Civility and Anti-Harassment Policy

At L Brands, our values define who we are and what we stand for, including the fact that we treat everyone with respect and dignity. As stated in our Code of Conduct, we do not tolerate discrimination or harassment

Unwelcome Conduct: Harassment, Discrimination and Bullying
While each situation must be evaluated on its own specific circumstances, for purposes of this policy examples of harassment or discrimination include any of the following:

  • Giving unwanted sexual attention to others – colleagues, customers, vendors, contractors, and other business partners or third parties.
  • Offering a workplace benefit in exchange for sexual conduct or giving work-related rewards for sexual conduct.
  • Sexually explicit or suggestive comments or behavior.
  • Sexual joking, storytelling, and the like.
  • Repeated requests for dates.
  • Comments, cartoons, jokes, emails, texts, social media posts or other communications that include degrading, insulting, or insensitive content or assumptions concerning any individual’s race, color, religion, gender, gender identity, national origin, citizenship, age, disability, sexual orientation, marital status or any other protected status under applicable laws.
  • Verbal, non-verbal, visual, or physical behavior that makes another person feel intimidated, offended or uncomfortable.
  • Slurs and other offensive remarks.
  • Joining in when others are harassing or discriminating against another person.

In addition to discrimination or harassment, bullying is another form of incivility and disrespectful behavior that can range from minor incidents to serious ones and will not be tolerated. Bullying typically involves repeated actions intended to intimidate, harass, degrade, or offend. Bullying can be verbal, nonverbal, psychological, or physical. For the most part, we usually know a bully when we see one in action. But for illustration, here are some examples of bullying that undermine our commitment to treat everyone with respect and dignity and violate company policy:

  • Demeaning a colleague, particularly in front of others.
  • Personal attacks (angry outbursts, name-calling, and the like).
  • Physical intimidation.
  • Encouraging others to turn against
  • or “gang up on” a targeted co-worker or groups of co-workers.
  • Pressuring someone to do or say something they don’t want to.
  • Sabotaging another’s work product or deliberately undermining their work performance.
  • Behavior that is malicious, hostile, or offensive.

Behavior that would be unacceptable at work is also unacceptable off-the-clock. Harassing, bullying, discriminating against or otherwise disrespecting a colleague, customer, vendor, contractor, or business partner electronically, off company property or off-the-clock, is also prohibited. While the company respects your privacy, if you violate our Code or this policy you may be subject to disciplinary action up to and including termination regardless of when or where that conduct occurs.

This policy also applies to all customers, vendors, contractors, business partners or potential business partners and other third parties when they are doing business with us or are on our premises, and we expect and require that they will be treated with respect and that they will behave in ways that align
with our culture of respect.

All violations of this policy – no matter how trivial the violation may seem – are harmful to individuals and the company and will be addressed accordingly. Associates who violate this policy are subject to disciplinary action up to and including termination of employment.

Speak Up: Doing What’s Right
The company strongly recommends the prompt reporting of all perceived incidents of harassment, discrimination or bullying by anyone experiencing or observing them. The company offers many ways to ask a question relating to harassment, discrimination or bullying, or to report a possible violation of this
policy. Under our Open Door policy, if you see something that you think is wrong, you are encouraged to raise it to your manager, next level manager, Human Resources partner, the Ethics Hotline (www.lb.ethicspoint.com) or the Ethics Office (ethics@lb.com). Managers are required to report any
complaints that they receive to their HR partners.

Any customers, vendors, contractors, or other business partners who believe they have been subjected to harassment, discrimination, or bullying should raise the incident to any member of the Human Resources Department, the Ethics Hotline (www.lb.ethicspoint.com), or the Ethics Office (ethics@lb.com).

The company will promptly investigate each report and the investigation will be conducted by an impartial individual. All such reports will be kept confidential to the extent reasonably possible and
permissible.

Under our Code, we strictly prohibit retaliation for reporting concerns. Anyone who retaliates or tries to retaliate against an individual who raises a concern in relation to this policy or who participates in the investigation, will be subject to disciplinary action up to and including termination of employment.