Statement of Corporate Policy and Code of Conduct

The Neiman Marcus Group, Inc. (NMG) has a strong commitment to compliance with the legal requirements that apply to our business and to the products that we sell. One unwavering rule lies at the core of NMG’s business philosophy: we will conduct our businesses in strict compliance with both the letter and the spirit of the law and with a scrupulous commitment to the highest standard of ethics. 

To this end, NMG has developed a program of U.S. Customs and other government agency compliance that provides strict guidelines for those doing business at NMG, including our agents and the manufacturers and suppliers of the goods we buy.

As a condition of doing business with NMG, manufacturers and suppliers must agree to comply with all applicable laws and regulations, including those related to the manufacture and distribution of products sold to consumers in the United States. Our contracts also require all suppliers to impose this same obligation on their contractors. In addition, NMG requires its vendors to abide by this standard Corporate Policy and Code of Conduct related to labor and employment practices. NMG believes our customers can have confidence that merchandise manufactured in compliance with these standards is not produced under exploitative or inhumane conditions.

Labor Law Compliance – NMG expects its manufacturers and suppliers to take all steps necessary to ensure legal compliance in the facilities where they produce merchandise for NMG, whether the facilities are operated by them or by their contractors. Such steps should include programs and procedures, through monitoring or other means, specifically designed to maintain labor compliance in these facilities. If there is credible evidence indicating that one of NMG’s manufacturers or suppliers, or one of their contractors, is violating the legal compliance provision of our contracts, NMG may suspend current business activity, cancel outstanding orders, prohibit subsequent use of the violating factory, or terminate its relationship with the supplier.

Forced Labor – NMG will not work with the manufacturers and suppliers that use forced labor, whether in the form of prison labor, indentured labor, or other types of compulsory labor.

Child Labor – NMG will do business only with the manufacturers and suppliers which comply with local laws governing child labor or which agree not to employ anyone younger than the age for completing compulsory education in the country of manufacture. NMG supports the development of legitimate workplace apprenticeship programs for the educational benefit of younger people.

Disciplinary Practices – NMG’s manufacturers and suppliers must agree to treat their employees with respect and dignity and agree not to use corporal punishment or other forms of mental or physical coercion.

Health and Safety – NMG will do business only with manufacturers and suppliers that provide their employees with a safe and healthy working environment. Vendors which provide residential facilities for their workers must provide safe and sanitary facilities.

Discrimination – While NMG recognizes and respects the cultural differences found in the global marketplace, we believe that workers should be employed on the basis of their ability to do the job, rather than on the basis of personal characteristics or beliefs. NMG will favor manufacturers and suppliers, which share this value.

Wages and Benefits – NMG recognizes that wages are essential to meeting employees’ basic needs and will only do business with companies that both provide legally mandated benefits and pay employees at least the minimum wage required by local law or the prevailing industry wage, whichever is higher.

Working Hours and Overtime Pay – NMG will do business only with manufacturers and suppliers who (1) do not require their employees to work more than 60 hours per week on a regularly scheduled basis, except for appropriately compensated overtime in compliance with local laws, or the maximum number of regular and overtime hours allowed by the law of the country of manufacture, whichever is less, and (2) provide employees with at least one day off in every seven day period. In addition to their compensation for regular hours of work, employees of NMG’s manufacturers and suppliers must be compensated for overtime hours at such premium rate as is legally required in the country of manufacture or, in those countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate.