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1 Code of Conduct and Ethics: Committed to Integrity
Code of Conduct and Ethics:
Committed to Integrity
2 Code of Conduct and Ethics: Committed to Integrity
Contents
Leadership message
Living our purpose, vision and values
Our Code
Compliance with our Code
To whom does our Code apply?
How to use our Code
We uphold our Code
We speak up
We make good ethical decisions
Our commitment to… each other
We embrace diversity, equity and inclusion
We promote respect
We keep our workplace healthy, safe and secure
Our commitment to… our customers and communities
We deliver safe, high-quality products and services
We market our products and services openly and honestly
We are committed to running a sustainable business
Our commitment to… our marketplace
We avoid conflicts of interest
We conduct our business honestly and with integrity
We comply with applicable financial laws and regulations
We comply with applicable international trade laws and regulations
We deliver high-quality pharmacy and healthcare services
Our commitment to… our partners
We choose suppliers with integrity
We adhere to laws relating to government contracts and programs
We maintain appropriate relationships with healthcare professionals
Our commitment to… our shareholders
We maintain accurate books and records
We protect WBA assets
We comply with insider trading laws
We safeguard confidential and proprietary information
We communicate responsibly
Contacts
Waivers
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2 Code of Conduct and Ethics: Committed to Integrity
3 Code of Conduct and Ethics: Committed to Integrity
At Walgreens Boots Alliance (WBA), integrity
and high ethical standards are the foundation
of everything we do. Our Code of Conduct
and Ethics (our Code) guides each of us in
fulfilling our purpose in line with our values.
The theme of our Code is “Committed to
Integrity.” This means we do the right thing
– every day, in every way. Our commitment
to integrity extends to how we interact with
each other, our patients and customers, our
communities, our marketplace, our partners
and our shareholders. Acting with integrity
protects our reputation, builds trust and is
essential to our continued success.
We expect everyone at WBA to read,
understand and commit to complying with
our Code. Refer to our Code when you have
questions or doubts about the right thing
to do, and use the many resources that are
available to support you. If something is still
unclear, please speak up. Your manager, a
representative from Human Resources or a
Compliance and Ethics leader should be able
to help. You can also use our confidential
Compliance and Ethics Hotline at any time to
ask questions or report concerns.
Thank you for your commitment to integrity
as we work to be a force for good in the
communities we serve around the world.
Best regards,
Stefano Pessina
Rosalind Brewer
Leadership message
Stefano Pessina Rosalind Brewer
Executive Chairman Chief Executive Ocer
3 Code of Conduct and Ethics: Committed to Integrity
4 Code of Conduct and Ethics: Committed to Integrity
Living our purpose, vision and values
Our Code helps guide our actions and supports our purpose, vision and values
▸ Courageous
Challenging the status- quo, addressing conflict
directly, and driving informed risk taking.
▸ Connected
Reflecting the communities we serve,
understanding the needs of others, and
innovating together.
▸ Committed
Leading with integrity, building on our legacy,
and striving boldly toward the future.
▸ Curious
Continuously learning and adapting, following
the science and data, and creating paths where
none existed.
Our Purpose
More joyful lives through better health.
Our Values
Our Vision
To be the leading partner in reimagining local healthcare and wellbeing for all.
5 Code of Conduct and Ethics: Committed to Integrity
At WBA, we are Committed to Integrity. This means complying with the laws,
regulations and WBA policies that apply to our work. It also means at times going
beyond compliance – doing the right thing even if there is no specific legal
requirement or applicable policy.
Our Code outlines the principles and behaviors we are expected to follow in
our daily work. It helps us fulfill our purpose. It keeps us true to our values and
enables us to build trust among our colleagues, customers, communities and
other stakeholders so that our business will be sustainable and successful in the
long run.
Compliance with our Code
Compliance with our Code is mandatory. If you fail to comply with laws, regulations
and WBA policies including our Code, there will be consequences, which may
include disciplinary action up to and including termination of employment. If your
actions violate the law, additional legal consequences including civil penalties,
criminal prosecution, fines and imprisonment may occur that could impact WBA,
individual team members and leaders.
To whom does our Code apply?
Our Code applies to:
Our Code
▸ WBA Board of Directors
▸ WBA ocers
▸ WBA team members
▸ WBA subsidiaries’ team members
▸ Ocers and employees of any
business in which WBA or a
subsidiary has a controlling interest
▸ Parties acting on behalf of WBA or its
subsidiaries, including consultants,
agents, suppliers, intermediaries or
representatives
6 Code of Conduct and Ethics: Committed to Integrity
How to use our Code
Our Code is divided into sections, outlining how we commit to
integrity with respect to:
Each other
Our customers and communities
Our marketplace
Our partners
Our shareholders
Our Code
Our commitment A statement of the principles that guide our actions in that area
Why it matters An explanation of how following these principles helps us to be better at what we do
Keeping our commitment A list of specific behaviors to follow
Examples For increased understanding of the topic
What should I do? Examples that bring select topics to life
Our Code is intended to define how we should conduct ourselves as team members or representatives of WBA.
We encourage you to refer to it often, whenever you have questions or need more information. For the various
topics covered in our Code, you will find the following information:
7 Code of Conduct and Ethics: Committed to Integrity
We uphold our Code
Our responsibilities
We are each responsible for reading, understanding and upholding our Code. We live our
commitment to integrity when we:
Managers’ additional responsibilities
If you are a manager, you have a special responsibility to live our commitment to integrity, and you
achieve this when you:
Our Code
Comply
with our Code,
company
policies and laws
and regulations
that apply to our
work.
Understand
the legal and
reputational risks
we face in our
business, and
how our Code
and company
policies help
manage those
risks.
Speak up
with any
questions or
concerns, and
report observed
or suspected
misconduct or
Code violations.
Cooperate
with audits and
investigations if
called upon.
Lead
others by acting
as role models in
living our values,
upholding
our Code and
supporting
an inclusive
environment.
Encourage
your team
to speak up
when they
have questions
or concerns;
actively
champion
and create
an inclusive
environment.
Listen
to team
members who
raise concerns,
and follow up to
ensure concerns
are addressed
appropriately
and eectively.
Never
retaliate
against anyone
who raises a
concern in good
faith and/or
cooperates in an
investigation.
Recognize
team members
who do the
right thing,
and consider
a commitment
to ethics and
values in
performance
reviews.
Never
compromise
our company’s
integrity or
values for
business results.
8 Code of Conduct and Ethics: Committed to Integrity
At WBA, we believe in creating an inclusive workplace where everyone feels comfortable
bringing forward their ideas – and their concerns.
If you have a concern, WBA needs to hear from you. Immediately report any situation that
compromises or appears to compromise our integrity or our reputation.
Support anyone who raises a concern in good faith. If you are asked to participate in an
investigation, provide accurate and complete details. Do not make false or misleading
statements in or during an investigation, and do not encourage anyone else to do so.
Seeking help
At WBA, our open-door environment is key to our culture. It encourages us to present ideas,
raise concerns and ask questions – including those of a legal or ethical nature. Your own
manager is often the best resource for most of your concerns, but if you feel uncomfortable,
you may raise your concerns with any member of management, without fear of retaliation.
Our Code cannot anticipate every situation you may find yourself in. If you ever have a
question about what you should do in a specific situation, we have resources available to help
you. You can raise your questions or concerns with:
We speak up
Any manager,
including your
own
Human
Resources or the
Compliance and
Ethics team
Our Global Chief
Compliance and
Ethics Ocer
The Compliance
and Ethics
Hotline
Ask a question Request guidance
Report a concern
Using the Compliance and Ethics Hotline
As part of our “Speak Up” culture, our confidential Compliance and Ethics Hotline is available
for any team member to raise concerns about inappropriate business conduct or unethical
behavior. The hotline is managed by an independent third party, and it is available 24 hours a
day, seven days a week in your local language. You can report via phone or an online portal to:
9 Code of Conduct and Ethics: Committed to Integrity
We speak up
What should I do?
Two months ago, I made an allegation of misconduct involving my team. Ever since then,
my manager and teammates have been ignoring me in meetings and not including me in
outside social activities.
Retaliation involves a significant change in how you are treated after raising an issue,
especially by your manager. If you are being treated dierently by your team after you
reported an allegation of misconduct, this could be retaliation. You should report your
concern about retaliation to senior management, the Compliance and Ethics Hotline,
Human Resources or the WBA Global Chief Compliance and Ethics Ocer.
Condentiality and anonymity
We will make every eort to protect the confidentiality of reporters, and you may remain
anonymous as allowed by law.
Retaliation
WBA is committed to protecting the rights of anyone who raises an issue in good faith, and we
do not tolerate retaliation. You will not be punished or retaliated against for raising a concern
in good faith.
Anyone retaliating against any team member for making a report or cooperating in an
investigation shall be subject to discipline, up to and including termination of employment.
Team members who feel that they are facing retaliation should report their concern to
management, the Compliance and Ethics Hotline, Human Resources or the WBA Global Chief
Compliance and Ethics Ocer.
9 Code of Conduct and Ethics: Committed to Integrity
10 Code of Conduct and Ethics: Committed to Integrity
Ethical decision-making guide
We commit to making decisions that align with our company values every day.
Use this resource as a guide for making ethical decisions.
We make good ethical decisions
▸ Ask the Compliance and Ethics Hotline.
▸ Ask the Global Chief Compliance and Ethics Ocer or any member of the Compliance and Ethics team.
▸ Ask your Human Resources or Legal representative.
Is it
legal?
Does it follow
applicable laws and
regulations?
Is it
compliant?
Is it consistent with the
WBA Code of Conduct
and relevant company
policies?
Is it
right?
Is it consistent with
our core values, and
does it support our
company reputation?
Do not do it*
No Ye s
Do not do it*
No Ye s
Consult resources below*
No Ye s
Proceed*
*If you are not sure of the answer to a question or how to proceed, consult with these resources:
11 Code of Conduct and Ethics: Committed to Integrity
Our commitment to...
each other
11 Code of Conduct and Ethics: Committed to Integrity
12 Code of Conduct and Ethics: Committed to Integrity
Examples
What should I do?
I am a hiring manager with two great candidates. They both have the same skills, abilities
and experiences. The only dierence is their gender, and we only have men on our team
now. Since they have the same qualifications, is it okay if I hire the woman just because it will
increase the diversity on my team?
You should hire the best qualified candidate for the job. If two candidates are equally
qualified, it is appropriate to consider factors such as experience with leading diverse
teams and valuing diverse perspectives.
Our commitment
At WBA, we pride ourselves on creating an inclusive environment that welcomes,
values and champions diversity, equity and inclusion.
Why it matters
DEI is a key aspect of WBA’s value system and culture. It helps inspire the
innovation that drives our business and enhances our competitive advantage.
Our workforce should reflect the diversity of our patients, customers and the
communities we serve across the globe.
Keeping our commitment
▸ Hire people from diverse backgrounds.
▸ Support team member-driven Business Resource Groups (BRGs) to drive
diversity and inclusion on a local level.
▸ Buy from diverse and small businesses.
▸ Provide diversity, equity and inclusion training and learning experiences.
Our business
▸ Focusing intentionally on our spend with diverse and small businesses, including
minority and women-owned businesses
▸ Earning top scores on the Disability Equality Index and the Corporate Equality Index on
LGBTQ workplace equality
Our team member experience
▸ Expanding BRGs globally across WBA
▸ Conducting unconscious bias training and DEI education initiatives
▸ Expanding programs for team members with disabilities
We embrace diversity, equity and inclusion
Diversity, equity and inclusion (DEI) means representing and supporting the unique identities,
experiences and abilities of all our team members, patients and customers.
13 Code of Conduct and Ethics: Committed to Integrity
We promote respect
A respectful work environment is free of harassment and discrimination. Harassment includes
conduct that creates an intimidating, hostile or oensive working environment. Discrimination
means treating people dierently based on factors such as race, color, gender, age, religion,
disability, sexual orientation, national origin, military status, marital status or any other status
protected by applicable law (known in the U.S. as a protected class).
Examples
Our commitment
We respect everyone, provide equal opportunities to team members and we do
not tolerate harassment or discrimination of any kind.
Why it matters
We do not tolerate harassment or discrimination because they are not aligned
with our core values and are prohibited by law. We believe in upholding a positive
and respectful work environment for our team members, every day. Additionally,
if you violate laws, regulations and WBA policies concerning harassment and
discrimination, you could face civil and criminal penalties.
Keeping our commitment
▸ Treat everyone with respect.
▸ Do not harass or discriminate against anyone.
▸ Report any act of discrimination or harassment you witness or experience.
Harassment
▸ Bullying, humiliating or intimidating others
▸ Threatening violence or engaging in violent acts
▸ Displaying oensive materials or jokes
▸ Initiating unwanted physical contact
▸ Committing physical or verbal abuse
▸ Engaging in conduct of a sexual, racial or other nature that unreasonably interferes with
an employee’s work performance or creates an intimidating, hostile or oensive working
environment
Discrimination
▸ Treating someone less favorably than others because of membership in a protected class
▸ Threatening dismissal or failing to promote based on membership in a protected class
14 Code of Conduct and Ethics: Committed to Integrity
We keep our workplace healthy, safe and secure
A healthy, safe and secure workplace is free from threats, violence, substance abuse and
hazardous conditions.
Examples
What should I do?
The doorbell to the receiving area rings three times while I am helping a customer. As I walk
through the store, I see a cleaning product spilled in the aisle. Should I stop to clean the spill
even though the delivery driver could be angry about the delay?
Everyone is responsible for safety, and a safe shopping and working environment is an
essential priority. Cleaning liquid spills or removing tripping hazards is more important
than routine tasks. First, put up the wet floor sign and then notify leadership on duty. Ask a
team member to bring you cleaning supplies while you stand by the spill. Be sure to wear
appropriate personal protective equipment and use the approved spill clean-up kit.
Our commitment
We are committed to providing a safe and secure environment that promotes
health and well-being. We do not tolerate violence, threats or weapons on
company property. We follow laws and regulations about safety, and we ban
illegal drug and alcohol use on company property.
Why it matters
The safety of every team member, customer and patient is essential. Taking steps
to provide for a healthy, safe and secure environment aligns with our values and
supports our commitment to each other.
Keeping our commitment
▸ Follow safety laws, regulations and WBA policies.
▸ Keep your workspace free of hazards.
▸ Report any conduct that is unsafe.
▸ Contact authorities if you feel you are in immediate danger.
▸ Do not use drugs or alcohol at work in violation of WBA policies.
Safe conditions
▸ Keeping store aisles and other passageways clear of unattended objects or trip hazards
▸ Immediately cleaning spills on the floor
Violence
▸ Never threatening or physically assaulting others
▸ Never bringing weapons onto company property
Substance abuse
▸ Prohibiting the use or possession in our workplace of illegal drugs, alcohol, cannabis or
any other substance which would violate company policy, including prohibiting working
while under the influence of such substances
Hazardous exposure
▸ Placing aected products into the proper disposal containers in a timely manner
▸ Following protocol for the safe disposal of hazardous materials
15 Code of Conduct and Ethics: Committed to Integrity
Our commitment to...
our customers and communities
15 Code of Conduct and Ethics: Committed to Integrity
16 Code of Conduct and Ethics: Committed to Integrity
We deliver safe, high-quality products and services
Safe, high-quality products and services help enable us to provide the highest standards of
care for our patients and customers.
Examples
Our commitment
We only sell products and provide services that meet our high standards of
safety and quality. We follow internal and external product safety rules, and
so do our suppliers. We comply with applicable bans and recalls. We report
defective or unsafe products immediately upon awareness.
Why it matters
The trust we have earned from our customers and patients is foundational to
our business and continued success. We must continue to earn their trust by
upholding our high ethical standards. One example is by oering safe, high-quality
products and services.
Keeping our commitment
▸ Follow product safety laws and regulations.
▸ Provide quality, dependable services.
▸ Require suppliers to uphold our standards.
▸ Report defective products.
Product safety
▸ Removing recalled products from the store shelves rapidly
▸ Reporting health and safety concerns related to our products promptly
▸ Knowing and following applicable food safety requirements
Healthcare advice
▸ Referring patients and customers with healthcare questions to licensed professionals
such as our pharmacists
▸ Only providing healthcare services from qualified professionals who follow ethical
standards for their roles
Our reputation
▸ Delivering safe and reliable products that comply with applicable laws and regulations
▸ Sourcing high-quality products from ethical suppliers
▸ Respecting applicable age restrictions when selling products
17 Code of Conduct and Ethics: Committed to Integrity
We market our products and services openly and honestly
Marketing openly and honestly means we provide clear and accurate information to our
customers while protecting personal information.
Examples
Our commitment
We are honest in our advertising and communications. We are truthful and do not
make misleading claims about our business or that of our competitors. We are
transparent to our customers and patients about how we use their personal data,
and we provide this information in a way that is clear and easily understood.
We are committed to protecting the privacy of our patients, customers and team
members. We handle personal information in a way that is both legal and ethical.
Why it matters
Trust is central to everything we do at WBA. Our patients and customers trust us
to be honest in our communications and trust us with their personal information,
including their health information. Every team member has a responsibility to
maintain this trust and protect our patients and customers.
Keeping our commitment
▸ Market our products and services honestly.
▸ Protect personal information.
▸ Understand and adhere to laws and regulations about personal information.
▸ Act ethically when handling personal information and use extra care when
dealing with sensitive information.
▸ Report misuse or loss of personal information.
Marketing
▸ Ensuring that our advertising and communications are clear, truthful and not misleading
▸ Respecting intellectual property rights, including in how we market our products and ideas
▸ Ethically designing and implementing technology-driven personalized marketing
campaigns
Protecting personal information
▸ Adhering to privacy and security laws and regulations when using personal information
▸ Only sharing company information with third parties who meet or exceed our high
standards
▸ Working with the WBA Privacy Oce to protect patient and customer privacy
What should I do?
I am concerned about my friend’s health, and I would like to share some marketing materials
with them on new medicines I think could help their condition. I know my friend fills their
prescriptions at our pharmacies. Can I look up their name in our system to learn which
medicines they are currently taking?
We respect the privacy of our patients, and we have an obligation to safeguard their
confidential information. Our team members are only allowed to access patient information
when necessary to complete their job responsibilities. Accordingly, you cannot research your
friend’s prescription records, and you would be subject to serious consequences for doing so.
18 Code of Conduct and Ethics: Committed to Integrity
We are committed to running a sustainable business
It is our responsibility to operate sustainably for people and the planet, act as caring corporate
citizens and build an enterprise that is resilient for the future.
Examples
Our commitment
Our Corporate Social Responsibility strategy is centered in healthcare, which is
aligned with our business operations, our expertise and our area of influence.
We are committed to: engaging with local communities to improve community
health and well-being; promoting equitable access to healthcare; protecting the
planet by reducing waste and emissions; conducting business fairly and with
integrity; driving responsible sourcing practices throughout our supply chain;
and fostering a diverse, equitable and inclusive culture.
Why it matters
As a leading global pharmacy retailer, we have a central role in communities and
as part of patient-care teams. We must be a force for good, responding to critical
societal needs for access to healthcare, trustworthy information and innovative
solutions.
Keeping our commitment
▸ Improve access to aordable, quality healthcare.
▸ Reduce energy consumption and emissions.
▸ Drive responsible sourcing practices and protect human rights.
▸ Develop and market healthier, more sustainable products and services.
▸ Foster a diverse, equitable and inclusive culture.
Healthy communities
▸ Providing lifesaving vaccines and life-changing vitamins to underserved communities
▸ Safely disposing of unwanted prescriptions to help fight opioid abuse
▸ Raising millions of dollars to fight cancer and child poverty
Healthy planet
▸ Investing in energy eciency
▸ Implementing zero-waste programs
Sustainable marketplace
▸ Protecting human rights and promoting ethical standards in our supply chains
▸ Implementing programs to purchase from diverse suppliers
▸ Working to reduce unnecessary plastics in the packaging of our own brand products
Healthy and inclusive workplace
▸ Increasing diversity in leadership
▸ Hiring military veterans
▸ Running industry-leading disability hiring programs
19 Code of Conduct and Ethics: Committed to Integrity
Our commitment to...
our marketplace
19 Code of Conduct and Ethics: Committed to Integrity
20 Code of Conduct and Ethics: Committed to Integrity
Examples
What should I do?
My spouse is the head of sales for a supplier that provides goods and services to WBA.
Is this okay?
First, you must disclose the potential conflict to your manager. After discussion with your
manager, the disclosure and actions taken must be documented. Refer to the Conflicts of
Interest Policy for additional direction and complete the disclosure form as required. In this
situation, you may refer your spouse’s company to Procurement for further review. You must
not be involved in any decision-making involving hiring or buying services from this company.
Keeping our commitment
▸ Recognize potential conflicts of interest.
▸ Avoid real or perceived conflicts of interest.
▸ Disclose potential conflicts to your current manager.
▸ Follow requirements for reporting conflicts of interest.
▸ Manage conflicts, in cooperation with your manager.
Personal nancial interests
Conflicts may include:
▸ Asking for or receiving payment, expensive gifts or entertainment from a WBA customer,
business partner or competitor
▸ Owning more than a one percent share of a company that does business with or
competes with WBA
▸ Using WBA business information to benefit yourself or a family member financially
Personal relationships
Conflicts may include:
▸ Supervising or hiring a family member or friend
▸ Dating someone you supervise
▸ Conducting company business with a family member
Outside work
Conflicts may include:
▸ Working as a consultant for a supplier
▸ Taking a job with a competitor of WBA
▸ Performing outside work that interferes with your WBA responsibilities
A conflict of interest occurs when a competing personal interest interferes with, or may appear
to interfere with, your work at WBA.
We avoid conflicts of interest
Our commitment
We act in the best interests of WBA and our customers. We do not let
personal interests interfere, or even appear to interfere, with our professional
responsibilities.
Why it matters
Conflicts of interest can cause significant harm to our company. Even the
appearance of a conflict could put our company and reputation at risk. Making
sound, unbiased decisions earns trust from our customers, our communities and
each other.
21 Code of Conduct and Ethics: Committed to Integrity
Examples
We conduct our business honestly and with integrity
What should I do?
I received an invitation from a supplier to visit its headquarters – located near a ski resort – for
a meeting. Not only has the supplier oered to pay for my airfare, hotel and meals, but they also
want to fly me to New York to speak at their annual sales meeting. They oered to pay for my
daughter and me to stay the weekend. In addition, they even got us tickets to a sold-out show.
This sounds great, but am I allowed to accept the supplier’s oer?
Avoiding improper payments
▸ Refusing requests for improper payments
▸ Reporting any request related to a bribe, kickback or other improper payment
▸ Only providing or accepting business courtesies (e.g., gifts and hospitality) in
accordance with our policies and procedures
Competing fairly
▸ Refusing to agree to or discuss arrangements with competitors that would improperly
restrict competition, including those related to pricing, customers and suppliers, sales,
market allocation or strategic plans
▸ Refusing to facilitate improper agreements between competitors at other levels of the
distribution chain, even if WBA does not compete with them
▸ Respecting the intellectual property and confidential information of our competitors
and suppliers
Sometimes, it may be appropriate to accept travel from a supplier for business meetings.
In this situation, however, you may not accept the lodging and entertainment for yourself
or your daughter as it is more than a modest gift of hospitality. Review the Providing and
Receiving Business Courtesies Procedure, and if you have questions, ask the Compliance
and Ethics team.
We succeed on the strength of our products, services and people. We do not try to gain an
advantage through unethical or illegal means.
Our commitment
We keep our interactions honest. We do not try to influence others by oering
or accepting improper gifts or payments of any kind. In addition, we abide by
antitrust and fair competition laws and regulations where we conduct business.
Why it matters
Doing business the right way strengthens our reputation and builds trust in
the marketplace. Failing to do so could significantly impact our company and
team members. Therefore, we must understand and follow the rules – even the
appearance of impropriety must be avoided.
Keeping our commitment
▸ Do not oer or accept a bribe, kickback or other improper payment, gift or
hospitality.
▸ Follow applicable anti-bribery and competition laws and regulations.
▸ Be aware of the rules, not only when dealing with government ocials and
healthcare professionals, but also with private parties.
▸ Report any unethical or dishonest behavior.
22 Code of Conduct and Ethics: Committed to Integrity
What should I do?
I am working at the register at one of our stores. A customer is trying to buy a large number
of gift cards split up across multiple transactions with many dierent payment methods. They
are in a rush and refuse to answer questions about their purchase or identity. This seems like
a red flag to me. What should I do?
Anti-money laundering
▸ Staying alert for financial transactions and cash payments that just do not
seem right
▸ Reporting suspicious activity involving financial products like money transfers
or gift cards
▸ Refusing to split apart orders, payments or contracts inappropriately
Examples
This situation is an example of suspicious activity that could be an indication of money
laundering. It is important to follow applicable laws, regulations, policies and any prompts
at the register. You should decline the transaction, report the situation to management and
complete any required documentation about the situation.
Why it matters
As a business, we are engaged in financial transactions and oer financial
services. We have an obligation to do our part to prevent misuse of the
financial system.
Keeping our commitment
▸ Understand and comply with anti-money laundering laws and regulations.
▸ Report suspicious financial activity and transaction details where required.
▸ Coordinate with Compliance and Legal and cooperate fully in response to
requests from regulatory and law enforcement agencies regarding actual
or suspected money laundering activities.
We comply with applicable financial laws and regulations
Our business involves financial transactions, which are subject to certain requirements,
including those designed to prevent and detect money laundering. Money laundering involves
disguising the true nature of funds, often to hide criminal activity.
Our commitment
We take steps to prevent and detect improper transactions that attempt to launder
money or commit consumer fraud. We take steps to know our customers and
speak up if something does not seem right. We also follow applicable laws and
regulations related to financial products and services.
23 Code of Conduct and Ethics: Committed to Integrity
We comply with applicable international trade
laws and regulations
Our commitment
We comply with applicable laws and regulations relating to the import and
export of our products and services. We will not conduct business with
individuals, entities, sectors or countries that are prohibited under any
applicable sanctions rules.
Why it matters
WBA is a global business built on trust and our reputation for ethical business
practices. Therefore, we must understand and comply with the rules that govern
our activities in the places where we conduct business. Even an inadvertent
failure to meet our responsibilities could harm our reputation and negatively
impact our ability to accomplish our business objectives.
Keeping our commitment
▸ Know our business partners, so we do not transact with sanctioned parties
or in prohibited locations.
▸ Understand and follow the rules governing our export and import activity.
Our business is complex, highly regulated and often can involve international trade.
Certain laws and regulations apply to these international transactions, covering topics
including, but not limited to, import and export controls, anti-boycott and economic and
trade sanctions.
Sanctions, import and export controls
▸ Understanding and complying with applicable import or export restrictions or
licensing requirements in the location where you are conducting business for
the company
▸ Avoiding doing business with any party who is sanctioned, blocked or located
in a country prohibited by applicable sanctions rules
▸ Refusing to participate in unlawful boycotts
Examples
24 Code of Conduct and Ethics: Committed to Integrity
Examples
We deliver high-quality pharmacy and healthcare services
What should I do?
I am a pharmacy manager, and I am reviewing a prescription for a regular customer. The
prescription is missing the drug name. I have seen this customer and prescription several times
in the past, so I could just look it up in the system. Should I fill the prescription?
High-quality healthcare
▸ Updating our oerings with agility to respond to emerging health conditions and
concerns
▸ Connecting patients and customers with convenient, equitable and aordable products
and care
▸ Innovating and shaping the future of healthcare with the latest technologies
Healthcare compliance
▸ Abiding by laws and regulations related to dispensing, distributing and billing
prescription medications
▸ Appropriately collaborating with other healthcare professionals and companies on the
healthcare services we provide
▸ Maintaining valid licenses and certifications for the pharmacy and healthcare services
we provide
▸ Viewing and sharing patient and customer information only when required and as
permitted by privacy laws and regulations
As a retail pharmacy and health and daily living destination, we hold an important place in our
communities’ healthcare ecosystem.
Our commitment
We comply with applicable pharmacy and healthcare laws and regulations
around the globe. We support positive health outcomes by appropriately
connecting our customers and patients to resources that support their health
journeys.
Why it matters
Delivering high-quality healthcare while following applicable laws and regulations
enables us to make a positive impact on the health and well-being of millions of
people every day. In doing so, we are also winning the trust of our patients and
customers and building on our strong reputation in the marketplace.
Keeping our commitment
▸ Follow applicable pharmacy and healthcare laws and regulations.
▸ Serve as trusted community health destinations, including to
underserved populations.
▸ Protect confidential patient and customer personal information.
Prescriptions must show the drug name before we can proceed with dispensing and billing
for the prescription. A pharmacy team member must contact the prescriber to obtain the
drug name (and any other missing information on the prescription). Once obtained, the
pharmacy team member must document the missing information before proceeding with
filling the prescription.
25 Code of Conduct and Ethics: Committed to Integrity
Our commitment to...
our partners
25 Code of Conduct and Ethics: Committed to Integrity
26 Code of Conduct and Ethics: Committed to Integrity
Suppliers and sourcing
▸ Hiring suppliers who are committed to fair working conditions
▸ Partnering with suppliers who comply with the labor, health and safety standards
where they operate
▸ Sourcing from an equitable range of suppliers through our supplier diversity program
▸ Conducting ethical compliance assessments on new and existing suppliers
Examples
We choose suppliers with integrity
We engage suppliers who are aligned with our values and share our commitment to ethical
business practices.
Our commitment
We work with suppliers who meet our high ethical standards for human rights
and responsible sourcing. We support fair pay practices and the elimination of
child and forced labor worldwide.
Why it matters
Respecting human rights and promoting health and well-being is central to our
purpose and consistent with our core values.
Keeping our commitment
▸ Follow applicable WBA procurement, anti-bribery and anti-corruption, and
ethical trading policies, procedures and other standards.
▸ Conduct due diligence as appropriate for the relevant type of supplier.
▸ Hire suppliers who are committed to human rights.
▸ Never tolerate forced or child labor or human tracking in our supply chain.
27 Code of Conduct and Ethics: Committed to Integrity
We adhere to laws relating to government
contracts and programs
What should I do?
I work in the pharmacy billing department and have been asked by my manager to submit
immunization claims to a government program (e.g., Medicare Part B, NHS). I noticed that we
have not obtained all of the required documentation that must be submitted with the claims.
Should I proceed with submitting these claims?
Government programs such as Medicare in the U.S. and the National Health Service (NHS) in
the UK pay for many of the healthcare products and services oered through our retail and
specialty pharmacies.
Our commitment
We uphold our high ethical standards when we appropriately submit claims and
bill government programs. We follow applicable laws and regulations including
accurately documenting the required information to bill for products and
services that are provided to government healthcare program beneficiaries.
Why it matters
We demonstrate our integrity and build trust with our stakeholders by committing
to compliance with standards, including those related to government contracts
and programs. Our commitment aligns with our values and upholds our reputation
in the marketplace.
Keeping our commitment
▸ Uphold requirements related to government-funded healthcare programs.
▸ Comply with applicable pharmacy and healthcare laws and regulations.
▸ Engage in compliant, accurate and timely billing practices.
▸ Strengthen collaborative partnerships with government regulators.
Government programs compliance
▸ Overseeing that public funds are used appropriately and in alignment with applicable
requirements
▸ Submitting complete and accurate healthcare claims for reimbursement
▸ Identifying and promptly refunding overpayments received from government programs
Examples
No. You must inform your manager that we have not obtained all the documentation in
order to submit these claims. Next, we must attempt to obtain the required documentation
prior to submitting the claims. In the event we are unable to obtain the documentation, we
may not submit these claims.
28 Code of Conduct and Ethics: Committed to Integrity
We maintain appropriate relationships with
healthcare professionals
Healthcare professional interactions
▸ Consulting with applicable policies for working with healthcare professionals
▸ Abiding by relevant spend thresholds for providing gifts, meals or other items of
value to healthcare professionals
Examples
Healthcare professionals play a pivotal role in supporting our company in delivering quality
pharmacy and healthcare services.
Our commitment
We understand and follow laws and regulations when interacting with healthcare
professionals. We do not oer anything of value to healthcare professionals that
could improperly influence them to refer or do business with WBA.
Why it matters
We maintain patients’ and customers’ trust in us by adhering to laws and
regulations when interacting with healthcare professionals and do not take
actions that might improperly interfere with the provider-patient relationship.
Keeping our commitment
▸ Understand and follow laws and regulations relating to interactions with
healthcare professionals.
▸ Keep patient care decisions objective and free of undue influence.
▸ Contact the Compliance and Ethics team or Hotline for questions about
appropriate provider relationships.
▸ Disclose any potential conflict of interests related to healthcare professionals.
29 Code of Conduct and Ethics: Committed to Integrity
Our commitment to...
our shareholders
29 Code of Conduct and Ethics: Committed to Integrity
30 Code of Conduct and Ethics: Committed to Integrity
What should I do?
We have fallen short of our third-quarter sales target because we could not close our last sale
prior to the end of the quarter. My supervisor has asked me to backdate the transaction to meet
the target. She said it is not a big deal and people do it all the time. Should I change the date?
Our books and records
▸ Accurately recording sales, expenses, corporate assets and liabilities
▸ Disclosing relevant details clearly and completely in financial reports
▸ Representing our financial operations honestly
▸ Reporting accounting irregularities
▸ Complying with legal holds for records subject to litigation or investigation
▸ Submitting detailed and accurate travel and expense reimbursement requests
Examples
We maintain accurate books and records
Our commitment
We strive to keep complete and accurate company records that fairly reflect our
business, and we submit timely reports to government regulators. We follow
applicable laws, regulations, accounting standards and WBA policies related to
our records. We do not improperly alter or misrepresent records, regardless of
how small the change or amount may be.
Why it matters
Maintaining the accuracy and integrity of our books and records builds trust with
our shareholders, regulators and other stakeholders who rely on this information.
Following company accounting and record-keeping policies supports our ability
to run our business eciently and demonstrates our commitment to integrity.
Keeping our commitment
▸ Keep complete and accurate records.
▸ Do not improperly alter or destroy records.
▸ Report irregularities and violations.
▸ Cooperate with audits and investigations.
▸ Follow Internal Controls and Records Management policies.
Our books and records explain and document the financial and operational details, history and
decisions of our business. Examples include invoices, expense reports, inventory and pricing
data, contracts and regulatory filings.
No, it is dishonest and a crime to falsify our financial records. You should not change the
date, and you should report this to the Compliance and Ethics team or the Compliance
and Ethics Hotline. If you do change the date, you and the company could face serious
consequences.
31 Code of Conduct and Ethics: Committed to Integrity
We protect WBA assets
Safeguarding assets
▸ Following applicable laws, regulations and WBA policies to handle WBA funds
honestly and responsibly
▸ Preventing theft and misuse of our data, copyrights, patents, trademarks, trade
secrets and logos
▸ Respecting the proper use of assets or property of colleagues, customers or
business partners
▸ Recognizing WBA’s rights to assets created with WBA time or money
Examples
Our commitment
We protect WBA’s assets from damage, waste, loss, fraud and theft. We handle
WBA assets responsibly, and we do not misuse company funds or property.
Why it matters
Our shareholders trust us to protect their investment by protecting WBA’s assets.
Keeping our costs low by minimizing the loss and misuse of our assets supports
continued investment in our business and our purpose.
Keeping our commitment
▸ Protect WBA assets from damage, waste, loss, fraud, theft and misuse.
▸ Follow protocol for keeping our physical and intangible assets secure.
▸ Report losses related to our assets.
An asset is anything of value to the company. Our physical assets include records, computers,
products and equipment. Our intangible assets include our brands, product lines, data,
intellectual property and trade secrets.
32 Code of Conduct and Ethics: Committed to Integrity
Insider trading compliance
▸ Never tipping friends and family with material, non-public information
▸ Trading legally and ethically using only public information
▸ Understanding quarterly trading blackout periods for applicable team members
Examples
We comply with insider trading laws
What should I do?
I saw a “confidential” folder on my manager’s desk at the end of this quarter. I wanted to
know if we met our goals, so I opened the folder. It was actually a memo about an upcoming
merger, but it will not be public knowledge for a week. My father is passionate about the
stock market, so I suggested he buy the stock of our new company before everyone else
hears about the merger. Is this okay?
Our commitment
We do not trade on or improperly share material, non-public information. We follow
insider trading and securities laws and regulations, and we handle material,
non-public information in accordance with applicable requirements. We forbid
insiders from using or disclosing material, non-public information for personal gain.
Why it matters
We uphold trust by operating honestly and fairly in the market. Insider trading is
illegal and unethical, and it violates WBA policies. Insider trading violations can
result in termination of employment and civil and criminal penalties, including
fines or even imprisonment. When we respect the rules of the market, we stand
by our values and demonstrate our commitment to integrity.
Keeping our commitment
▸ Comply with WBA’s Insider Trading Policy.
▸ Keep material, non-public information confidential.
▸ Never use material, non-public information for personal gain.
▸ Ask for guidance from the Legal department if you have questions.
Insider trading occurs when someone illegally uses material, non-public information when
trading in stock or other securities. “Material” means the information would be important to
someone who is considering buying, selling or holding a stock or other security. “Non-public”
means the information has not been shared widely with the public. Examples of material, non-
public information include financial results, potential sales, mergers and acquisitions, significant
contracts, major litigation and joint ventures.
Insider trading can also occur when someone discloses material, non-public information to
others, including friends and family, to use for their own financial benefit. This is called tipping.
No, this is considered insider trading. You have put yourself, your manager, your father and
the company at risk. There are significant civil and criminal penalties for insider trading,
which can include imprisonment. You should not have opened the folder and should not
have shared the confidential information with your father.
33 Code of Conduct and Ethics: Committed to Integrity
We safeguard confidential and proprietary information
WBA is committed to protecting personal and confidential information that we collect in the course of
doing business where unauthorized disclosure, compromise or destruction could provide significant
advantages to a competitor or result in serious adverse financial or reputational harm to WBA.
Our commitment
We manage confidential information with integrity, and we follow data privacy laws
and regulations. We respect the privacy of our patients, customers, team members
and partners, and we use their information appropriately. We protect confidential and
proprietary information in accordance with information security standards. Nothing in
our Code is designed to limit the ability of our U.S. team members to discuss terms and
conditions of employment such as pay, benefits, schedules or workloads as protected
by U.S. laws and regulations.
Why it matters
Our proprietary information, such as our intellectual property, is crucial for sustaining
our business today and in the future, so we must safeguard it. If this information is
improperly accessed or disclosed, we could lose certain competitive advantages or
areas of company value.
Our patients and customers also trust us with their personal information, such as their
prescriptions, and our shareholders trust us to protect confidential information, such as
our internal business details. When we maintain the trust of our patients, customers and
shareholders, it builds our reputation and enables our business to thrive.
Keeping our commitment
▸ Protect confidential and proprietary information.
▸ Prohibit unauthorized access to information, including by third parties.
▸ Follow WBA policies and instructions on good information security practices.
Safeguarding information
▸ Viewing patient information only when it is needed for your job
▸ Preventing unauthorized parties from accessing, using or transferring confidential
and proprietary information
▸ Accessing, storing and sharing information only as permitted
Examples
What should I do?
I received an urgent email from my manager directing me to a link to upload documents
related to a project. The email states that we need to provide the documentation
immediately in order to meet an important deadline. I do not want to be responsible for
causing a delay that could harm our company, but the link and the email address it came
from are not familiar to me. Should I proceed with responding to the request?
Even if an email appears urgent, it is important to take the time to examine if the
message is legitimate prior to responding or clicking on links. Steps such as validating
that the sender’s email address and links appear correct prior to taking action can help
prevent unauthorized parties from gaining access to WBA’s information. You should not
take action on the email until after confirming its legitimacy with your manager and/or
the applicable Information Security team in accordance with company policy.
34 Code of Conduct and Ethics: Committed to Integrity
Responsible communication
▸ Acting as a spokesperson for WBA only with ocial approval from Corporate
Communications
▸ Directing shareholder questions to Investor Relations, and media inquiries to Corporate
Communications
▸ Never posting confidential WBA Information, as defined in our Information Classification
Policy, on internal/external mass communication and social media channels
▸ Following WBA policies when identifying yourself as someone who works for WBA on
social media
Examples
What should I do?
Today a patient yelled at me when his prescription was not ready. I informed him that his
doctor had not sent us his refill information, so we could not legally fill the prescription. The
patient created a scene, so one of our pharmacy team members started a live-streaming
video on social media. Our team member just wanted to document the incident, but the
video got hundreds of likes and shares. Some people even tagged the WBA corporate
account. Was it a good idea to post that video?
We communicate responsibly
Communication is anything we, as a company, convey through words or images. It includes
internal emails, articles and anything we say publicly to investors, analysts, the media or on
social media. Responsible communication aligns with our company culture, reflects our core
values and follows our communication guidelines.
Our commitment
We are responsible and professional in how we communicate – internally and
externally. We are mindful of our reputation, and we only allow authorized
representatives to communicate externally on behalf of WBA. We require our
team members to follow WBA policies when representing us, including on
social media. We understand when we may be seen as communicating on
behalf of the company as opposed to as an individual, and we ask for guidance
and approval from Corporate Communication if we are unsure.
Why it matters
Our reputation influences behaviors and perceptions and is key to maintaining
trust among our stakeholders, patients and customers. When we communicate
responsibly with messages that are clear, transparent and consistent, this
strengthens our reputation and builds trust in WBA.
Keeping our commitment
▸ Communicate responsibly, and keep in mind how our messages may be
perceived.
▸ Follow WBA policies for communication.
▸ Direct inquiries to authorized WBA representatives.
▸ Protect our company’s reputation.
No. The video should not have been recorded or shared. Posting this video disrespected the
patient, violated our policies and could cause legal issues. We must respect our patients and
their privacy, both in-person and online.
35 Code of Conduct and Ethics: Committed to Integrity
Contacts
Compliance and Ethics Hotline
The Compliance and Ethics Hotline allows WBA team members to report ethics and
compliance concerns by phone or web, 24 hours a day, seven days a week. The
hotline is managed by an independent third party with operators in many languages.
You may remain anonymous, and we will make every eort to protect confidentiality
as allowed by law.
Online portal
wba.ethicspoint.com
Phone
Chile 1230 020 8964
Germany 0800 1809032
Hong Kong 800 964 909
Italy 800 909 716
Mexico 800 099 0306
Republic of Ireland 1 800 903 328
Switzerland 0 800 895 268
Thailand 1 800 012 642
United Kingdom 0800 088 5554
United States 855 WAG CODE (855 924 2633)
United States (No. 7 Beauty Company) 844 709 4047
Corporate contact information
Matt D’Ambrosio, Senior Vice President, Global Chief Compliance and Ethics Ocer
+ 1 847 964 6519
35 Code of Conduct and Ethics: Committed to Integrity
36 Code of Conduct and Ethics: Committed to Integrity36 Code of Conduct and Ethics: Committed to Integrity
The Code has been translated into other languages but, if discrepancies occur in the text, the English version will prevail. Businesses may adapt this Code for local use provided the revisions remain equally comprehensive and do not result in any
inconsistency with or lessening of any of the principles, standards or obligations stated in this Code. An advance copy of any adaptations must be forwarded for approval to the Global Chief Compliance and Ethics Ocer prior to implementation.
Waivers
The company may consider a request for a waiver of limited
elements of our Code in rare circumstances. A request
for a waiver must be submitted to the SVP, Global Chief
Compliance and Ethics Ocer. Any waiver for a director or an
executive ocer must be approved by the Board of Directors
and will be disclosed to shareholders. Any waiver requested
by other team members may be subject to the approval of
the General Counsel or the Chief Executive Ocer.
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