Our Code of Conduct | Bath & Body Works, Inc. (2024)

Table of Contents
Harassment, Discrimination and Retaliation Reporting Guidance Drug- and Alcohol-Free Workplace Partnering with Responsible Suppliers Environmental Responsibility Product Quality Global Trade Money Laundering Conflicts of Interest Financial Interests Working with Family Members and Close Friends Outside Employment Board Memberships and Personal Political Activities How do I know if a conflict of interest exists? A Bath & Body Works supplier asked me to serve as a consultant for them off-hours. Can I do it? My brother-in-law would be a perfect fit for the open position on our team. Can I hire them? Elizabeth and Dave are dating and both work for the company, but in different locations. Because they don’t work together, they’ve never told anyone about their relationship. Recently, Dave was promoted and moved to Elizabeth’s location. What should they do? Fair Competition and Fair Dealing Interactions with Governments Political Engagement Bribery and Corruption I am working in another country and one of the local associates told me that offering a small bribe is a customary way to do business and get things done there. What should I do? A supplier told me that they sometimes pay off government officials to avoid customs and duties on materials they supply to the company. This probably saves the company money, but is it okay? Business Gifts and Hospitality Offering Gifts and Hospitality How do I know if a meal with a supplier or other party is considered extravagant? Is there something I should do ahead of time to avoid a possible violation of the Code? A Bath & Body Works supplier is sponsoring a sporting event and invited only me to attend as a “thank you” for renewing their contract for another three years. Some of the vendor’s key executives and representatives will attend the event and it will be an opportunity for me to network with them. Should I accept? Accepting Gifts and Hospitality FAQs

Harassment, Discrimination and Retaliation Reporting Guidance

If you are subjected to any conduct you believe violates the company’s Sexual Harassment Prevention Policy, Civility, Anti-Discrimination and Other Harassment Prevention Policy, Anti-Retaliation Policy or another policy, or witness any such conduct, you should promptly report the conduct. You may speak to, write or contact your direct supervisor or, if the conduct involves your direct supervisor, any other manager or supervisor; your Human Resources partner, Global Ethics & Compliance, or the Ethics Hotline.

Supervisors and managers – even temporarily serving in such a capacity – have an obligation to report sexual or other harassment, discrimination, retaliation, or other misconduct of which they become aware. Supervisors and managers who observe such conduct or who receive any complaints of misconduct must report the conduct or complaint to their Human Resources partner or Global Ethics & Compliance so the company can investigate and take corrective action, if appropriate.

You can find more information about reporting concerns and the investigation process by reviewing the Harassment, Discrimination and Retaliation Reporting Guidance.

Drug- and Alcohol-Free Workplace

We are committed to providing a drug- and alcohol-free workplace. You must work entirely free of the effects of alcohol and illegal drugs, as well as the adverse effects of any other legal substance. You may not sell, possess, distribute, use or purchase illegal drugs - or sell, transfer or distribute prescription drugs - on company premises or during working hours. You may not report to work after consuming alcohol or illegal drugs. For example, you may not go to lunch, drink alcohol, and then return to work. The company has adopted a Global Associate Alcohol Policy that addresses consumption of alcohol at company-sponsored events or while on company business.

Partnering with Responsible Suppliers

We seek to partner only with suppliers that share our values and our commitment to ethical and responsible business practices. We strongly believe the quality of our merchandise begins with the treatment of the people who create our products. For that reason, we have a supplier code of conduct and compliance guidebook that outlines our standards for suppliers. While we recognize there are different legal and cultural environments in which our suppliers operate around the world, we expect our suppliers to comply with Bath & Body Works’ high standards in order to do business with us. Bath & Body Works will not knowingly partner with suppliers that engage in any form of modern slavery or are unwilling to commit to or comply with our supplier standards.

Environmental Responsibility

We believe in doing what is right in our industry, our community and our world. We comply with all applicable environmental laws and strive to conduct our business in an environmentally responsible way, to minimize our impact on the environment.

Product Quality

We pride ourselves on the quality and integrity of our products. We strive to sell high-quality products that comply with all applicable product safety laws.

Global Trade

We comply with import and export laws and regulations. Countries may impose economic sanctions and restrictions relating to business dealings with specific countries, economic sectors, entities or individuals of concern. Export controls on the export or in-country transfer of certain restricted items or technology are also common. We comply with all economic sanctions as well as export control laws applicable to our business and we don’t participate in boycotts that the United States does not support.

Money Laundering

We comply with all applicable laws that relate to money laundering. Money laundering is the process of making money or proceeds generated by a criminal activity, such as drug trafficking or terrorist funding, that appear to come from a legitimate source. Criminal proceeds also include all forms of assets, real estate and intangible property that are derived from criminal activity.

Conflicts of Interest

We avoid conflicts of interest. A conflict of interest is any activity, financial interest or personal or professional relationship that interferes (or may appear to interfere) with your ability to make objective decisions on behalf of the company. Conflicts of interest create risks for our company, and we all have a duty to avoid situations that could create – or even appear to create – conflicts of interest. Your own actions, financial and business interests or relationships may create conflicts of interest. You must report potential conflicts of interest as part of the annual survey process and as they may arise to your manager, Human Resources partner or Global Ethics & Compliance at EthicsandCompliance@bbw.com.

You should never use company property, information or your position at Bath & Body Works for personal gain. You should never compete with the company, either by engaging in the same line of business or by taking away any opportunity for sales or purchase of products, services or interests. Situations involving conflicts of interest are not always obvious or easy to resolve. This section describes some of the more common circ*mstances you might encounter.

Financial Interests

A conflict of interest can arise when your judgment could be influenced – or appear to be influenced – by potential personal financial gain. For example, if you have a financial interest in a company that does business with Bath & Body Works and your role directly or indirectly involves that company, you may have a conflict of interest. If you have a financial interest in a supplier that might pose a conflict of interest, you must disclose it to Global Ethics & Compliance.

Working with Family Members and Close Friends

If you work with a family member or anyone with whom you have a close personal relationship, the relationship can lead to the appearance of bias. For the purposes of this policy, a “close personal relationship” includes (but is not limited to) your spouse, partner, relative (by blood, marriage or adoption), person you’re romantically or intimately involved with, or those you live with. You must report any close personal relationship you have with anyone in your reporting line to your Human Resources partner or Global Ethics & Compliance. In addition, you may not be involved in any decisions related to the hiring, compensation, evaluation or promotion of anyone with whom you have a close personal relationship. Executives in positions of Senior Vice President and above may not have romantic or intimate relationships with other associates. Also, if you or anyone with whom you have a close personal relationship works for a supplier, customer or competitor, notify your manager and Human Resources partner immediately and remove yourself from any decision-making as it relates to the third party. Do not use your position at Bath & Body Works to influence the bidding process or any negotiation that involves someone with whom you have a close personal relationship.

Outside Employment

While Bath & Body Works recognizes that some associates may have side businesses or work second jobs, you should never engage in any outside employment or other activities that interfere with your responsibilities as a Bath & Body Works associate, are contingent on your use of company assets, violate your confidentiality or other obligations to the company or require you to supply products from the company. Associates may not work for a supplier if they have direct or indirect influence over the supplier’s business with Bath & Body Works. If you have questions about whether outside employment is a potential conflict, contact Global Ethics & Compliance.

Board Memberships and Personal Political Activities

Before accepting a position to serve on a for-profit board of directors or as a government official, seek approval from Global Ethics & Compliance to ensure no conflict of interest exists and that such service will not affect your ability to do your job. If you choose to personally engage in the political process by working on a political campaign or a similar activity, you may do so only on your own time using your own money or resources. You are not authorized to act on behalf of the company or use company resources or services for your personal political activities.

Our Code of Conduct | Bath & Body Works, Inc. (1)

How do I know if a conflict of interest exists?

Ask yourself:

  • Do my outside interests influence – or appear to influence – my ability to make sound business decisions?

  • Will I personally benefit from my involvement in the situation? Will a friend or relative benefit?

  • Could my participation in this activity interfere with my ability to do my job?

  • Will I be using company assets for my personal benefit?

  • If the situation becomes public, would I be embarrassed?

  • Would it embarrass the company?

If the answer to any of these questions is “yes” or “I don’t know,” seek guidance from Global Ethics & Compliance.

A Bath & Body Works supplier asked me to serve as a consultant for them off-hours. Can I do it?

Not without approval. Serving as a consultant for another company that does business with Bath & Body Works can create a conflict of interest. Raise the issue to your manager or Global Ethics & Compliance.

My brother-in-law would be a perfect fit for the open position on our team. Can I hire them?

You can refer your brother-in-law, but they must go through the normal application process. In addition, you must excuse yourself from the decision-making process and you should not seek to influence the outcome of the hiring decision in any way.

Elizabeth and Dave are dating and both work for the company, but in different locations. Because they don’t work together, they’ve never told anyone about their relationship. Recently, Dave was promoted and moved to Elizabeth’s location. What should they do?

Neither Elizabeth nor Dave can be involved in decisions related to the other’s compensation, benefits, evaluations or promotions. If either Elizabeth or Dave supervises or reports to the other, they must immediately disclose their relationship to Human Resources and Global Ethics & Compliance.

Fair Competition and Fair Dealing

We compete vigorously but fairly and ethically. We do not engage in unfair or fraudulent business practices either directly or indirectly through a third party either to help our business or hurt a competitor’s business. It is important that we comply with all applicable competition, fair dealing and antitrust laws and avoid practices that interfere with fair and open competition. This means, for example, that you may not enter into any agreement (whether formal or informal) with a supplier or other third party that illegally impedes competition. We must also avoid discussions and agreements with competitors that might prevent consumers from receiving the benefits of competition – even if the competitor suggests it or if the topic comes up at a trade event. In addition, we engage in truthful and accurate sales and marketing practices and guard against making deceptive, unfair or inaccurate claims about our merchandise and services. For specific information about applicable laws or to seek guidance, contact the Legal Department (ChiefLegalOfficer@bbw.com).

Interactions with Governments

We are truthful and straightforward with government entities. If you are contacted by a government or regulatory representative and asked to provide information or submit to an inspection as a representative of the company, follow your department or store procedures. Never knowingly provide false or misleading information to any government official or representative or destroy records related to an investigation and never direct or encourage another associate to do so.

You may share information about your own employment with others or cooperate with any fair employment practices agency. You may also report possible violations of law to any government agency or entity or make any other disclosure that is protected under applicable law or regulation. You do not need prior authorization from the company to make such reports, and you are not required to notify the company that you have made such reports. If you have questions about responding to a government or regulatory inquiry, you should seek assistance from the Legal Department (ChiefLegalOfficer@bbw.com).

Political Engagement

We believe that involvement in political activities in the communities we serve is important to our success. The company engages in public policy issues and may make political contributions as laws allow. Global Ethics & Compliance and Government Affairs must pre-approve any use or commitment of company money or other company resources for political activities.

The company also communicates with government officials and agencies around the world about public policy issues that may affect our business. Because lobbying is strictly regulated at all levels, Government Affairs must pre-approve lobbying activities on the company’s behalf.

Bribery and Corruption

We are committed to using honest and ethical business practices. We follow all applicable and anti-bribery laws and do not tolerate bribery, corruption or unethical practices of any kind anywhere we do business.

Among other things, anti-corruption laws and our Global Anti-Corruption Policy prohibit offering or giving anything of value to anyone to gain an improper advantage for the company, regardless of local practice or custom, and even if refusing to do so will disadvantage our business. The term “anything of value” should be broadly construed to include not only cash or cash equivalents such as gift cards, but also, among other things, discounts, gifts, entertainment, event tickets, meals and drinks, transportation, lodging and promises of future employment. This prohibition also applies to third parties; we may not ask or allow a third party to take any action we can’t take directly. As a result, we may require additional review of certain third parties and ensure our agreements include appropriate anti-corruption provisions.

You must immediately report any suspected violations or any requests for a bribe or other improper payment. For questions and guidance, contact Global Ethics & Compliance at ethicsandcompliance@bbw.com.

Our Code of Conduct | Bath & Body Works, Inc. (2)

I am working in another country and one of the local associates told me that offering a small bribe is a customary way to do business and get things done there. What should I do?

Even if offering a bribe seems like the easiest way to get something done, it is always improper. You should neither offer or pay a bribe or let someone else pay a bribe on your or the company’s behalf, regardless of how “customary” it might be. If a business partner or supplier suggests that you pay a bribe, you should immediately report the incident to Global Ethics & Compliance.

A supplier told me that they sometimes pay off government officials to avoid customs and duties on materials they supply to the company. This probably saves the company money, but is it okay?

No. We expect our business partners to comply with the law and we will only do business with suppliers who conduct themselves ethically and legally. You should report the supplier’s conduct to Global Ethics & Compliance immediately.

Business Gifts and Hospitality

We do not exchange gifts or hospitality that may look like an attempt to improperly influence a business decision. This policy applies if you are the giver or the recipient. Gifts include cash or cash equivalents (gift cards, gift certificates, rebates and discounts), merchandise, personal favors, transportation, travel or vacation accommodations, business or employment opportunities (including internships) and anything else of value. Hospitality includes business meals, co*cktails, tickets to events (sporting events, concerts, theater, etc.), other forms of entertainment and related travel. You must strictly adhere to the thresholds and requirements set forth in this policy; any exceptions require pre-approval by Global Ethics & Compliance.

This Gifts & Hospitality Policy does not apply to gifts to government officials. Anything of value (including gifts and hospitality) offered or given to a government official must comply with all applicable laws and the company’s Global Anti-Corruption Policy. While this policy provides general guidelines related to giving and receiving gifts and hospitality, Bath & Body Works may impose more restrictive limits to specific regions, departments or functions. If you have any questions about gifts and hospitality, you should seek assistance from Global Ethics & Compliance.

Offering Gifts and Hospitality

There are times when you may want to offer gifts or hospitality to a business contact. We never offer anything of value to influence a business decision or make offers that may be perceived as such. As long as that is not the case, and if it is otherwise consistent with our values and approved by your manager, you may offer:

  • Gifts or hospitality with a value of $50 or less;

  • Business meals provided they are not extravagant;

  • An invitation to an occasional event provided the related costs are reasonable, customary and appropriate, and you will attend the event with the external party; and

  • Company gift cards redeemable for Bath & Body Works merchandise with a value of $50 or less.

You may never offer or give:

  • Cash;

  • Cash equivalents such as gift cards (other than company gift cards as described above), gift certificates, discounts and rebates;

  • Anything valued at more than $50;

  • Any solicited gift or hospitality (that is, the external party asks you for the gift or hospitality);

  • Anything of value as a quid pro quo; or

  • Anything that would cause other people to violate their employer's standard. Always be mindful that our business partners have their own rules on receiving gifts and hospitality, and you should never offer anything that would violate those rules.

Any gift or hospitality you give must be budgeted and accurately disclosed in detail in our financial records.

Our Code of Conduct | Bath & Body Works, Inc. (3)

How do I know if a meal with a supplier or other party is considered extravagant? Is there something I should do ahead of time to avoid a possible violation of the Code?

You should ask yourself if the type of meal – location, cost – is reasonable and customary for the circ*mstances. To avoid a potential violation of the Code, if a supplier or third party invites you to a meal, you can suggest a venue that you know to be reasonable and make sure you discuss the meeting with your manager before attending.

A Bath & Body Works supplier is sponsoring a sporting event and invited only me to attend as a “thank you” for renewing their contract for another three years. Some of the vendor’s key executives and representatives will attend the event and it will be an opportunity for me to network with them. Should I accept?

No. You cannot accept hospitality as an individual reward for conducting company business. From time to time, a department or team may attend a “celebration event” with a vendor at the conclusion of a major project, but no individual associate may personally benefit from working with a vendor.

Accepting Gifts and Hospitality

You may never accept gifts or hospitality from any supplier, vendor or other third party if you have any reason to believe the third party may be seeking to influence business decisions or transactions. And you may never request gifts or hospitality from any third party. Perception matters as well. You should always be aware of how the act of accepting a gift or hospitality might be perceived by the public, by other company suppliers or vendors, or by other associates.

If you are fully satisfied that the giver is not attempting to influence business and the acceptance of a gift will not result in a negative perception, then you may accept:

  • Gifts or hospitality with a value of $50 or less;

  • Business meals, if they are not extravagant;

  • An invitation to an occasional event provided the related costs are reasonable, customary and appropriate, you will attend the event with the external party and your manager approves; and

  • Perishable gifts, if they are shared with the team or donated to a charitable organization.

  • Associates in Asia may accept one lai see/hongbao/red envelope valued at $15 or less from a person, company or vendor group outside of Bath & Body Works for a single holiday or event each year.

You may never accept:

  • Cash;

  • Cash equivalents (including gift cards, gift certificates, discounts and rebates);

  • Anything valued more than $50 (with the exception of the perishable gifts described above);

  • Anything of value as a quid pro quo; or

  • Anything that would cause other people to violate their employer’s standards.

In the rare instance when refusing or returning a gift or hospitality would be impractical or embarrassing, you should immediately notify Global Ethics & Compliance so they can give you guidance on how to manage the gift in a fair and objective manner that does not benefit you personally, such as donating it to a company-sponsored silent auction fundraiser or charitable cause. You should also immediately notify Global Ethics & Compliance about any other gift or hospitality you believe was offered in violation of our policy.

Our Code of Conduct | Bath & Body Works, Inc. (2024)

FAQs

What is the code of conduct for Bath and Body Works? ›

We do not tolerate discrimination of any kind, harassment, or bullying or other abusive behavior in the workplace. We have no tolerance for retaliation of any kind. IT MATTERS HOW WE PLAY THE GAME. Doing what is right means following our beliefs — and the rules — even when no one is watching.

What are the main points of the code of conduct? ›

A code of conduct should include several key components, such as a message from the CEO, company values, guidelines for respecting other employees as well as clients/customers, procedures for reporting misconduct, consequences for code violations, and compliance resources.

What is the employee code of conduct? ›

The Employee Code of Conduct policy details the behavioral expectations for employees towards colleagues, supervisors, and the organization. It emphasizes open communication, professionalism, respect, and adherence to laws, while also outlining potential disciplinary actions for violations.

What to put in a code of conduct? ›

Key elements to include in your code of conduct
  1. Compliance with Legislation. ...
  2. Commitment to High Standards. ...
  3. Honesty and Integrity. ...
  4. Care and Diligence. ...
  5. Job Description Compliance. ...
  6. Policies and Procedures. ...
  7. Respect and Courtesy. ...
  8. Anti-Bullying and Harassment.

Is there a lawsuit against Bath and Body Works? ›

REPORT AND RECOMMENDATION

Plaintiff Latara Harris sues Defendant Bath & Body Works, LLC, under 42 U.S.C. § 1981, alleging Defendant refused to allow her to exchange candles she bought online with candles in a store because of her race.

What is Bath and Body Works dress code? ›

Apron with name tag, white shirt (t shirt or long sleeve doesn't matter) blue denim or khaki pants, and canvas tennis shoes or boots like Chelsea's, doc martens, etc. White finished color top, no tee shirts, jeans with no holes, no athletic shoes or flip flops, anything else is ok. Tattoos and piercings now accepted.

What are the 7 codes of conduct? ›

7 Ethical Principles
  • Honesty and Integrity.
  • Fairness of commercial practices.
  • Data confidentiality.
  • Professional behavior.
  • Professional skills and added value.
  • Social respect.
  • Environmental care.

What is an example of a bad code of conduct? ›

Asking for recognition for someone else's job, calling in sick to go to the hill station, sabotaging someone else's work, and, in sales, falsifying the product or service to fulfill the target are all examples of unethical behavior in the workplace.

What is the code of conduct in simple words? ›

A code of conduct is a set of values, rules, standards, and principles outlining what employers expect from staff within an organization.

How to answer what do you understand by privacy and code of conduct? ›

Privacy, at its core, is the safeguarding of personal information, which can significantly impact employee behavior. In contrast, a code of conduct is a set of regulations delineating an organization's behavior and ethical standards, including the proper use of company resources.

What is the employee code? ›

An employee ID number code is a unique code assigned by employers to individual employees. This identification code can also simply be called an employee number, employee code, employee ID or any other similar term.

What is the personal code of conduct? ›

What's Included in a Personal Code of Conduct? A personal code of conduct is deeply personal and relates specifically to you, the person writing it. This will be the set of behavior rules you live by, guiding every action you take in life. Try to set behavior standards for yourself that are realistic and flexible.

What are 2 examples of what can be written in a code of conduct? ›

The primary areas a code of conduct usually address include: Company values Employee behaviours Dress code Tardiness and absenteeism Leave policy Employee break policy Conflicts of interest Communication Harassment Reporting of misconduct Disciplinary actions Illegal activities such as corruption and fraud ...

How do I fill out a code of conduct form? ›

How to write a code of conduct
  1. Your company's core values.
  2. Compliance with laws.
  3. Rules and policies for: Respect (including harassment, discrimination, and more) Use of company property. Personal appearance (including cleanliness and dress code) Absenteeism and lateness. ...
  4. Disciplinary actions.
  5. Signature page.
Jun 9, 2022

What not to do in code of conduct? ›

(7) No aspect of the private life, not connected with the public activities, of the leaders or workers of other parties shall be permitted to be criticized. (8) Other parties or their workers shall not be criticized based on unverified allegations or on distortions.

What is the MSPA code of conduct? ›

The MSPA expects members and shoppers to follow principles of honesty, professionalism, fairness and confidentiality to guard the interests of the public and our clients in order to promote good business practices. For this purpose, MSPA encourages shoppers to obtain MSPA Shopper Certification.

What are Bath and Body Works core values? ›

They aren't optional or aspirational … they are how we behave and serve as a lens for decision-making to ensure we have a positive impact on our customers, associates and the world around us in a way that makes us proud. Our values are: The customer rules. Diversity, equity and inclusion make us stronger.

What is a code of conduct in the clothing industry? ›

In other words, a Code of Conduct is an agreement with rules and regulations within and between organizations and people. It shows what kind of behaviour is not accepted and what is expected. In the case of a fashion brand, the standards are used to hold their suppliers accountable.

Does code of conduct include dress code? ›

A code of conduct in practice can range from big picture ideals to specific rules. For example, a code of conduct can outline how employees should behave to reflect the organization's wider mission, but it can also define fixed regulations related to internal practices such as dress code or break policy.

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