INTRODUCTION PEOPLE COMMUNITY PLANET GOVERNANCE APPENDIX ethical business practices Policy of Ethical Standards for Business Conduct We strive to be a company that embodies the highest Our governance commitments are outlined in our ethical standards and we are committed to fostering refreshed Corporate Governance Guidelines. In our Policy a culture of uncompromising integrity. We take steps of Ethical Standards for Business Conduct, we detail the to ensure strong business ethics as we continue to standards to which we hold all Associates and Directors strengthen governance procedures that increase accountable, including expectations around compliance transparency and accountability. with laws and regulations, bribery and anti-corruption, fair “Speak Up” Ethics & Integrity Helpline competition, conflicts of interest, and confidentiality. We expect honesty and personal accountability across Associates receive training on the Policy upon joining the Company and provide opportunities for Associates to the company and on an annual basis thereafter. As part ask questions or report ethical concerns. Associates can of this process, Associates are required to confirm they Required annual ethics training voice feedback directly to our Chief People Officer, CLO, or understand and are in compliance with the Policy. In through our anonymous helpline. addition, Associates receive annual training on a variety of The “Speak Up” helpline is a confidential, anonymous other topics, which are targeted based on their roles and Business ethics tool for all Associates and external stakeholders to raise job function and focus on our commitment to high ethical All Associates concerns and ask questions related to integrity, ethics, standards and fostering a culture of honesty and integrity. safety and related topics. The helpline is accessible 24/7 by Bribery and anti- phone and web and broadly communicated to Associates corruption (FCPA) and stakeholders through the Company’s intranet and Officers and buying teams postings in common areas and breakrooms. All reports are automatically escalated to the Security and Insider trading Loss Prevention investigations department, where they Corporate Associates and Store and supply are triaged and assigned for response or investigation. To chain team management preserve anonymity, the tool is managed by a third party; questions and responses to reporters are routed back Regulation fair through our helpline administrator. disclosure We do not tolerate retaliation or discrimination for reports Senior executives and certain or complaints made in good faith. other Associates Anti-harassment All Associates Bed Bath & Beyond 2021 ESG Report 33