Financial Integrity and Accurate Records

We ensure that company records are accurate, timely and completely reflect actual transactions and events. Our shareholders, customers, fellow associates, the public and government entities are entitled to accurate and truthful business records. We use company assets appropriately and reflect all expenditures, transactions, assets and liabilities properly in our business records. It is your responsibility to create accurate and complete records and follow internal controls. Never falsify any record or document for any reason. Do not attempt to circumvent internal controls and processes. For purposes of this policy, the term “records” includes any information we make or keep, regardless of the format. If you are unsure about what is required, talk to your manager or Ethics & Compliance.

I don’t work in finance or accounting.
Is “financial integrity” my responsibility?
Yes. Accuracy in recordkeeping is everyone’s job. From expense reports and benefits enrollment forms, to inventory records and sales invoices, all of our transactions – whether they are routine or extraordinary
- must be accurate, complete and properly recorded.

I saw a coworker sign off on an inspection report when he hadn’t actually done the inspection. What should I do?
You should report the issue to your manager, Global Ethics & Compliance or the Ethics Hotline. Signing off on the report when he hadn’t done the inspection would be considered a form of falsifying records and would violate the Code of Conduct.

Protecting Personal and Business Information

We protect our information assets and employ privacy safeguards to protect associate, customer and contractor information. We comply with applicable laws and protect information in accordance with the law, our policies and our company values. Information may be on paper or electronic. You must only collect or save information needed to conduct company business and only keep that information for as long as necessary for legal or business purposes. You must ensure that we protect our customers and associates by exercising compliant business practices related to data collection, use, choice and control, localization, disposal, transfer and communication. In addition, you should ensure that suppliers and other third parties with access to our customer or business information comply with applicable laws and our policies.

If you have access to confidential and sensitive information, you should comply with company policies and procedures related to securing and protecting that information against unauthorized access, use and disclosure. You should never use our information assets for your own benefit or use another company’s proprietary and non-public information for Victoria’s Secret & Co.’s benefit without that company’s written permission. Trade secrets are an example of business information we must protect. In addition to protecting Victoria’s Secret & Co.’s trade secrets, you may not disclose the trade secrets of any supplier or business partner or any company for which you were previously employed. Respect other associates’ obligations to protect the confidentiality of former employers. Do not download, distribute, keep or produce unauthorized content of books, magazines, newspapers, films, videos, music recordings, websites, products or computer programs.

Specific departments within our company may also have special privacy rules or procedures. You must comply with the privacy requirements that apply to specific areas of the business and your role or function. You may only destroy information and records in accordance with the company’s records management policies and never in response to or in anticipation of an audit, investigation or lawsuit. If you have questions about the record-keeping requirements applicable to your job, contact Ethics & Compliance.

Personal information about associates, customers, suppliers and vendors must be securely managed. If you suspect a breach of personal information, contact the Legal Department (VSPrivacy@victoria.com).

You should never:

• Share your system passwords with anyone.
• Leave laptops or other mobile devices unattended while traveling or in an exposed location where they can be stolen.
• Download unauthorized or unlicensed software on Victoria’s Secret & Co. devices.

I emailed a report to a supplier and accidentally attached a report that contained the email addresses of many Victoria’s Secret & Co. customers.
What should I do?
You should immediately ask the supplier to delete the email and report the incident to the Legal Department (VSPrivacy@victoria.com).

A valued supplier wants to promote a new product and reached out to me for an associate email list so it can extend its marketing reach. Should I share the list?
No. Anything that relates to the identify of associates, such as personal email addresses, phone numbers, salary details, etc., is personal information and should not be shared with suppliers – or even with other associates who do not have a business justification to have the information.

Audits and Investigations

We cooperate fully with internal and external audits and investigations of possible violations of company policies. Do not destroy or alter any documents that may be requested as part of an investigation or audit on behalf of the company. Do not lie, make intentionally false or misleading statements or fail to provide accurate information to internal or external auditors or investigators, or cause others to do so.

Use of Company Property

We use work time and company property for the benefit of the company. Company property includes our premises, information, equipment, documents, data, software, technology assets, supplies, merchandise, samples and support services. Improper use of company property can expose the company to legal or financial risk. On occasion, you may use company property for limited, incidental personal use. You’re responsible for taking reasonable steps to protect Victoria’s Secret & Co. property under your control from theft, misuse, loss or damage. Except as restricted by law, you have no expectation of privacy related to your use of Victoria’s Secret & Co. communication tools (such as email or company messaging platforms) or when you are using the company’s network. Victoria’s Secret & Co. has the right to — and does – monitor communications and communication tools, including their content and usage.

Inside Information

We comply with insider trading laws. Inside information is information (about our company or another company) that is not public and is also material – that is, information that a reasonable investor would consider important in deciding whether to buy, sell or hold stock. Company policies and the law strictly limit what we can do while we hold inside information. Examples of material information include earnings and other financial results, sales data, inventory levels, management changes, plans for an acquisition, sale or merger, and business strategies.

You may not trade Victoria’s Secret & Co. stock and other securities while you possess material, non-public information about the company. This applies to all Victoria’s Secret & Co. associates and their families. Trading includes buying, selling and shifting account balances, investment allocations and investment directions in company plans.

In addition, you may not share inside information with anyone unless they have a business need to know and you may never share inside information outside of Victoria’s Secret & Co.

Intellectual Property

Our intellectual property rights are among our most valuable assets. Our intellectual property includes legally protected creations, such as copyrights, trademarks, patents, brands, design rights and trade secrets. The work you create as part of your work responsibilities, including inventions, designs, know-how or innovations using company time, resources or information, also belongs to the company.

For the company’s protection as well as your own, we expect you to report the distribution of counterfeit merchandise or other improper distribution of our products. We expect you to comply with laws governing copyright, trademarks and other intellectual property, including the company’s own copyrights, trademarks and brands. Never use deceptive or illegal tactics to obtain information about our competitors’ intellectual property. If you are unsure about your proper use of our intellectual property, check with your manager or the Legal Department (generalcounselVS@victoria.com).

External Communications

Only authorized associates may communicate to the public on the company’s behalf. The company releases information related to its financial performance and position on significant issues and strategies only through associates who are authorized to speak publicly on behalf of the company.

The company will respond to investors and the media only through a designated spokesperson. If you’re ever asked to make a comment to investors or the media on behalf of the company, direct the request to Communications.

All requests to speak externally as a representative of the company at occasions such as industry conferences, education presentations and panel discussions must be approved in advance by Communications. You may not participate in case studies, white papers, other published pieces or award entries without Communication’s preapproval. If you or a third party wants to use the company’s logos or name in external venues such as press releases, case study websites or at trade shows by external parties, including the media, you must seek approval in advance from Communications (communications@victoria.com)

I don’t work in Finance or have access to financial information. Do prohibitions on insider trading apply to me?
Yes. Anyone with knowledge of confidential, material information can violate insider trading laws if they trade on that information or disclose that information to third parties who then trade stock based on the information. You must exercise caution and not disclose confidential company information even during casual conversations with family and friends.

In a meeting with one of our vendors, I learned information that could affect some stock trades my brother-in-law is considering. Can I share what I know since it won’t benefit me personally?
No. The law not only prohibits you from buying or selling stock based on inside information, it also prohibits you from tipping off your brother-in-law (or anyone else) in order for him to trade.

A friend asked me if I could confirm an internet blog that claimed Victoria’s Secret & Co. was launching a new line of home fragrance next year. Can I tell him what I know?
No. Product plan and launch information is confidential information and should not be discussed with anyone outside of the company unless the information has been made public. If you have questions about whether certain information has been made public, please contact your manager or Communications (communications@victoria.com).

Using Social Media

We use social media responsibly.Customers, competitors and associates all over the world can easily access information posted on social media. All associates should follow general best practices when using social media, even for personal use.

If you mention Victoria’s Secret & Co. or any of our brands or products in a post about the company you must clearly state your affiliation with the company (for example, “I work for Victoria’s Secret, and I love the new Holiday Collection”) and comply with the following guidelines:

• Do not discuss confidential or proprietary company information.
• Always communicate honestly and, if you share an opinion, state that it is your opinion and not that of the company.
• Never make harassing, vulgar, demeaning or intimidating comments about other associates, customers or suppliers, as such comments may be deemed discrimination or harassment.
• Do not make disparaging or misleading remarks about our competitors.
• Use the Code of Conduct and our values as your guide.