Ethics OBSD Business Partner Toolkit MAY 2023 FINAL

[Audio] Ethics Toolkit OBS&D Business Partners h t.

[Audio] Table of Contents Ethics Overview………………………………………………………. Conflicts of Interest………………………………………………….. Gifts, Meals, Travel, etc.……………………………………. Business Dealings………………………………………….. Anti-Bribery…………………………………………………... Working Together…………………………………………………….. Proactive Communication……………………………….... Anti-Harassment…………………………………………….. Maintaining Trust……………………………………………………... Subcontracting……………………………………………… Product Quality……………………………………………… Audits ………………………………………………………... Inspections…………………………………………………... Confidentiality, Security, Privacy………………………… slide slide slide slide slide slide slide slide slide slide slide slide slide slide 3 12 13 22 34 41 42 45 53 54 65 72 75 88.

[Audio] Ethics at Target Our purpose at Target is to help all families discover the joy of everyday life, and how we bring that purpose to life matters. It means living out Target's values and following the highest ethical standards, using Target's Code of Ethics as our guide. Our commitment to these ethical standards should be reflected in everything we do, no matter what challenges we might be navigating together..

[Audio] Business Partner Expectations source ethically and responsibly stay alert, proactively communicate We put our trust voice concerns follow business partner code of conduct, SOVE and global trade requirements in our business partners to make the right ethical decisions share expectations with employees and business partners and hold accountable provide safe and reliable products follow the law.

[Audio] Business Partners Target Team Members Guests fines damaged reputation rework personal injury chargebacks One unethical decision increased workload damaged reputation loss of trust Impact of Unethical Behavior legal action stress increased payroll illness loss of employment criminal penalties wasted time recalls penalties frustration wasted time loss of business criminal penalties lost sales factory shutdowns frustration legal action increased workload.

[Audio] Impact of Unethical Business Conduct Target investigates Target becomes aware of possible If an allegation is verified, action is taken to the each claim root cause find unethical behavior Potential impact of unethical behavior: Factory Vendor • • Production promptly Removal from Target’s Factory Matrix Cannot produce for Target for at least 3 years Additional oversight Legal action • • Chargebacks Removal of product from store shelves Reputation impacted Removal from Target’s Vendor Matrix Legal action • • • • • •.

[Audio] What to do when you have a concern? If you hear or see or suspect a violation of the Law, The Code or Target policy, you have a responsibility to report it. US 1-800-541-6838 Q. How do I share or report a concern when something isn't right? A. You have many ways to share your concern. Your Target partner, Ethics@target.com or the independent Integrity Hotline. Scan the QR Code or Visit: Ethics@Target SharePoint site or www.TargetIntegrityHotline.com to report anonymously, by completing the online Hotline Webform or Call the Integrity Hotline, 24 hours a day, managed by a third-party provider (interpreters available) Email: Ethics@target.com Write: Corporate Compliance & Ethics Target Corporation 1000 Nicollet Mall #3110 Minneapolis, MN 55403 India 000-800-100-1657 Bangladesh (0) 9610-998509 China 4001201894 Hong Kong 800906528 Indonesia (021) 50918413 Vietnam 024 4458 3187 Other locations: 470-219-7116 collect call non-U.S. place a to the U.S..

[Audio] Reporting Channel - Online Web Form Option Steps for completing the confidential www.targetintegrityhotline.com. online web form visit 3 On the next page highlight your country from the drop-down menu. 2 Select the report button above the image. 1 Select your language in the upper right. . Proceed to filling out the rest of the form..

[Audio] What happens when a concern is shared? Target reviews each concern, and determines next steps. If an investigation is needed, Target will conduct a fair, timely, impartial, and thorough investigation. If the investigation finds that misconduct or a policy violation has occurred, Target takes prompt action to address. The concern or complaint is tracked and monitored throughout the investigation progress. Ethics works with only the appropriate partners to conduct the investigation to ensure fair treatment and reach reasonable conclusions based on evidence. *Investigation follow-up may be kept confidential.

[Audio] Next Steps Ensure all employees and business partners understand Target expectations and how report concerns to Conduct ongoing training sessions and onboard new employees Seek guidance promptly to discuss business, product, quality, production or shipping challenges with the appropriate business partners and leaders Escalate any ethical, legal, product compliance or safety concerns by contacting Ethics@target.com or using one of the reporting channels If you suspect, potential misconduct involving anyone representing Target, or another business partner you have a responsibility to provide visibility to any risks that could jeopardize Target's and your business email Ethics@target.com immediately..

[Audio] Conflicts of Interest. Conflicts of Interest.

[Audio] Conflict of Interest Conflicts of interest can occur when a relationship, financial interest activities are prioritized or compete with Target's business interests. or external Business Partners are prohibited from offering anything of value anyone working on Target’s behalf. to • Never offer anything of value (including but not limited to, a gift, meal, transportation/lodging, entertainment, donations, services, etc.) or anything else that could appear to influence or make unfair business decisions. Avoid relationships or activities that could create the appearance of bias or favor and undermine the independent judgement of those involved. Disclose any requests or favors made by anyone representing Target. • • Conflicts of interest also apply to those family members or close personal relationships of those working on Target’s behalf..

[Audio] Gifts, Meals, Travel, Entertainment or Other Offers of any Value Business Partner Scenarios h t.

[Audio] Scenario 1 – Gifts A vendor learned that a Target team member is getting married, so the Senior Leader the member a congratulations gift for sent team their wedding. Is this ok?.

[Audio] Is it ok for the vendor to give a wedding gift to a Target team member or anyone representing Target? No, even if it’s customary to give a celebration gift, Target's ethical and policy expectations must be prioritized and upheld. When it comes to Target business, policy expectations must be prioritized over cultural customs, events and holidays. When an external business partner gives item of value to a Target employee or any other third party working on behalf of Target, it can create bias or favor when it comes to making business decisions. any . Contact Ethics@target.com to discuss or report concerns.

[Audio] Scenario 2 – Gifts A Target vendor has a good relationship with a Target employee because the employee has helped the vendor solve many problems so they a good will thank you gift. sent Is this ok?.

[Audio] Scenario 2 – Gifts Is it ok to give a gift to show my appreciation to a Target employee or a third- party inspector working on Target's behalf? Never offer anything of value to a Target employee or third-party inspector, a simple thank-you is acceptable. When it comes to Target business, policy expectations must be prioritized over cultural customs. When a vendor or factory gives any item of value to a Target employee or any other third party working on behalf of Target, it can create bias or favor when it comes to making business decisions. Contact Ethics@target.com to discuss or report concerns.

[Audio] Scenario 3 – Meals & Offers A very important audit will be taking place at a factory. The night before the audit, the factory manager visits the inspector at their hotel and insists on taking the auditor out for an extravagant meal, followed by a massage, Karaoke and drinks. Is this ok?.

[Audio] Scenario 3 – Meals & Offers Is it okay for a factory manager to take an Audit? auditor out the night before an No, this is considered bribery, which is never acceptable in any form. Vendors or factories should never offer anything of value including but not limited to, meals, entertainment or gifts of anything decisions or pass inspections. that could influence business Use one of the Ethics reporting channels to report this immediately. Contact Ethics@target.com to discuss or report concerns.

[Audio] Scenario 4 – Travel Factory A is located in a remote area where it’s difficult to travel to by public 3rd transportation. As a result, Factory A’s management offers the party inspector a free ride to the facility, and back to the inspectors’ home after inspections are complete. Additionally, there are no restaurants prepares a meal for inspectors. close to the factory, so the factory Is this ok?.

[Audio] Is it ok for vendors or factories to provide transportation or meals to inspectors? Anyone working on Target’s behalf is not allowed to accept transportation or meals from a vendor or a factory without prior approval from Ethics. Target has strict requirements when it comes to accepting anything of value from a vendor or a factory. There may be a situation where safety, accessibility or availability becomes a concern. In those situations it's up to the person working behalf of Target to contact Ethics@target.com prior to the visit for guidance. on Contact Ethics@target.com to discuss or report concerns.

[Audio] Business Dealings h t Family or Close Personal Relationships Business Partner Scenarios.

[Audio] Scenario 1 – Business Dealings A factory's annual audit result is about to expire. Currently, there many Target orders in production that will be shipped soon. During the factory assessment, the factory inspector's sibling is looking for a job. The could hire an inspector’s sibling to work in manager learned that the factory manager advised they the factory, so they could ensure there are no problems with the annual audit results to maintain production and delivery. Is this ok?.

[Audio] 1 – Business Dealings Scenario Is it ok to hire a Target team member’s family member? No, it is never ok to offer a job Target to engage in making or to family member of anyone working on behalf of influencing business decisions. This goes against Target’s conflicts of interest requirements using a relationship to influence business results. Bribery is also a concern and Target strictly partners offering something to get something else in return. prohibits business Contact Ethics@target.com to discuss or report concerns.

[Audio] Scenario 2 – Business Dealings poll A Target employee is visiting a new factory to perform their first factory assessment. The Target employee advises there are a number of issues, which will prevent the factory from passing the assessment. a.) No, the factory vendor and Target should work with the to understand The Target team member suggests hiring expert consultant (also a former Target employee and the team member’s family an standards and meet requirements b.) Yes, it’s ok as long as they make the timely improvements before production c) Yes, as long as no one knows they hired a former Target employee d) Maybe, I can hire them as a consultant, but not a full time employee member) to guide the factory to meet Target standards. I s this okay?.

[Audio] a.) No, the factory should work with the The Target team member suggests hiring expert consultant (also a former Target employee and friend) to guide the factory and meet Target standards. vendor and Target to understand standards and meet requirements b.) Yes, it’s ok as long as they make the timely improvements before production c) Yes, as long as no one knows that they hired a former Target employee d) Maybe, I can hire them as a consultant but not a full time employee s this okay?.

[Audio] Business Dealings Scenario 3 – A factory manager producing Target goods heard that a Target employee resigned, and wants to hire the employee to improve the factory’s performance, and help with Target-related business, such as quality control, factory inspections and other processes to meet Target’s requirements. Is this ok?.

[Audio] Scenario 3 – Business Dealings Is it ok to hire a former Target team member? It may be ok, as long as they are not engaging with current Target team members to avoid any bias or favor that occur based on the former team member’s relationships, which create an unfair business advantage. may Ethics approval is needed prior to any current Target team member engaging in work former Target team member until the former team member has reached the 2 year anniversary of their last date of employment with Target. Contact Ethics@Target.com with a to discuss prior to having a former team member work with current Target team members. Contact Ethics@target.com to discuss or report concerns.

[Audio] Business Dealings Scenario 4 – 3rd Target’s contracted party inspector found 6 defects during an inspection. During the closing meeting, the factory team asked the inspector not to record all defects found during the inspection, and ‘reconsider’ defects to avoid inspection failure. wants the inspector to Is this ok?.

[Audio] Scenario 4 – Business Dealings Is it ok to ask the auditor to misrepresent data? It’s never ok to intentionally misrepresent data It’s critical that you proactively share concerns provide visibility to the concern so that we can or ask someone to do this is unethical. with the appropriate Target RS partners to determine how to address the situation. If you see, hear or suspect anyone being asked to or misrepresenting Ethics reporting channels to report this immediately. data, use one of the Contact Ethics@target.com to discuss or report concerns.

[Audio] During a Responsible Sourcing audit at Factory 123, the auditor noted a number of exit doors that appeared to be sealed shut. As the auditor noted the issues, the production floor manager pleaded with the auditor not to include the findings. The production floor manager indicated he had sealed the doors shut to prevent workers from taking unapproved smoke breaks. If the factory audit doesn’t go well, he may lose his job. Is this ok?.

[Audio] Scenario 5 – Business Dealings Is it ok to ask an auditor to report inaccurate findings? It’s never ok to ask anyone working on behalf of Target to not share accurate findings or misrepresent inspections especially as they relate to severe health and safety concerns that could put anyone at risk. It’s critical to proactively share concerns with the appropriate Target RS partners upfront to provide visibility to the concern so that we can determine how to address the situation. see, hear or suspect anyone reporting inaccurate information Use one of the Ethics reporting channels to report this immediately. If you Contact Ethics@target.com to discuss or report concerns.

[Audio] Business Partner Code of Conduct Target employees nor anyone working on Target’s behalf should solicit anything of value from a business partner. This includes, but is not limited to employment, interns, favors, travel, gifts, meals, cash, etc. Business partners must never offer, suggest or perform any favors for Target team members or a team member’s family member or third-party auditors to avoid a conflict of interest or implicate bribery. Target has zero tolerance when it comes to bribery of any kind. When conducting business, you must prioritize Target values and never agree a request or even suggest to give something to get something in return. Immediately report a situation like this, using one of Target's ethics reporting options. to.

[Audio] Anti-Bribery Commercial Bribery, FCPA Business Partner Scenarios h t.

[Audio] Anti-Bribery and Commercial Bribery Target does not tolerate bribery of any kind Bribery of Government Officials Commercial Bribery.

[Audio] Commercial Bribery Never offer a bribe directly or indirectly to anyone working on behalf of Target. A bribe consists of offering anything of value decisions to: to influence business • • • • influence a business decision receive gain an provide favorable treatment advantage personal gain to the recipient.

[Audio] Scenario 1 – Commercial Bribery During an Audit, you learn that the Quality Control(QC) manager from Factory A left a red envelope work. in an auditor's bag and a sample as a gift for all of their hard Is this ok?.

[Audio] Scenario 1 – Commercial Bribery Is it ok to leave a red envelope or anything of value with the auditor? No factory or business partner should exert this type of influence over inspectors. Bribery in any form is never okay. Vendors or factories should never feel obligated to pay anything to manage business or maintain relationships. Report this immediately using one of the Ethics reporting options. Contact Ethics@target.com to discuss or report concerns.

[Audio] Scenario 2 – Commercial Bribery A third-party inspector was hired by Target and to inspect products. While visiting a factory, during the inspection, the inspector paid a lot of attention to small defects of the goods, and said, "these are big problems" and "you know what to do to make this go away". The factory manager is worried about the result of the inspection, which would impact the delivery of the products. Subsequently, the manager decided to use some special "methods" to make the problem go away to ensure the inspection passes. Is this ok?.

[Audio] Is it ok to use special methods to ensure inspections pass? No, vendors or factories should ever pay a fee or provide anything of value inspection. Using any special method that results in undue pressure on the factory to make the problem go away is considered commercial bribery. to pass the vendor or Use one of the Ethics reporting channels to report this immediately. Contact Ethics@target.com to discuss or report concerns.

[Audio] Working Together. Working Together.

[Audio] Proactive Communication Business Partner Scenarios h t.

[Audio] Scenario 1 – Proactive Communication A factory is preparing to produce Target goods. The Vendor has provided Sourcing and PSQA with information about production capacity and capabilities through virtual meetings and documents as they were not able to visit the factory in person. Just before production, Target learned that the factory does not have the machinery or the equipment it should have. When asking the vendor and the factory about it, neither was able to provide an explanation. Is this ok?.

[Audio] Is it ok to promise certain capabilities that you don’t have at program confirmation? the time of No. When working with Target, always be open, transparent and truthful about your current capabilities, capacity and any other claims. We depend on you to deliver the required agreements, and never falsify any information to obtain business or promise something you currently cannot deliver. Violations of agreements have severe consequences. Proactively communicate upfront and if any changes happen if you cannot meet the agreed upon requirements contact your RS partner immediately. Contact Ethics@target.com to discuss or report concerns.

[Audio] h Anti-Harassment Business Partner Scenarios t.

[Audio] Anti- Harassment Target is committed to creating a harascsment-free working environment. Target is committed to a safe and inclusive workplace where every employee and business partner feels safe, respected, and valued. Target does not allow any type of harassment based on protected class characteristics Anyone who has personally experienced, witnessed or learned of any behavior that may violate Target's harassment policy should contact Ethics@target.com immediately..

[Audio] 1 – Anti-Harassment Scenario Some factory workers registered a verbal abuse, harassment complaint against a factory leader. Management reached out to the entire worker force advising a full investigation would be conducted, and immediate action would be taken against the accused. Within a week, each of the workers who filed a complaint resigned or transferred to another unit. Is this ok?.

[Audio] Scenario 1 – Anti-Harassment Did the Factory leadership approach this situation appropriately? No, all factories are required to provide an adequate grievance mechanism that allows employees to voice concerns and report grievances anonymously without fear of retaliation. All workers must be protected from dismissal, penalties and any other type of reprisal reporting grievances truthfully. Report immediately using one of the Ethics reporting channels for Business Partners of any kind must never engage in or condone, or tolerate physical, verbal, mental or sexual harassment against or among any of their workers. Contact Ethics@target.com to discuss or report concerns.

[Audio] – Anti-Harassment Scenario 2 A Target team member made jokes during a factory visit that were considered inappropriate because they made the factory personnel feel very uncomfortable. Is this ok?.

[Audio] Scenario 2 – Anti-Harassment Is it ok to share jokes in the workplace? Nothing should be shared if it could be considered offensive or make others feel uncomfortable in the work environment. Everyone should feel safe, valued and respected in the workplace. If you are in a situation that makes anyone, uncomfortable or disrespected, we ask that you use one of the Ethics work with the appropriate reporting options partners address to report this type your concern immediately. of behavior immediately. Ethics will Contact Ethics@target.com to discuss or report concerns.