How to use the Code of Conduct

We should use the Code of Conduct to guide us in making the right decisions. As part of our commitment to our values, we want to make sure you have the resources you need to make good choices for Victoria’s Secret & Co. and our associates. Our Code is based on our values and sets forth our standards and expectations and points you to the Victoria’s Secret & Co. associates who are available to help you. In addition to the Code, you are also expected to comply with any other policies and procedures that apply to your role and function.

We conduct business around the world, so our policies are sometimes different from local laws, rules, cultural norms and regulations. When it appears there is a conflict, you should typically comply with the more restrictive requirement. However, if a cultural norm appears to violate our values or if you are unsure about the right course of action in a specific situation, contact your manager, Human Resources partner or Global Ethics & Compliance.

Victoria’s Secret & Co. directors, officers and associates must comply with our Code of Conduct. Third parties representing Victoria’s Secret & Co. may be asked to comply with relevant aspects of our Code of Conduct. Victoria’s Secret & Co. associates working with third parties should make sure third parties have appropriate information about our policy requirements and report third party misconduct or potential violations of law to Global Ethics & Compliance.

Code of Conduct Pyramid

Procedures Operational processes for day-to-day activities

  • Applies to brand function
  • Visible to managers and Human Resources
  • Detailed, instructional
  • Frequent changes based on business operations
  • Examples include: Standard Operating Procedures (SOPs) & Manager Guides

Stand-Alone Policies
Specific guidance for our actions based on the Code

  • Applies enterprise-wide
  • Visible to associates
  • Expands detail from Code of Conduct
  • Periodic changes
  • Examples include: Global Travel & Expense Reimbursement Policy and At Your Best Summary Plans

Code of Conduct
Guidelines for making the right decisions

  • Applies enterprise-wide
  • Visible to the public
  • Highest standards even beyond the law
  • Infrequent changes

Our Values Foundation for all we do

The customer rules!
Everything we do must begin and end with an insatiable drive to anticipate and fulfill our customers’ desires.

Passion leads to success.
We pursue excellence because we are emotionally, intellectually and spiritually engaged in our work ... and that makes our talent formidable and our results extraordinary.

Diversity, Equity and Inclusion make us stronger.
We cherish diversity, equity and inclusion because embracing others’ thoughts, experiences, hopes and dreams makes our own more complete and connects us to our customers.

Acknowledgement

We ask all associates to certify to our Code of Conduct, which means that:

  • You have read and agree to abide by our values and the Code of Conduct.
  • You understand how the Code of Conduct relates to your position with Victoria’s Secret & Co.
  • You agree to ask questions of the appropriate contacts when you are unsure about the right course of action.
  • You will complete all required training on a timely basis.
  • You understand our expectation that you will report suspected violations of our Code of Conduct.
  • You will cooperate in any investigations of possible violations.
  • You understand this Code of Conduct is not an employment contract, and we may change it at any time.
  • Your electronic signature constitutes your certification to the Code of Conduct.