Code Of Ethics At Our Best.

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Code of EthicsAt our best.Every decision. Every day.

Best BuyBeliefs.ContentsResourcesNextBackLast PageWork can be an instrument for doing good things in the world.Open &HonestEthics LineA company is a human organization – a group of individuals working together in pursuit of agoal, not a soul-less body.The purpose of a corporation is to contribute to the common good, by having a positive impacton its customers, employees, vendors, shareholders and the communities in which it operates.A business is more than for profit. It is about doing well by doing good.“Magic” happens if you can connect what drives the individuals working at the company to thepurpose of the company. More broadly, we believe that great things happen at companies wherethe individuals who work there can feel a sense of purpose, develop personal connections, haveautonomy, develop a certain mastery and feel they are in a growth environment.Work is not about attempting to achieve perfection, but about human connections. Webelieve performance and growth come from accepting and embracing our imperfectionsand vulnerabilities.Leadership is not about power, fame, glory or money. Leadership is about purposeful,authentic, human service.Implications of these BeliefsLeadership is NOT about tradeoffs. It is about alignment of purpose, vision and strategy.The size of a company does NOT matter. What matters is how each person connects theirsearch for meaning with the purpose of the company and how we build human connectionsin a meaningful and authentic way.Strategy does NOT start with “what.” It has to first be anchored in a clear purpose.Diversity and inclusion is NOT a politically correct nice-to-have. It is essential to a company’ssuccess and humanity.Corporate Social Responsibility should NOT be an afterthought. It needs to be integrated intothe core focus of the company.The above principles are NOT just for good times. They still apply in challenging situations.Code of Ethics. l 2 l

Contents.ContentsResourcesNextA message from Corie.BackOur Purpose, Guiding Behaviors and Values.Introduction.Our Code03Last PageOur vendors.Maintain integrity in vendor relationsOur responsibilitiesFoster mutually beneficial partnershipsOur leaders’ responsibilitiesFollow global trade lawsRaising concerns and speaking upCompete fairlyOpen &HonestEthics LineAvoid conflicts of interest01Avoid bribery and corruptionOur customers.Advertise and sell responsiblyPromote product safetyKeep private information private04Our shareholders.Protect our assetsEnsure financial integrity02Avoid insider tradingOur employees.Communicate responsiblyCelebrate our diversityProtect confidential business informationRespect each otherHonor human rightsMaintain a safe and healthy workplace05Our communities.Protect the environmentEngage responsibly in political activitiesMake a positive impactThink about tomorrow.Additional resources.At our best.l3l

A message from Corie.ContentsResourcesNextBackLast PageDear Best Buy Stakeholders:For more than 50 years, Best Buy has been a purposeful, values-driven, human organization,one dedicated to serving our customers, our employees, our vendors, our shareholders andthe communities in which we operate. Building on this wonderful legacy, we are pursuing anoble purpose, which is to enrich lives through technology by addressing key human needs.As we do this, we know that each of our stakeholders expects that we operate in an entirelyethical manner. Ethics is indeed a critical foundation for any company. It is about doing theright thing. In this context, I am very pleased to share the Best Buy Code of Ethics with you.In our Code of Ethics, we discuss the fundamental beliefs, principles and expectations ofall of us at Best Buy. At Best Buy, we know that we do well by doing good. In every decision,every day.Respectfully,Corie BarryCEOWatch CorieCode of Ethics. l 4 lOpen &HonestEthics Line

Defining us.Inspiring us.ContentsResourcesNextBackLast PageOpen &HonestEthics LinePurpose:Let’s talk aboutRallying Cry: what’s possible. Guiding Behaviors:Values:Enrich livesthrough technology. Be human. Put people before all else. Make it real. Bring the extraordinary into the everyday. Think about tomorrow. Account for what comes next, it makes all the difference. Unleash the power of our people. Learn from challenge and change. Show respect, humility and integrity. Have fun while being the best.At our best.l5l

ContentsResourcesNextBackLast PageOpen &HonestEthics LineIntroduction.Our CodeOur responsibilitiesOur leaders’ responsibilitiesRaising concerns and speaking upCode of Ethics. l 6 l

Our Code.Our responsibilities.ContentsResourcesAt our best. Every decision. Every day. How can you be atyour best? Start here, with our Code. It will help you takeour Purpose, Guiding Behaviors and Values and apply themto the everyday work you do on behalf of Best Buy. It willalso help you navigate your way through (sometimes sticky)ethical dilemmas.On the pages that follow, you’ll find details about whatit means to be “At our best. Every decision. Every day.”But Best Buy expects everyone, at every level of theCompany to:Will the Code provide the answer to every question you mightencounter while working at Best Buy? Live our Purpose, Guiding Behaviors and Values.It all begins and ends with that.No document could do that. But it will give you the tools youneed to make the right decision, regardless of the challengesyou might face. And it will point you to people who can help youwhen the right decision is not so clear.Remember your moral compass when things get tough. Becauseultimately, no document, including this Code, is a substitute foryour good judgment.Who has to comply with our Code? You do.Actually, everyone at our Company does.And when we say “Company” and “Best Buy,” we meanboard members, officers, employees, contingent workers andcontracted workers at Best Buy and all of its subsidiaries aroundthe world – a family of more than 125,000.What about oursuppliers, vendorsand other third-partybusiness partners?NextBackLast PageOpen &HonestEthics Line Use good judgment and act with integrity andhonesty. We cannot – and will not – emphasizeperformance at the expense of our integrity.We expect them to upholdthe same high standards ofbusiness conduct as we doand to follow the spirit ofour Code. Do not let the pressure to succeed make youdo things you know are wrong. No one hasthe authority to make you do something thatviolates our Code.The specific requirementsthat they must meet areoutlined in our Supplier Codeof Conduct, located on ourBest Buy Partner Portal. Follow all policies and laws that applyto your job. Complete all trainingsassigned to you – that’s the best wayto learn. Speak up if you see or suspectmisconduct or unethicalbehavior. It’s always the rightthing to do.What happens when our Code is violated? Our customers’ trustis weakened and our brand is tarnished. That’s why violations ofthe Code, our policies or the law can result in disciplinary action,up to and including termination of employment. Depending onhow serious the incident is, there can even be civil or criminalconsequences for the person involved and for Best Buy.At our best.l7l

Our leaders’responsibilities.Leadership is about purposeful, authentic, human service.This belief is summarized into the Five Be’s of Leadership: Be a purposeful leader. Be clear about your purpose asan individual and how it connects with the purpose ofthe organization. Be clear about who you serve. You are here to serveothers, in particular those on the front line, not yourselfor the person you work for. Be clear about your role as a leader. It is not to besmarter than anyone else. It is to create an environmentin which others can be successful. Be a values-driven leader. Integrity is the cornerstoneto everything. Be an authentic leader. Be yourself, your full self. Bewho you are.What doesethical leadershiplook like?- Foster an environmentin which employees feelcomfortable coming toyou with questions andconcerns.- Document and escalateconcerns raised to youthrough the correctchannels. Don’t put theburden back on theemployee to solve theissue.ContentsResourcesWhen the answer is not clear In every decision you make,we count on you to use good judgment. But there will beinstances when that won’t be easy. When you encounter agray area, ask yourself:NextBackLast PageOpen &HonestEthics LineDoes it reflect ourPurpose, GuidingBehaviors andValues?Is it legal?Is it permitted byour Code and ourpolicies?- Don’t retaliate againstemployees who raise aconcern in good faith.Would you becomfortable if youractions were reportedby the media?Is itconsistent withour commitmentto our customers,employees, vendors,shareholders andcommunities weserve?If you answer “yes” to all of these questions, it’s probably OK to proceed. But if you answer “no” or“I’m not sure” at any point, stop and reconsider. Keep in mind, it’s always appropriate (and smart!) toask for help if you are not certain.What if ?There’s a conflict between the Code and the way we do something inmy department.Generally, if a local business practice conflicts with our Code, follow the Code. If a local lawconflicts with our Code, follow the law. Still not sure? Either follow the stricter standard orseek guidance from your manager or the Ethics Office.Code of Ethics. l 8 l

Concerned? Speak up. If you see or experience conductthat is inconsistent with our high standards, have thecourage to speak up. Best Buy takes all reported concernsseriously. And there are many ways to share your concerns.Start local – yourmanager is usuallyin a good position tounderstand and respondto your concern.If you’re not comfortabledoing that, reach out toHuman Resources (HR),Employee Relations orthe Ethics Office.See this iconthe screen?on the right side ofIf you are aware of misconduct or unethical behavior, clickon the icon to go directly to the Open & Honest Ethics Linereporting page.If you wantto contact anindependent thirdparty, use the Open& Honest Ethics Line.Accessible by phone(833.BBY.OPEN) or web(BestBuyEthics.com), theEthics Line allows you(anonymously, if you wish) toask questions or share yourconcerns 24 hours a day,7 days a week. Informationyou provide through theEthics Line is documented indetail and forwarded to theEthics Office.ContentsThink about tomorrow.Raising concernsand speaking up.ResourcesWhat happens next? No matter who you contactor which resource you choose, your concernwill be promptly reviewed and, if necessary,investigated by the team with the appropriatesubject matter expertise. Information you providewill be shared only with people who need to knowin order to resolve the issue.If the concern is substantiated, HR will make arecommendation to the individual’s managerregarding what, if any, disciplinary action isneeded using the Coaching and CorrectiveAction Guidelines. The reporter will be notifiedwhen the matter is resolved, although details ofthe outcome will likely not be shared in order toprotect the confidentiality of the investigation.NextWhat does “goodfaith” mean?BackSharing a concern in goodfaith means that you honestlybelieve that there may be aviolation of our Code, ourpolicies or the law.Last PageOpen &HonestEthics LineRetaliation? Not here. Best Buy does not allowany form of retaliation against anyone who reportsa concern, makes a complaint in good faith orcooperates in an investigation. If you believe youhave been retaliated against, reachout to HR, Employee Relations orthe Open & Honest Ethics Line.Find out more. Investigation Resource for Reporters Investigation Resource for SubjectsAt our best.l9l

ContentsResourcesNextBackLast PageOpen &HonestEthics Line01Our customers.Advertise and sell responsiblyPromote product safetyKeep private information privateCode of Ethics. l 10 l

ContentsResourcesNextBackLast PageOpen &HonestEthics LineOur customers:Customers are at the center of everything we do. Ourpurpose is to enrich their lives through technology byaddressing key human needs across a range of areas,including entertainment, productivity, communication,food, security and health. Together, we are talking aboutwhat’s possible and building deeper relationships withthose we serve.At our best.l 11 l

Advertise and sellresponsibly.Our customers are the reason we are here, so we treat themwith respect, honesty and fairness.The success of our business depends on putting people before all else, and providing them anunparalleled level of service before, during and after the sale of our products and services. Wehave standard operating procedures (SOPs) in place to ensure that we meet (or exceed!) customerexpectations and provide a positive, consistent experience, no matter which employee they meet.It is the right thing to do and it is consistent with our Guiding Behaviors.Every decision. Every day. Treat our customersequitably. Provide excellentcustomer experiences toall, regardless of individualdifferences. Preserve trust. Honesty reallyis the best policy, and clear,accurate information helpsour customers make informedbuying decisions. C omply with applicablelaws and know our SOPs.In our advertising, sales andpromotional materials, befair, truthful and transparent.Make sure that descriptionsand information you provideaccurately represent thequality, features, availabilityand price of our productsand services. In addition, anyclaims you make about ourproducts and services need tobe adequately substantiated. W atch out! Be alert forfraudulent and suspicioustransactions. And followpolicies and trainingsdesigned to prevent ourproducts and services frombeing used to facilitate illicitactivity.If we’re not credible,customers won’tbuy what we sell.But worse than that,customers won’t trustus. That’s why we’redetermined to alwaysadvertise, market andsell responsibly. Follow our Price MatchPolicy. We want ourcustomers to have aconsistent experience withour products and pricing.Honor Best Buy systemverified competitor prices viaprice match when requestedby our customers. H onor our return andexchange policies. Betransparent about whatour support and protectionplans, our policies and ourmanufacturer warrantiescover and exclude. If aproduct or service doesn’tlive up to a customer’sexpectation and it meetsour return or exchangeguidelines, respect theirrequest. Customers who feelgood about our processeswill be more inclined tocome back.ContentsResourcesNextWhat if ?BackLast PageSometimes I encourage customers to buyservice plans, accessories or services. I wantour territory to come out on top in terms ofsales. Is that OK?Open &HonestEthics LineSelling additional products and services is important, butour customers should never feel pressured to purchasesomething they don’t want or need. Make sureyour efforts are focused on informingand empowering our customers, notintimidating them.Find out more. Policy Against Racial Profiling and thePromotion of Customer Inclusion GSP Fulfillment SOP Manufacturer Warranty Entitlement SOP Margin Erosion SOP No-Receipt Returns SOP Processing AppleCare Plans SOP Processing Geek Squad Protection (GSP)Plans SOP Responding to Customer Concerns SOP Returns and Exchanges SOPCode of Ethics. l 12 l

Promoteproduct safety.ContentsWhat if ?We set high standards for ourselves andour vendors.We expect the products we sell to work the way they’re supposedto and to be safe for our customers to use. We take pride in ourCompany and the products we offer, and we take action on anypotential safety hazards not just to ensure compliance, but alsobecause it’s the right thing to do.Every decision. Every day. Set expectations. Everyone has a role in ensuring saferproducts. If you are selecting our product assortment, you arein a position to inform third parties and vendors of our productsafety requirements. If you are working in the stores, you mayhear from customers about experiences with products that maybe harmful. Stay aware and report anything of concern.When in doubt, report.If you are not sure thatan incident rises to thelevel of a product safetyconcern, report it.ResourcesA customer returned acomputer with obviousdamage from meltingbecause it overheated. Isthere anything more I needto do other than processthe return?NextBackLast PageYes. Potential product safetyissues like this need to be reportedthrough the Product SafetyIncident Reporting Portal. TheProduct Safety team will review thedetails of the report and determineif further action is needed.Open &HonestEthics Line Complete the training. If applicable to you, complete yourproduct safety eLearning responsibilities in a timely fashion. Raise your hand. Contact your manager and make a reportusing the Product Safety Incident Report Form if you see orsuspect that a product we sell:- Is creating a risk of injury to customers- May be hazardous or dangerous for customers- May have caused a potential safety incident- Doesn’t comply with rules, regulations, standardsor bans enforced by any governmental agencyFind out more. Product Safety IncidentReporting Portal SOP P roduct Safety IncidentReport FormAt our best.l 13 l

Keep privateinformation private.We respect and protect personal information.Customers, vendors and co-workers who provide us with their personal information trust that wewill handle it with care and use it appropriately and only for the purposes provided, in accordancewith the law and our stated privacy notices and policies.Every decision. Every day. Recognize “personal information.” Personal information is any information that can reasonablybe linked to a person. In the Best Buy environment, we often link information to individuals byusing member numbers, Party IDs, tokens or other “unique identifiers.” Honor our privacy promises. Best Buy’s purpose is to enrich lives through technology. And wepromise to all that we will collect, use or share personal information only for that purpose. Know when it’s OK to share. We also promise that we won’t sell personal information to anyoneelse. New laws have expanded what it means to “sell” information, so it’s more important thanever to have the appropriate contract in place beforesharing personal information outside Best Buy. AndSuspect that personalbecause personal information is confidential information,information has beenwe don’t share it with anyone who doesn’t have a businessbreached or used inneed to know it. Get clearance! The Health Insurance Portability andAccountability Act (HIPAA) applies to some personalinformation from Best Buy Health. Be aware that it containsserious privacy restrictions, security requirements and(gulp) individual criminal penalties. Work with EnterprisePrivacy to clear any transfer of personal information fromBest Buy Health to another area of the Company. Don’t forget customer devices. Our policies apply not onlyto information stored on Company systems and records,but also to information stored on customer devices wehandle when providing services.a way that violatesour policies? Reportit immediately to theEmergency Hotline.It’s what you wouldwant someone todo if it was yourinformation.ContentsResourcesNextNew privacy rightsas of 2020The California Consumer PrivacyAct (CCPA) gives Californiaconsumers a groundbreakingset of privacy rights:- Access: Consumers now havea right to receive copies of allpersonal information aboutthem we have on file.- Delete: Upon request, BestBuy must delete all personalinformation we have about aconsumer. There are exceptionsto this requirement, but wemust still follow our recordsmanagement policies anddelete data on a timely basis.What if ?BackI’ve heard great things about an onlineanalytics tool. Even better, it’s FREE! Therearen’t any customer names in the file I’dupload so there aren’t any privacy issueshere, right?Any time you’re getting something for free online,chances are you’re not the cust

Ethics Line Code of Ethics. l 2 l Best Buy Beliefs. Work can be an instrument for doing good things in the world. A company is a human organization – a group of individuals working together in pursuit of a goal, not a soul-less body.

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