Anti-Corruption Compliance Policy

Lowe’s does not tolerate bribery or corruption, and the Code of Business Conduct and Ethics specifically prohibits paying bribes of any kind. This Policy describes specific areas of concern and sets forth procedures and requirements to mitigate the risks of public and commercial bribery. Under this Policy, bribery and corruption are defined as offering anything of value, to any person or entity, in order to influence a decision or gain an improper business advantage. Bribery and corruption are problematic because they can create an unfair competitive environment, undermineand public trust, and negatively affect government workings.

Lowe’s and its affiliates conduct business in compliance with the U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act, and all other applicable global anti-corruption laws which prohibit offering anything of value to a government official for purposes of obtaining an improper advantage.

This Policy applies to all associates of Lowe’s Companies, Inc. and its affiliates and subsidiaries. This Policy also applies to every third-party working on Lowe’s behalf.

Policy

General Guidelines

• Lowe’s associates and any third parties acting on Lowe’s behalf must not offer anything of value to any person or entity for the purpose of influencing a decision or gaining an improper business advantage.
• Anything of value can include cash, cash equivalents, gifts, favors, services, debt forgiveness, charitable contributions, sponsorships, job offers or other promises, and the determination of value is subjective; it only matters if a recipient values the item or gesture even if what is being offered is worthless to Lowe’s.
• While Lowe’s prohibits all bribery, associates and vendors must practice special precautions when dealing with government officials. Government officials can include individuals working for or representing federal, state/provincial, and local/municipal political bodies, any related agencies or bureaus, any public services, and any state-owned businesses. With respect to government officials, even extending normal business courtesies like meals, refreshments, or company memorabilia could carry the risk of being interpreted as a bribe. Associates must obtain approval from Corporate Compliance and Ethics before offering anything whatsoever to a government official.
• In some settings, government agencies may offer expedited processing of routine and non-discretionary requests in exchange for a fee. These are commonly known as “facilitation payments”. Facilitation payments implicate increased bribery risk and must never be made without express authorization from Corporate Compliance and Ethics.
• Third Parties can present corruption risk since Lowe’s is directly responsible for their interactions with government officials. If a third party pays a bribe on Lowe’s behalf, Lowe’s will be liable. Because of this, associates and business teams must exercise caution when engaging third parties who will be interacting with, or representing Lowe’s before, government officials (“High Risk Vendors”). For High Risk Vendors, the following specific guidelines apply:
  • These can only be engaged with the approval of Corporate Compliance and Ethics following comprehensive due diligence;
  • There must be a written contract including representations and warranties relating to bribery, corruption, and illegal conduct;
  • Compensation must be reasonable given the market, location, and service; and
  • All services and activities must be invoiced in specific detail.
• Lowe’s associates must not authorize any third-party payments which are being made for purposes of influencing decisions or gaining an improper business advantage. If an associate suspects that a payment might be used for these purposes, they should contact Corporate Compliance and Ethics immediately.
• Foreign (non-US) sponsorships, charitable contributions, and political contributions also carry heightened corruption risk and must be approved by Corporate Compliance and Ethics before any payments in connection with these activities are made.
• Associates must adhere to Lowe’s system of internal financial controls. This includes maintaining books and records that accurately reflect transactions in reasonable detail. Associates must never make false or deceptive entries, must never make payments that are not properly documented and recorded, and must always follow payment approval processes.
  While associates and third parties must never intentionally pay bribes, if there is an extortion threat which imminently affects personal safety, associates should take whatever measures are necessary to ensure their safety including making payments. Afterwards, associates should disclose any extraordinary measures or payments to Corporate Compliance and Ethics for documentation and follow up.
• Associates must not engage any third parties for the specific purpose of channeling bribes to any person or entity.

Policy Violations

• Violation of this Policy by associates may result in corrective action up to and including immediate termination of employment.
• Violation of this Policy by vendors or third parties will result in immediate suspension of any services and could lead to termination of any commercial relationship with Lowe’s.
• Violation of anti-corruption laws can lead to significant fines and restrictions against Lowe’s.
• Violation of anti-corruption laws may also subject individuals to fines, penalties, and up to fifteen (15) years in prison.

Reporting Procedures

• If you have questions or concerns regarding bribery or corruption, or if you are uncertain about the propriety of any subject of discussion or proposed activity with an external party, you should stop the discussion immediately and bring the issue to the attention of Corporate Compliance and Ethics.
• Concerns about conduct that may be a violation of this Policy or the Code of Business Conduct and Ethics should be reported to Corporate Compliance and Ethics, openly or anonymously, by any of the following methods:
  • Online: www.ethicspoint.com; or
  • Email: [email protected]; or
  • Telephone: 800-784-9592 for the U.S. and Canada; 10-800-120-1239 for Southern China; 10-800-712-1239 for Northern China; 800-964214 for Hong Kong; 001-8008407907 or 001-866-737-6850 for Mexico; 00801-13-7956 for Taiwan; 1-800-80-8641 for Malaysia; 001-803-011-3570 or 007-803-011-0160 for Indonesia; 120-11067 for Vietnam; 001-800-12-0665204 for Thailand; 000-800-100-1071 or 000-800-001-6112 for India; 01800-9-155860 for Colombia; 0800-8911667 for Brazil or 503-619-1883 for use internationally.

Anti-Retaliation

• Lowe’s prohibits retaliation against any person who reports anti-corruption violations or potential violations, or who has participated in an investigation of such a claim.
• Retaliation for reporting, in good faith, suspected violations will not be tolerated and will be considered a serious form of misconduct which can result in corrective action up to and including immediate termination of employment.