Best Buy Code of Ethics

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BEST BUY Code o Business Ethics

BEST BUY

Código de Ética

Comercial

BEST BUY

Code de DéontologieDes Aaires

BEST BUY

Aärsetisk kod

BEST BUY

Código de Eticade Negocios

BEST BUY

Zakelijke

gedragscode

BEST BUY

Codice di etica

aziendale

BEST BUY

Grundsätze der

Geschätsethik

BEST BUY BEST BUY

Is Etigi KlavuzuBEST BUY

Code o Business Ethics



The Code applies to Best Buy Co., Inc., its subsidiaries, aliates, joint ventures and agents. Any waiver o the Code or executiveocers or directors may be made only by the Board o Directors or a Board committee and will be promptly disclosed toshareholders. Any waiver o the Code or any other employee may be made only by the Enterprise Ethics Oce. Use o the Code isintended or Best Buy’s business purposes only. The Code is not intended to describe legal relationships. Written permission rom aBest Buy ocer is required or use outside o the stated purpose.

Future additions are encompassed by this Code. This Code is applicable to all Section 16 ocers regardless o geographic location.



‘‘’’ETHICS AND ACTIONEthics is about putting principles into action. Consistency between what we saywe value and what our actions say we value is a matter o integrity.

It is also about sel-restraint:• Notdoingwhatyouhavethepowertodo.Anactisn’tpropersimplybecause

it is permissible or you can get away with it.

• Notdoingwhatyouhavetherighttodo.Thereisabigdifferencebetween what you have the right to do and what is right to do.

• Notdoingwhatyouwanttodo.Inthewell-wornturnofphrase,anethicalperson oten chooses to do more than the law requires and less than the law allows.

From the Josephson Institute o Ethics websitehttp://www.josephsoninstitute.org

best bu y code of business ethics | page 1



4 message from best buy ’s ceo

6 introduction

6 how do i act ethically

7 when to seek guidance

7 partnering to stop

misconduct

8 the code and the law

8 get answers to your

questions or report your

concerns

9 confidentiality

9 zero-tolerance policy

on retaliation

10 resolving your concerns –

the process

12 responsibility to each other

14 honoring our differences

14 harassment-free workplace

14 information privacy

15 health & safety

16 environment

16 wage & hour standards

16 loss prevention

table of contents

page 2 | best bu y code of business ethics



36 fair dealing

36 corporate opportunities

36 conflicts of interest

38 gifts, business courtesies

& vendor relations

39 business courtesy

39 giving gifts

40 responsibility to our communities

42 charitable contributions

42 involvement in political

activities

42 government requests &

inquiries

42 global business operations

43 anti-bribery / anti-corruption

& fcpa

43 employment & labor issues

44 special ethical obligations for

employees with financial

reporting responsibilities

45 global resources

18 responsibility to our customers

20 retail sales & advertising

20 selling products & services

21 honoring our customers

differences

22 customer and employee privacy

24 responsibility to our

shareholders

26 maintaining financial

integrity

26 information disclosure

28 fair disclosure

28 securities trading &

material information

30 protection & proper use of

company assets

30 protecting intellectual

property

32 responsibility to our business

associates

34 competitive intelligence

gathering

35 antitrust & competition

table of contents




Best Buy is a company with a phenomenal record o success in our 40-year history,growing rom a single store in St. Paul, Minnesota to a company with thousands o stores and tens o thousands o employees across the world.

This success is a direct refection o our people, our culture and our values. As we’vegrown, our commitment to living the company values and using them as a guide inthe decisions we make has grown increasingly important.

Each o us makes decisions every day – decisions that may have nancial, human,community or ethical implications. And as our growth creates increased complexityin all o our operations across the globe, it’s important that we have a sharedunderstanding o what ethical business conduct is.

That’s why we have the Best Buy Code o Business Ethics, to provide us with acommon set o guidelines to help reinorce and uphold our values. The Code:

• Outlinesethicalstandardsthathelpguideyourdecision-making

• Referencescompanypoliciesthatsupportyourethicaldecisions • Includesquestionsandanswersaboutdifcultethicalmatters–includingquestions

that may be specic to your country, location or unction• Providesyouwithalistofresourcesforreportingethicalconcerns,fromanywhere

in the world

Every employee worldwide receives a copy o this code. Each year, you may be askedto sign an acknowledgment o your commitment to living our company values andsupporting our Code o Business Ethics.

Thank you in advance or everything you do to hold yourselves and Best Buy to thehighest ethical and environmental standards.

Brian J. DunnChie Executive Ocer, Best Buy Co., Inc.

a message from best bu y ’s ce o




unleash thepower ofour people

learn fromchallenge andchange

show respect,humility andintegrity

have fun while being

the best

introduction




INTRODUCTIONAt Best Buy, our goal is to be a responsible, values-driven global enterprise. As anemployee, each o us plays a critical role in living our values even as we ocus on ournancial, social, and environmental perormance. Our values refect the behaviorsneeded to demonstrate, build and maintain relationships between our customers, ourCompany and our colleagues.

In today’s global workplace, you will encounter unamiliar situations where the rightthing to do is not always clear. You may nd yoursel needing to make a decision whenthere are multiple choices o right, or when two equally important values collide.

This Code o Business Ethics (the Code) contains a broad overview and severalscenarios that can help guide your decisions. This Code is not all-inclusive; there willbe times that you nd yoursel in situations that are not answered here. When thathappens, please reach out to any o the resources identied in the back o this Code.

Note: Throughout the Code are reerences to Best Buy. Best Buy includes: Best BuyU.S., Future Shop, Best Buy Canada, Magnolia, Geek Squad, Best Buy For Business,Audiovisions, Five Star, Best Buy China, Pacic Sales, Speakeasy, Best Buy Mobile,Geek Squad UK, Best Buy Mexico, Best Buy Europe, The Carphone Warehouse,

The Phone House, Napster, Best Buy Turkey, Dealtree, and all subsequent additions,aliates and subsidiaries.

HOw DO I ACT ETHICAllY?

At Best Buy, we demonstrate our ethics by living our values. This means that welive our values every day in our interactions with one another, customers, vendors,business partners, competitors and in the communities in which we work, live andplay. It also means that our business decisions consider not only the nancial riskor reward, but just as important, the impact on people, communities, and theenvironment.

introduction




wHEN TO SEEk gUIDANCE

When you’re unsure o the right thing to do, ask yoursel the questions listed belowto help guide your decision. This should help you maintain personal integrity and thebest interests o Best Buy.• IstheactionconsistentwithBestBuyvalues? • Willmydecisionaffectthecustomerexperience? • WillmydecisioncompromiseanyofBestBuy’scommitmentstoemployees,

customers,businesspartners,shareholdersorthecommunitiesweserve? • Istheactionfairandjust? • Istheactionlegal? • DoestheactionsupportBestBuypoliciesandprocedures? • CanItakeprideinmyactionswhentellingmyfamily? • WillmydecisionimpactBestBuy’sreputationormypersonalreputation? • DoesitplaceBestBuyormeinacompromisingposition?

PARTNERINg TO STOP mISCONDUCT

There is a tremendous amount o value – intangible worth – in a good reputation.Both your proessional reputation and the reputation o Best Buy depend onethical decision-making by our employees. You should immediately report illegal orunethical conduct to an appropriate Best Buy representative. I you do not do so, theunreported activity could harm you, Best Buy, and other employees. Failure to reportsuspected violations may also lead to disciplinary action.

Managers who receive reports o possible illegal or unethical conduct must take

immediate action. The type o action taken depends on the alleged misconduct.Managers should identiy and consider the important key stakeholders – those whocould be aected by the possible illegal or unethical conduct, including employees,customers, shareholders, or others important to the business. At any point managersmay seek advice to decide on an appropriate course o action to stop any illegal orunethical conduct.

introduction




THE CODE AND THE lAw

Best Buy operations and employees are subject to the laws o many countries andother jurisdictions around the world. Employees and agents acting on behal o Best Buy are expected to comply with the Code and all applicable laws, rules, andregulations. I a local law conficts with our Code, we ollow the law; i a local businesspractice conficts with our Code, we ollow our Code. When in doubt, ask orguidance.

gET ANSwERS TO YOUR qUESTIONS OR REPORT YOUR CONCERNS

When you raise a concern, it helps Best Buy correct specic problems, and identiesareas that require improvement or the need or additional training. It also helps assessand improve our Company’s level o ethical awareness, which is crucial to our goalo living our values. You can raise concerns about questionable ethical behavior atBest Buy in several ways. I you are uncomortable with any o these resources, or i the resource is part o the problem, please consider another option, but DO raise theconcern – don’t ignore it.

Discuss with your manager

Face-to-ace discussions with your manager are the best way to solve most on-the- job issues.

Contact your employee or associate relations representative

Your representative will investigate the issue, and may call the Ethics Oce orassistance.

Contact the Ethics Ofce You may always call the Ethics Oce directly, or contact the oce via the postalservice, e-mail, text message, web report or ax. The contact inormation is ound onthe resources page in the back o this Code.

introduction


Best Buy oera stries or airness and ain the riht

choices or our epoyees as e as our custoers.

— Tanya, SuperviSor uS‘‘’’



Open & Honest or anonymous reports

A multi-lingual interview specialist, employed by an external vendor, will answeryour call. All pertinent inormation is gathered and documented on an incidentreport, which is sent to the Ethics Oce. Please note that although you may remainanonymous when voicing a concern, providing your name or other identiyinginormation may help resolve the issue.

Web Reporting

You have the option to submit your complaint via the web site o our third partyvendor. Just like a phone call to Open and Honest, your report is received directlyby the vendor and orwarded to the Best Buy Ethics Oce. The only sel identiyinginormation in this report is that which you choose to include. The contact inormationis ound on the resources page in the back o this Code.

Note: Many EU countries limit the type and anonymity permitted regarding reportsmade. Our Open & Honest phone and web reporting process is designed to comply

with these limitations.CONfIDENTIAlITY

TheEthicsOfceandotherinvestigators(InternalAudit,HumanResources,Employee

Relations,LossPrevention,InformationSecurityandtheLegalDepartment)handleall

issues and concerns with care. Specically, inormation will be shared only with peoplewho need to know, and in accordance with our business practices, policies and the law.

ZERO-TOlERANCE POlICY ON RETAlIATION

I you observe or suspect a violation o the law or Company policy, report it using anyo the resources listed in the back o this Code.

Retaliationforreportingaconcernormakingacomplaintingoodfaithisprohibited

and is a violation o the Code. Allegations made maliciously or in bad aith may leadto disciplinary action.

introduction




RESOlvINg YOUR CONCERNS– THE PROCESS

introduction


YES You will receive

a conrmation

upon receipt o

your issue.

I you wish to remain anonymous, call the Open & Honest hotline. The Ethics Ofce will provide a response

to our Open & Honest vendor who will then arrange or you to receive the response electronically.

Contact your

manager or

submit your

question/

complaint/

concern to the

Ethics Ocevia e-mail, text

message, web,phone, or ax.

Include your

contact ino? NOSubmit your

concern through

the Open &

Honest hotline,

or the web orm.

They will serve asan intermediary

between the

Ethics Oce

and yoursel.

Your concern

will be

reviewed and

a resolution

sought.

•IsitaGlobal

Concern?

•Involvean ofcer?

•ABoard

ofDirectors

member?

•Havean

impact on

thebrand?

1. 2. 3.

Employee

with an ethicalquestion.



introduction


YESThe Enterprise

Ethics Oce

will partner in

the investigative

resolution.

NOI the local

Ethics Oce

was unable

to resolve theissue they will

consult otherdepartments

with subject

matter expertise.

I necessary

there willbe urther

investigation.

Hasaviolation

o Company

policy occured?

The local

Ethics Oce

partners ith

local Employeeor Associate

Relations,Loss

Prevention,

Internal Audit,

and/orLegal.

The local Ethics

Oce reers

the issue toEmployee

or Associate

Relations,Loss

Prevention,

Internal Audit,

Inormation

Security, and/

orLegal.

YESEmployee

or Associate

Relations,in

cooperation with

the Ethics Oce

will determine

appropriate

action and ollowup with you.

AND / ORI there is a

ault in theprocess, policiesor procedures,

a root cause

analysis will nd

the problem

and it will be

addressed.

4. 5. 6. 7.

NOMatter closed.



RESPONSIBIlITY to Each Other

2SECTION



At Best Buy, we are energized by the people who surround us. Our employeesare committed to learning, growing and working in an environment that valuesour unique talents, skills and perspectives.

To continue to lead and innovate in our quickly-changing industry, we have aresponsibility to encourage new ideas, high-quality work, career opportunitiesand an entrepreneurial spirit. Meeting those expectations requires treatingeach other respectully and ethically.

responsibility to each other


NEw

IDEAS

ENTREPRENEURIAl

SPIRIT

CAREER

OPPORTUNITIES

HIgH-qUAlITY

wORk

YOU



HONORINg OUR DIffERENCES

Best Buy is continually energized by the uniqueness o every individual. We aspire tocelebrate dierences, and place value on diversity in everything we do.

One o our values is to show respect, humility and integrity. Creating a positive workenvironment supports this value. Discrimination o any type is a violation o the value.

Best Buy will not discriminate based on age, sex, race, color, ethnicity, citizenship,

national origin, sexual orientation, gender identity, creed, religious preerence orbelie, disability, marital/amily status or any other characteristic protected by law.Other characteristics may be recognized and protected under specic national,provincial, state or local laws, regulations or ordinances. Best Buy is dedicated toensuring this policy is ollowed during hiring, selection or training, promotion,transer, layo, termination, leaves o absence, rates o pay or any other term orcondition o employment.

When necessary, Best Buy will provide reasonable accommodations or disabledemployees or those with specic religious requirements.

HARASSmENT-fREE wORkPlACE

Best Buy prohibits any type o harassment in the workplace by an employee,supervisor, customer or visitor. This includes, but is not limited to, harassment on thebasis o age, sex, race, color, ethnicity, citizenship, national origin, sexual orientation,gender identity, creed, religious preerence or belie, disability, marital/amily status orany other characteristic protected by law. Various national, state, local and provincial

laws may include additional protected categories.INfORmATION PRIvACY

In the course o your work you may have access to private, personal and businessinormation about your co-workers. This inormation should only be shared with BestBuy employees who need it to perorm their jobs.



Best Buy is continuay enerized by the uniueness o eery

indiidua. vauin diersity and ceebratin dierences

shoud be a natura part o eerythin e do.



HEAlTH & SAfETY

We have a responsibility to provide a healthy and sae workplace; it is essential oremployee and customer satisaction. Each o us must work saely and encourageotherstomaintainahealthyandsafeworkplace.Why?Because: •Wehaveapersonalresponsibilitytoourselvesandourfamiliestoreturnhome

ree o injury.•Wehaveanethicalresponsibilitytokeepourco-workersandcustomerssafe.

•Wecannothavefunorbethebestifanyemployeeorcustomerisinjured, or i Best Buy property is damaged or unsae.

Q. WhenshouldIreportaconcernaboutharassmentordiscrimination?

a.The situation should be reported immediately to your manager and/

orHRrepresentative.Ifyouareuncomfortablediscussingyourconcernwithyour

managerorHRrepresentative,youshouldcontactEmployeeRelations.Every

eort will be made to deal with concerns privately and respectully. Harassmentand discrimination issues are managed as condentially as possible. However,the Company reserves the right to disclose certain inormation or legitimatebusiness purposes and to conduct a proper investigation. Associates are requiredto participate in an investigation and must keep the proceedings condential.

Q. IthinkIwasnotpromotedbecauseofmyrace.WhatshouldIdo?

a. Anyone who eels discriminated against or harassed because o their race or another legally protected characteristic should contact any o thereporting avenues outlined on the resources page o this Code. All reportedcomplaints o discrimination and harassment in violation o Best Buy’s policy or

applicable laws will be investigated.





ENvIRONmENT

Best Buy expects employees to conduct Company business in a way thatdemonstrates respect or the physical environment.

As a global retailer o consumer electronics, and the largest consumer electronicsretailer in the U.S., Best Buy has an obligation to help our ellow employees and ourcustomers, make sae and smart decisions when disposing o the devices they use intheir daily lives and reduce our environmental impact.

Examples o environmentally conscious behavior include:• Properlydisposingofhazardousmaterial,suchasunusedpaintand

printer cartridges

• Recyclingoldorobsoletemobilephonesandconsumerelectronics • Includinganenvironmentalscreeninourauditsofthird-party

manuacturing acilities• Participatinginandsupportingcommunityenvironmentalinitiatives

• Creativelyminimizingandrecyclingpackaging • Helpingemployeesandcustomersmakesafeandsmartdecisions • ReducingourCompanyenvironmentalimpact

wAgE & HOUR STANDARDS

Best Buy ollows applicable national, provincial, state and local laws and regulationsthat govern pay rates, overtime, meals and rest breaks and child labor. I you seeany violation o these standards, please report it immediately by using the contactinormation ound on the resources page in the back o this Code.

lOSS PREvENTION

We all have a responsibility to protect Company assets. Thet, raud, misuse o theemployee discount or misappropriation o the Company, employee, supplier orcustomer property is a violation o this Code. In addition to violating the Code,you may also be subject to personal legal penalties i you engage in these typeso behaviors.







Q. WhatifItakecoldmedicinetomakememorealertduringtheworkday?

a. Associates taking over-the-counter or prescription drugs must be awareo any potential eect such drugs may have on their ability to work saely andcommunicate any such eect to their manager.

Q. I am an hourly employee who works part-time. On my days o, I nd ithelpfultocomeintoworktoreviewmye-mailandcheckmymail.Isthisokay?

a. No. These tasks are considered a part o your job and should be doneduring regular work hours unless otherwise agreed upon with your manager.

Because reviewing your mail and e-mail are part o your job, you must be paid ortime spent perorming such work-related tasks (whether at work or home). Eventhough employees may sometimes be required to work overtime, managementmust approve all overtime hours. Employees will be paid in accordance with allapplicable ederal, state, local and provincial laws.

Q. I am a part-time distribution center driver, and occasionally I work on

special projects, like assisting in the warehouse. Should I track this time spent onmylogsheet?

a. Yes. All hours worked, whether driving or not, must be tracked. TheCompany expects anyone who observes or has knowledge o any wage and hourviolations to report those issues immediately. Use the resources page in the backo this Code.



RESPONSIBIlITY to Our Customers

3SECTION



responsibility to our customers


Customers are at the core o our success and must be treated with respect.One way we do this is through our customer-ocused business model– customer centricity.

Customer centricity requires an ongoing relationship o trust between theemployee and the customer because the relationship between the customerand the employee is much more than transactional.

Our employees share an obligation to:

» Treat all customers airly and honestly» Communicate in a respectul and helpul manner» Provide prompt and accurate customer service

EmPlOYEE CUSTOmERTRUST



RETAIl SAlES & ADvERTISINg

Our customers, suppliers, communities, vendors and shareholders know that they can trust

us to do what we say and to act with their best interests in mind. Employees must provide

customers with clear, accurate inormation to help them make inormed buying decisions.

Accurate inormation is both the oundation o our advertising practices, and the way we

communicate the competitive advantages that distinguish Best Buy rom other retailers.

Please remember this is an important responsibility to our customers that we take seriously.

SEllINg PRODUCTS & SERvICES

Our customers rely on us to price and present our products and services airly andaccurately; we do not condone any behavior that would violate their trust in us.

Q. Whataresomeofthepracticesweshouldavoid?

a. Misleading or deceiving customers about the coverage or benefts o

servicesorwarranties(examplesareGSBTPplansorRWPs)orthereliabilityofproducts.

• Misleadingormisrepresentingproductsormanufacturer’swarrantiesfor example by saying “the manuacturer doesn’t cover anything.”

• Misleadingcustomersaboutproductavailabilityiftheyrefusecompletesolution

purchases (known as “walking customers”).• Pressuringcustomerstobuyacompletesolutionitemtothepointofjeopardizingthesale.

• “Turningover”ordirectingcustomerstoanotheremployeeafterunsuccessful attempts at selling accessories or attachments. (Example: ater an attempt to sellaGSBTPplansorRWP.) • Pricecuttingor“inboarding”toincludeacompletesolutioniteminthesaleor duringano-lemonexchange.(e.g.aGSBTPplansorRWP) • Forcingcustomerstosignorinitialreceiptswhenrefusingordecliningan accessoryorattachment.(e.g.aGSBTPplansorRWP) • Refusingareturnorexchangeonanyproductmeetingreturnandexchange guidelineswhetherornotaGSBTPplansorRWPhasbeenpurchased. • Failingtoprovideacopyofthemanufacturer’sfulltextwarrantytocustomers

upon their request.• Disparaginganyproduct,brandorservice,includingcompetitors,isstrictlyagainst

Company policy. We never want to be negative to make Best Buy or its products

look better. Disparaging products and/or manuacturers’ warranties can damage

our vendor relationships and potentially cause us to lose their product lines.

responsibility to ou r customers




HONORINg OUR CUSTOmERS DIffERENCES

Best Buy will not discriminate based on age, sex, race, color, ethnicity, citizenship,national origin, sexual orientation, gender identity, creed, religious preerence orbelie, disability, marital/amily status or any other characteristic protected by law.Other characteristics may be recognized and protected under specic national,provincial, state or local laws, regulations or ordinances.

When necessary, Best Buy will provide reasonable accommodations or disabledcustomers.

Q. A customer returned a product to our store. There is nothing wrongwith it. However, the box has been opened. I I re-seal the item, can I place thisproductonclearance?

a. No. “Open-Item” merchandise (serviced or returned), demo products,discontinued items, incomplete or damaged merchandise are not consideredclearance products. Clearance tags represent Best Buy’s intention to sell allremaining inventory o that product at the listed price or lower. We must inspectall o our products and obtain management approval prior to designating anyitem as an “open-item.”

Q. Sometimes I pressure customers to buy service plans, accessories andservices in order to make sure our territory comes out on top or selling theseproducts.Isthisokay?

a. No. While individual employees or Best Buy stores may be ranked onthe number o Complete Solutions sold, these products must be promoted tocustomers in a positive way. Selling additional services and products is important

but our customers are more important and must not eel pressured to purchase aservice plan.





CUSTOmER AND EmPlOYEE PRIvACY

Both customers and employees entrust Best Buy with their personal inormation so wecan serve them better. To retain their trust, we must protect their personal inormationwhilethisdataisinourcare.Respectingandprotectingcustomerprivacyisthekey

to enable our customer centricity strategy and the growth o our organization bothdomestically and internationally. In addition, honoring our employees’ privacy iscritical to ensuring a positive employee experience. These commitments are refected

in the Best Buy privacy policy, or known to our European partners as data protection,and in the actions o our employees. Customer and employee privacy is important toour customers, employees and shareholders.

Customer (and employee) inormation is dened as any piece o personallyidentiable inormation such as name, mailing address, e-mail address, phonenumber, credit card number, driver’s license number and social security number. Otherexamples o inormation entrusted to us include data owned or created by a customer(e.g., photos, videos, movies, documents) and stored on a product or device that we

might handle in service to the customer.

Every employee is responsible or knowing what customer and employee inormationis, how to protect it and appropriate methods or handling, storing and destroyingthis data. Employees are required to understand and comply with the standards andguidelines provided to them, to ensure we respect personal privacy.

I an employee violates privacy and/or data protection policies, they may be subject todisciplinary action up to, and including, dismissal and/or legal action i applicable.

It is our duty to protect customer and employee privacy.

responsibility to ou r customers


It is our duty to protect our custoers’ inoration

and priacy.



Q. I am authorized to view customer inormation. A riend asked me tolookuptheinformationthatBestBuyhasonhiminourdatabases.CanIdothis?

a. No. The access that you have to view customer inormation is or specicbusiness purposes. For more inormation about our privacy practices, direct your riend

to contact the Customer Privacy Group at [email protected].

Q. I’ve noticed that several employees leave their workstations unlockedevenwhentheyareviewingcustomerinformation.Isthisappropriate?

a. No. Always lock your workstation when you leave your desk to protect

customer inormation.

Q. HowmuchcustomerinformationcanIsharewithothersatBestBuy?

a. Only share inormation that is critical to the task. For example,i you need to send an e-mail containing customer inormation to anotheremployee, only include the inormation necessary to complete the request. Send

inormation only to the necessary persons and mark it as condential.





RESPONSIBIlITY to Our Shareholders

4SECTION



responsibility to ou r shareholders


As employees we are required to act in the best interest o Best Buy. Thismeans that every employee must make business decisions or the Companywith the same deliberate care they would take with personal nancial decisions.

We must also act to ensure the Company’s nancial integrity and saeguard theBest Buy brand.

BEST

INTERESTS

BUSINESS

DECISIONS

fINANCIAl

INTEgRITY

SAfEgUARD

THE BRAND



mAINTAININg fINANCIAl INTEgRITY

Employees are required to maintain the highest level o nancial integrity. To do this,we must:• AppropriatelymanageandsafeguardCompanyassets. • Fullyandfairlydisclosematerialnancialinformation,whichmeansinformationan

investor would consider important in making an investment decision.• Maintaincompleteandaccuratenancialrecords.

• AssuretheintegrityofallCompanybooks,recordsandaccountingpractices.

INfORmATION DISClOSURE

Exciting new Company strategies, tests, products and initiatives are continuallydeveloped and reviewed. Because o this, it is extremely important to keep ourCompany’s private inormation condential. We must not discuss these condentialmatters with anyone outside Best Buy. This inormation should only be sharedwith Best Buy employees who need it to perorm their job or in connection with adisclosure required by law.

When disclosure o Company inormation is required or legal reasons, a small groupo people will handle it. Employees should never discuss in any orum issues thatrelate to a pending or resolved lawsuit, investigation or allegation (even ater theissue is made public), unless authorized by the legal department or i there is one inyour business, a corporate relations director. I you are uncertain about the type o inormation that may be shared, please contact your manager or the corporate publicrelations department.





Q. I requently request temporary employee services or our department.I usually do not receive the bill until a month ater the services have been

provided.IsitappropriatetowaituntilIreceivethebilltorecordtheexpense?

a.No. The expense should be recorded and refected during the period

that services were provided. Work with the Finance Department to ensure properaccrual o expenses.

Q. I have been negotiating a deal with a small vendor who is not one o our primary vendors. Negotiations have moved quickly and I am not sure i thecorrectpeopleknowthenancialimpact.WhoshouldItalkto?

a. When negotiating with new vendors or as soon as you are aware o any term adjustments to vendor agreements, involve the Finance Department.The Finance Department will disclose and record nancial results at theappropriate time.

Q. A reporter rom a local paper called to ask about key strategies our

Companyisworkingonforthenextscalyear.HowshouldIrespond?

a. Best Buy employees are not authorized to talk with the media orinvestors about Best Buy’s business, including product assortment or potentialbusinessrelationships.AskthereportertocontactMediaRelations.





fAIR DISClOSURE

“Fair disclosure” ensures that investors and the public have access to the sameinormation about Best Buy at the same time. We have a responsibility to ourshareholders to make sure that no one has an advantage by receiving inormationthat is not yet publicly communicated. Selective disclosure is unair and exposes theCompany and you to serious legal and nancial consequences.

SECURITIES TRADINg & mATERIAl INfORmATION

Material non-public inormation is inormation which an investor would considerimportant in making a decision to buy or sell securities (meaning stock, bonds, mutualunds, options and other similar market instruments). Some employees may haveaccess to “material non-public inormation” concerning Best Buy or another companywith whom we do business or against whom we compete. Employees who are inpossession o this type o inormation are called “insiders.”

Possessing material non-public inormation while buying, selling or reallocating your

portolio is a violation o law and Company policies. In insider trading cases, simplyknowing non-public inormation is enough to create a problem or you or the Company.These rules aect anyone trading in the U.S. markets, whether or not the person is aU.S. citizen or lives in the United States. Insider trading is unethical and illegal.

Employees may not trade Best Buy securities or securities o other companies, i theypossess material non-public inormation that has not been disclosed to the public atleast 48 hours prior to trading. As always, i local law or policy is more conservative,the more conservative law or policy prevails.

In addition, employees should never discuss material non-public inormation withanyone else including, or example, amily and household members, riends, co-workersand business associates. Nor should employees recommend a trade in the securitieso Best Buy or other companies, or express an opinion based on material non-publicinormation about trading in securities o Best Buy or other companies.

Certain employees, members o the Company board o directors, and certain typesofstocktransactionshaveadditionalrestrictions.EmployeesmaycontacttheLegal

Department or answers to general questions.





Q. Yesterday, my director briefy mentioned that the Company is planningto issue an announcement about adjusting our earnings outlook or the third andourth quarters. I mentioned this story to my riend, and we agreed now would bea good time to sell our Best Buy stock. I really helped a riend save some moneyandIbenetedtoo.Thisisokay,right?

a. You have violated the law by “tipping” your riend concerning materialnon-public inormation and trading on material non-public inormation. Theollowing may occur because o your actions:• Youmaybesubjecttoseriouscriminaland/orcivilnesandpenaltiesfor

“tipping” and or trading on material non-public inormation.• Youmaybedisciplined,uptoandincludingterminationofyouremployment. • Yourfriendmaybesubjecttolegalpenaltiesbytradingonmaterialnon-

public inormation.• Yourdirectormaybedisciplinedfor“tipping,”ifyoudidnotneedtoknowthe

material non-public inormation to perorm your job duties.



I tae reat pride in orin or a copany that puts

interity, huiity and respect in their aues.

— beST buy employee‘‘’’



PROTECTION & PROPER USE Of COmPANY ASSETS

Keeping Best Buy assets sae – on and o Company grounds – is the responsibility o all employees and Company representatives. This includes nancial assets, Companyproperty, products, inventory, supplies, intellectual property and inormationtechnology.

Inormation technology includes, but isn’t limited to, acilities, equipment, supplies,services and other resources to aid in processing, storing or carrying electronic data,inormation or communications. It also includes computers, network connections,mobile phones, PDAs, and networks.

Best Buy assets should be handled with care and respect and guarded againstthet, carelessness, waste and abuse. Company resources are to be used to conductCompany business or or purposes authorized by management. Any unauthorizedcopying o sotware, DVDs, or other legally protected work is a misuse o assets thatmay create nancial and legal liability or you and the Company.

PROTECTINg INTEllECTUAl PROPERTY

Employees must maintain the condentiality o intellectual property that belongsto the Company. Intellectual property includes identiable names, trademarks,logos, images, graphics and other copyrighted materials o Best Buy or any o its subsidiaries. Best Buy’s proprietary inormation and competitive knowledge iscondential. It is limited or use within the Company unless specically authorizedor release and disclosure elsewhere. I you have questions about what material isconsidered condential please reer your questions to the appropriate resource within

your country and business.





Q. During a business trip, a colleague rom another company asked to usemylaptoptosendane-mailtohismanager.Isthisokay?

a. No. Because he is not a Best Buy employee. Your laptop was purchasedby Best Buy or you to do your job. Condential inormation may be on your

laptop that should not be viewed by a non-Best Buy employee.

Q. AthomeIblog.Lastweek,InoticedcommentsfromformerBest

Buy employees describing their bad job experiences. This upset me very muchbecauselknowitisuntrue.MayIrespondtothesecomments?

a.It is inappropriate or you to respond to comments on behal o Best Buy.• IfyouweretomentioncondentialCompanyinformationyouractionswould

violate our policy on nondisclosure o inormation.• ItiscrucialtopreservetheintegrityoftheCompany.Ifyourespondwith

inaccurate inormation you could risk the Company’s reputation. ContactEmployeeRelationsat(866)692-2947orsendane-mailto [email protected]. • TheCompany’sbloggingguidelinesareavailableonthewikiandonthe

Best Buy website.

Q. May I share Best Buy’s logo or similar branding materials withindividualsoutsideoftheCompanyfortheirownuse?

a. No. Intellectual property includes the Company’s logo or similarbranding materials and must be protected.





RESPONSIBIlITY toOur Business Associates

5SECTION



responsibility to ou r business associates


Best Buy’s success is based on strong relationships with customers, vendors,suppliers and others. Our business associates help provide our customerswith products and services they need at competitive prices. We trust thateach business associate will make and keep reasonable promises and behaveethically in all business dealings.

CUSTOmERS

vENDORS

SUPPlIERS

STRONgRElATIONSHIPS



COmPETITIvE INTEllIgENCE gATHERINg

Competitive intelligence is the process o understanding and anticipating thecompetitive environment in which Best Buy operates. It is our intent to competeaggressively and airly, with our behavior always rmly anchored in our values.

Your actions in this regard should never be infuenced by what you think ourcompetitors are doing or would approve o doing. People oten believe thatcompetitors will act less ethically than they or their own employer would in collectingintelligence. This perception is seldom accurate. Don’t be tempted to cross any legalor ethical line because “others do it.”

Because the gathering o competitive intelligence can occur in almost anycircumstance, there is no set o rules that can specically address every conceivablecircumstance. However, Best Buy expects that each and every employee ollow notonly the letter but also the spirit o these guidelines.• Wealwaysrespecttherightofothercompaniestoprotecttheirproprietary

inormation. Never encourage or pressure others to violate their obligationsto protect the condentiality o their current or ormer employer’s proprietaryinormation. No employee may take another company’s proprietary inormationwithout that company’s authorization, nor may you obtain another company’sproprietary inormation as a result o deception, misrepresentation, promisesor threats.

• Itiseachemployee’spersonalresponsibilitytoknowandunderstandallapplicable Company policies and procedures beore seeking any competitive inormation.

Whenever you are uncertain about how to proceed, contact your manager or the CompetitiveIntelligenceTeam,LegalDepartment,orEthicsOfcetohelpthink through the issues and make a decision.



No copetitie inoration is orth eopardizin Best Buy’s

reputation or your on.





ANTITRUST & COmPETITION

Antitrust and competition laws protect the ree enterprise system and encouragevigorous, but air, competition. All enterprise employees are expected to comply withapplicable domestic and international antitrust and competition laws.

For example, engaging in, conspiring to, or agreeing to do any o the ollowingactions is prohibited:• Agreeingorconsultingwithcompetitor(s)regardingprices,termsorconditionsof

sale, output, or production (Price Fixing).• Agreeingwithcompetitor(s)regardingbidstobesubmittedduringauction (BidRigging). • Agreeingwithcompetitor(s)nottodealwithvendorsordistributors,other

competitors, or customers (Group Boycott).• Agreeingwithcompetitor(s)tosplitterritoriesorcustomers(Territoryor

Customer Allocation).•Offeringtopaybribesorkickbacksinanattempttodoanyoftheabove.

“Agreeing” includes stated or implied, ormal or inormal, oral or writtenunderstandings, whether created directly with another party or indirectly through athird party.

Q. I want to share a vendor’s price list or televisions with another vendor

in an attempt to get a lower wholesale price. By doing this, I can oer alltelevisionsatretailatthesameprice.Isthispermissible?

a. No. You may be improperly disclosing condential inormation rom onevendor to another. This could be a breach o contract and may lead to a director indirect agreement to x prices. Never accept a competitor’s price list rom avendor or competitor, even i it is oered to you without your request.

All business dealings, including agreements, mergers, acquisitions, strategic alliancesor other extraordinary business combinations that raise antitrust or competitivequestionsorconcernsshouldreceivetimelylegalreview.PleasecontacttheLegal

[email protected].



fAIR DEAlINg

Employees must deal airly with Best Buy’s customers, suppliers, competitors andother employees. No employee should take unair advantage o anyone throughmanipulation, concealment, abuse o privileged inormation, misrepresentation o material acts or any other unair practice.

CORPORATE OPPORTUNITIES

Employees and directors are prohibited rom:• Takingpersonaladvantageofopportunitiesthatarediscoveredthroughtheuseof

corporate property, inormation or position.• Usingcorporateproperty,information,orpositionforpersonalgain. • CompetingwithBestBuyoritsbrands.

Employees and directors must advance Best Buy’s legitimate interest when theopportunity arises. Questions should be directed to the Ethics Oce by using thecontact inormation ound on the resources page in the back o this Code.

CONflICTS Of INTEREST

Employees are required to disclose or avoid any activity or interest that may beregarded as a possible confict with Best Buy’s interest.

A confict o interest occurs when an employee places, or gives the appearance o placing, personal interests ahead o, or at the expense o, the interests o Best Buywhile doing Company business. Personal interests can cloud our judgment and makeit dicult to make good business decisions.

Conficts o interest also arise when an employee or director, or a member o theiramily, receives improper personal benet as a result o her/his connection to theCompany.Loansorguaranteesofobligationsareexamplesofpotentiallyimproper

personal benets that must be avoided.

Best Buy’s Conficts o Interest policy also extends to your amily members and closepersonal relationships, including members o your economic household (sometimesreerred to as “related parties”). These include a spouse, signicant other, civil

partner, son, daughter, parent, sibling, in-laws, step-relations, or any relation up to andincluding a rst cousin.

Some examples o possible conficts are listed below. This list does not include allpossible types o conficts o interest.







• UsingBestBuytimeand/orresourcesandorinuencetopromotepersonal interests or the interests o third parties.

• Holdingasecondjobwith,orconsultingforacompetitor,vendororsupplierwith whom the Company conducts business.

• ConductingCompanybusinesswithrelatedpartiesordealingwithbusinessesin which you or related parties have signicant interest.

• Speculatingordealing,forpersonaluse,inmaterials,supplies,equipmentor

product which the Company buys or sells, or in the property rights in which theCompany may be interested.

• Servingasadirector,ofcer,associateorconsultantwithCompanybusiness partners or competitors, unless at the request o Best Buy.

• Makingorholdinganinvestmentincompetitorsorincompanieswithwhomthe Company does business i, 1) you own or have the right to acquire more than

onepercentoftheoutstandingstockofsuchcompanies;and2)theinvestment constitutes more than ten percent o your net worth, you must disclose such

investments.Lawsmayvarybycountry. • Acceptingtipsorgiftsfromcustomers,vendorsorotherthirdparties.Referto “Gifts,BusinessCourtesiesandVendorRelations”below. • Formingsocialrelationshipsthatleadtoaweakness,ortheappearanceof

weakness, in the Company’s system o internal controls.

Q. I am a management-level employee and have taken a part-time jobwithWal-Mart.Isthispermitted?

a. No, not without obtaining prior permission rom your manager.• HavingworkhoursoutsideoftheCompany(i.e.,apart-timeeveningjob)that

confict with your productivity or work hours at Best Buy is also likely to beperceived as a confict o interest.

• Servingasadirector,ofcer,employeeorconsultantforcompaniesthatdo

business with or are competitors o Best Buy may also be a confict o interest.



gIfTS, BUSINESS COURTESIES & vENDOR RElATIONS

Gits and entertainment can help build relationships, but they must never infuencedecisions, nor should they be considered part o “doing business.”• Ourrolewithcustomersistobeatrustedadvisor.Eventheappearanceofhaving

our decisions improperly infuenced is unacceptable.• EmployeesareexpectedtobemindfuloftheCompany’svaluesandstandardsin

their business dealings. It is never acceptable to solicit gits, gratuities or business

courtesies on behal o Best Buy or the personal benet o an employee, amilymember or riend.

We recognize that git-giving customs vary around the world. As a global Company,we respect the cultures o all the Countries where we do business. Employeesmust always rerain rom paying or receiving a bribe intended to infuence businessoperations or government conduct. In addition, no Company assets may be used tobribe or infuence any decision, including a decision o an ocer, director, employeeor agent o another company, any government employee, political party or candidate

or public oce. Such conduct is illegal and unethical and the employee and thecompany could be held criminally liable.

Q. A vendor gave me an airline ticket to travel with him to Japan. May Iaccepttheticket?

a. Possibly, i the trip is or a legitimate purpose, the vendor is inattendance, the travel is not extravagant, and is approved by the business VP.Always discuss the issue with your manager or the Ethics Oce.



Best Buy aays ants to ae an ipact on the ies they

touch either associates, endors, or custoers.

— gladyS, dhrm, puerTo rico‘‘’’





Q. MayIgiveavendoragift?MayIacceptagiftfromavendor?

a. Employees are generally prohibited rom oering or giving a gitor gratuity to any current or potential customer or vendor. However, trinkets,meals, business courtesies given or received may be acceptable i they t within

Company guidelines.

BUSINESS COURTESIES

To determine whether or not a business courtesy rom a vendor is acceptable, askyoursel the ollowing questions:• Whatdoesthepolicysay? • Istherealaworregulationgoverningthissituation?

• Isitcustomaryinthetradeorindustry? • IsthevalueinaccordancewithCompanyguidelines? • Wasitgivenandacceptedwithanexpressedorimpliedunderstandingthatthe recipientisanywayobligated? • Doesitgivetheappearanceofcreatinganundueinuenceorimpropriety? • DoesitplaceyouorBestBuyinacompromisingposition?

Some business units and country managers may choose to adopt more conservative

rules based on the environment and specic work involved. When in doubt, pleasediscuss with your manager or the Ethics Oce.

gIvINg gIfTS

It may be acceptable, with management approval, to entertain or provide small gits toa customer, supplier or business partner o Best Buy, as long as they meet the criteria setorth in our policies.



RESPONSIBIlITY to Our Communities

6SECTION



responsibility to ou r communities

page 41best bu y code of business ethics | page 41

Best Buy is committed to making a meaningul and lasting impact on thequality o lie in the countries and communities in which we operate. We striveto be a valued and trusted member in each area while upholding the laws andpracticing ethical behavior in all our business dealings.

lOCAllY &

glOBAllY

mAkINg

AN ImPACT



CHARITABlE CONTRIBUTIONS

One distinguished element o our charitable contribution program is the Company’sannual giving goal o 1.5 percent o pre-tax earnings, which it contributes throughboth the Best Buy Children’s Foundation (BBCF) and direct corporate or retail sectorcontributions to non-prot organizations.

INvOlvEmENT IN POlITICAl ACTIvITIES

Best Buy respects and supports everyone’s right to participate in political activities.Contributing your time, your own money, or resources to any political activity isentirely personal and voluntary, and varies greatly rom country to country.

In all situations employees are prohibited rom implying that they represent Best Buyin their various political activities.

gOvERNmENT REqUESTS & INqUIRIES

Best Buy cooperates with every reasonable request by government ocials orinormation needed in an investigation. False reporting to governmental agencies isstrictly prohibited.

Best Buy and its employees are entitled to all saeguards provided by law orcompanies and individuals involved in investigations. This includes the right to berepresented by and consult with counsel.

I you are contacted by a representative o any government agency, don’t handle thesituationbyyourself.ConsultyourCountryLegalDepartment.

Q. Locallawallowscompaniestoemployprisoninmatestoperformwork

atminimalcost.Whycan’twehirethesetypesofworkers?

a. Doing so would violate Company policy banning orced labor.Everyone makes a personal choice to be employed by Best Buy.





glOBAl BUSINESS OPERATIONS

As Best Buy conducts business around the world, it respects local customs andpractices, abides by U.S. standards and applicable oreign laws, and adheres toCompanyvaluesandstandardsofethicalbusinessconduct.ConsultyourcountryLegal

Department i questions arise regarding specic issues, such as customs compliance.

ANTI-BRIBERY / ANTI-CORRUPTION & fCPA

As a global enterprise, we abide by each country’s anti-bribery and anti-corruptionlaws. In addition, Best Buy and its employees in all countries must comply withthe Foreign Corrupt Practices Act (FCPA). In general, the FCPA prohibits corruptpayments or bribes to all non-U.S. government ocials, political parties or politicalcandidates or the purpose o obtaining or keeping business or improperly infuencinggovernment action. Included in the anti-bribery prohibition is a corrupt payment througha third party.

The FCPA applies to individuals as well as corporations and requires companies to keep

and maintain books and records that accurately refect the transactions o the corporation.

RefertotheCompany’santi-briberyandanti-corruptionpolicyforspecicobligations

regarding the FCPA. In a situation in which the local laws and the FCPA confict, we willabide by the most conservative standard.

EmPlOYmENT & lABOR ISSUES

c l

We will not knowingly do business with a vendor or business partner that illegally or

improperly employs underage workers.F l

Best Buy does not employ orced labor (involuntary labor o any kind including prisonlabor, debt bondage or orced labor by the government) and will not knowinglypartner with a vendor or business partner that employs orced labor.




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SPECIAl ETHICAlOBlIgATIONSSPECIAl ETHICAl OBlIgATIONS fOR EmPlOYEES

wITH fINANCIAl REPORTINg RESPONSIBIlITIES

Best Buy has adopted the ollowing Finance Code o Ethics which applies to its Chie Executive Ocer, Chie Financial Ocer, Principal Accounting Ocer, Controller (orother persons perorming similar unctions) and all members o Best Buy’s FinanceDepartment no matter which country you are in. This Finance Code o Ethics isintended to supplement the Best Buy Code o Business Ethics.

fINANCE CODE Of ETHICS

Each employee covered by this Finance Code o Ethics agrees that he or she will:•Actwithhonestyandintegrity,avoidingactualorapparentconictsofinterest

in personal and proessional relationships.•Provideinformationthatisaccurate,complete,objective,relevant,timely

and understandable to ensure ull, air, accurate, timely, and understandabledisclosure in reports and document that Best Buy les with, or submits to,government agencies and in other public communications.

•Complywithapplicablerulesandregulationsofgoverningprivateandpublic regulatory agencies.

•PromptlyreportanypossibleviolationofthelaworbusinessethicstotheEthics

Oce, the Director o Internal Audit, General Counsel and/or the Chair o theAudit Committee.

•BeaccountableforadherencetothisFinanceCodeofEthicsandtheBestBuy Code o Business Ethics.

special ethical obligations



glOBAlRESOURCESBEST BUY EmPlOYEES wORlDwIDE ENTERPRISE ETHICS OffICE

7601PennAvenueSouth

Minneapolis,MN55423 Facsimile952-430-4200 DirectDial612-291-7451

Text612-437-1387 [email protected] callers outside North America, the country code is 01.

OPEN & HONEST, THE ETHICS HElPlINE

g W-s www.tnwinc.com/reportline/bestbuy rt:

counTry inTernaTional provider & region acceSS code phone number

u.S., pt r 800-520-1132

c:

c AT&TSouthernRegion 10-811 800-520-1132

AT&TNorth,BeijingCNCG1 108-888 800-520-1132

AT&TChinaTelecom 108-10 800-520-1132

AT&TNorth,BeijingCNCG(2) 108-710 800-520-1132

ITFSChinaNorthNetcomGroup 10-800-711-0756

ITFSChinaSouthTelecomSouth 10-800-110-0701

i ITFSIreland 1-800-550-000 800-520-1132

ITFSUIFN 00-800-222-55288 800-520-1132

Tk 0811-288-0001 800-520-1132

global resources



http://slidepdf.com/reader/full/best-buy-code-of-ethics 48/52page 46 | best bu y code of business ethics

OPEN & HONEST, THE ETHICS HElPlINE (t)

counTry phone number

b 0800-7-2176

F 0800-91-4103

g 0800-183-0628

lx 800-2-3473

mx 001-800-520-1132

nts 0800-022-9645

pt 800-8-11506

S 900-98-1146

Sw 020-796545

Swtz 0800-83-7308

ut K (bT) 0808-234-4335

global resources



PERSONAlCOmmITmENTI acknowledge that I have received and will comply with Best Buy’s Code o Business Ethics (the Code). I also understand that I have the responsibility to

review Best Buy’s policies and procedures. I understand and agree that theCode is not an employment contract between Best Buy and me. I understandthat violation o the policies and ethical standards outlined in the Code maysubject me to disciplinary action up to and including termination withoutnotice. I understand that i I have questions related to the standards o conductoutlined in the Code or other Company polices not covered in the Code,I am to discuss them promptly with my manager, the Ethics Oce, HumanResources,EmployeeRelationsorOpen&Honest.

I also understand that I may be required to sign one or more annual statementsreporting conficts o interest or receipt o gits and gratuities.

SIGNATURE DATE

PRINTNAME EMPLOYEENUMBER

BUSINESSGROUPORDEPARTMENT

LOCATION

personal commitment statement and acknowledgement of receipt






ACkNOwlEDgmENT AND

THANkS TO THE PROjECT TEAm

Thanks to all who wrote, reviewed and gatheredmaterial or this work. It is a ar better resultbecause o our collaboration. Project TeamLeaderMelanie(BestBuyHRU.S.),Hero(Best

BuyChina),Rose(BestBuyChina),Amy(Best

Buy/Future Shop Canada), Simeon (Best BuyImplementation Project US ), Darnisha (Best BuyHRUS),Suzan(BestBuyLegalUS),KimMarie

(Store #843 US), Kelly (Best Buy CommunicationsUS),Scott(BestBuyLPTerritory#4US),Michael

(Best Buy Communications US), Chuck (Best

BuyHRUS),Kathleen(BestBuyEthicsUS)and

the dozens o others who oered their time and

expertise to editing and giving advice on thisliving document.



HR–0151004

ENGUSACODE0909

Documents

Best Buy Code of Ethics