Board Oversight

In partnership with L Brands, Victoria’s Secret & Co. established a new Human Capital and Compensation Committee of the Victoria’s Secret & Co. Board of Directors to provide explicit oversight of the company’s programs, policies, practices and strategies relating to culture, talent diversity, inclusion and equal employment opportunities. Additionally, any allegation regarding discrimination or harassment involving senior management or that could be a material risk to the company is reviewed by the committee.

Diversity, Equity & Inclusion

Grew the scope and impact of our work focused on diversity, equity and inclusion to foster a culture that is anti-racist, consists of active allies, embraces social change, takes action and is accountable. Led by our Offices of Inclusion and with oversight from the Human Capital and Compensation Committee, the enterprise strategy has five key pillars:

• Recruitment
• Education and development
• Engagement and retention
• Community
• Business

Code of Conduct and Training

Updated our values-based Code of Conduct. While we are putting more emphasis on our leaders’ responsibility to report wrongdoings to help drive accountability for behavior, we expect all of our associates to surface issues that seem inconsistent with the company’s values or Code of Conduct. As defined by our No Retaliation Policy, no associate will be subject to retaliation, disciplinary action or any career disadvantage for raising a concern.

The Civility & Anti-Harassment Policy, adopted in 2018, is now part of the Code of Conduct. Training specific to the Civility & Anti-Harassment Policy is ongoing for our associates.

Global Ethics & Compliance Program

Adopted enhanced governance for our Global Ethics & Compliance Program which includes a formal case management workflow, escalation protocols and investigation guidelines.

Models and Photo Shoots

Established robust, best-in-class Photo Shoot Procedures which apply to all photo and video shoots involving talent. Individuals involved in a shoot must read and certify that they will follow the guidelines, and an independent monitor is required at shoots to ensure that the guidelines are followed. All violations are promptly reviewed and investigated, as appropriate, by the Victoria’s Secret & Co. Ethics and Compliance department.

Third-Party Reporting

Enhanced the Ethics Hotline, which is operated by an independent third party and is available to associates worldwide, as well as customers, vendors, contractors and other business partners. The hotline is monitored 24/7, provides translation services and now has a dedicated case manager. Our updated Code of Conduct and our Photo Shoot Procedures emphasize the availability of the hotline and reinforce that we absolutely do not tolerate retaliation against reporters, as defined by our No Retaliation Policy. The hotline is also available to non-associates, including talent, who participate in photo and video shoots for the company.

With a predominantly female workforce of more than 30,000 associates – Victoria’s Secret & Co. is intensely focused on ensuring its corporate governance, workplace and compliance practices provide support and the appropriate framework for reporting.

Victoria’s Secret & Co. is committed to creating a positive culture, and we will continue to periodically evaluate the effectiveness of our policies, procedures and programs to ensure that Victoria’s Secret & Co. provides a safe, welcoming and empowering workplace for every associate.