ethics always true to Target.

Target Corporation Code of Ethics

enter > home 2 table of contents. a message from our CEO conducting business fairly prevent bribery ...... 23 defining ethics at Target follow international trade rules...... 24 our purpose, culture and values provide accurate financial information ...... 25 trade securities fairly and legally ...... 26 prevent laundering...... 27 putting ethics into action compete fairly ...... 28 how to use our Code ...... 6 reporting concerns ...... 7 safeguarding what’s ours how to comply with our Code ...... 8 secure our assets...... 30 making ethical choices ...... 9 protect non-public information ...... 31 respect and preserve intellectual property .. 32 working together manage records ...... 33 appreciate our diversity communicate responsibly ...... 34 and demonstrate inclusivity ...... 11 show respect at work ...... 12 promote health and safety ...... 13 caring for our world record time honestly...... 14 respect human rights ...... 36 engage responsibly in political activities ...... 37 maintaining trust care for our planet ...... 38 invest in our communities ...... 39 provide safe food and products ...... 16 select business partners carefully ...... 17 avoid conflicts of interest...... 18 summing it up be truthful in marketing and advertising...... 19 policy and resource look-up ...... 41 keep privacy in mind ...... 20 essential resources...... 44 manage financial products ...... 21

Code of Ethics table of contents home 3 a message from our CEO.

As a purpose-driven company, we know how important it is to defining ethics at Target. draw on our shared values and behaviors to bring that purpose to life. To help you do that each and every day, we’ve created a Target’s commitment to ethical standards is reflected in Code of Ethics that can help you make choices and decisions the way we conduct business and through our actions. that uphold our values and make good on the promises we As members, at any level, we must always make to our guests, team, stakeholders, communities and our consider the impact on our guests, team members, culture. stakeholders, community and the Target brand when making business decisions. No matter what you hold or where you work, it’s up to you to know and follow our Code. I encourage you to read it carefully We must each demonstrate a commitment to building and ask questions if something isn’t clear. Use it to identify a strong ethical culture by: anything that might violate our policies and report any concerns. Consider it an essential resource for making ethical choices – • Modeling Target’s culture and values through our decisions and actions the choices that matter to our guests, our communities and our Company. • Exhibiting honesty, respect and concern for others through every interaction

In our daily work, we’re building connections with the people • Understanding and following Target policies and procedures and communities we serve. Every good decision strengthens those bonds and gives us all a company we can be proud of • Complying with all laws every day. Thank you for making ethical decisions and staying • Seeking guidance when you have ethical questions true to our values. • Reporting any suspected violations or concerns

By holding ourselves and each other accountable to Sincerely, these standards, we deliver on our brand promises while deepening the trust of our guests, team members, stakeholders and communities.

Brian Cornell Chairman and Chief Executive Officer

Code of Ethics a message from our CEO defining ethics at Target home 4 our purpose, culture and values.

culture – care, grow and win together

We care by showing up for each other and treating one another with respect; we grow by investing in our people, their development and opportunities to reach their fullest potential; and we win together by leaning purpose into our collective power to accomplish more, striving to make things better for each other and our guests. to help all families values – how we bring our purpose to life discover the joy of Our values represent how we present ourselves to the world as Target team members. These values stand everyday life out at Target as the elements that make us distinctly who we are. They are deeply ingrained principles that guide our actions and our decisions.

inclusivity Our guests are the reason valuing diverse voices and approaches, being authentic and respectful and creating equitable Target exists. They place their experiences. trust in us as team members. connection building trusted relationships, collaborating across business functions and recognizing and celebrating In return, we are accountable progress. to them. drive doing what’s right for Target, our team and our guest(s), delivering results that matter, choosing progress over perfection and continually learning.

Code of Ethics our purpose, culture and values home 5 putting ethics into action. Target’s Code of Ethics, “the Code,” is your resource for making ethical decisions. how to use our Code ...... 6 reporting concerns ...... 7 how to comply with our Code ...... 8 making ethical choices ...... 9

Code of Ethics putting ethics into action home 6 how to use our Code.

why we need it each topic in the Code covers the Code applies to all team We make countless decisions at work our commitment members Our Board of Directors has its own separate each day. Our Code can help you navigate what we believe as an organization As a team member at , Code of Ethics within in our Corporate challenging situations and align your and why this topic is important “Target” or “our Company”, the Code Governance Guidelines that is similar to this decisions and behaviors with Target’s values. applies to you, no matter what job you Code but tailored to the responsibilities that The Code also helps you comply with hold. Whether you work in the stores, DCs, are unique to Board members. laws, Target policies and procedures. Any how it’s done headquarters, global offices or any other reference to “laws” in this Code includes any the way we work to fulfill Target location, you will be held accountable applicable external rules and regulations that our commitment for understanding and following the Code, apply to our business. Target policies, procedures and the laws that your rights as a team member apply to Target. You have rights as a team member under The Code covers a wide variety of situations in your daily work specific labor laws within each country. Nothing that you may encounter as a team member the actions you should take when the Code is violated in this Code is meant to interfere with those to help you understand how you’re expected to make ethical decisions If someone violates our policies, ignores rights, including which include, among other to handle them. Whenever you have a another team member’s misconduct or things, your right to communicate about: question, go to the Code first for guidance. pressures someone to violate our Code, the • or hours The Code can’t cover every possible work consider this impact could damage Target’s reputation, • Other terms and conditions of your situation, but it’s a good starting point and determine the impact to Target compromise guest and team member safety, the Ethics team is here to help you when before making decisions and jeopardize our financial health and decrease Nothing in this Code or any other Target you’re not sure about what to do. taking action guest trust. policy or agreement prohibits you from reporting any potential legal violations to As a team member, you are obligated to a government authority. what if follow the Code and report any violations common scenarios that may arise or potential violations. Any action Target All team members have the right to be and guidance on what to do takes will be prompt, fair and consistent and heard when they have an issue or a concern. may involve disciplinary action, including Target provides a variety of outlets for team immediate termination. If your actions violate members to express their concerns. Refer to policy spot the law, additional legal consequences may the Open Door Culture guidelines for more learn more about specific policies impact Target and result in civil penalties, information. or resources that impact your work criminal prosecution, fines and even jail time for you, other team members and leaders.

Code of Ethics putting ethics into action how to use our Code home 7 reporting concerns.

If you see or suspect any activity that violates our Code, policies or laws, you have a responsibility to promptly report in good faith using one of the reporting options. You also have a responsibility to report any suspected violations shared with you by another team member. What should I do if … Voice a concern, ask a What happens when There are times when you may need to question or report a violation. you contact Ethics? seek guidance on what action to take, I have questions or need guidance. as the Code cannot include every topic. Talk Talk to your leader or Human The Ethics team or third-party The Ethics team is here to help you make Resources partner. hotline representative creates a the right ethical decisions. I observe, experience or suspect unethical conduct. Email [email protected] report of your concern. The Ethics team will work to ensure the Every allegation received is appropriate are engaged to evaluate There is a problem that may put Visit www.TargetIntegrityHotline.com appropriately investigated and only any reported matters. Target, the team or our reputation the necessary partners are involved. in jeopardy. Call Integrity Hotline, anonymous option available 24 hours a day If your report is substantiated, Target U.S.: 1-800-541-6838 Target does not tolerate retaliation will act promptly and appropriately. India: 000-800-100-1657 of any kind against someone who The outcome may be kept Other non-U.S. locations: confidential. reports a concern in good faith. place a collect call to the U.S. at: 1-470-219-7116

Write Corporate Compliance & Ethics

Target Corporation Point your smartphone camera 1000 #3110 at this QR code, then tap the pop-up notification to go to the , MN 55402 Integrity Hotline website.

Code of Ethics putting ethics into action reporting concerns home 8 how to comply with our Code. Know your responsibilities.

As team members, you’re expected to: Leaders have additional responsibilities:

Live Target values Follow the law Be a good example Open your door Make sure every action you take Get to know the laws that apply Make ethical decisions, model Create a safe environment and is professional and ethical and that to Target and your job. Follow them Target values and demonstrate them in encourage team members to come your behaviors align with our values. consistently and ask questions everything you do. to you when they need to talk. Listen, if something isn’t clear. offer guidance, and follow-up. Contact [email protected] promptly to Understand and follow Set expectations report employee concerns or if the Code Stay alert and voice Talk openly about ethics in your you need additional guidance. Read the Code carefully and refer your concerns business and let team members know to it often, along with the policies Watch for potential violations of our that you expect them to make ethical that apply to your work. Code, our policies or any laws and business decisions. Take action voice your concerns immediately. Watch for misconduct. If you become aware of a violation, a potential Prioritize Target’s Talk up the Code violation or any other concern, Refer to the Code often and know voice your concerns immediately. business interests where to go for resources and answers Never retaliate or allow others to retaliate. Always look out for Target’s best to team member questions. interests when making business decisions or taking action.

Code of Ethics putting ethics into action how to comply with our Code home 9 making ethical choices.

consider the impact and risk to Target when making decisions ethical decision-making tool We must proactively identify and manage risks, always If you’re ever in a situation where the ethical choice isn’t clear, looking out for Target’s best interests. ask yourself: understand your impact Each decision you make has an impact on our Company. That’s why you must always be mindful of making decisions that reflect the very best in ourselves and our Company. Sometimes it’s hard to know “what is the right thing to do?” Is it legal? Is it in line with our values, So, consider the ethical decision-making tool before making policies and our Code? decisions or taking action.

? Does it enhance If my decision or action our reputation? was reported in the media, would it reflect positively on Target?

If you answered “no” to any of these questions, the answer is simple – “don’t do it” – and voice your concern if someone else is doing it. If you’re not sure, stop and reconsider the impact of your actions. Ask for advice by contacting [email protected] – that’s always the right choice.

Code of Ethics putting ethics into action making ethical choices home 10 working together. Together we build trust by taking personal accountability for our behaviors and actions. appreciate our diversity and demonstrate inclusivity ...... 11 show respect at work ...... 12 promote health and safety ...... 13 record time honestly...... 14

Code of Ethics working together home 11 appreciate our diversity and demonstrate inclusivity. We embrace diversity and strive to give everyone access to the same opportunities.

our commitment in your daily work consider this We value and support each other and work Strengthen inclusion acumen. By Discrimination based on protected status If you witness or experience behavior that to ensure a diverse, welcoming and inclusive strengthening your inclusion acumen, is illegal and it goes against everything you believe is discriminatory, always culture. At Target, we know every team you can help everyone around you feel Target stands for. That means we don’t remember that you can reach out to any member has something to contribute. When welcomed, respected and valued. discriminate against team members, leader with your concerns, even if that leader we are inclusive and do our best to create Examples of inclusion acumen include: applicants or business partners based is not your direct . You have multiple opportunities for everyone, we all benefit from • Seeking to understand the viewpoints on characteristics like: reporting options to voice your concerns. of others and advocating on their the richness of different perspectives and • Race, national • Marital status behalf enhanced points of view across our team. origin or ancestry • Creating a safe environment for the • Citizenship status • Color team where all perspectives are • Military or how it’s done welcome • Sex veteran status • Being aware of societal issues that can We aim to champion a more inclusive society • Genetic impact the team and our business • Pregnancy status what if and deliver inclusive guest experiences by information • Gender identity : I believe a job applicant may have embracing diversity and making Target an or characteristics Promote equal employment opportunities. or expression (or those of a been disqualified because of a inclusive and welcoming place to work. Our Q We believe that every individual deserves an • Religion or family member) disability, but since I wasn’t actually aspiration is to have a team that represents opportunity to succeed, so we follow laws that religious creed the spectrum of guest perspectives and a • Perceived involved in the hiring process, should promote equal employment opportunities. membership in a that supports and enables those • Age I just let this go? protected class perspectives to exist within our business • Medical condition objectives. That is what will help us deliver or disability • Any other : No, you shouldn’t. If discrimination did characteristic on behalf of our guests. occur, it could violate the law and our • Sexual orientation protected by A applicable laws commitment to . At Target, embracing diversity means • Gender identity Voice your concerns immediately. understanding and recognizing that each of or expression us is unique and our dimensions of difference Voice your concerns. If you ever experience, are one of our greatest strengths. Inclusion policy spot is about creating an environment where see or suspect behavior that violates our commitment to inclusion or equality, don’t Equal Employment Opportunity and everyone feels welcome, valued and Harassment-Free Workplace Policy respected. It means that all individuals enjoy ignore it. Voice your concerns immediately a sense of belonging and level of support so we can take action to protect our guests, that allows them to do their best work. each other, and our workplace.

Code of Ethics working together appreciate our diversity and demonstrate inclusivity home 12 show respect at work. Target believes that each individual deserves respect and a workplace that’s free from harassment.

our commitment in your daily work Harassment based on protected status in Recognize signs of harassment. When Help stop bullying. Sometimes harassment can any form, is illegal and will not be tolerated. behavior interferes with someone’s work or involve bullying or persistent mistreatment that It’s your responsibility as a team member to creates a hostile or offensive environment, threatens someone’s physical or emotional well- prevent any type of harassment at Target. it may be harassment, particularly if it’s being. Bullying can be targeted at a single person Examples of harassment include, but are based on a person’s race, color, sex, gender, or a group and could involve singling someone out not limited to, intimidation, bullying, stalking, national origin, citizenship status, religion, age, for ridicule, exclusion or other harmful treatment. verbal or physical aggression, harassment or disability, sexual orientation, gender identity or coercion. expression, genetic information or any other Stay alert for violence. Target has a Violence- protected class. Harassment can take a variety Free Workplace Policy and prohibits any acts or Harassment and other intimidating or abusive of forms and can be visual, verbal, physical or threats related to violence. behavior can do widespread damage, harming sexual in nature. those who are targeted and our work Voice your concerns. If you have seen, heard or what if environment. That is why we won’t tolerate Stay alert for . This type experienced, harassing or intimidating behavior, : A coworker often insults me, then turns harassment by anyone at Target and work of harassment includes asking someone out don’t let it continue – you have a responsibility Q around and says, “Just kidding.” This has to ensure that everyone feels comfortable repeatedly, sexual advances or requests for to report your concerns. Voice your been going on for a long time, and it’s and respected at work. sexual favors, inappropriate touching, sharing concerns immediately. really upsetting me. Am I overreacting if of sexual materials/jokes, continuing to make I voice my concerns? sexual advances after being refused or any how it’s done other inappropriate verbal or physical conduct. consider this : No, you’re not. Harassment can be a One of the best ways to prevent harassment Sexual harassment can occur unintentionally, Harassment takes many forms and might matter of perception. If it’s hurtful to is through awareness – team members so be aware of your own behavior. A look like: you, it shouldn’t be tolerated, and we watching out for each other and using care in • Jokes, slurs or gestures need to know about it. Voice your their own interactions. Treat each person you concerns immediately. encounter with respect and fairness, including: • Threats or intimidation • Coworkers • Stalking • Leaders • Sharing offensive material • Business partners • Coercion policy spot • Guests Equal Employment Opportunity and Harassment-Free Workplace Policy

Violence-Free Workplace Policy

Code of Ethics working together show respect at work home 13 promote health and safety. We look out for each other and do our part to maintain a safe, healthy and secure environment.

our commitment in your daily work what if We want to maintain a safe and secure Prevent substance use. Working under the Stay alert for violence. We don’t permit team : While unloading the trailer a few pallets work environment for our team members, influence of drugs or alcohol is risky – for you members to possess weapons of any kind in Q and carts are pulled into aisle contractors and business partners and a and everyone else. The use, consumption, our workplace, and we won’t tolerate threatening to give the team more room in the safe shopping environment for our guests. or possession of any drug or controlled behavior against any team member or guest. backroom. You just learned that leaving This requires each team member to commit substance that isn’t used or obtained legally Target has a Violence-Free Workplace Policy anything in the fire aisle is a violation of to being a safety advocate at all times (including prescription drugs that have been and prohibits any acts or threats related to OSHA, fire code and Target policy, but and to follow all laws, safety procedures prescribed to someone else) is prohibited. violence. If you ever see or suspect harmful the items will only be in the aisle a short and the Occupational Safety and Health Always keep a clear head and don’t bring behavior or weapons, immediately contact one time, and team members will be nearby Administration (OSHA) standards. these substances into our workplace. Don’t the following: to remove them quickly if needed. Is this try to work if your judgment or abilities • Your leader something I should report? are impaired (even by legally-obtained • Human Resources partner how it’s done prescription drugs). Voice your concerns • Corporate Security (HQ) : Yes. Remove the items from the fire When you stay alert and follow our safety immediately if you become aware of • Assets Protection (Stores/DCs) aisle immediately and remind leaders procedures, you’re better able to protect substance abuse in the workplace. A and team members that “nothing in yourself, your coworkers and our guests. Store and team members. Be sure to reference Recognize your responsibility to help maintain Additionally, Target maintains a tobacco-free the Stores and Distribution Centers Emergency the fire aisle” means just that – even a safe and healthy workplace and take action workplace, so tobacco in any form (including Procedures Flipchart often to ensure you are if items are there only “temporarily.” when potentially unsafe situations come up. electronic cigarettes) is prohibited outside of prepared to respond to any of situations, Voice your concerns immediately. designated areas. including assault and active shooter scenarios.

Follow safety rules. Our health and safety policy spot programs and procedures are here for you, consider this Safety Policy so follow these closely, with no exceptions Injuries can happen to anyone and can be and no short-cuts. Use personal protective Violence-Free Workplace Policy life-altering events that could affect what equipment (PPE) as required, and report you, your team and our guests are able to Drug, Alcohol, Tobacco-Free incidents, injuries and near misses right away. do at work, home or at play. Always follow Workplace Policy Talk to your leader if you become aware of a safety best practices to: safety hazard or unsafe behavior, so it can be Visitor Policy addressed immediately. • Call out and resolve hazards • Act in a safe manner Help make sure that you, your team and our guests leave each of our locations safely. Code of Ethics working together promote health and safety home 14 record time honestly. We value our team members and compensate them for all time worked.

our commitment in your daily work consider this Target follows all employment laws, including Don’t work off the clock. It is illegal and Working off the clock happens when someone: those involving wages earned and hours against Target’s policy for non-exempt or • Starts work before punching in worked. Violating these laws goes against our hourly team members to work (or be paid for • Works during a meal or rest values. It’s not just a legal issue – it’s an issue work) outside of scheduled work time. This period of what’s right. is considered “working off the clock” and is • Works or is asked to work after illegal. If you lead a team, make sure non- clocking out exempt team members are provided time to how it’s done take required duty-free meal periods and rest Being paid for all time worked is our promise breaks and account for all of the time they’ve to our team members, but to make sure it worked. happens, we depend on hourly (non-exempt) team members to record the time they work Record responsibly. If you are a non-exempt what if honestly and accurately and follow our or hourly team member, accurately record : I am a non-exempt team member and requirements for meals and break periods. the time you start and stop work, and submit a punch correction if you missed recording Q on a busy day, my leader has asked your time. Only record your own time – never me to work an extra half hour without record a coworker’s time in or out under any recording the time. I really don’t mind, circumstances. If you see an error on your but is this OK? paycheck, talk to your leader right away, and voice your concerns immediately about : No, it’s not. Your leader is prohibited and hour issues. A from asking or requiring you to work outside your regular hours or to be Submit time off. Promptly submit actual time dishonest with your time record. off honestly and accurately. Voice your concerns immediately.

policy spot Team Member Handbooks

Code of Ethics working together record time honestly home 15 maintaining trust. The everyday choices we make matter to those we work with and our guests. provide safe food and products ...... 16 select business partners carefully ...... 17 avoid conflicts of interest ...... 18 be truthful in marketing and advertising ...... 19 keep privacy in mind ...... 20 manage financial products ...... 21

Code of Ethics maintaining trust home 16 provide safe food and products. We are committed to providing our guests with safe, reliable and quality products.

our commitment in your daily work consider this Our guests expect the products they purchase Monitor business partners. If you work with If you are a leader, ensure proper . If your job impacts product or food safety from Target, regardless of brand, to function our business partners, ensure they have the Make sure any team member who handles or quality, understand and follow: properly and be safe to consume or use. expertise, experience and capacity to provide food receives the proper training. If you see • All applicable laws Anything less could harm guests, damage our the type of products we are purchasing from anyone, including a team member, leader or • Applicable product safety standards reputation and jeopardize guest trust. We’re them. Ask questions about what product vendor compromising our safety or cleanliness • Internal compliance requirements committed to protecting our reputation for quality and safety programs they have in place. standards, don’t ignore it. Voice your concerns • Vendor risk management policies quality and safety by setting high expectations Seek guidance from the appropriate teams to immediately. for ourselves and our business partners. understand all applicable requirements. Know how to handle product removals. Insist on safe products. We expect our Issues with products may arise and pose a risk how it’s done products to comply with all applicable product to our guests and Target’s reputation. If this It’s up to team members to take pride in laws. Make sure the business partners we work happens, the Product Investigations and Removal what if our Company and the products we offer by with are aware of compliance requirements and (PIR) team within Product Safety and Quality initiating conversations with business partners Target requirements to ensure that we offer safe, Assurance (PSQA) for General Merchandise : I noticed a team member who was in to ensure they understand and comply with all reliable and quality products. Seek guidance or the Food and Essentials Safety and Quality Q a hurry to stock produce. They finished applicable laws and meet safety and product from the appropriate teams so you understand Assurance (FESQA) team for Food and Essentials eating their lunch, then immediately quality standards. all applicable requirements before any product will investigate and may work with stores went out to the floor and started reaches our guests. and distribution centers to execute a market handling the fruit they were stocking. Is withdrawal or consumer level recall. Promptly and this OK? Insist on safe food. Our Distribution Centers, carefully follow instructions to quickly stop sale Import Warehouses and Stores must comply and remove product from the shelves and supply : No, it isn’t. Personal hygiene is critical with all applicable health and food safety laws chain. The authorized teams may notify guests of A when it comes to food safety, including and standards with no exceptions. Make sure a product safety issue. hand washing after touching your face, they are clean, sanitary and well-maintained. hair, clothing or equipment. Voice your You should also understand and follow all safe concerns immediately. food handling procedures. Food and beverages for humans or animals should not be offered for sale past their expiration dates. Perishable foods should be stored, transported and displayed at the proper temperatures.

Code of Ethics maintaining trust provide safe food and products home 17 select business partners carefully. We are committed to doing business ethically and legally and seek to work with business partners who share the same commitment.

our commitment in your daily work what if The actions of any business partner (including Choose wisely. If you’re responsible for a Stay involved. If you work with business : I visited a third-party work site recently and vendors, suppliers, third-party sellers, business partner relationship, make your partners, initiate conversations to confirm Q heard my point-of-contact instructing their manufacturers, contractors, subcontractors, selections carefully by weighing criteria they understand the importance of complying employees to “stay until the work is done.” locations and their agents) who work with such as ethics, quality, service, price, with the laws that apply to their products Their comments raised concerns that they us, or on our behalf, may have a direct effect reputation, availability, experience, equity or services and align to our commitments. may be violating wage and hour laws. Do I on our reputation. There’s a lot at stake: an and inclusion. Monitor their performance under their contract have a responsibility to say something? unethical act, breach of trust or a law violation to ensure they are meeting their obligations. If can have serious consequences for us. So, we Set the standard. All business partners you see or suspect any activity that could put : Yes. We hold our business partners take care in choosing our business partners. must follow our Vendor Code of Conduct our Company or our guests at risk, voice your accountable to our high standards and and Standards of Vendor Engagement concerns immediately. A expect them to follow the law. Target does (SOVE), which describes what we not tolerate illegal employment practices. how it’s done expect from them. Examples of these Take note of the situation and voice your We rely on team members to choose and expectations include, but are not limited to: consider this concerns immediately. manage business partners wisely. This • Meeting our quality, compliance and includes monitoring each business partner security standards There is information throughout our Code throughout the business relationship life • Complying with all laws and Target that speaks to our relationships with cycle beginning with proper selection and policies applicable to their business business partners. If you work with business policy spot in accordance with our Vendor and products partners, make sure you understand what’s Vendor Code of Conduct Risk Management Policy. • Maintaining a safe and healthy required by type of business partner and workplace initiate conversations with your partners Standards of Vendor Engagement (SOVE) • Treating workers fairly and not to ensure they understand the following Vendor Risk Management Policy tolerating discrimination or requirements: harassment • Promote product safety Conflicts of Interest Policy • Prohibiting underage or child labor • Protect third-party information Anti-Bribery Policy • Prohibiting the use of forced labor • Avoid conflicts of interest or in their • Uphold ethical business practices operations and within the operations of their suppliers

Code of Ethics maintaining trust select business partners carefully home 18 avoid conflicts of interest. We have interests and relationships outside of work, but we act in Target’s best interest and avoid even the appearance of a conflict of interest.

our commitment what if We never allow our personal interests to Know when to say “No.” Offers of gifts, • A business partner offering to pay for : A business partner that works with Target impact the business decisions we make as entertainment or accommodations that do a meal, gift or entertainment that does asked if I would be willing to do a little not further a legitimate business purpose Q Target team members. When our outside not further a legitimate business purpose or or exceeds our policy guidelines work for them “on the side.” Is this OK? activities conflict or even appear to conflict don’t comply with our policies can also create with our responsibilities as a Target team a conflict of interest and cause others to • Investing in a company that competes : It depends. If the work is unrelated to member, we avoid and disclose any activity question your objectivity. Know what’s allowed with, does business with or seeks to do business with Target A Target’s business, it may be OK. If the work that could be considered a conflict of interest. – and what isn’t – and turn down anything that competes with our business, or interferes is, or could be perceived as a violation of our • Transacting business on behalf of Target with your ability to do your job or could policy. with a company in which you or a family how it’s done member has a substantial financial interest influence your judgment, you should not accept it. It is also a conflict if you The best way to avoid a conflict of interest Consider your influence. Never misuse the • Using your position or authority at are responsible for managing or making is to know and avoid the types of situations authority of your position for personal benefit. Target, or company property, resources or information, for personal gain instead of decisions about that business relationship where conflicts typically arise between Your role should never be used to acquire putting Target first on behalf of Target. The best course of personal and business interests and anything of value or pressure a business action is to contact [email protected] and relationships. Seek guidance immediately if partner for personal gain. • A family member performing services for you see, hear or suspect a potential conflict. a current or prospective business partner ask for guidance before proceeding. or for an entity that competes with Target Always prioritize Target’s business interests Disclose potential conflicts. Despite your when making decisions. efforts, conflicts of interest can still arise, • Becoming a member of an outside board even if you’re careful to avoid them. Promptly of directors or advisory board disclose any actual, potential or perceived policy spot in your daily work conflict to your leader, Human Resources consider this Conflicts of Interest Policy Be alert to the activities of family members. partner or the Ethics team so it can be Not sure if there’s a conflict of interest? Conflicts of Interest Business Conflict of interest situations extend beyond addressed and resolved. Depending on the Ask yourself: Amenities Table your own activities – they also apply to you hold, you may be required to complete • Could it affect my objectivity? activities of your family members. Always an annual Conflicts of Interest Disclosure Travel and Expense Policy disclose any personal or family relationships Statement. • Could it influence the decisions I make on behalf of Target? or activities that have the potential to influence decisions you make on the job. If you’re not Be aware. It’s not possible to list every • Could an outside observer view it as a possible conflict? sure if a particular situation creates a conflict, situation that could pose a conflict, but here always ask for guidance by contacting are some that often arise: If the answer to any question is “yes,” or [email protected]. “I’m not sure,” seek guidance.

Code of Ethics maintaining trust avoid conflicts of interest home 19 be truthful in marketing and advertising. In promoting our business, we communicate accurately and honestly.

our commitment what if Our guests make decisions about where Always make sure that product attributes : My team has been working on an they’ll shop and what they’ll buy based accurately represent the quality, features and Q advertising campaign for a new apparel on what they see in stores, online or what availability of our products. line, and we want to generate excitement they learn about us. We have an obligation about it. Can we suggest that wearing in our promotions, advertising and guest Honor guest expectations. We strive to have the gear will help burn calories as long advertised merchandise available for guests communications to follow all laws and as we don’t say it directly? provide guests with accurate information. to buy. If a product doesn’t live up to guest expectations, we honor our return policy. : No. All claims must be accurate and how it’s done A comply with any applicable laws, and we must have substantiation from our Honesty really is the best policy. When you consider this vendor or supplier for the claims before communicate clearly and accurately about Laws related to truth-in-advertising and we make the claim in our ads – whether our products, you keep our guests happy marketing apply on our product packaging the claim is expressed or implied. and promote Target’s brand. You also and hangtags, and anywhere we place an ad. preserve the reputation we’ve earned as Examples include, but are not limited to: a Company that does what’s right. • A newspaper or magazine • The internet in your daily work • Postal mail Maintain trust. If your work involves • Billboards or buses promotions, advertising or guest Always know and comply with the law. communications, observe responsible advertising practices and comply with all applicable laws. Make sure that any claims you make: • Are true • Have been adequately substantiated • Accurately state prices

Code of Ethics maintaining trust be truthful in marketing and advertising home 20 keep privacy in mind. We are committed to handling personal information responsibly.

our commitment what if As part of our day-to-day operations, we Examples of personal information include, • Use guest personal information only for : I am on a marketing team and would come into contact with the personal but are not limited to: purposes disclosed in the applicable Q like to email a merchandise coupon to information of our guests, team members • Name privacy policies or consent form a list of guests who have purchased an and business partners. We understand the • Address • Use team member personal information item on Target.com. What should I do? critical obligation we have to collect, use and • Mobile device ID only for employment-related purposes, share this information in an appropriate way • Date of birth unless you receive consent from the team : If you don’t normally send guest emails and follow the laws that prevent improper member to use it for another purpose • Social security number A as part of your work, contact the Privacy disclosure or use. • Credit card number • Keep personal information only to fulfill the team at [email protected] before you • Email address reasonable business purposes for which it proceed. Marketing emails are subject to federal law that, if violated, may have how it’s done • Phone number was collected or for legal compliance serious legal and reputational consequences We expect you to protect the privacy of • Destroy personal information when no for Target. They must have specific guests, team members and business partners, Handle personal information responsibly. longer needed or remove details that could content and include a link to unsubscribe. and take precautions to keep all personal Use personal information only for legitimate identify someone Additionally, marketing email lists must information safe. Follow all applicable data business purposes. Responsible handling privacy laws and our Enterprise policies of personal information includes, but is not come from Target’s Email Marketing for collecting, storing, using, sharing and limited to: Universe and exclude guests who have • Share personal information only with consider this disposing of personal information. opted out of email marketing. others authorized to see it and who Understand where you encounter data in have a business need to know it your role and help protect guest and team in your daily work • Share personal information externally member personal information by: policy spot only if you have appropriate contract Be able to recognize personal information. • Recognizing personal information and Privacy Compliance Policy language in place or if required following all laws to protect it Personal information is any information that or permitted by law alone, or in combination with other data, • Handling and protecting personal Target Privacy Policy can identify an individual, either directly • Collect, use and share the minimum information with care amount of personal information or indirectly. necessary for your project • Using personal information only for legitimate business purposes

Code of Ethics maintaining trust keep privacy in mind home 21 manage financial products. We want our guests to have a good experience using our guest services and financial products.

our commitment in your daily work consider this what if We comply with the laws that relate to our Stay up to date. If you are involved in Laws are far-reaching and govern our work. : A coworker told me if they haven’t received consumer financial products, the way we creating, marketing or managing any of Q a RedCard™ application in a while, they offer financial products and how we manage our financial products (such as the Target® Financial Services team members reapply with their own information to help guest data. Each guest interaction gives us the Mastercard®, Target Credit Card™, Target must understand how we: increase the store’s RedCard™ application opportunity to build and deepen guest trust, Debit Card™, Target GiftCard™ or prepaid • Advertise our financial products and totals. What should I do? so we take great care in offering payment cards offered by other issuers), complete disclose product terms • Manage cardholder accounts and options that work for our guests and handle your required training and follow all : You should use one of the ethics reporting all personal information responsibly to protect laws and policies that apply to these collect on past-due balances A options to voice your concern. Entering that trust. payment responsibilities. applications in your own name or in Store team members must understand someone else’s name is a violation of Handle guest personal information with the following: the RedCard Sales Practices Policy. how it’s done care. If you manage financial products, • The proper way to open a Target Each of us has an obligation to follow the laws payment terms or collect data, there are RedCard™ account for a guest: only with their knowledge and consent that relate to how we manage and promote many laws you need to follow to protect our financial products, disclose product terms guests and lawfully manage our financial • How to display Target GiftCards™ and policy spot prepaid cards and collect on past-due payments. We also business. It is up to you to secure guest data RedCard Sales Practices Policy • Follow all (POS) have a responsibility to safeguard all personal by following all applicable laws, policies and prompts (refer to Target’s Anti- Anti-Money Laundering Policy procedures, as this is a critical component of information that our guests share with us. Money Laundering Policy for more managing our financial products. information) TD Bank Privacy Policy for Target Credit Card We count on you to know what’s required and to ask questions when you don’t know Target Debit Card Privacy Policy what is required.

Code of Ethics maintaining trust manage financial products home 22 conducting business fairly. Our everyday actions focus on our honesty and accountability in our work.

prevent bribery ...... 23 follow international trade rules ...... 24 provide accurate financial information ...... 25 trade securities fairly and legally ...... 26 prevent money laundering ...... 27 compete fairly ...... 28

Code of Ethics conducting business fairly home 23 prevent bribery. We work honestly, without resorting to bribery in any area of our business.

our commitment what if There’s only one way we win in business – Get to know the law. Bribery laws around Use extra care with government officials. : I would like to pay for a government by acting ethically. We neither rely upon nor the world, including the U.S. Foreign Corrupt If you work with government officials or hire Q official’s meal. Can I do that? tolerate unethical or illegal business practices. Practices Act (FCPA), apply to our business. a business partner to work with government This activity damages our Company and the In addition to prohibiting bribery, the FCPA officials on Target’s behalf, make sure you : Generally, no. However, if the meal serves communities where we operate. requires companies to keep accurate books understand your responsibilities for ensuring A a permissible business purpose, is modest and records and maintain effective financial compliance with Target’s Anti-Bribery Policy. and customary in nature and does not controls. Ask for guidance if you need help violate any applicable law, you may seek how it’s done understanding how to comply with these laws approval from the Vice President of Ethics by contacting [email protected]. We comply with all anti-bribery laws. You by emailing [email protected]. Consult the may never authorize, offer or pay a bribe consider this Anti-Bribery Policy for additional details. to a government official. You must watch Be vigilant. Work with the Compliance team business partners closely to make sure or the Vendor Risk Management team to Someone in another country might tell you they don’t pay bribes. complete the required due diligence process a bribe is customary there. It may seem like prior to using any vendor that will be interacting the easiest way to get something done, but policy spot with government officials on Target’s behalf. it’s always wrong. Don’t ever pay it or allow Anti-Bribery Policy in your daily work Closely monitor the activities of all business anyone else to pay it. Vendor Risk Management Policy Remember, a bribe can take many forms. partners, even after they are hired. Voice your A bribe can be anything of value. Examples concerns immediately if you suspect a bribe. include, but are not limited to: • Cash, a or merchandise • A meal, gift or entertainment • Travel • A charitable or political contribution • An offer of employment or an

Code of Ethics conducting business fairly prevent bribery home 24 follow international trade rules. We import goods from around the world and follow the rules that apply.

our commitment in your daily work consider this As an importer of significant size, Target is Respect trade regulations. There may Do your due diligence. Remember that third Conducting business across borders is committed to following all trade laws that be times when it is unclear what laws, party business partners in the supply chain complex and involves many laws enforced apply to our business. International trade customs and practices govern a particular represent us, and if they violate the law, Target by numerous agencies, which are often rules regulate where, how and with whom we international trade transaction. If questions or could be held responsible. If you work with subject to change. If you have responsibilities can conduct business across borders. We potential conflicts arise and you’re not sure business partners in the supply chain, monitor for import compliance: follow these rules to comply with the law, to how to proceed, always ask for guidance by their performance and never overlook or ignore • Complete all required avoid incurring penalties or sanctions, and to contacting [email protected]. If you have any concerns that could indicate unlawful or • Seek help if you have any questions preserve Target’s status as a trusted trader. reason to believe that a supply chain business unethical activity. by contacting [email protected] We strive to maintain positive relationships partner is violating an applicable law, voice with the U.S. government agencies that have your concerns immediately. If you work with merchandise business oversight of international trade. partners, initiate conversations to ensure Comply with government sanctions. We don’t your partners can validate that all product conduct business with countries or entities that information they supply is complete, how it’s done are subject to trade embargoes or economic accurate and sufficient to satisfy applicable what if If your work in the supply chain involves sanctions, and we don’t participate in or trade law requirements. : After determining the proper duty international trade compliance, we expect promote boycotts that the U.S. government classification for a new import item with you to know, understand and follow the laws doesn’t support. If you work in the supply chain Q an origin of , the classification that apply to your work and the movement of and uncover or hear about any circumstances our goods. Initiate discussions to understand that potentially violate those commitments, specialist informs the Sourcing Manager how your internal and external supply voice your concerns immediately. (SM) that the product is subject to anti- chain partners are also complying with the dumping duties at a rate of 250%. The SM international trade laws that apply to their shares this information with the vendor, business and operations. who encourages the use of Taiwan as the country of origin to evade the additional duties. How should the SM proceed?

: The SM should inform the business A partner that the proposal is illegal and unethical. The SM should then escalate the issue to their manager or voice any concerns immediately.

Code of Ethics conducting business fairly follow international trade rules home 25 provide accurate financial information. We present an honest and accurate financial image of our business.

our commitment in your daily work consider this The U.S. Securities and Exchange Commission Insist on accuracy. Always record information Examples of financial records include, but are and other governing bodies have strict rules such as costs, expenses, time records and not limited to: about the accuracy of our financial statements contracts accurately. Follow our procedures • Payroll records and disclosures and the strength of our and never falsify a record or transaction, • Purchase orders or invoices internal controls over financial reporting. Our including those required by regulatory • Expense reports financial and operational records must remain authorities or auditors. Save supporting • Sales or inventory data accurate, so we can make sound business documentation in accordance with our records • Regulatory filings decisions, keep our operations running management procedures and obtain any efficiently and meet our goals and obligations. needed approvals before submitting complete and accurate expenses for reimbursement or making payments on our behalf. how it’s done As team members, we have an obligation Review team member expenses. If you are to follow all internal control procedures to a leader, you are responsible for reviewing all what if maintain our financial records – this includes expenses submitted by your team members : I work in accounting and recently submitting an expense report, reviewing or before approving expenses to ensure they are Q noticed some odd invoices from a approving financials and handling any other accurate and truthful. contractor. Every time they come in business record. Accurate recordkeeping the same coworker always says they’ll helps us provide complete, accurate, timely Know your responsibilities. Keep in mind handle it. Could this be a warning sign and understandable information in our public that, our internal audit team and external of record falsification? disclosures. auditors periodically test our internal controls and the accuracy of our financial statements : Yes, it could be. If you suspect invoices and disclosures. It is your responsibility to are being paid to an unauthorized know and follow all accounting standards for A organization, person or team member, your area. If anyone ever asks you to falsify voice your concerns immediately. a financial record, or you become aware of any violation of our accounting standards or inaccuracy in our financial records,voice your concerns immediately.

Code of Ethics conducting business fairly provide accurate financial information home 26 trade securities fairly and legally. We promote trust in the marketplace by supporting fair and open securities markets.

our commitment in your daily work what if Trading securities of a company based on Recognize inside information that could be Limit sharing accordingly. Don’t share inside : Another team member just told me that inside information (information that is both material. If you have access to information information with anyone else at Target unless Q a significant acquisition by Target of material and non-public) is illegal and unfair. that isn’t publicly accessible, you’re an insider. that person reasonably needs the information one of its largest business partners has When we take steps to prevent it, we uphold Although you’re always obligated to maintain to perform their job. Information must never be gone public. Is it safe for me to buy more our Company’s reputation for dealing honestly the confidentiality of any non-public information shared with anyone outside of Target, including shares of Target stock now? wherever we do business. you learn as part of your job you should be your family and friends. Always be aware of your sensitive to information that could potentially surroundings so that you don’t inadvertently share : It depends. Before trading, confirm be used for insider trading purposes. Examples information with anyone you shouldn’t. A that the information has been publicly how it’s done of inside information include, but are not announced by checking Target’s investor As part of your job, you may be exposed limited to: Watch what you say. Never recommend, instruct, relations website or another publicly to inside information about our Company • Sales and earnings figures or suggest that anyone else buy or sell securities available source, such as an industry or another company, such as one of our • Projections and reaffirmations of of any company when you have inside information website or journal. Additionally, you business partners. It is unfair and illegal to projections of future sales and earnings about that company. This is called tipping, and the should confirm that at least 24 hours use inside information to buy or sell securities • Dividend or share repurchase actions consequences can be severe. have passed since that information was for personal gain. We should trade only when • Significant mergers, acquisitions or publicly announced. Finally, you should information is lawfully and publicly available. divestitures We should also not tip others by sharing inside evaluate any other information you know • Significant new contracts or lawsuits consider this information with them to trade. and confirm that nothing is material and/ • Changes in key suppliers Even if you recommend that someone or non-public before you decide to trade. • Key management changes else buy or sell securities of a company and • Labor negotiations don’t give a reason for the recommendation, policy spot • Pricing or marketing strategy changes you are still violating the law and our policy Securities Trading Policy • Significant cybersecurity events when you have inside information about a company. If you’re not sure if trading is Acceptable Use of Information allowed, always seek guidance by contacting Resources Policy [email protected].

Code of Ethics conducting business fairly trade securities fairly and legally home 27 prevent money laundering. We remain alert, cautious and inquisitive to help prevent money laundering or other financial crimes.

our commitment in your daily work what if Money laundering is the process of moving Stay alert with gift cards. Prepaid gift Take a stand. Remember that by preventing : A guest is trying to purchase a large around money made from criminal activity cards are easy to resell and difficult to track, money laundering, you’re not just protecting Q amount of gift cards in a store. While so that the proceeds appear legitimate. making them an appealing tool for money Target – you may also be preventing a serious ringing up the sale, a register prompt Money laundering is illegal and can be laundering. Our point of sale system is set crime. If any transaction, by either a business pops up to prevent the transaction from connected to almost any criminal activity, up to control this activity. If you are a store partner or a guest, seems suspicious, being completed. What should I do? including terrorist activities and drug team member, always follow register voice your concerns immediately. transactions. We conduct business carefully prompts when assisting a guest with a gift : Follow the point of sale (POS) prompts, to help prevent money laundering and other card transaction, never complete back-to- A never attempt to override the pop financial crimes. Remaining alert, cautious back gift card transactions, and consult a consider this up and contact the Store Leader and inquisitive also helps protect Target, leader when prompted. immediately. our values and the economy. Money laundering warning signs to watch for Be vigilant with large cash RedCard™ include, but are not limited to: payments. Large payments made with • Large cash payment made to policy spot how it’s done a RedCard™ cash are risky because the source of the Anti-Money Laundering Policy We comply with anti-money laundering and funds can be difficult to determine. • Overpayment of RedCard™ followed by a credit balance request anti-terrorism laws in all countries where we • Store team members: If a guest do business. We rely on you to monitor your makes a payment on their RedCard™ • Merchandise purchased with large sums of cash business closely so we can take the necessary with a large sum of cash, notify [email protected] after the action to help prevent or report suspected • Large purchases of gift cards or payment is made prepaid products financial crimes. • Headquarters team members: • Attempts to avoid recordkeeping If you identify a large cash payment, requirements or several payments which equal a • Payments to individuals not involved large cash payment on a guest in the transaction account, notify [email protected] • Attempts to disguise or withhold identification information

Code of Ethics conducting business fairly prevent money laundering home 28 compete fairly. We compete vigorously, but always fairly and legally.

our commitment what if Acting ethically is core to our culture. Gather competitive information fairly. If you : We just hired someone who previously Competition and antitrust laws promote free gather information about our competitors, use Q worked for one of our competitors. Is and fair competition between companies. honest methods. Never encourage anyone it OK if I ask them about some of the By complying with these laws, we contribute to give you information that should be kept secret new services their company was to a thriving marketplace and compete confidential, and always refuse information you developing before they left? for business based on the quality of our suspect was improperly obtained. It is never products and services. OK to share confidential information from a : No. It’s never appropriate to ask previous employer. A someone to disclose confidential how it’s done business information of a former employer. We have a responsibility to Target acts with integrity and in the spirit gather information ethically. of fair dealing. To do your part, follow consider this antitrust laws and don’t make agreements Before any interaction with a competitor, with competitors or others that restrain consult with Target’s Law Department. If you competition. Use legitimate sources when are engaging in a legitimate interaction with policy spot acquiring business information and when a competitor (for example, a Target-approved Antitrust Policy doing business with others, avoid practices trade association), and the topic of an improper that are unfair, manipulative or deceptive. agreement comes up (for example, aligning retail pricing on a product), make sure you immediately: in your daily work 1) Stop the conversation Follow antitrust laws. Never discuss or 2) Make it clear you don’t want reach an agreement with a competitor on to participate price, terms of sale, assortment, margins, 3) Remove yourself from the situation promotions, business partner relationships 4) Voice your concerns immediately or the division or allocation of markets, territories or channels where Target does business. Avoid even the appearance that any of our pricing, promotional or assortment decisions are influenced by information exchanged with a competitor.

Code of Ethics conducting business fairly compete fairly home 29 safeguarding what’s ours. Target’s reputation is in our hands, so we carefully protect our resources.

secure our assets ...... 30 protect non-public information...... 31 respect and preserve intellectual property ..... 32 manage records ...... 33 communicate responsibly ...... 34

Code of Ethics safeguarding what’s ours home 30 secure our assets. We keep track of our physical property and assets, only using them for legitimate Target business.

our commitment what if Target’s resources are provided to help us Secure our assets. Follow our security : I noticed a fellow team member taking manage our business effectively and efficiently procedures to secure Target assets. Unless Q home returned merchandise. They said you’re authorized, physical assets should never while serving our guests. If we use these it was damaged, so it didn’t matter. Can be removed from Target property without resources inappropriately, we inadvertently permission or used for personal gain or benefit. they do that? risk financial loss, reputational damage and If you see someone acting suspiciously or our ability to grow and thrive. engaging in dishonest activity, contact either: : No, they may not. Even if merchandise • Assets Protection (Stores and DCs) A is damaged or to be disposed of, it’s how it’s done • Corporate Security (HQ) still Target property and needs to be accounted for and properly processed Each of us is expected to care for Target’s If you see this type of behavior, voice for inventory purposes. Voice your assets and use them responsibly, along with your concerns immediately, as it is your concerns immediately. any assets or information belonging to our responsibility to protect Target’s physical business partners. You are responsible for assets and ethical culture. the resources provided to you, which means taking care of all resources to prevent any policy spot loss, damage, theft, fraud, misuse, waste or consider this Acceptable Use of Information unauthorized disclosure. Resources Policy One of the easiest ways to prevent a vehicle break-in is to keep all valuables out of sight. Conflicts of Interest Policy This is important when you are traveling in your daily work Visitor Management Policy with a company-issued device such as a Know what to protect. Our assets take laptop or iPad. If you leave company assets different forms. Examples of assets include, in your vehicle, protect them by removing but are not limited to: them from sight. All company-issued • Physical assets – merchandise, devices contain confidential information samples, buildings, fixtures, office furniture, tools, equipment, phones, and intellectual property that you are credit cards or cash responsible for protecting. • Technology – computers, phones, tablets, handheld devices, hardware, software, network systems and access to systems

Code of Ethics safeguarding what’s ours secure our assets home 31 protect non-public information. We handle our information with the utmost care, protecting it from misuse, disclosure and attacks.

our commitment what if Target’s non-public information can be a critical Target’s information is classified as: Use strong security practices. : My business partner set up a file- business asset. Our top priority is keeping this • Public • Review your emails carefully Q sharing site and asked me to send information protected and safe for our guests • Internal o Never click on any unfamiliar links Target documents to that location for and team members. If non-public information is • Confidential or respond to unusual requests review. Since we have a contract, is this mishandled or disclosed, it can compromise trust, o Report suspicious emails immediately • Secure Handling Required (SHR) OK? negatively impact our business and damage our to [email protected] reputation. Share information wisely. If you have access • Never use your Target login information : No, it’s against Target’s Acceptable Use or passwords on personal accounts. If of Information Resources Policy to to information that isn’t publicly available, handle it a personal password is compromised, it A how it’s done with care. can endanger all applications/websites store or share Target information using • Access only the information you need • Only install and use authorized software unapproved, external tools. Instead, Everyone, at every level of Target, has a to do your job, share and store it using on Target devices. give the business partner access to the responsibility to protect our non-public Target-approved tools and never share it with documents through an approved Target information by following our Acceptable Use anyone that is not authorized to access the file-sharing tool. Refer to the Where to of Information Resources Policy and the information Share guide for detailed direction. Information Security Policy. All team members • External business partners must have a non- consider this must also complete the required training to disclosure agreement or contract in place Contact [email protected] with understand the required behaviors and technical prior to accessing any non-public Target questions that come up to help information requirements to help safeguard information determine what is best for Target, our resources at Target. • When discussing non-public information, pay guests and team members. Examples policy spot attention to your environment (for example: of common situations that often arise Acceptable Use of Information elevator, breakroom, coffee shop, or home include, but are not limited to: Resources Policy in your daily work office) and be mindful of others who could overhear your conversations • I received a suspicious e-mail and Information Security Policy Know what’s non-public. Examples of • Confidential or SHR information should never want to have it evaluated. information not publicly available include, but be attached or included in meeting invites • What can I do, or not do, when Vendor Risk Management Policy are not limited to information about Target’s as calendars are often accessible to team handling non-public information? procedures, systems, operations, finances, members or contractors who may not be • What should I consider from a merchandising, contracts, strategies, product authorized to access the information security perspective when building development and guests. • Verify email addresses prior to sending, so or buying a new app? that information isn’t shared with the wrong • My password may have been recipients compromised. What should I do? • Protect your Target user ID and passwords and never share this information with anyone

Code of Ethics safeguarding what’s ours protect non-public information home 32 respect and preserve intellectual property. We value our strong brand and carefully protect intellectual property.

our commitment in your daily work Anything we create at Target may be considered Understand your responsibilities. Follow all Work with the Target Brands team, to review intellectual property, including new brands, policies and procedures in place for developing, and avoid any potential intellectual property marketing campaigns, artwork, product designs protecting and enforcing Target’s intellectual issues. Obtain the necessary permission and business innovations. We respect and treat property rights. required by third parties before using anyone’s our intellectual property as a valuable Company intellectual property. If you have concerns asset. We also respect valid intellectual property Respect all intellectual property. Deal fairly about someone not following intellectual owned by others and comply with the laws that with the intellectual rights of others when property policies, always voice your protect intellectual property. working with music, logos, written materials, concerns immediately. software, videos, lyrics, images, designs and even a person’s name or likeness. how it’s done We must always protect Target’s intellectual Follow the laws governing: consider this property and respect intellectual property • Intellectual property (creative or What you develop while you’re employed owned by others. Intellectual property can proprietary items that support our by Target may belong to Target. In some brand and make us unique) exist for: instances, you may not use it for your own • Trademarks (brands, logos and slogans – • Brands and logos (trademarks) benefit or share with another entity, even think of our famous bullseye) • Literary and artistic works, such as after you leave Target. graphics, product designs, pictures, • Copyrights (creative designs, software, artwork, music, videos, text and other photos and images) artistic elements (copyrights) • Patents (covering our innovations • Marketing campaigns and inventions) • Inventions and business innovations • Trade secrets (non-public information (patents) that makes us competitive) what if : Who do I contact if I have a question Q regarding intellectual property?

: Email the Target Brands team at A [email protected].

Code of Ethics safeguarding what’s ours respect and preserve intellectual property home 33 manage records. We create and maintain records that accurately reflect our business activities, commitments and decisions.

our commitment in your daily work consider this what if We understand the importance of protecting, Know what’s required. Work with your Accurate records management can be : The retention period listed for records storing, managing and disposing of our leader to understand what records your team achieved if you: Q I keep seems far too short. I’d like to information in a way that will help us comply needs to create and manage manually or • Create complete and accurate records keep them a few years longer, just in with the law and address our operational electronically. Make sure records can be easily as part of your normal business process case I might need them. Is this OK? needs. We keep accurate records to retrieved when needed. by telling a story – include who, what, when, where and why demonstrate compliance with the law : No, record retention periods are and operate more efficiently by effectively Think of others. You may no longer need • Store records in a sustainable location where you and others can easily find A determined by an inter-departmental managing our information. the record in your day-to-day role, but others when needed team to ensure we are meeting legal may rely on it in the future. A record-retention • Retain records according to the Records and operational objectives while period is established to meet the needs of all Retention for your area managing risk and expense. If you how it’s done business areas. • Destroy or purge records when the believe a retention period is too short Each of us has a role in managing records, retention period has been reached– or too long, you should contact whether you create records in your job or Hold on to records. Although retention unless on legal, tax, or investigation hold [email protected] develop technology that automates a business should always comply with the Records to have it reviewed. process. It is up to you to understand and Retention Schedule, your law or tax partners follow the recordkeeping laws and Target’s may occasionally contact you to put records policies so you can manage information on “hold.” In this case, do not destroy those properly in your business. records until the hold is released. policy spot Records and Information Let it go. Not all documents and data need to Management Policy be kept as records. If you only have a copy, or it’s not considered a record, purge it when you are done with it unless it is on hold.

Code of Ethics safeguarding what’s ours manage records home 34 communicate responsibly. We understand the impact our words can have, so we communicate thoughtfully and responsibly.

our commitment what if As team members, we love our Company Communicate accurately with government : While online, I came across a post from a and enjoy talking about it – to each other and authorities. If your work authorizes you to Request: Email: Q guest who was upset with the service they everyone. We designate authorized individuals communicate with or respond to government received at a store. It would be so easy for who are trained to speak on behalf of Target or regulatory entities, it’s important to be me to reply and help them out. Is that OK? Comments to Public because we can damage our reputation in just accurate. Anything you say or report to these the media Relations a few words with an untrue statement. entities should be accurate, complete and : No. Unless you are authorized to speak consistent. Never mislead, provide incorrect A on Target’s behalf, you may not reply, information or omit important details. Financial or Investor as your response could be misinterpreted. how it’s done investment Relations Notify Guest Services or Guest Relations Help us speak with one voice. You can inquiries Our reputation is one of our greatest assets, about the post so appropriate action can make sure official messaging about our and it’s up to each team member to protect be taken. it. We refer all outside inquiries about Target’s Company is accurate and complete by Guest Guest business to our Enterprise Communications allowing only authorized individuals to speak complaints Relations team to ensure that all information conveyed for Target. They get the right messages out to the public, regulatory authority and others is to protect our Company and our reputation. accurate, complete and consistent. Never speak for Target if you’re not Invitations to policy spot Presentations authorized, and remember, if you are asked make a speech Social Media Policy to speak about your role as a Target team Delegation of Authority Policy in your daily work member, outside of Target, you must receive Corporate approval from [email protected]. Donations External Presentation Decision Filter Post responsibly on social media. Posting on Responsibility social media helps you connect with others, but use care when posting on social media channels. Make it clear that any opinions you express are your own and do not reflect those consider this of Target. If you speak about Target goods Never post anything online that: or services, you must disclose that you are a • Would compromise non-public Target team member. Never share proprietary business information (guest and or other non-public information. Of course, business partner communication) discriminatory or harassing remarks or threats • Appears to be on Target’s behalf of violence will not be tolerated. without authorization

Code of Ethics safeguarding what’s ours communicate responsibly home 35 caring for our world. We invest in our communities.

respect human rights ...... 36 engage responsibly in political activities ...... 37 care for our planet ...... 38 invest in our communities ...... 39

Code of Ethics caring for our world home 36 respect human rights. We’re dedicated to making a positive impact on our communities through the actions we take.

our commitment in your daily work what if Ensure positive partnerships. Choose Target is committed to prioritizing and Protect human rights. Human rights are business partners who share our values and : A business partner I’m considering protecting human rights across our global embedded in all aspects of our business. demonstrate an ongoing commitment to Q working with had an employment law operations – from our team members, Every team member has a role to prioritize and human rights. It’s up to you to hold business violation a few years ago that I read guests, supply chain, and our communities protect human rights across our global supply partners accountable to our high ethical about in the news. They shared that the because we believe every person deserves chain operations and hold business partners standards. company is under new management and to be treated with dignity and respect. We accountable to those same standards. Some now has a good recent record. Do we are continuously working to do better and of our priorities include, but are not limited to: Once a merchandise business partner have to consider this past violation? our approach is to effectively respond when • Ensuring safe and sanitary working is selected, the Responsible Sourcing & concerns are raised. conditions Sustainability team may monitor and audit : Yes, we do. Even though their current • Providing legal compensation for all hours the business partner as part of our oversight A record is good, it’s important that we worked or services performed and due diligence process to make sure how it’s done consider any past violations by business they comply with our Standards of Vendor • Striving to give everyone access to the partners when we become aware of We expect every team member and business same opportunities through inclusive Engagement (SOVE) and follow all applicable them. Talk to your leader about this partner to show respect for human rights guest experiences, work environments, laws. and follow all laws that protect human workforce diversity, and societal impact vendor’s past before making any vendor selection decisions. rights, including those that prohibit forced • Working to validate that supply chain or compulsory labor, child labor and human workers have clean, drinkable water and trafficking. sanitation on site policy spot • Preventing Owned Brand manufacturing consider this Human Rights Statement facilities from discharging untreated All business partners are expected to follow wastewater into the communities our SOVE. We also expect all business Vendor Code of Conduct • Striving to accelerate economic partners we work with to treat workers fairly development and vitality in the with dignity and provide safe and healthy Standards of Vendor Engagement (SOVE) communities where we operate work conditions. If you work with business Equal Employment Opportunity and partners and have concerns or hear about Harassment-Free Workplace Policy any human rights issues, voice your concerns immediately. Target’s Integrity Hotline

Code of Ethics caring for our world respect human rights home 37 engage responsibly in political activities. Our community gets stronger when everyone is engaged and invested in making it a better place.

our commitment in your daily work what if The Government Affairs team works to make Understand Target’s policy. Before you Act on your own behalf. If you want to : I’m a team leader, and I support a political sure that Target has a voice in decisions contact a government official on behalf contribute your personal time or money Q candidate in our community. I’d like made by government officials. Target also of Target, always obtain approval from to political activities, be clear that you’re everyone on my team to support that encourages team members to participate Government Affairs. This ensures that acting on your own behalf and not on candidate, too. May I ask them to donate in the civic process. Target’s advocacy is consistent, Target’s behalf. You may not use Target’s or volunteer? coordinated and in compliance with the name to suggest that Target sponsors or law. Only Government Affairs is authorized to endorses your personal politics, nor may you : No. You may not use your position at how it’s done promise or make political contributions use your position to pressure other team A Target to pressure others into supporting on behalf of Target. members to make political contributions or When you engage in advocacy on behalf of any candidate or cause, or to make a Target, you must always follow the policies to support or oppose particular candidates. political donation. and laws that apply. You must also keep your You must also obtain pre-approval from More generally, you may not use any Target personal political activities separate from Ethics prior to providing anything of value to a resources or services (except as permitted your role at Target. government official. Examples include, but are by Government Affairs) for political purposes. not limited to policy spot • Meals Political Activities, Lobbying, and Government Ethics Policy • Gifts consider this • Entertainment Conflicts of Interest Policy If you are considering becoming a candidate • Travel for political office or accepting an appointment Anti-Bribery Policy If you’re ever unsure, ask for guidance by to a government position, contact Government contacting [email protected]. Affairs first. Government Affairs can help you identify and navigate any potential conflicts of interest and understand the applicable policy requirements.

Code of Ethics caring for our world engage responsibly in political activities home 38 care for our planet. We are good stewards of our resources and do our part to protect the planet.

our commitment in your daily work what if We operate our business by using resources Take responsibility. Follow Target’s best Be aware of your impact on the : I noticed several team members responsibly and following environmental practices to comply with environmental laws environment. Help us achieve our Q dumping chemicals improperly. It may laws that impact Target. Having a good by properly disposing of waste and handling environmental goals by: have only happened once, so I’m not environmental record matters to our guests, and storing chemicals and other hazardous • Following Target policies and procedures sure if I should say something. Should I? team members and communities, and that materials safely. If your work with business that focus on proper disposal of waste and unsellable items, improving water commitment is ingrained throughout our partners involves sustainability practices, : Yes, you should. We should follow all business. make sure you initiate discussions to confirm quality, optimizing water efficiency and managing chemicals A applicable environmental laws and do they understand our expectations to comply what we can to properly dispose of with all laws, act responsibly and follow the • Increasing efforts to offer sustainable products and ensuring sustainable materials that could harm people and how it’s done environmental standards as outlined in the operations the environment Voice your concerns We comply with the environmental laws that Standards of Vendor Engagement (SOVE). • Conserving resources such as water immediately. apply to Target and follow all policies and and paper Watch for hazards. Watch for environmental procedures in place. We use and conserve • Reusing plastics and metal whenever you resources by recycling and reusing when hazards like improper waste disposal or can to minimize our carbon footprint possible and disposing materials properly. By release of pollutants. If you see a potential policy spot doing so, we also reduce our carbon footprint. hazard, don’t ignore it –– report it immediately Standards of Vendor Engagement (SOVE) through the stores My Help App or contact Corporate Responsibility Reports [email protected]. consider this Target recycling and salvage programs Corporate Responsibility have a significant impact on decreasing our Planet Overview carbon footprint by removing waste properly. If you have questions regarding recycling, you can follow and ask questions on the #knowthespace community on Yammer.

Store team members – make sure all materials are properly placed, labeled and disposed of by carefully following all procedures.

Code of Ethics caring for our world care for our planet home 39 invest in our communities. We are committed to bringing about positive impact in the communities we serve.

our commitment what if policy spot Our Company was founded on a deep belief Act on your own behalf. We encourage you : I’m on a team that wants to donate Delegation of Authority Policy that the enduring success of our business to become involved in your community. Target clothing or money to a nonprofit. Q No Solicitation and Distribution relies on the strength and vitality of the However, unless approved, do not make Can we do this? Policy communities we serve. By investing in the donations or speak on behalf of Target. Contact places where we live and work, we create the Enterprise Communications team with : While Target is committed to addressing at Target FAQs more resilient and vibrant communities questions. needs within our communities, teams A Waste Minimization Donation Process for future generations of guests and must follow Target’s Waste Minimization team members. Donation Process. In certain instances, Charitable Donations consider this the Corporate Responsibility team and the how it’s done Team members carry out Target’s legacy of Waste Minimization team may approve in- kind donations tied to a corporate strategic No matter what job you hold or where you volunteerism by donating time and talent initiative. work, you have a responsibility to maintain in the communities where we do business. Corporate volunteer opportunities can be our reputation, make honest decisions that Always contact Corporate Responsibility found at myGiving, and additional resources reflect our values and act responsibly in before engaging in any discussion with a are provided below to understand the our communities. nonprofit to ensure tax, legal and governance limitations placed on volunteering. requirements are considered. International • Target’s charitable donations and in your daily work cause marketing campaigns must donations have additional requirements be pre-approved by the Corporate including pre-approval of all charities by the Seek pre-approval. All of Target’s Responsibility team Corporate Responsibility team. charitable donations or cause marketing campaigns must be pre-approved by the • The No Solicitation Distribution Corporate Responsibility team. Contact Policy provides all team members the ability to work free from distraction [email protected] with and the pressure of solicitation, as questions. team members are prohibited from asking others to make contributions • When volunteering on work time, always keep your leader informed

Code of Ethics caring for our world invest in our communities home 40 summing it up. How will we stay true to Target? That depends on you.

Reading this Code is a great first step. The next step is taking what you’ve learned from the Code and turning it into actions that make our Company the best it can be. Never forget the impact you have on Target and our guests. The decisions you make, no matter how small, should reflect what’s most important to us, our values and doing what’s right for our guests.

If you have any questions about our Code or policies or need additional guidance, please don’t hesitate to ask. Keep in mind that we may modify or update the Code as needed, so refer to it often. In rare cases, it might be appropriate for Target to waive a part of the Code. Any waiver applicable to our executive officers, chief accounting officer or controller may be made only by Target’s Board of Directors (or a committee of the Board) and will be promptly disclosed to our shareholders.

Code of Ethics summing it up home 41 policy and resource look-up.

Want to know more? Here is an alphabetical list of all the policies and resources referenced in our Code. Enterprise Policies can also be accessed through our Ethics Site. If you have questions about them or how they apply to you or your role, please contact your leader or your Human Resources partner.

Policy or Referenced Policy or Referenced Describes: Describes: Resource Name: on page: Resource Name: on page:

Acceptable Use of Information Defines the information classification levels and 26 Corporate Responsibility establishes requirements for handling information 30 Overview of Target’s commitment to better our planet. 38 Resources Policy securely to protect Target’s information resources. 31 Planet Overview

Updates stakeholders on Target’s progress against our Outlines requirements for team members who work 17 corporate responsibility commitments on an annual 38 with government officials or supervise vendors that Anti-Bribery Policy Corporate Responsibility Reports basis. The report represents Target’s global operations work with government officials. 23 39 for each fiscal year.

Outlines requirements regarding who can authorize Outlines requirements for accepting cash payments 21 and execute contracts, make charitable or political 34 Anti-Money Laundering Policy Delegation of Authority Policy for merchandise transactions or to fund gift cards. 27 contributions and represent Target at external 39 speaking engagements.

Defines Target’s commitment to maintaining a workplace free of illicit drugs, alcohol and tobacco. Outlines requirements that prohibit business practices Drug, Alcohol, Tobacco-Free 28 Also describes the types of substance testing that 13 Antitrust Policy that interfere with a competitive, free marketplace. Workplace Policy Target team members may be required to undergo during the course of their employment.

Prohibits discrimination and harassment of team 11 members on the basis of any protected characteristic, Outlines what charitable donations are allowed and Equal Employment Opportunity and 12 39 as well as retaliation against individuals who complain Charitable Donations when to contact Corporate Responsibility. Harassment-Free Workplace Policy of or participate in an investigation related to 16 discrimination or harassment. 36

Outlines limits for accepting gifts, meals, entertainment Conflicts of Interest Business External Presentation Decision-making tool to determine if acceptable to and/or travel offered by a vendor, prospective vendor 18 34 speak at an external engagement. Amenities Table or competitor. Decision Filter

Outlines requirements for accepting gifts, meals, entertainment 17 and/or travel offered by a current or prospective business 18 Outlines requirements to ensure the confidentiality, Conflicts of Interest Policy partner, or competitor. Also includes information regarding Information Security Policy integrity and availability of Target’s information 31 outside employment, financial investments and business 30 resources and information assets. dealings with former team members. 37

Code of Ethics policy and resource look-up home 42 policy and resource look-up continued.

Policy or Referenced Policy or Referenced Describes: Describes: Resource Name: on page: Resource Name: on page:

A site for team members to find volunteer Discloses how Target collects, uses, shares 39 20 myGiving opportunities. Retail Privacy Policy and protects guest information.

Prohibits team members from soliciting others during No Solicitation and Distribution their own or another team member’s work time, and Outlines requirements for team members regarding 39 Safety Policy 13 Policy from distributing literature during or in safety, compliance and claims. work areas.

Encourages team members who have a job-related idea Prohibits trading in our securities and certain other or concern to share with their leader. If a satisfactory companies’ securities by Insiders (all team members 6 26 Open Door Culture resolution isn’t reached, team members can go to Securities Trading Policy and members of the Board of Directors) when they another higher level leader within the organization. are aware of material, non-public information.

Outlines requirements for Company and Political Action Political Activities, Lobbying, Committee (PAC) political contributions, personal political Outlines guidelines about what can and cannot be activity by team members, lobbying, the provision of hospitality 37 Social Media Policy shared by team members on social media outside 34 and Government Ethics Policy to government officials and limits on the activities of team of Target. members who were formerly government officials.

Outlines requirements to ensure the proper collection, 17 Standards of Vendor Engagement Outlines social, labor and environmental expectations use, sharing and deletion of Target Guest and Team 20 36 Privacy Compliance Policy for merchandise vendors and factories. Member Personal Information. (SOVE) 38

Records and Information Outlines requirements to ensure records and non- Discloses how Target collects, uses, shares and 33 Target Debit Card Privacy Policy 21 Management Policy record information assets are managed effectively. protects Debit Card personal information.

Outlines requirements for team members who solicit and TD Bank Privacy Policy for Discloses how TD Bank collects, uses, shares and RedCard Sales Practices Policy 21 21 process Target Credit and Debit Card applications. Target Credit Card protects Credit Card personal information.

Code of Ethics policy and resource look-up home 43 policy and resource look-up continued.

Policy or Referenced Policy or Referenced Describes: Describes: Resource Name: on page: Resource Name: on page:

Outlines requirements for hosting visitors, vendors or 14 13 Team Member Handbooks Provides team members with expectations. Visitor Management Policy guests to ensure safe and secure environments at Target locations. 30

Outlines requirements for team members traveling Travel and Expense Policy for Target business and seeking business expense 18 Volunteering at Target FAQs FAQs for volunteering and team member giving. 39 reimbursement.

Outlines standards and expectations for 17 Waste Minimization Vendor Code of Conduct Overview of donation process by location. 39 merchandise vendors. 36 Donation Process

16 Defines conduct considered to be workplace violence, prohibits that conduct and describes the 12 Outlines requirements to manage the strategic, 17 Vendor Risk Management Policy operational, reputational, compliance and financial Violence-Free Workplace Policy consequences for violating the Policy. Also addresses 13 23 risks that may arise when working with vendors. the use and possession of weapons, explosives and 16 31 other dangerous items in the workplace.

Code of Ethics policy and resource look-up home 44 essential resources. notes.

Have a question? Target offers a variety of resources for more help and to report concerns:

Issues or Concerns: Contact:

To ask questions, report Talk Talk to your leader or Human potential misconduct or Resources partner. other ethical concerns Email [email protected]

Visit www.TargetIntegrityHotline.com

Call Integrity Hotline, anonymous option available 24 hours a day U.S.: 1-800-541-6838 India: 000-800-100-1657 Other non-U.S. locations: place a collect call to the U.S. at: 1-470-219-7116

Write Corporate Compliance & Ethics Target Corporation 1000 Nicollet Mall #3110 Minneapolis, MN 55402

Point your smartphone camera at this QR code, then tap the pop-up notification to go to the Integrity Hotline website.

For questions on the Code of Ethics [email protected]

To view Enterprise policies Enterprise Policies To view information about Team Member Handbooks Company Benefits

June 2021 #1 Code of Ethics essential resources