walgreens code of business conduct 2015 -...

Walgreens Code of Business Conduct

2015

2015 1

A message from Chief Compliance OfEcer Diane Nobles....................................... 2

Our Code and Your Responsibilities

The purpose of our Code of Business Conduct....................................................... 3

Key principles ........................................................................................................... 4

Publication and amendments................................................................................... 4

We are all accountable ............................................................................................. 4

Team leaders have additional responsibilities .......................................................... 4

Where we can seek help........................................................................................... 4

No retaliation policy .................................................................................................. 5

Open Door Policy ..................................................................................................... 5

What happens if we violate our Code?..................................................................... 5

A Foundation of Trust for Our Customers ................................................................. 6

We uphold our trustworthy reputation through product safety ................................ 7

We provide quality, dependable services our customers can count on ................... 7

We market our products and services honestly ....................................................... 7

We expect our suppliers to uphold our values ......................................................... 8

We protect the private information and intellectual property of others .................... 8

We uphold the competition and antitrust laws that apply to our work..................... 8

We obtain competitive information fairly .................................................................. 9

We work on government contracts and programs lawfully and ethically ................. 9

We maintain appropriate relationships with healthcare professionals...................... 9

A Foundation of Trust for Our Company and Our Fellow Team Members ............. 10

We foster diversity and inclusion in our workplace .................................................. 11

We respect each other and do not tolerate harassment .......................................... 11

We strive to create a safe and healthy work environment........................................ 11

We work to protect our company’s assets ............................................................... 11

We safeguard each other’s personal information ..................................................... 12

We use our computer systems appropriately........................................................... 12

Individual social networking and blogging ............................................................... 12

A Foundation of Trust for Our Investors .................................................................... 14

We keep honest, accurate Pnancial books and records........................................... 15

We maintain records in compliance with the law and company policy.................... 15

We avoid conQict of interest situations..................................................................... 15

Gifts and entertainment ............................................................................................ 16

Doing business with friends and relatives ................................................................ 16

Outside positions...................................................................................................... 16

Business opportunities ............................................................................................. 17

We uphold insider trading laws ................................................................................ 17

A Foundation of Trust for Our Communities ............................................................. 18

We follow healthcare laws ........................................................................................ 19

We comply with the Federal False Claims Act ......................................................... 19

We work to build sustainable supply chains ............................................................ 19

We follow international trade laws............................................................................ 19

We do our part to protect the environment .............................................................. 21

We support our local communities ........................................................................... 21

We communicate with a single voice ....................................................................... 21

Asking Questions and Raising Concerns .................................................................. 22

Table of Contents

2 2015

Dear Team Members:

Welcome to the 2015 edition of Walgreens Code of Business Conduct. This importantdocument is both a primer and a guidebook created to help ensure Walgreens maintainsits trusted reputation with our customers and patients, communities, healthcareprofessionals and organizations, clients, shareholders and all with whom we do business.

One of the things I’ve seen since my earliest days at Walgreens is how tuned in our teammembers are when it comes to ethics, a strong sense of responsibility and integrity. Theimportance of our cultural beliefs in our everyday work certainly attests to that. We are allabout doing the right thing, in the right way—the essence of integrity. I see it in meetings,in conversation, when setting strategies—and it is just this kind of mindset that has keptWalgreens going strong through its 114-year history. We hold ourselves accountable forWalgreens success—just as we should. And the reality is, accountability is a critical factorin how Walgreens does business here and around the world, and how each and every oneof us does business. In fact, holding ourselves accountable is the very basis on which thesuccess of all our endeavors rests.

Who hasn’t seen the fall of individuals, companies and organizations dueto the loss of reputation or misconduct? Just as Walgreens reputationhas been built one decision at a time over more than a century, it can bedestroyed one decision at a time. Each of us is a representative ofWalgreens, which is why each of us is accountable for behaving ethicallyand being compliant with regulations. And that’s the key behind thispublication: to ensure we’re all working off the same page—literally—when it comes to ethics and integrity at Walgreens. Please be sure to readthrough the Code of Business Conduct beginning to end. Each year, ourcode is refreshed to keep up with changing policies, regulations and laws.

From our open door policy and reporting violations with no fear ofretaliation to ethical principles and practical guidance, our Code coversthe ethical behaviors our team members need to demonstrate on the job.Your Compliance Office is always ready to answer questions or discussissues—just call 847-964-6519 or email [email protected] a confidential conversation.

When you demonstrate ethical behavior, you’re playing the ultimate role of the teammember—keeping our company safe and our reputation intact, and safeguarding ourcustomers, patients, clients, shareholders—and each other.

Thank you, and be well.

Diane Nobles

A Message from Chief Compliance OfEcer Diane Nobles

Diane Nobles

“When you demonstrateethical behavior, you’replaying the ultimate roleof the team member—keeping our companysafe and our reputationintact, and safeguardingour customers, patients,clients, shareholders—and each other.”Diane NoblesChief Compliance Officer

2015 3

The purpose of our Code of Business Conduct Our Code of Business Conduct is a guide to the ethical and legal

responsibilities we share as members of the Walgreens Family of Companies (collectively “Walgreens”). We use this Code for

guidance and direction to resources to help us make the right decisions. It helps us choose the right action to take. We all

encounter situations that force us to make decisions at work, and sometimes the most ethical response is not always the

most obvious choice. As we cannot address every decision you must make, our Code is not a summary of all laws and

policies that apply to Walgreens business. Instead, it is a starting point to help us determine when and where to seek help

when we are unsure. We have a solid foundation today and many things we don’t want to lose, like the desire to win, our

innovative mindset and looking out for each other. Our key strategic components include our core values and cultural beliefs.

Evolving our culture is about respecting what’s here and welcoming the new.

Each of us isresponsible forfollowing the principlesoutlined in our Code.

A Foundation of Trustfor Our Customers

A Foundation of Trustfor Our Companyand Our FellowTeam Members

A Foundation of Trustfor Our Investors

A Foundation of Trustfor Our Communities

OUR CODEAND YOURRESPONSIBILITIES

at the corner of ETHICS and COMPLIANCE

4 2015


usual high standards, to lead by example and act as role models.

If you are part of leadership, you can do this by:

• Reinforcing the Code and ensuring it is consistently applied

• Making sure each team member has completed all

required training

• Communicating relevant policies to team members and helping

them to understand the policies

• Encouraging all team members to raise any questions

or concerns

• Dealing with reports of misconduct promptly and properly

• Never ignoring any type of misconduct or retaliation against a

team member

• Never retaliating against a team member for raising questions or

issues, in good faith, to those outside your chain of command

(for example the confidential hotline, Asset Protection Solutions,

or HR Shared Services).

Team leadership must strive to create a positive work environment

where team members feel comfortable asking for help and raising

concerns about this Code. Team leadership must also be alert to

any situations or actions that may violate the letter or spirit of the

Code or company policy or that may damage our company’s repu-

tation. It is important that, as team leadership, you take immediate

action to address such situations.

When team leadership receive reports of a situation that may be

unethical or potentially damaging to our company’s reputation,

or suspect that one exists, he or she must promptly notify the

chief compliance officer, company hotline, or HR Shared Services

and work to resolve the issue. Team leadership who know about,

or should know about, misconduct and do not act promptly to

report it and cooperate with any investigation to correct the

situation will be subject to disciplinary action.

Where we can seek help

If you are ever unsure about the best course of action, however,

there are many company resources available to help you.

If you become aware of or even reasonably suspect any violations

of our Code or company policy, you are required to report your

concerns to your direct team leadership, the chief compliance

officer, HR Shared Services or the company hotline. Speaking up

when you sense any activity that could violate our core values

helps maintain Walgreens culture of trust and integrity and our

responsibility to uphold our company’s high moral standards.

There are a number of ways to raise issues. If you believe that a

law has been violated or an ethical violation has occurred, contact

Each of us is responsible for following the principles outlined

in our Code. We are all expected to be familiar with and follow

company policies, as well as the laws and regulations in every

location where we do business. By reviewing and understanding

our Code and policies, we become better prepared to handle

ethical issues as they arise.

Key principles

Each of us is responsible for:

Integrity and compliance – Achieving our goals with

integrity and in compliance with company policy and

legal requirements

Open communication – Encouraging open, honest and

full discussion about our policies and procedures

Raising questions – Raising and resolving questions about

ethical business conduct

Reporting violations – Reporting actual or perceived Code,

policy or legal violations to management, the chief compliance

officer or the company hotline

Cooperation – Assisting with any audit, compliance assess-

ment, legal or other internal inquiry with candid, accurate

and complete information

Non-retaliation – Ensuring that no punishment or retaliation

occurs against anyone for raising a good-faith concern

Publication and amendments

The current version of the Code of Business Conduct is posted

and maintained on the Walgreens website at www.walgreens.com

>Investor Relations >Corporate Governance >Code of Business

Conduct. Amendments are also posted on the website, as required

by applicable law. Because the Code is revised periodically, please

check the website for the most recent version.

We are all accountable

Whatever our role is with Walgreens, our actions represent the

company, and we must always do our best to uphold Walgreens

reputation. Our success as a company depends on each of us

accepting personal responsibility for always doing the right thing.

We must accept the obligation to stop or prevent actions that

could harm our customers or our company’s reputation and to

report any such actions as soon as we learn of them.

Team leadership has additional responsibilities

Performing honestly and with integrity is an obligation we all share.

Team leadership, however, are expected to perform beyond our

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-855-WAG-CODE (1-855-924-2633) or send an email to [email protected].

2015 5


No retaliation policy

Walgreens does not tolerate retaliation against anyone who

participates in an investigation, raises a legal or ethical concern,

or reports misconduct in good faith. “Good faith” means that the

report was made out of genuine concern for the company or

team members involved.

Here are some examples of retaliation:

• schedule changes that are outside of the business need

and/or the team members request after reporting an issue

• unreasonably denied or delayed promotions

• excluded from meetings, making decisions, denial of

administrative support, or reassigning job duties

• excluded from training that contributes to

professional advancement

• reprimanded for contacting the hotline or Asset

Protection Solutions

• verbal abuse by a supervisor or someone else

in management

Open Door Policy

Our Open Door Policy is a key part of our culture. It encourages

us to present ideas, raise concerns and ask questions—including

those of a legal or ethical nature—without fear of retaliation. You

are encouraged to address situations first with your team leader,

who is often best able to resolve the issue. You can avoid many

potential violations by simply asking for guidance before acting.

In certain cases, you may feel uncomfortable discussing a matter

with your team leader, or you might be unable to reach a satisfac-

tory solution. If this is the case, you may speak with any other

member of management, the chief compliance officer, HR Shared

Services or you may call the company hotline. You will never be

punished or retaliated against for making good faith use of our

Open Door Policy.

What happens if we violate our Code?

To maintain the highest standards of integrity, we must dedicate

ourselves to complying with our Code, company policies and

procedures and applicable laws and regulations. Violations

of our Code not only damage our company’s standing in the

communities we serve—they may also be illegal. Team members

involved in violating our Code will likely face negative conse-

quences. Walgreens will take the appropriate disciplinary action

in response to each case, up to and including termination. In

addition, team members involved may be subject to government

fines or criminal or civil liability.

the chief compliance officer immediately. For other matters, you can

talk to your team leadership or any other member of management.

Sometimes, just talking to your team leadership will help clarify the

situation and answer your questions.

If you still have concerns after talking with your team leader, you

can always contact the chief compliance officer, company hotline

or HR Shared Services.

Chief compliance officer

• Phone: 847-964-6519

• Email: [email protected]

• Web: www.tnwgrc.com/walgreens

• Hotline: 1-855-WAG-CODE (1-855-924-2633)

HR Shared Services

• Phone: 847-315-4455

The Walgreens hotline (1-855-WAG-CODE) is a toll-free

telephone line reserved specifically for team member calls

on ethics and compliance issues. This hotline is an option

that is made available to you to report your concerns if you

feel uncomfortable doing so in person.

The hotline is staffed 24 hours a day, seven days a week, 365

days a year by an outside firm experienced in handling sensitive

calls and accepting calls in many languages. Callers may report

anonymously. Anonymous callers should know, however, that

it is sometimes more difficult to follow up on issues raised by

individuals who don’t identify themselves.

Our company is committed to reviewing, evaluating and responding

to all reports of misconduct—big or small. To the extent practical,

considering our need to investigate and comply with company

obligations, Walgreens will make every effort to protect the confi-

dentiality of any person who comes forward with information, as

well as the information itself.

My team leadership asked me to do something that

I don’t believe is in compliance with the law. Should I

follow his/her instructions?

No. We must all obey the law. Regardless of the posi-

tion of the team leader within the company, if you think

you have been asked to do something that is against the

law, you have a duty to report the situation. You can

use the Open Door Policy or go to another member of

team leadership, the chief compliance officer, HR Shared

Services or call the Walgreens hotline. Remember that all

good faith reporting is protected from retaliation.


A FOUNDATION OF TRUST

for Our Customers

Be One

Be Real

Be Bold

Build Trust

Love Customers

Own ItLive It

2015 7


A FOUNDATION OF TRUST for Our Customers

Walgreens team members must always follow the highest

standards of integrity and ethics when interacting with our

customers and patients. Even team members who do not

interact with customers must be aware that the decisions they

make and the work they perform ultimately affect our customers.

We uphold our trustworthy reputation through product safety

Our customers count on us to sell safe reliable products that

meet the highest quality and safety standards. In our company’s

long history, we have earned our customers’ trust by sticking to

this principle.

As part of our commitment to exceeding our customers’ expecta-

tions, we must also ensure that we purchase only the highest

quality products from our suppliers. If you become aware of any

defective products or other issues that could pose a health or safety

risk, you have a responsibility to report the matter immediately.

As a store manager, I received a communication from

the company that a certain product is being pulled and

quarantined due to quality concerns. I have some other

tasks that I’d like to complete before pulling the product

from the sales floor. Is that okay?

No. Our customers trust us to provide safe, quality

products. The pull and quarantine items should be pulled

from the floor immediately. You must focus on maintaining

our customers’ safety and complete the other tasks later.

We provide quality, dependable services our customers

can count on

Due to our unique standing as both a retailer and a healthcare

provider, we must maintain our commitment to the integrity of

our products and services. Many of our customers rely on our

pharmacists and other healthcare providers for advice and

dependable service. Those professionals are required to maintain

current licenses, certifications or registrations and follow standards

of ethics that correspond with their occupations. Further, you may

not give any type of medical, pharmaceutical or other professional

advice unless you are licensed to do so.

We market our products and services honestly

We must preserve Walgreens principles of integrity and honesty

when we market our products—whether in any advertising,

promotions, packaging, or labeling. Our customers’ trust is one

of our most valuable assets, and we are committed to maintaining

that confidence.

Our marketing materials and company communications are

meant to inform our customers about our products and services.

They are expected to meet all industry standards that govern

advertising and promotion. As such, we must follow all relevant

laws and regulations regarding the marketing of our products,

services and the Walgreens brand. In addition, we must never

falsely represent any of our competitors’ products or services or

engage in any deceptive marketing practices.

I’m having trouble meeting my sales goals. I’ve tried

many selling techniques, but I still can’t meet the com-

pany’s expectations. My team leader said that we should

“do what it takes” to meet sales targets. My team leader

becomes eligible for incentives with sales success, and

team members earn rewards for sales results. I’ve heard

that some team members in other areas have been meet-

ing sales goals by overstating the benefits of our services

or issuing unauthorized discounts to offset costs for the

customer. I feel I’m on the verge of disciplinary action for

my lack of success in sales. What should I do?

You should not engage in any improper sales

practices to meet these goals. You also should never

misrepresent products or services to a customer or issue

unauthorized discounts. You have a number of alterna-

tives available to you. For instance, you can speak to your

colleagues or team leader for help in meeting your goals.

You can also review sales training or practice your use of

sales techniques, maybe with a team leader or colleague.

You should also report the rumors you have heard about

other team members using improper sales techniques

to the chief compliance officer or the company hotline.

8 2015

I often communicate with our healthcare providers bye-mail. If they request patient information that is privateand confidential, is it okay to send it electronically?

Patient information may be sent by e-mail to healthcareproviders, but only if the e-mail is encrypted. In somesituations, be sure the provider has signed any necessaryagreements to receive protected health information. Ifyou have questions as to when signed agreements arerequired, contact the chief compliance officer. In addition,send only the information requested.

We must never knowingly violate the intellectual property rights of

others. Those of us with marketing or advertising responsibilities

should be particularly careful when preparing advertising or

promotional materials that use the name, printed materials, or

trademarks of another company. As a general rule, we may not

make unauthorized copies of any copyrighted material. Further,

we may not install or distribute software products on company-

owned computers without an appropriate license.

In addition, you should not disclose the confidential information

or trade secrets of others, including your former employers (e,g.,

picture care plus data or balance rewards data). If anyone at

Walgreens asks or pressures you to do so, you should report

the matter to your direct team leadership, another member of

management or the chief compliance officer. Never use or share

any information divulged to you by a third party—whether inten-

tionally or unintentionally—unless you know it is not confidential

or a trade secret. If you are unsure of how to use information you

have received, contact your direct team leader, another member

of management or the chief compliance officer.

We uphold the competition and antitrust laws that applyto our workThroughout our history, Walgreens has been dedicated to robust

competition. However, we believe in competing solely on merit—

never through deceptive or dishonest practices. In this regard, we

must always be accurate and truthful in our dealings with suppliers

and other business partners, and we expect the same from them.

While we compete actively, we do not misrepresent, manipulate, or

conceal any material information to gain a competitive advantage.

We promote our products and services based on their high stan-

dards, and never by making disparaging or false allegations about

our competitors.

There are strict competition and antitrust laws in place to ensure

fair competitive business practices. Walgreens counts on each

of us to obey these laws. Specifically, we never discuss with

competitors any information about pricing, suppliers, promotional

strategies, territories or any other sensitive marketing information.

We never discuss or make agreements about boycotting third

parties or allocating markets or customers.


We expect our suppliers to uphold our valuesWe rely on our suppliers’ and other business partners’ integrity

in all our dealings, and we expect them to assure the safety and

performance of their products and services. We pursue legally

compliant ways to make the most reliable purchasing decisions

based on cost, product and quality, so that we can deliver quality

goods at competitive prices to our customers.

Walgreens develops lasting relationships with suppliers who meet

our high standards of business ethics. Our standing in the commu-

nities we serve is based on the trust that those communities place

with us. To maintain that trust and continue to deliver the best

products to our customers, we follow all company procurement

policies in our purchasing interactions. We will not purchase prod-

ucts from a supplier who uses involuntary labor, prison labor or

child labor. We respect all applicable laws establishing a minimum

age for employment to support the end of child labor worldwide

and we expect our suppliers to do the same.

Our company expects its vendors to comply with the standards

outlined in the Walgreens Vendor Responsibility Standards and

Supplier Code of Conduct. Any team member who becomes

aware of a supplier operating unethically must immediately report

the supplier to our chief compliance officer. If the report is verified,

Walgreens will notify the vendor and require that it take steps

to immediately comply with our standards. If the vendor fails

to comply with our standards, or its conduct or rehabilitation

efforts are not in Walgreens best interests, we will terminate

the business relationship.

We protect the private information and intellectual propertyof othersOur relationship with customers is one of our most valuable assets.

It is vital to our success as a company that we treat customers with

the highest amount of respect. As healthcare providers, our cus-

tomers entrust us with health information, which is protected under

state and federal law. It is essential that we keep this private data—

including names, addresses, dates of birth, social security numbers,

phone numbers, prescription histories and health condition—secure

and confidential consistent with company policy. It is important to

use good judgment when handling this type of data and to ensure

any disclosure of a customer’s protected health information to a

third party complies with company policy. Our customers value

our discretion with their legally protected information.


Our customers’ trust is one of our most valuableassets, and we are committed to maintainingthat confidence.

2015 9


If a competitor tries to engage you in a discussion on any of

the above-mentioned topics, even informally, you must end the

conversation immediately and report the incident to the chief

compliance officer. We should be especially mindful during trade

association meetings or conferences where we are likely to have

more frequent interactions with our competitors. Remember, we

must avoid even the appearance of unethical business practices.

Antitrust laws can be challenging to grasp, and violations carry

serious penalties—both civil and criminal—for the team members

involved and our company. If your job involves sales, marketing

or procurement, you must know and understand these laws as

they apply to your work. For further guidance, please contact

the chief compliance officer or [email protected].

DOs and DO NOTs of antitrust and competition laws:• Do NOT discuss pricing or the terms of our bid witha competitor.

• Do NOT agree with competitors to target certain customers,products, services or geographic territories.

• Do NOT agree to boycott a customer, supplier, licensoror licensee.

• Do NOT agree with a vendor on the prices at which aproduct will be resold to a third party.

• Do obtain the chief compliance officer’s review before:

– Communicating with our competitors or participating intrade association activity

– Teaming with our competitors

– Entering into joint bidding or supply arrangements orforming a joint venture

– Acquiring assets or voting securities

– Agreeing to contracts containing exclusivity provisions.

We obtain competitive information fairly

Remaining current on market practices and developments is

vital to the continued success of Walgreens. While we recognize

the importance of obtaining information we must only do so in

a lawful and ethical manner. This means we obtain information

only through publicly available resources. We also protect any

information provided to us in confidence by our suppliers and

other business partners.

We must not ask our colleagues to disclose any confidential

information about their previous employers. If we lawfully obtain

confidential information from suppliers or other business partners,

we must take care to protect it as we would our company’s own

proprietary data.

We work on government contracts and programs lawfully

and ethically

Many of our customers rely on our ability to provide the services

they need through government-backed healthcare programs such

as Medicare, Medicaid and other federal and state programs.

When working on potential or existing government contracts or

funded programs, it is critical that we adhere to all of the laws,

regulations and procedures that apply to these contracts and

programs. These rules are often much stricter and more complex

than those that govern our other contracts.

If your work involves government contracts, government-funded

programs, or complying with government program parameters,

you have a duty to familiarize yourself with the relevant laws and

regulations that affect your job. To seek help in doing so, contact

the chief compliance officer. Please note that violations of these

rules can result in substantial penalties, the loss of future govern-

ment contracts, exclusion from government funded programs

and even civil liability and/or criminal prosecution for the team

members involved and our company.

We maintain appropriate relationships with healthcare

professionals

Our relationships with healthcare professionals are heavily regu-

lated and the rules are strictly enforced. A healthcare professional

is any individual or entity, directly or indirectly involved in the deliv-

ery of healthcare who can purchase, prescribe, lease, recommend

or use our healthcare products or services. The federal and state

laws that govern paying, providing or offering anything of value to

healthcare professionals such as gifts, meals, entertainment or

grants are complex and highly regulated.

The consequences for failing to comply with these laws can result

in significant monetary and even criminal penalties. It is important

that you understand and comply with these laws and company

policy when dealing with healthcare professionals. If you have

questions or need assistance determining whether a particular

relationship is appropriate, contact the chief compliance officer.

A local physician hinted that if I made a donation

to his foundation, he would increase the number of

prescriptions directed to my location. What should I do?

Decline the physician’s offer and inform your team

leader or the chief compliance officer. Our relationships

with healthcare professionals prohibit us from making

improper payments that influence business decisions.

This prescriber is putting our company at risk by solicit-

ing for donations, and making this type of donation could

subject us to serious consequences.


A FOUNDATION OF TRUSTfor Our Company andOur Fellow Team Members

Be One

Be Real

Be Bold

Build Trust

Love Customers

Own ItLive It

2015 11


A FOUNDATION OF TRUST for Our Company and Our Fellow Team Members

We foster diversity and inclusion in our workplace

We believe fostering diversity and promoting inclusive hiring

practices in the workplace encourages a wider range of abilities

and experiences, and helps us attract the best talent possible.

Diversity helps inspire the innovation that drives our business and

helps enhance the ideas that provide our competitive advantage as

we serve consumers from all walks of life. Our hiring decisions are

based solely on merit. We never make any employment-related

decisions based upon a person’s race, color, gender, age, religion,

disability, sexual orientation, veteran status, marital status or any

other basis protected by law. Diversity and inclusion are key aspects

of Walgreens strong value system and culture, which have carried

us through more than a century of service to our communities.

We respect each other and do not tolerate harassment

By working for Walgreens, we are committed to treating each

other with respect. Each of us is responsible for ensuring that our

workplace is free from any type of harassment. Harassment is any

unwelcome conduct that creates an intimidating or offensive work

environment—whether it is of a sexual nature or not. Harassment

can include physical actions, spoken or written remarks and

pictures or videos. In any case, harassment is offensive and may

expose the individuals involved and Walgreens to legal liability.

Therefore, our company will not tolerate harassment of any kind.

If you experience or witness any act of discrimination or harassment,

you should report it immediately. You will not face retaliation for

making a report in good faith.

What is harassment?

It includes:

• Unwanted physical contact

• Display of offensive material

• Threat of dismissal or failure to promote based on sex,

race, age, color, national origin, disability, religion or

sexual orientation

• Conduct of a sexual, racial or other nature that unreasonably

interferes with a teammember’s work performance or creates

an intimidating, hostile or offensive working environment

• Bullying, humiliation or intimidation

• Threatened or actual violence

• Offensive jokes

• Abuse

We strive to create a safe and healthy work environment

Violence and threats of violence are prohibited. Walgreens will not

stand for any threatening behavior, even if made in a seemingly

joking fashion. In that regard, we must never bring any weapons

into the workplace.

Drugs and alcohol impair judgment and in the workplace can

affect everyone’s safety. You may not possess, distribute or

be under the influence of alcohol or drugs, including certain pre-

scription drugs, while on the job or while conducting company

business. If you have any questions or need assistance with a

substance abuse problem, please contact HR Shared Services

or the company hotline.

Certain safety laws and standards are in place to ensure each

of us enjoys a safe and healthy work environment. We all have

a responsibility to uphold these laws and to follow any safety

standards and guidelines specific to our jobs. We should always

report any concerns about misconduct or hazardous conditions

that may threaten the safety of our workplace. Our leadership

is committed to the safety, health, and well-being of our team

members, our business partners, and our customers.

I noticed activities that may be creating a safety and

environmental hazard, but it is not in my area, and I do

not want to get involved. I do not have to report it, do I?

This is not the best way to handle your concern.

Safety and the environment are every team member’s

“area.” Report your concern to your leadership. If you

are uncomfortable doing so, then you should contact

the chief compliance officer or the company hotline.

We work to protect our company’s assets

Our shareholders trust us to protect our company’s assets—both

physical and intangible. Our physical assets include company

records, computers, products, equipment and the like. We must be

considerate while utilizing these assets, and protect them at all times

from loss, damage, theft and misuse. Intangible assets include our

reputation, the Walgreens brand and any sensitive or confidential

information about our company. Your obligation to protect this

information continues even after your employment ends.

Our company’s intellectual property is an equally valuable asset.

“Intellectual property” includes copyrights, patents, trademarks,

trade secrets, logos and other intangible industrial or commercial

property. These creations are protected by law, and we are obli-

gated to protect them. Also, keep in mind that—to the extent

permitted by law—the rights to certain intellectual property are

assigned to Walgreens. This applies to any such materials we

create on our company’s time and expense or within the scope

of the duties we perform for Walgreens.

12 2015


We are also expected to protect the intellectual property of

our vendors and suppliers, which we may encounter during

the normal course of our business dealings. We are able to

provide top-quality products because we have cultivated strong

relationships with our vendors and suppliers. It is therefore

critical that we maintain those relationships by honoring our

vendors’ and suppliers’ proprietary information and protecting

it from unauthorized disclosure or misuse.

We safeguard each other’s personal information

In keeping true to our values of trust and integrity, Walgreens

strives to safeguard the private personal information of all

team members. During the course of our employment, we each

provide sensitive personal, medical and financial information to

our company. Additionally, some of us may have access to infor-

mation regarding our colleagues’ salaries, performance reviews,

disabilities, leaves of absence, prescription drug history, and

online purchases (i.e., Walgreens.com, drugstore.com).

We may only use such data for relevant and appropriate business

purposes. We must not share this information with anyone inside

or outside our company who does not need to know it. If your job

entails having access to this type of information, you must take

special precautions to keep the data private in accordance with

Walgreens policies and the law. You can be assured that our

company is committed to keeping our personal information

secure at all times, whether on paper or in electronic format.

I know that some of the information I work with is

confidential. Does this mean I can’t talk about it with

anyone, even other team members?

Confidential means that you should keep the infor-

mation secure. You should discuss such information

only with those who need to know about it for company

business purposes. If you have any questions about

who you can discuss the information with, you should

ask your team leadership.

We use our computer systems appropriately

While limited personal use of our computer and network systems

is acceptable, it should not detract from our work for Walgreens.

We should also never use our company computers or network

systems for inappropriate conduct, such as viewing obscene or

sexually explicit materials, spreading profanity or derogatory remarks

or communicating harassing or discriminatory statements.

Walgreens reserves the right to block access to inappropriate

sites. Please also be aware that our company may monitor all


data and communications to the extent permitted by local law.

Walgreens also retains the right to report any suspected or

actual violations of the law to the appropriate authorities.

We always need to use our computer and network systems

appropriately. This means composing e-mails and other electronic

communications professionally. All business communications may

later be reviewed and interpreted by other parties, so take care in

how you compose your thoughts because electronic messages

can be forwarded without your consent. In addition, we may not

post our company’s confidential information to Internet chat

rooms, message forums or any other public forum. It is important

to keep in mind that none of us should have any expectation of

privacy when using company computers, mobile devices, or

network systems.

Individual social networking and blogging

Walgreens family of companies recognizes that team members

may use social media to participate in discussions. If an individual

chooses to identify as a team member of the company or includes

other identifying information concerning the company while

participating in social media discussions, they must do so

within the guidelines of Walgreens policy, which can be found

on Walgreens intranet sites.

Nothing in the policy is intended to interfere with team members’

Section 7 rights under the National Labor Relations Act. However,

team members should be aware that the improper and inappropri-

ate use of social media can pose tremendous risks to Walgreens

family of companies, including:

• Disclosure of Walgreens family of companies confidential and

proprietary information

• Infringement of third-party intellectual property rights

• Harassment

• Privacy violations

• Potential damage to reputation and brand

Social media refers to the external online tools used to share

content, profiles, opinions and experiences. Social media tools

include, but are not limited to:

• Professional networking sites (e.g., LinkedIn)

• Social networking sites (e.g., Facebook, Tumblr)

• Video and photo sharing websites (e.g., YouTube)

• Micro-blogging sites (e.g., Twitter)

• Personal websites and blogs

• Forums and discussion boards (e.g.,Yahoo! Groups,

GoogleGroups, Yelp)

2015 13



By working forWalgreens, we arecommitted to treatingeach other with respect.


for Our Investors

Be One

Be Bold

Be Real

Build Trust

Love Customers

Own It

Live It

2015 15


A FOUNDATION OF TRUST for Our Investors

We keep honest, accurate financial books and records

We are committed to making accurate, timely, complete, fair and

clear disclosures in our reports to the U.S. Securities and Exchange

Commission and other regulatory bodies. It is our duty to ensure

that our business records reflect an honest and accurate picture

of our financial standing. For this reason, it is important to keep

accurate records of receipts, sales, expenses, corporate assets

and corporate liabilities. If you become aware of any accounting or

auditing irregularity, you have a duty to report it immediately so that

Walgreens can take the appropriate steps to resolve the matter.

Furthermore, each of us must cooperate with requests by auditors

or government investigators. If management, auditors or govern-

ment authorities request information, we must not conceal, alter or

destroy any of those requested records. Falsifying business records

can lead to termination and even criminal prosecution. If you become

aware or suspect that our company is under investigation, you are

required to involve the chief compliance officer immediately.

I worked quite a bit of overtime last week. My team

leader told me that I could miss a day of work this week

if I don’t record last week’s overtime on my timesheet.

This seems like a good solution because Walgreens

won’t have to pay me for overtime, and I can get some

extra time with my family. Is this okay?

No. You need to be paid for all time worked and to

ensure that all of the records you submit are complete

and accurate. Team leaders should never place pressure

on their team members to do otherwise. You should report

the situation to HR Shared Services or the company hotline.

We maintain records in compliance with the law and

company policy

There are many state and federal laws and regulations that govern

how we maintain company documents, including business, financial

and healthcare records. Each of us is responsible for ensuring

that company records are retained and disposed of in accordance

with all applicable laws and regulations, as well as licensing and

accreditation requirements. Records include information stored in

various formats, including paper, electronic, audio and video.

The length of time to retain records depends on the content and

type of record involved. We are each responsible for maintaining

records in compliance with the Walgreens Enterprise Records

Retention Schedule. If you are a person with knowledge of records

related to litigation, an investigation or other dispute, you may

receive a “Legal Hold Notice.” Each person who receives a Legal

Hold Notice is responsible for retaining original records related to the

dispute, as directed in the Legal Hold Notice. Failure to comply with

a Legal Hold Notice could result in disciplinary action up to and

including termination.

We avoid conflict of interest situations

To uphold our company’s reputation, we must be alert to any

situations that may create a conflict of interest, whether real or

perceived. A conflict of interest occurs when there is an actual or

apparent interference with our ability to make objective business

decisions because of our personal relationships or loyalties. Certain

situations are more likely to hinder our capabilities in making good

judgment calls, and we must take care to avoid those circum-

stances. If you have knowledge about a situation that may be a

conflict of interest, you should immediately disclose it to the chief

compliance officer or call the company hotline.

Conflicts of interest could include:

• Serving as an officer or director of or having ownership

interest in another company that does business or competes

with Walgreens

• Having a family member that has ownership interest in another

company that does business or competes with Walgreens

• Using Walgreens information for your own personal gain, to

benefit a family member or another company for which you serve

as an officer or director, or in which you have financial interest

• Participating in business transactions for your own personal

gain based on information or relationships developed as a

Walgreens team member

• Failing to disclose that you are closely related to someone,

such as a vendor or customer who has sought or is seeking

a financial relationship with Walgreens

• Having a romantic relationship with a team member that you

supervise or that is in your line of supervision

• Having a relationship with a commercial entity that administers

or delivers Medicare or Medicaid benefits which may include

producing, marketing, reselling, distributing, or providing

healthcare related products and/or services

If a team member wishes to engage in a transaction or activity,

which is, or potentially may be a conflict, the team member must

first make a full written disclosure to the chief compliance officer.

Following this procedure will ensure that conflict of interest

provisions are not violated.

Additional common conflict of interest situations are described on

the next page, as well as guidelines you should follow in dealing

with them. Please remember that these guidelines also apply to

members of your “immediate family.” This includes your spouse,

domestic partner, parents, children, siblings, in-laws and anyone

who resides in your home.

16 2015

Gifts and entertainment

My supplier offered me tickets to a concert. The

tickets have a face value of $200, however the supplier

indicates that he only paid $75 for the tickets. Can I

accept the tickets?

Acceptance of entertainment from a supplier or

vendor is only permissible if the entertainment is offered

for legitimate business purposes and the provider is in

attendance. The face value of the tickets could appear

excessive and thus would need to be approved by the

Walgreens chief compliance officer and appropriate

business unit Vice President.

Business gifts and entertainment on a modest scale are commonly

used to build goodwill and strengthen working relationships among

suppliers and other business associates. Providing or accepting

occasional meals, small company mementoes and tickets to

sporting and cultural events may be appropriate in certain circum-

stances. However, if offers of gifts or entertainment are frequent

or of substantial value, they may create the appearance of, or an

actual conflict of interest or illicit payment.

When deciding on the appropriateness of giving or receiving

a business gift or entertainment, consider:

• the value of the gift or entertainment (should be of minimal value)

• the sum of gifts or entertainment to or from an entity over

time (normally over a one year period)

• the suitability of the gift or entertainment given your position

at Walgreens

• the impact of the gift or entertainment on building positive

business relations with the recipient and

• how the gift or entertainment might look to an outsider

Team members must always report receipt/giving of gifts using the

gift and entertainment registry form, which can be found within the

policy and at WalNet> Company>Compliance Office>Policies).

Keep in mind that rules governing the giving of gifts, favors and

entertainment to any U.S. or foreign public government official

(or their family members), or healthcare providers/referral sources

(or their family members) are much stricter than those set forth

in this section. No gifts, favors, or entertainment can be given

to any domestic or foreign government official without prior

written approval of the chief compliance officer. Gifts to foreign

businesses cannot be made without prior notice and approval

by the chief compliance officer.

Additional information regarding gifts and entertainment can be

found in our Gift and Entertainment Policy. If your role involves

providing or receiving business gifts or entertainment in any


way, you should become familiar with this policy. If you have

any questions, please contact the chief compliance officer.

Doing business with friends and relatives

Another common conflict of interest can occur when doing

business with or while supervising family or friends. We are not

permitted to directly oversee immediate family members. If you

are put in such a situation, you should disclose it to your team

leader immediately so that reassignments can be made. In addi-

tion, you may not enter our company into a business relationship

with a friend or family member or a business owned or operated

by a friend or family member without the prior approval of the

chief compliance officer. You must avoid any scenario where

you stand to gain personally from Walgreens-related dealings

or where there may be any appearance of favoritism.

Outside positions

We may have outside business interests or employment, as long

as those interests do not interfere or conflict with our current

position and responsibilities for Walgreens. In general, this means

we may not work for or have a significant financial interest in a

competitor, supplier or customer. A conflict of interest may also

exist if any member of your immediate family is, or has ownership

interest in, a competitor, supplier or customer of the company.

We must immediately disclose any such situations to the chief

compliance officer.

You may not serve as a director, trustee or officer of another

company, or in a similar paid or unpaid position, other than

with Walgreens, without prior approval of the chief compliance

officer. This rule does not apply to political, non-profit or social

organizations, or to residential boards whose activities do not

conflict with our company’s interests.

You may join industry or trade associations with the approval

of your team leader, as long as you ensure that any related

activities are consistent with our company’s interests.

Some examples of possible conflicts of interest:

• A purchasing agent hires his brother-in-law to provide

vending services to the company lunch areas.

• A team member who is a member of a company employee

selection team fails to disclose that he is related to a job

candidate whom the company is considering for a position.

• A member of team leadership provides paid consulting

services on the weekend to a company customer or supplier.

• A team member works part time in the evening for a

company that makes a product that competes with the

products of his full time employer.

• A store team member has secondary employment as a

pharmacy technician at another retailer.


2015 17

Business opportunities

We may not accept business opportunities, commissions or

advantageous financial arrangements from a customer, supplier

or business partner of our company for our personal benefit.

In addition, we may not purchase the goods or services of our

company’s vendors for personal use on terms other than those

available to the general public or established by company policy.

If you become aware of any business opportunities in which

Walgreens might be interested, you are required to bring them

to the attention of your team leader and not take advantage of

those prospects for your personal gain.

We uphold insider trading laws

Walgreens expects all of its employees, directors and other insiders

to comply fully with applicable insider trading and securities laws.

While working for Walgreens, it is possible that you could become

aware of “material non-public” information about our company or

one of the companies we deal with. Information is considered

“material” if there is a substantial likelihood that a reasonable

shareholder would consider it important in determining whether

to buy, sell or hold, or engage in other transactions concerning,

Walgreens securities, or if it would be viewed as having signifi-

cantly altered the total mix of information available. Both positive

and negative information may be material. Examples of informa-

tion that may be material include: financial results, trends or

forecasts; potential mergers, acquisitions, divestitures or joint


ventures; and significant operational, regulatory, litigation, or

contractual developments. Information is “non-public” until it

has been widely distributed to the public and the public has

had time to absorb and evaluate it.

It is illegal to purchase or sell securities on the basis of material

non-public information. Until Walgreens has made this important

information about the company public, you must keep it confi-

dential and may not use it for your own personal gain. This applies

to stock, options or other securities of Walgreens or another com-

pany, as well as to transfers into or out of stock based retirement

plans. In the course of your job, you also may receive material non-

public information about other companies. You must also hold this

information confidential and may not trade in the securities of

other companies on the basis of it. You must also refrain from

disclosing material non-public information to others—including

friends and family—to use for their own financial benefit (known

as “tipping”). The consequences for violating insider-trading laws

are severe, and punishment may include fines and imprisonment,

as well as termination of employment. If your friends or family

members trade in securities while in possession of material non-

public information that you revealed to them, you are exposing

them and yourself to potential criminal and civil liability, even if

you do not personally take advantage of this information.

Walgreens has adopted an Insider Trading Policy, which is

applicable to all employees, directors and other insiders, and

which more fully sets forth your obligations regarding trading in

the securities of Walgreens and other companies. The Insider

Trading Policy is available on the Company’s intranet site. You

are required to become familiar with the policy and comply with

it. Employees at the divisional vice president level or above and

others who regularly have access to material non-public informa-

tion have additional obligations, including in some cases monthly

or quarterly “blackout periods” or an obligation to pre-clear

transactions with the legal team. These obligations—and more

information about trading generally—are set forth in the Insider

Trading Policy.

I work in an office where I am aware of the finaliza-

tion and negotiations of an acquisition; however, the

news has not been announced. My brother has heard

rumors and calls me to inquire about the news. What

should I do?

You should tell your brother that you are not permitted

to discuss the topic and what he is asking is illegal.


There are many laws and regulations that govern

how we maintain company documents, including

business, financial and healthcare records. Each

of us is responsible for ensuring that company

records are retained and disposed of in accor-

dance with all applicable laws and regulations, as

well as licensing and accreditation requirements.


for Our Communities

Be One

BeReal

Be Bold

Build Trust

Love CustomersOwn It

Live It

2015 19


A FOUNDATION OF TRUST for Our Communities

The auditors have requested a certain range of

files, and when I was scanning them, I realized there are

some documents missing. I don’t think the documents

are critical, but I know the auditors will look for them.

Can I recreate the missing documents for the audit?

No. Recreating records might be viewed as an

improper attempt to alter existing records. Speak to

your team leader about this situation so it can be

properly disclosed to the auditors.

If you have any questions or concerns involving the various health-

care laws that apply to your area of work, please consult the chief

compliance officer.

We work to build sustainable supply chains

We want to ensure that the goods and services we provide,

and the local and global suppliers that provide them, are treated

fairly and follow the same high standards that we have set for

ourselves. Therefore, we strive to only purchase from suppliers

who respect basic human rights and abide by the laws and regu-

lations wherever they operate. In addition, we strive to only work

with suppliers who maintain our company’s commitment to free-

dom of association and fair wages and hours for all workers and

who share our commitment to environmental and resource sus-

tainability. If you suspect or know of any of Walgreens suppliers

who do not act in accordance with our standards, you have a

duty to our company to report it.

We follow international trade laws

The United States has a number of laws controlling the importa-

tion of goods. For example, it is illegal to trade with certain

countries specified by the U.S. government or with individuals

and organizations against which the United States has imposed

embargoes. U.S. customs laws also place restrictions on the

importation of goods into the United States. If your job entails

trade with other countries, you need to be familiar with the

processes and requirements that apply to your work. Each of

us must be vigilant to ensure that we comply with trade laws and

regulations—both in the United States and in the countries where

we do business. Consequences for violations of these laws are

severe for both our company and the team members involved.

We follow healthcare laws

Because we are a healthcare provider, many of our services are

heavily regulated by various governmental and regulatory agencies.

We are all responsible for ensuring compliance with any clinical

and regulatory standards that apply to our work. In addition, as

a healthcare company, we are regulated by many laws that are

designed to prevent, detect and punish fraud, waste and abuse.

This includes laws and regulations such as the Federal Anti-

Kickback Statute, Stark Law, Federal False Claims Act and

Federal False Statements Act. In general, these laws seek to:

• Prevent any false or fraudulent claims to federal healthcare

programs, such as Medicare and Medicaid

• Ensure that decisions made by healthcare providers about

patient treatment or product use are not influenced by

personal gain

• Reduce the cost of healthcare to support patients and

promote the quality of healthcare services

We comply with the Federal False Claims Act

The Federal False Claims Act prohibits knowingly submitting a

false or fraudulent claim for payment to the federal government.

The Act is intended to reduce fraud, waste and abuse of federal

funds. Many states have enacted similar laws. The Act allows

individuals to file suit on behalf of the government against people

or businesses alleged to have committed fraud. The Act also

provides whistleblower protection for those who report violations.

Walgreens will never retaliate against team members who exercise

their rights under the Federal False Claims Act—or any other federal

or state anti-fraud laws. We must all comply with the Federal False

Claims Act, and any applicable state false claims acts. We must

never make false claims or statements to the Federal government

or to any state government.

Which of the following could be an example of filing aFalse Claim?

A. Billing for services that have not been performed.

B. Filing duplicate claims for the same service.

C. Using a diagnosis code from a previous claim.

D. All of the above.

Answer: D

20 2015


In addition, we are prohibited from engaging in or appearing to

support boycotts against certain countries or companies. We

are required by law to report any requests to participate in an

unsanctioned boycott to the U.S. government. For that reason,

if you believe you have received a boycott request or have any

questions about boycott activities, it is crucial that you notify

the chief compliance officer immediately.

As part of our company’s commitment to honesty, we also refuse

to offer, authorize, give or promise bribes or any questionable

payments. A bribe is providing something of value—including

gifts, cash, and favors—in order to influence a business decision.

In the United States, we are governed by and must follow the

Foreign Corrupt Practices Act (FCPA) and all other laws, treaties

and regulations that make it illegal to bribe government officials.


As a good corporate citizen, Walgreens takes pridethat its team members are leaders in our communities.Each of us is encouraged to be involved in community,volunteer and charitable activities.

2015 21



A government official is any officer or employee of a foreign

government or any department, agency, or of a public interna-

tional organization, or any person acting in an official capacity

for or on behalf of any such public international organization.

All state-owned enterprises and joint venture entities with a

state-owned interest would also fall within the definition.

The consequences for violating anti-bribery laws are severe,

including fines, termination and imprisonment. You are required

to report any government official who requests a bribe. Further,

if you suspect a fellow team member is engaging in unethical

or questionable conduct as it relates to bribery or kickbacks,

you are required to report the behavior to our chief compliance

officer immediately.

We do our part to protect the environment

As a responsible corporate citizen, our goal is to comply with all

relevant environmental laws, rules, and regulations in the places

where we do business. But beyond regulatory compliance, we are

committed to reducing the carbon footprint and environmental

impact of our retail and pharmacy sites, our distribution centers,

and our fleet through the use of energy efficient lighting, renewable

energy, smart logistics, and recycling. If you become aware of any

violation by the company of any environmental laws or regulations,

you should immediately notify the chief compliance officer or call

the company hotline.

I’m a company accountant and I read a news article

claiming that a Walgreens supplier is violating environ-

mental protection laws. I know we are committed to

protecting the environment, but my job responsibilities

don’t deal directly with our environmental programs. Is it

okay to put aside the article, because it’s likely someone

who deals with this issue directly also read the article?

By not contacting anyone about the article, you are

not violating any policy or law, but we all are responsible

for upholding our company’s values and commitments.

Instead of ignoring it, you should share the article with

your team leader or with the appropriate department so

that the matter can be investigated and the appropriate

action can be taken to protect Walgreens and our

commitment to the environment.

We support our local communities

As a good corporate citizen, Walgreens takes pride that its team

members are leaders in our communities. Each of us is encouraged

to be involved in community, volunteer and charitable activities.

In fact, there are many opportunities for participating in volunteer

efforts through your employment at our company. We should,

however, not identify ourselves as representatives of Walgreens

at community events without prior approval from a team leader.

Likewise, Walgreens encourages us to support the well-being of

our communities by participating in the political activities that

interest us. However, our involvement in political activities needs

to be on our own time and at our own expense. We will not be

reimbursed by the company for any political donations we make.

In addition, we must not use company time or resources while

participating in or contributing to political or charitable causes.

We should also never use our company’s name while taking part

in these activities, and no company funds, property, or services

are to be used to support any political party or candidate without

the prior approval of the chief compliance officer.

We may pool personal funds in the Walgreen company Political

Action Committee (PAC), and participation is voluntary. Through

the PAC, we can support candidates running for elected office

who share our company’s views on important public policy issues.

We must never use our position of authority to compel or pressure

another employee to participate in any political event or cause.

Please speak with your team leader if you need further guidance.

We communicate with a single voice

We have built a reputation of trust over the many years we have

been in business. A part of maintaining that trust means communi-

cating to our various stakeholders with a consistent and singular

voice. To ensure our corporate communications are reliable and

give a clear picture of the message we want to convey, any external

communications must be made only by authorized representatives

in accordance with Walgreens Disclosure Policy and Guidelines

available on the Company’s intranet site. This Disclosure Policy is

applicable to all employees and directors, and more fully sets forth

your obligations.

If you receive any inquiries from shareholders, analysts or other

securities market professionals, you should refer them to Investor

Relations. Any media requests should be directed to Corporate

Communications. If you have any further questions about whom

to refer an outside inquiry on any topic, you should contact the

chief compliance officer.

22 2015


Asking Questions and Raising Concerns

Good faith means that the report was made out of genuineconcern for the company or team members involved.

All statements contained in this Code are intended to reflectgeneral policies, principles, and procedures. They do not repre-sent contractual commitments on the part of the company,and may be changed at any time without notice. Without limitingthe generality of the foregoing, nothing in this Code should beconstrued to grant to any team member any right to continuedemployment or benefits under any employee benefit plan, program,or arrangement. Violations of this Code may result in disciplinaryactions, including, if appropriate, termination of employment.

If you want your voice to be heard, Walgreens needs to hear fromyou. If you ever feel your integrity or the integrity of the company isbeing compromised, talk with your team leader or the chief compli-ance office. By the same token, support those who raise concernsin good faith and cooperate with investigations when they happen.Educating yourself about the right choices is a big part of makingintegrity real every day.

As mentioned earlier, our Open Door Policy is a key part of ourculture. It is in place to encourage us to present ideas, raiseconcerns and ask questions—including those of a legal or ethicalnature—without fear of retaliation. You are encouraged to addresssituations first with your team leader, who is often best able toresolve the issue. You can avoid many potential violations bysimply asking for guidance before acting. In certain cases, you mayfeel uncomfortable discussing a matter with your team leader, oryou might be unable to reach a satisfactory solution. If this is thecase, you should speak with any other member of management,the chief compliance officer, HR Shared Services or you may callthe company hotline. You will never be punished or retaliatedagainst for making good faith use of our Open Door Policy.

Most concerns can be resolved by working with your teamleader, but you also have the option to report issues orconcerns by contacting:

• The chief compliance officer at 847-964-6519

• The compliance office mailbox at [email protected]

• The Walgreens hotline at 1-855-WAG-CODE (1-855-924-2633)

• HR Shared Services at 847-315-4455

• The compliance web portal (also accessible to team membersoutside the United States) at www.tnwgrc.com/walgreens.

Walgreens hotline is managed for Walgreens by an independentcompany that provides reporting services for hundreds of compa-nies worldwide. It is available 24 hours a day, seven days a week.You may remain anonymous, and whether or not you give yourname, your call will not be recorded. Information received by theindependent company is relayed to Walgreens compliance officefor further investigation and review as appropriate. The hotlinecan be used to ask a question, obtain guidance, or report anintegrity concern. This hotline is an option that is made availableto you to report your concerns if you feel uncomfortable doingso in person.

Remember: You have a responsibility to report unethicalbusiness conduct and known or suspected violations of theCode of Business Conduct or other Walgreens policy. An issuecannot be addressed unless it is brought to the proper person’sattention. Keep in mind that Walgreens does not tolerate retalia-tion against anyone who participates in an investigation, raisesa legal or ethical concern, or reports misconduct in good faith.

Walgreens Code of Business ConductDecision Guide

walgreens code of business conduct 2015 -...

Documents