Best Buy Anti-Corruption Policy

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1 Best Buy Anti-Corruption Policy 1. Scope 2. Policy Statement 3. Prohibited Conduct and Obligations 4. Definitions 5. Transparency 6. Communication and Reporting 7. Business Partners and Commercial Intermediaries 8. Business Courtesies to Vendors and Commercial Parties 9. Gifts to Government Officials 10. Hospitality and Travel to Government Officials 11. Political Contributions 12. Charitable Contributions 13. Facilitating or Informal Expediting Payments 14. Responding to Safety and Security Concerns 15. Auditing and Internal Controls 16. History of Policy Date February 3, 2012

2 Best Buy Anti-Corruption Policy Scope The Best Buy Anti-Corruption Policy (the Policy ) applies to all Best Buy employees, officers, directors, agents, subsidiaries, joint ventures, consortiums, consultants, brokers, or other individuals, intermediaries, contractors, distributors, suppliers, or entities over which Best Buy has control, or who are doing business on behalf of Best Buy with respect to all of their commercial transactions, whether local or international. This policy covers bribery, other forms of corrupt activity s and is to be read in conjunction with Best Buy s Conflict of Interest Policy and Gifts, Business Courtesies and Vendor Relations Policy. Compliance with this policy is mandatory. Policy Statement Best Buy values its reputation for ethical behavior and customer trust. We recognize that involvement in bribery or corrupt behavior would negatively impact our reputation and the trust of our shareholders and our customers. Therefore Best Buy strictly prohibits paying or receiving a bribe, to or from, any third party, public or private, with whom the company does business. This policy covers both commercial transactions and relations with government officials. No employee will suffer adverse consequences for refusing to pay a bribe or engaging in other corrupt behavior even if this may result in the loss of business. Prohibited Conduct and Obligations It is Best Buy s policy to comply with the letter and spirit of all applicable anti-bribery and anticorruption laws such as the U.S. Foreign Corrupt Practices Act (the FCPA ), the UK Bribery Act 2010 (Bribery Act), The Canadian Corruption of Foreign Public Officials Act (Corruption Act), and similar applicable laws of countries in which the company operates. These laws prohibit payment or receipt of bribes to any third party, including a government official and/or to private sector employees, either directly or indirectly. Bribes include any offer, promise or actual gift or receipt of anything of value for the purpose of improperly influencing actions by a third party. A bribe may include, but is not limited to, money, gifts, hospitality, expenses, reciprocal favors, political or charitable contributions, or any direct or indirect benefit or consideration. All employees are required to comply with this policy and its guidelines as applicable to their activities. This includes following the policy guidelines with respect to gifts, hospitality and other items of value given to third parties, where applicable, reporting and recorded any such activities. Even the appearance of an improper or corrupt payment must be avoided. The prevention, detection and reporting of bribery or corruption is the responsibility of all employees across the Best Buy enterprise. Employees must be aware of the legal standards and business risks applicable to their assigned duties, including the FCPA, Bribery Act, and Corruption Act, the legal standards of the employee s country of origin, and the legal standards of the country in which the work is performed, and to conduct themselves accordingly in all respects. 2

3 Definitions Bribe: An offer, promise or actual gift or receipt of anything of value for the purpose of improperly influencing actions by a third party. A bribe may include, but is not limited to, money, gifts, hospitality, expenses, reciprocal favors, political or charitable contributions, or any direct or indirect benefit or consideration. Control: The contractual power of Best Buy to direct, manage, oversee and/or restrict its relationship with another entity. Corruption: Behavior by which someone uses a position of trust and/or authority for personal gain or enrichment. This includes, but is not limited to, bribery, conflicts of interest, misrepresentation, fraud, kickbacks, and money laundering. Facilitating Payment: also known as expediting payments or grease payments, are bribes paid to induce foreign officials to perform routine functions they are otherwise obligated to perform. Examples of such routine functions include issuing licenses or permits and installing telephone lines and other basic services. Gift: Any tangible object of any kind, regardless of value. Government Official: Any officer or employee, regardless of rank, of any government or any department, agency, or instrumentality thereof; any person acting in an official capacity on behalf of a government or any department, agency, or instrumentality thereof; any officer or employee of a company or business owned in whole or in part by a government; any officer or employee of a public international organization such as the World Bank or the United Nations; any political party or any official thereof; or any candidate or prospective candidate, or anyone acting on their behalf for political office. Hospitality: Any event or form of entertainment, including meals (whether hosted at a Best Buy facility or elsewhere) and social events (including sporting events, parties, golf outings, theatre or other live entertainment and receptions). Communication and Reporting No policy can anticipate every situation that may arise. Employees are encouraged to discuss with any member of senior management, the Legal Department or the Enterprise Ethics Office, questions about particular circumstances that may constitute bribery, fraud, or other forms of corruption. Employees who believe that Best Buy s standards articulated in this policy are not being practiced are required to report the circumstance to the Office of the General Counsel, the Chief Compliance Officer, the Enterprise Ethics Office or to the Open & Honest Hotline. Any calls or web reports to the Open & Honest Hotline may be made anonymously, although employees are encouraged to identify themselves so that a full investigation is possible. 3

4 Retaliation for good faith reports of misconduct by others is prohibited by law, and the company will not permit retaliation of any kind against any employee who reports misconduct in good faith. Contact information for reporting: Legal Compliance: Open & Honest Hotline: or Business Partners and Commercial Intermediaries Best Buy is responsible under the FCPA and other applicable anti-bribery laws for any corrupt actions by affiliated third parties, such as joint venture partners or agents retained to represent Best Buy or otherwise perform services on its behalf. Relationships with third parties are a common source of antibribery violations for global companies like Best Buy. Every Best Buy employee, officer or director retaining third parties on behalf of Best Buy is therefore responsible for screening and overseeing such third parties, as necessary, to ensure that they do not intend to or are otherwise likely to engage in improper practices. In determining whether to engage a particular third party, one should consider factors such as the third party s reputation and qualifications, the manner and reasonableness of compensation, the relationship, if any, between the owners and employees of the third party and a government official, the presence or absence of any secret partners, the willingness of the third party to fully disclose its relationship with Best Buy and the legality of the relationship under local law. Any agreement to retain a third party for purposes likely to involve interaction with government officials on Best Buy s behalf must be reviewed by the Best Buy Legal Department to ensure appropriate contractual and legal protections against potential anti-corruption violations, including express representations and warranties that such party will fully comply with the FCPA, Bribery Act and the Corruption Act, and all other applicable anti-corruption and anti-bribery laws. All such agreements must also include appropriate representations and covenants by the third party regarding their compliance with anti-corruption and anti-bribery laws. Business Courtesies to Vendors and Commercial Partners Refer to Best Buy s Gifts, Business Courtesies and Vendor Relations Policy for questions about offering or accepting nominal business courtesies to or from Best Buy s vendors. Gifts to Government Officials Pre-approved, nominal gifts to government officials are permitted if all of the following statements are true: The gift is offered or given under circumstances in which gift giving is widely accepted; The total value of the gift is reasonable and customary under the circumstances 4

5 The gift is not offered or provided in exchange for any official act or omission or other corrupt purpose; The gift is tasteful and commensurate with generally accepted standards of professional courtesy in the United States and in the government official s home country; Is not given to a government official with authority over a pending regulatory decision unless the Best Buy Corporate Legal Department grants prior approval; Is not provided to any one government official more than once in a three month period; and Complies with local laws and regulations. The Best Buy Legal Team has created a list of pre-approved nominal gifts that may be given in accordance with this policy. All gifts, including those on the pre-approved list, require prior approval from the appropriate supervisor and comply with the applicable record-keeping requirements. Changes or exceptions to the pre-approved gift list must be approved by the Local Legal Department team. Hospitality and Travel to Government Officials Certain reasonable and bona fide promotional and government relations expenses involving the provision of meals, travel, lodging and similar benefits to government officials are permitted. Such expenditures must be approved in advance by the Best Buy Legal department unless all of the following conditions are met: The expense must relate directly to the promotion, demonstration, or explanation of Best Buy and its products and services. The expense may not involve the provision of cash or cash equivalents such as pre-loaded gift cards or debit cards, or cash reimbursement to the government official. The expense must be reasonable and may not include premium travel or accommodations, extravagant meals or entertainment, or adult entertainment. The expense must not exceed U.S. $100 per person or the applicable country-specific limit determined by the Best Buy Corporate Legal Department. Entertainment may not be given to a single government official more than once in any threemonth period. The expense must not have the purpose or appearance of inducing a government official to misuse his or her authority, to deviate from his or her official responsibilities, or otherwise act improperly. Entertainment may not be provided to a government official with authority over a pending regulatory decision without authorization by the Best Buy Corporate Legal Department. If any of the above conditions are not met, consult with the Best Buy Corporate Legal Department before proposing or making the expenditure. Any expenditure requires prior approval from the appropriate supervisor and must comply with all applicable record-keeping requirements. Political Contributions Contributions to political parties, party officials, candidates, or organizations or individuals engaged in politics may be used as a pretext for bribery. All political contributions must comply with Best Buy s Political Activity & Government Relations Policy. 5

6 Charitable Contributions While contributions to local charitable organizations are permitted and encouraged in conjunction with community relations building, such contributions can also be used as a pretext for bribery. Any charitable contribution or sponsorships must comply with Best Buy s Political Activity and Political Contributions Policy. Facilitating or Informal Expediting Payments Best Buy no longer allows nominal payments for non-discretionary actions sometimes referred to as facilitation payments to be made to government officials under this policy. The laws of certain jurisdictions allow for certain nominal payments to government officials for nondiscretionary government actions. These are sometimes referred to as facilitation payments or expediting payments. While sometimes practiced, global standards strongly discourage such payments. Distinguishing facilitating payments from appropriate payments is often difficult. Even if a facilitating payment is permitted under certain US anti-bribery laws, it may still violate local law. For these reasons, Best Buy has adopted a policy of prohibiting such payments. All questions regarding facilitating payments should be directed to the Best Buy Corporate Legal Department. Responding to Safety and Security Concerns In light of the risks posed to those doing business in some countries (and in recognition that the safety of our employees is a top priority), payments may be made (1) when it is necessary to secure critical governmental services (e.g. police protection, medical evacuation) in response to a medical or safety emergency or (2) when there is a reasonable fear of serious harm and no other prudent alternatives are available. Payments made under these circumstances must be reported to the Best Buy Corporate Legal department and must be accounted for accurately in the company s books and records. Continuous demand for payment must be reported to the Legal Department. Auditing and Internal Accounting Controls All transactions must be recorded in a timely and accurate manner, including any information material to the transaction. No transaction should ever be entered into that requires or contemplates the making of false or fictitious records in whole or in part. This requirement applies to all transactions whether or not they would otherwise be considered financially material. Best Buy will subject its system of internal controls, in particular accounting and recordkeeping practices, to regular review and audit to evaluate its design and effectiveness. We will take corrective action as needed. Best Buy will respond with appropriate disciplinary measures to violations of this anti-corruption policy, up to and including termination when appropriate. 6

7 HISTORY Effective Date: August 2006 Last Update: August 23, 2011 REVISION HISTORY Date Revision Number Modification August Modification of policy and guidelines June 12, Modification of policy and guidelines March 3, Modification of policy and guidelines September 3, Modification of policy and guidelines November 19, Modification of policy and guidelines February 3, Modification of policy and guidelines 7

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