Session Termination Session procedure. A Final Counseling Session is used if an associate demonstrates a pattern of behavior, repeatedly violates the Company s policies, and/or has received multiple Counseling Notices (more than two notices), and/or commits a serious violation that does not warrant termination for a first offense. For minor work rule violations, this meeting normally occurs after repeated violations of Company policies as the final step in the discipline process. When Managers/Supervisors Fail to Comply with These Requirements These requirements must be followed. Managers/supervisors who deviate from the requirements are subject to discipline up to and including termination. Exceptions to this SOP must be approved by the Human Resources Vice President (or equivalent) of the business unit. CONFIDENTIAL AND PROPRIETARY - This is an unpublished work containing confidential and proprietary information of The Home Depot. All rights reserved. 11