BUSINESS CODE OF CONDUCT AND ETHICS© 2020 Home Depot Product Authority, LLC. All Rights Reserved.

BUSINESS CODE OF CONDUCT AND ETHICS Doing theRight ThingThe Home Depot has a Doing the right thing each and every day for the benefit of our associates, customers, vendors, suppliers, service providers and the communities we strong commitment to serve is critical to our ongoing success.ethics and integrity, and Each day we are challenged to be fair and consistent, to comply with the our core values define laws that govern our activities, and to notify others when something needs to be corrected. Our Business Code of Conduct and Ethics provides you the means by which with guidance in making the right choices when called upon to do so. we do business. Please become familiar with our Code, as well as all of our Corporate Compliance Policies and Standard Operating Procedures. As you review these materials, please keep in mind that it is not simply the letter of the Code, but the spirit that we all must embrace. If you are faced with a situation where you think our Company values or compliance with the law may be in question, you should bring this to the attention of your immediate manager or supervisor, your Human Resource representative, Corporate Compliance, or, if you prefer, you may anonymously report your concern through the AwareLine at 800-286- 4909, or the HR Service Center at 866-myTHDHR (866-698-4347). Working together, we will maintain our values and ensure the success of The Home Depot. Thank you. Sincerely, Chairman, Chief Executive Officer and President

TABLE OFCONTENTSINTRODUCTION DOING THE RIGHT THING1.......Our Core Values FOR OUR CUSTOMERS2.......Complying with the Code and the Law 7......Antitrust and Fair Competition2.......The Open Door Policy 8......Confidentiality, Privacy and Information Protection2.......Zero Tolerance for Retaliation DOING THE RIGHT THING2.......Waivers to this Code FOR OUR SHAREHOLDERS2.......Getting Answers to Your Questions or Reporting a Concern 9......Protecting the Company’s Assets and Intellectual Property 9......Insider TradingDOING THE RIGHT THING 10......Financial Integrity and ReportingFOR OUR ASSOCIATES 10......Records Retention3......Safety4......Labor and Employment DOING THE RIGHT THING Alcohol and Drug Abuse FOR OUR COMMUNITIES Fair Employment-Practices/Discrimination 11....Environmental Responsibility Harassment 12....Government Interactions Violence in the Workplace Political Involvement4......Who to Call for Assistance Government Contracting5......Conflicts of Interest The Foreign Corrupt Practices Act (FCPA) and Anti-Bribery Financial Interests Relationships with Suppliers, Vendors and Service Providers Gifts and Entertainment
(Video) Code of Conduct and Ethics for Employees |

Have a question? We’re here to help The Corporate Compliance Team can provide guidance in situations where you are unsure of the right thing to do. We understand that doing the right thing at work is not always as easy as it may sound. Just send us an email with your question at corporate_compliance@ Business Code of Conduct and Ethics (the Code) is intended to provide you straightforward information about The HomeDepot’s operating principles and offer tools to help you make decisions that align with our ethical expectations and legalobligations. All associates are expected to act with honesty and integrity. Adhering to the highest ethical standards and doingthe right thing are the driving forces behind The Home Depot’s success and have been a core component of how we havedone business since the beginning. Inside you will find examples of ethical decisions you may face as an associate as well asreferences to our global Corporate Compliance policies. You will also find information on what to do if you have questions orconcerns regarding ethical conduct.This Code applies worldwide to all of The Home Depot associates, inclusive of business operating units, subsidiaries andall members of the Board of Directors. This Code is designed to provide abroad overview and scenarios on how to conduct Company business in amanner consistent with our core values. As it cannot cover every potentialscenario you may encounter, remember that in most situations your owngood judgment is the best gauge when facing a potential ethical issue.OUR CORE VALUESOur values reflect the beliefs, principles and standards that form thegroundwork of our behavior and should be drawn on when makingdecisions. We believe in Excellent Customer Service, Building StrongRelationships, Entrepreneurial Spirit, Respect for All People, CreatingShareholder Value, Doing the Right Thing, Giving Back and Taking Careof Our People. 1

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COMPLYING WITH THE CODE AND THE LAWWe have operations in countries around the world, and our GETTING ANSWERS TO YOUR QUESTIONSassociates are citizens of these various countries. As OR REPORTING A CONCERNa result, our operations are subject to a diverse set of local If you have questions or concerns, speak up. Thelaws and cultures. Associates are expected to comply with Home Depot provides several options to reportthis Code and all applicable laws and regulations. If local law potential violations of this Code, Company policies orever conflicts with this Code, seek the guidance of Corporate applicable laws and regulations.Compliance or your Legal partner for resolution. Depending on your concern, often it is best to speakBoard members, officers and associates are expected to first with your immediate manager or supervisor. Yourreport suspected or observed violations of this Code, immediate manager or supervisor is best-suited toCompany policies or applicable laws and regulations to respond to your issue immediately and may alreadyCompany management. Failure to follow the provisions be familiar with the concern you are reporting.of this Code can lead to discipline, up to and includingtermination. If you feel uncomfortable talking with your immediate manager or supervisor for any reason, contact one ofTHE OPEN DOOR POLICY the following resources:We each have a right and responsibility to ask questions • Contact the 24-hour AwareLine at 800-286-4909about issues that are not clear to us. The Home Depot’s or, where you can chooseOpen Door Policy provides you access to two-way, honest to remain anonymousand respectful communications. This Policy is intended • Contact your HR representative or the HR Serviceto create an atmosphere that encourages you to voice Center (HRSC) at 866-myTHDHR (866-698-4347)your concerns, express doubts, discuss problems, ask • Contact Corporate Compliance at 770-384-4098,questions, make observations and offer suggestions about or via email atworkplace issues. You should feel comfortable approaching corporate_compliance@homedepot.comyour immediate supervisor, any other supervisor/manager,human resource associate, corporate officer or any otherCompany resource at any time.ZERO TOLERANCE-FOR RETALIATIONIf you suspect wrongdoing, including violations of thisCode, Company policies or the law, report it immediately.Retaliation against anyone who reports a good faith concernis prohibited and will not be tolerated. Good faith means thatyour concern is honest and accurate to your knowledge,regardless of whether it is discovered at a later date that youwere mistaken. Allegations made maliciously in bad faithmay be subject to disciplinary action.WAIVERS TO THIS CODEFor associates, Executive Vice Presidents may authorizean exception to certain provisions of this Code or maydesignate a Senior Vice President or Vice President to reviewand approve such exceptions on their behalf. All exceptionsmust be approved in advance and must be submitted toCorporate Compliance Board members and Executive Officers, waivers of theBusiness Code of Conduct and Ethics may be granted only Q. I reported a concern about fraud in our store to myby the Audit Committee or the full Board of Directors and supervisor, Bob. Since reporting my concern, Bobwill be subject to applicable laws and regulations regarding has stopped including me in certain meetings. Is thisdisclosure to shareholders. retaliation? A. Significant changes in how you are treated after reporting a potential issue can be perceived as retaliation. If you feel you are being treated differently since reporting an allegation, raise your concern by notifying your HR representative, contacting the HRSC, AwareLine or Corporate Compliance. 2

DOING THERIGHT THINGFOR OURASSOCIATESSAFETYWe are committed to providing our associates and Q. Marcus, a freight supervisor, asked Tonya tocustomers a safe working and shopping environment. As use a forklift to help move some pallets, unawarean associate, you are expected to comply with all safety that Tonya was not properly trained to operaterequirements. If you are concerned about safety or have lift equipment. What should each party do in thisquestions, comments or feedback regarding regulatory situation?requirements, notify your supervisor immediately. TheHome Depot should never ask or expect an associate to A. Realizing the potential safety issue, Tonya shouldperform any task that is considered unsafe. tell Marcus she is not properly trained. Marcus should advise Tonya not to operate the forklift, find To learn more about Home Depot’s commitment another associate to help and ensure Tonya gets the to the safety and health of its customers and necessary training so she can assist in the future. associates, read the Safety Policy available on myApron or by calling Corporate Compliance. 3

LABOR AND EMPLOYMENT WHO TO CALL FOR ASSISTANCE DOING THE RIGHT THING FOR OUR ASSOCIATESThe Home Depot believes that all people should be treated CARE/Solutions for Life is your free andwith dignity, and we will not accept conduct that fails to show confidential resource, available 24 hoursappropriate respect to others. Our core value of Respect for All a day, seven days a week, to providePeople exemplifies how we should treat our fellow associates, information and services to improve thecustomers, suppliers, vendors and service providers. quality of your work and home life.Any conduct that fails to show appropriate respect to others, Assistance includes:including fellow associates, customers, professional customers, • Short-term counseling for individual,vendors, suppliers and service providers, violates the Company’s relationship and family concernsvalues. The following are examples of unacceptable conduct: • Child/family and adult/elder care servicesinsults; threats; intimidation; ridicule; vulgarity; discrimination; • Financial and legal assistance and otherharassment; physical or verbal abuse; sexually explicit humor, resourcesconversation or behavior; slurs or stereotyping; unwelcomesexual advances; unwelcome touching or invasion of personal These are all available at no cost to you andspace; ignoring the rights of others; and insensitivity to the your household members.beliefs and customs of others. For information or assistance, please callALCOHOL AND DRUG ABUSE CARE/Solutions for Life at 1-800-553-3504We are committed to providing a safe, healthy and drug-free or visit Using illegal drugs at any time, using alcohol whenon the job or on Company premises or coming to work under theinfluence of alcohol or drugs is strictly prohibited. This prohibitionis a condition of employment. Any associate found in violation ofthis condition of employment is subject to immediate termination.Please refer to the Company’s Standardsof Performance for further detail.FAIR EMPLOYMENT PRACTICES/DISCRIMINATIONThe Home Depot is an equal opportunity employer committed toensuring associates work in an environment of mutual respect.We will not discriminate against any associate or applicant withregard to race, color, sex (gender), sexual orientation, genderidentity or expression, age, religion, national origin, disability,protected veteran or other uniformed service status or any othercharacteristic or basis protected by applicable law. Q. I think I was passed up for a promotion due toHARASSMENT my race. What should I do?The Home Depot will not tolerate harassment in the workplace. A. If you feel you have been discriminated against dueHarassment or disrespectful behavior can be verbal, non-verbal or to race or any other legally protected characteristic,physical. Examples include: you should raise your concern by notifying your• Sexual advances, requests for sexual favors or any other HR representative, the HRSC, or by contacting the unwelcome visual, verbal or physical conduct of a sexual AwareLine or Corporate Compliance. nature• Offensive jokes, racial slurs or inappropriate comments regarding an individual’s ethnicity• Yelling or intimidating others, including making threats Q. My co-worker circulated an email that was offensive to me. What should I do?VIOLENCE IN THE WORKPLACE A. First ask the co-worker to stop sending youWe have a zero tolerance policy for actions that threaten our these types of emails. If you are not comfortableassociates, customers, suppliers, vendors, service providers, speaking directly with the co-worker, or the co-visitors or property. Examples of threatening actions include worker does not stop sending these types of emails,physical assaults or the intentional destruction of Home Depot you should contact your immediate supervisor,property or merchandise. If you observe a situation that could HR representative, the HRSC, the AwareLine orbecome potentially violent, report it to your immediate supervisor, Corporate Compliance.HR Representative or the AwareLine. Want to learn more about Home Depot’s Labor and Employment standards? Read the Labor and Employment Policy or the Standards of Performance available on myApron or by calling Corporate Compliance. 4

CONFLICTS OF INTEREST DOING THE RIGHT THING FOR OUR ASSOCIATESYou have a responsibility to make decisions based on the interests of The Home Depot without regard to how they mightbenefit you. A conflict can occur when your private or professional interests interfere in any way – or even appear to interfere– with the interests of the Company. Even if you did not intend for your actions to create a conflict, the perception of aconflict by others can be just as damaging to you or The Home Depot. Be on the lookout for situations that may create theappearance of a conflict and avoid them whenever possible.Questions concerning conflicts of interest should be referred to Corporate Compliance. For further information, see the Conflict of Interest Policy, available on myApron or by calling Corporate Compliance.FINANCIAL INTERESTSYour personal financial interests, or those of your family, should not conflict with your responsibilities to The Home Depot.In particular, financial interests in a Home Depot current or prospective supplier, vendor or service provider, as well as anyinstance in which you or a family member may receive personal gain through opportunities discovered through HomeDepot, may present a conflict of interest.If you have the authority to award business to or control decisions regarding a particular supplier, vendor or serviceprovider, or supervise others who have that authority, you (and your immediate family members) should not have a directfinancial interest (including debt and all forms of equity such as shares of common or preferred stock, options, warrants,LLC membership interests, etc.) in that entity, unless you receive approval from Corporate Compliance.Additionally, associates should not have a financial interest that creates a competing interest against The Home Depot.If you are unsure if a financial interest creates a conflict of interest, contact Corporate Compliance or read the Conflict ofInterest Policy available on myApron for guidance.Financial investments where you have no direct investment (e.g., mutual funds, 401k investments, etc.) are not consideredconflicts of interest for the purpose of this Code.RELATIONSHIPS WITH SUPPLIERS, VENDORS AND SERVICE PROVIDERSSocial and romantic relationships with current or prospective suppliers, vendors and service providers can create anappearance of a conflict of interest and, in the worst case, could interfere with your ability to perform your job objectively. Ifyou have a social or romantic relationship with a supplier, vendor or service provider for which you have direct and primaryresponsibility for the business relationship, disclose the relationship to Corporate Compliance. If you are unsure whether arelationship creates a conflict, contact Corporate Compliance for guidance.In addition, if you are asked to serve as a board member, consultant, advisor or employee of any current or prospectivethird party that may do business with Home Depot, you must have Corporate Compliance review the relationship for anypotential conflicts of interest prior to accepting the position.The Home Depot expects its suppliers, vendors and service providers to act ethically and in a manner that meetsor exceeds the standards set forth in this Business Code of Conduct and Ethics. 5

GIFTS AND ENTERTAINMENT DOING THE RIGHT THING FOR OUR ASSOCIATESThe acceptance of gifts and entertainment from current or potential suppliers, vendors or service providers can cause aconflict of interest or give the appearance that you put your personal interests ahead of The Home Depot’s best interests.As a general rule, you should not accept gifts and entertainment except for the limited situations, described below, inwhich gifts and entertainment may be accepted as part of normal business activities or common courtesies betweenbusiness partners.Gifts and entertainment should never be solicited and when accepted, should beinfrequent and a reasonable dollar value. Gifts and entertainment should never influence orappear to influence a business decision. If you have a question about a situation, discuss itwith your supervisor or Corporate Compliance.The following examples of gifts and entertainment are never allowed:• Cash or cash equivalents such as gift cards or gift certificates• Free or discounted merchandise or services not available to the general public• Vendor product samples for personal use• Travel for an associate or an associate’s family memberThe following examples of gifts and entertainment are allowed when infrequent and reasonable:• Meals that are associated with business activities• Admission to industry events such as conferences and trade shows and related activities during the event (meals, giveaways, etc.) as long as it is provided to multiple clients or potential clients• Continuing professional education or development opportunities, such as product knowledge training or other activities to further associate knowledge and skills• Tickets to sporting or cultural events offered to associates with a market value under $100 if the offer is for the associate to attend the event with the supplier, vendor or service provider (in no case should an associate solicit tickets)• Gift baskets and other perishable items, provided they are shared with other associates at your work location• Other nominal gifts under $100Financial or in-kind donations made directly to The Home Depot Foundation are not considered to be a form of gifts andentertainment and are therefore not subject to this policy.WHAT TO DO IF YOU RECEIVE AN UNSOLICITED GIFT THAT IS NOT LISTED ABOVE?If you receive an unsolicited gift that is not allowed above, advise your immediate supervisor and return the gift with a letterexplaining our guidelines. You can find a Gift Return Letter template on the Corporate Compliance page on myApron or bycontacting Corporate Compliance.There are some situations when refusing a gift would be inappropriate, awkward or cause professional embarrassment.Certain gifts may also be impractical to return. If you are faced with these situations, contact Corporate Compliance todetermine proper disposition of the gift.If you are a store associate and receive an unsolicited gift that is not allowed above, give it to your Store Manager, and theywill donate the item to a Home Depot-approved charity through the Framing Hope program. For more information, pleasevisit the Framing Hope page on myApron.APPROVAL OF GIFTS AND ENTERTAINMENTApprovals are not needed for any items allowed above. If there is a business reason why you should accept a gift orentertainment that is not explicitly allowed, complete a Gift Approval Form and return it to Corporate Compliance. You canfind a Gift Approval Form on the Corporate Compliance page of myApron or by contacting Corporate Compliance.GIVING GIFTS AND ENTERTAINMENTGifts and entertainment for customers, suppliers, vendors and service providers should be supported by a valid businesspurpose and should be reasonable under the circumstances. We should always be respectful of the policies of ourcustomers, suppliers, vendors and service providers when considering potential gifts or entertainment.Any gifts or entertainment for foreign government officials or employees of foreign state-owned enterprises must comply withThe Home Depot Foreign Corrupt Practices Act (FCPA) and Anti-Bribery Policy. Providing anything of value to local, stateor federal officials in the U.S. must comply with The Home Depot Political Activity and Government Relations Policy. Moreinformation about these topics can be found in the “Doing the Right Thing For Our Communities” section of this document. 6

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DOING THERIGHT THINGFOR OURCUSTOMERSANTITRUST AND FAIR COMPETITIONThe Home Depot competes vigorously and lawfully to serve our customers in the competitive environment in which weoperate and always acts with integrity and a spirit of fair dealing in doing so. Accordingly, all associates are required tocomply with antitrust and related competition laws in jurisdictions in which we do business. These laws in the United Statesand other countries typically restrict and/or regulate competitive business practices in order to preserve fair, honest andvigorous competition. Violations of these laws can result in damage to our reputation, severe monetary penalties, and criminalpenalties for those involved.It is important to collect information about our competitors to compete effectively; however, such collection must be donein a lawful and ethical manner. Associates are prohibited from engaging in illegal business practices, including entering intoagreements, reaching “understandings” or exchanging information with competitors about how we do business and sharingconfidential and proprietary business information with or requesting such information from competitors. In addition, pricingdecisions must be made independently of our suppliers, vendors or service providers. If you are dealing with a potentialantitrust issue, seek the advice of the Legal Team at To learn more about fair competition and how to interact with competitors, read the Antitrust Policy available on myApron or by calling Corporate Compliance. 7
CONFIDENTIALITY, PRIVACY AND INFORMATION PROTECTIONMuch of the information with which we come into contact at work each day is confidential. Confidential information is notgenerally known to competitors and others outside the Company and may include: financial information, including butnot limited to information about sales, earnings, expenses and investments; pricing information; supplier, vendor or serviceprovider lists; customer data; plans for future store/facility locations; business development materials; costs of goods;personnel files, Company policies, manuals, guidelines, procedures and SOPs; computer software; design documentsand specifications; videos; and memos. Confidential information is critical to our competitive advantage and must not bedisclosed, except as specifically authorized or legally required. Information that has been made public by the Company,such as press releases, news articles or advertisements, is not considered confidential and does not require protection. Itis the responsibility of each of us to use discretion in handling Company information so that we do not inadvertently revealconfidential information to competitors, suppliers, vendors, service providers, friends and/or family members. If you areunsure about whether certain information is confidential, presume that it is.We respect the privacy of our customers and associates and are committed to the responsible collection, use and disposalof their Personal Information. Personal Information is information that can be used to identify a specific individual. Someexamples of Personal Information include a person's name in combination with their credit card number, driver’s licensenumber and/or social security number. All associates are expected to safeguard Personal Information in accordance withour Privacy & Information Protection Policy and applicable laws. For more details and suggestions on how PersonalInformation should be properly handled, refer to the Company’s Privacy & Information Protection Policy.If you identify a loss, theft or misuse of any Personal Information, report it immediately to Home Depot maintains a large variety of assets including physical assets and valuable proprietary and confidentialinformation assets. Proprietary and confidential information may be maintained in either hardcopy or electronic formats. It isvital to our reputation that all associates ensure this information is adequately protected and controlled. Examples of waysto protect proprietary or confidential information include:• Password protect proprietary or confidential information on a shared computer drive• Lock your computer screen when away from your computer• Properly dispose of Personal Information Q. A department manager asked me to send her a Q. I cannot find a thumb drive I used to store some list of everyone in her department who worked on a files I was working on for my job. Thumb drives are recent Team Depot event so that she can thank them not that expensive, so I think it will be faster and for their participation. I want to help her out, but I easier if I just pay to replace it myself. The files on am very busy. Is it ok if I just send her a spreadsheet the thumb drive may have contained some customer I prepared for HR that lists the names of everyone information. Do I still need to tell someone that I lost in our department and circle the Team Depot the thumb drive? participants? Does it matter that the spreadsheet also includes other information, such as associates’ A. Yes. Personal Information should not be stored on social security numbers, phone numbers, addresses flash or thumb drives as they are easily lost or stolen. and emergency contact information? Any lost or stolen Personal Information should be immediately reported to your manager and A. No, the spreadsheet should not be shared. Associates should always be on alert for situations in which they might be handling Personal Information and protect it accordingly. This responsibility includes limiting access to this kind of information to only those who have a legitimate business need to see it. Here, the spreadsheet contains additional Personal Information, including Sensitive Personal Information such as social security numbers, which the department manager does not need to do her job. Only the minimum amount of information necessary for the department manager to do her job should be shared. Want to learn more about how to protect personal and business information? Read the Privacy & Information Protection Policy available on myApron or by calling Corporate Compliance. 8
DOING THERIGHT THINGFOR OURSHAREHOLDERSPROTECTING THE COMPANY'S ASSETS AND INTELLECTUAL PROPERTYWhile at work you will have access to important Company property and information. All associates should protect The HomeDepot's property in order to avoid theft, carelessness and waste as these have a direct impact on our profitability. All Companyassets should be used for the benefit of The Home Depot and never used to promote your own interests or those of anotherperson or company.Our intellectual property must be used properly and protected from infringement by others. The Home Depot logo, Homer,advertisements and computer software are examples of assets that make up our intellectual property. Inventions, discoveries,ideas, concepts, written material and trade secrets that are created by associates using Company time, resources or materialsare also the property of The Home Depot.INSIDER TRADINGWe comply with federal and state securities laws and do not tolerate insider trading. Insider trading means trading securities onthe basis of material, non-public information or sharing material non-public information with another person so they can trade."Material" information is information that a reasonable investor would likely consider important when making a decision to buy,sell or hold securities. Some examples of material, non-public information would include the following if not otherwise publiclydisclosed:• Earnings, revenues or other financial information Q. I am good friends with Jack,• Business conditions or strategies, including sales volumes, margins and a vendor representative at ABC conditions affecting our industry Company. Jack told me that• Potential mergers, acquisitions, tender offers, joint ventures or changes in assets ABC Company just landed• Introduction of significant new products or services or business development a big sale with The Home initiatives Depot. Although an official• Developments regarding customers or suppliers, including the gain or loss of announcement has not been customers or suppliers made, can I purchase shares• Changes in the control or management of The Home Depot of ABC Company?• Borrowing activities or issues related to liquidity• Events related to our securities (e.g. stock splits, dividend changes, share A. No. This could be considered repurchases) trading on the basis of material, non-public information and aIt is unethical and illegal to buy or sell stock or other securities on the basis of violation of Company policy, asmaterial non-public information. It also is illegal to communicate non-public well as federal securities laws.information to any other person so that they may trade.In addition, neither associates nor members of the Company’s Board of Directors To learn more aboutmay enter into hedging or monetization transactions designed to limit the financial insider tradingrisk of ownership of Home Depot securities. These include prepaid variable forward restrictions includingcontracts, equity swaps, collars, exchange funds and other similar transactions, as who to call about awell as speculative transactions in derivatives of Home Depot’s securities, such as potential trade, read theputs, calls, options (other than those granted under a Home Depot compensation Securities Laws Policyplan) or other derivatives. available on myApron or by calling Corporate Compliance. 9
FINANCIAL INTEGRITY AND REPORTING DOING THE RIGHT THING FOR OUR SHAREHOLDERSAccurate business records are essential to the management of the Company and maintaining the Company’s reputationand credibility. It is the responsibility of each associate to maintain complete and accurate financial and business records.These records include financial statements as well as time sheets, bills, invoices, expense reports, payroll and benefitsrecords and other essential Company data. The Home Depot is committed to providing full, fair, accurate, timely andunderstandable reports and disclosures to regulatory authorities and the public. Associates must comply with all governmentlaws, rules and regulations and the requirements of other appropriate private and public regulatory authorities applicable toour financial and business records. This includes making sure that our financial statements conform with generally acceptedaccounting principles, the Company’s accounting policies and its system of internal controls. Associates are expected toreport any observed or suspected violations of law or regulation, Company Policy or activity that might constitute financialfraud or financial misconduct to the General Counsel or another member of senior management, Internal Audit or CorporateCompliance. If you are uncomfortable approaching a member of management, Internal Audit or Corporate Compliance, youcan call the AwareLine on a confidential basis. Any proposed change in Company accounting policies and practices must bereported to and approved in advance by the Corporate Controller and the Chief Financial Officer. To learn more about the Company’s commitment to maintaining accurate books and records, read the Financial Controls Policy available on myApron or by calling Corporate Compliance.RECORDS RETENTIONYou may collect large amounts of information as part of your daily job, such as emails, spreadsheets and contracts thatmay need to be retained for business or legal reasons. It is important to keep this information for the period of time requiredand then properly dispose of it thereafter.The Home Depot maintains a Records Management Policy that provides guidance on what documents are businessrecords and how long they should be maintained. Associates should consult this policy before destroying business records. To determine the required retention time for your documents, see the Records Management Policy available on myApron, or email Records Management at 10
DOING THERIGHT THINGFOR OURCOMMUNITIESENVIRONMENTAL RESPONSIBILITYWe are committed to obeying environmental laws and regulations and acting responsibly to conserve and preserve naturalresources. Due to our unique position in the marketplace, we work to use our influence to minimize impacts on the environmentby supporting and promoting innovation in the responsible use of our resources. The Home Depot will continue to promoterecycling, conservation of energy and natural resources, safeuse and disposal of hazardous materials and the developmentof environmentally sound alternatives. We expect ourassociates, suppliers and other business partners to join in our Q. An associate spilled fertilizer in a store aisle.efforts to preserve our environment, and we encourage our The associate swept up the spilled fertilizer andcustomers to do likewise. threw it in the trash. Was this the correct way to handle the spill? A. Certain fertilizers can be hazardous materials. To learn more about the Company’s The associate should follow the Safety SOP commitment to the environment, visit the located on myApron regarding the correct steps Responsibility page of Home Depot's website to take when dealing with and disposing of at hazardous waste. 11
GOVERNMENT INTERACTIONS DOING THE RIGHT THING FOR OUR COMMUNITIESThe Home Depot demands the highest standards of professional conduct and ethics in our interactions with governmentofficials. We strictly prohibit the giving of money, gifts, services or entertainment to government officials in exchange forofficial action or otherwise to gain an improper business advantage. In addition, potential business transactions involvinggovernment officials or their family members can raise special regulatory and ethical concerns. Any requests fromgovernment officials or their family members for payments by, business relationships with, or benefits from the Companyfor the officials or their family members should be brought to the attention of the General Counsel or Corporate Compliance.Additional detail on specific aspects of interactions with government officials is provided below.POLITICAL INVOLVEMENTIn an effort to ensure that federal, state and local governments of those countries in which we conduct business actresponsibly and in the best interest of our customers and associates, The Home Depot actively participates, andencourages its associates to participate, in the political process. In doing so, Home Depot demands the highest standardsof professional conduct and ethics from our associates. All associates are required to comply with the Company's PoliticalActivity and Government Relations Policy, which contains standards of conduct for participation in the political process.The Home Depot sponsors The Home Depot Political Action Committee (PAC), which supports public officials andcandidates who understand the issues affecting The Home Depot and promote a favorable business climate for theCompany. Participation in the PAC is strictly voluntary and has no effect on one's employment with The Home Depot.Some state and local governments have laws that restrict political contributions from companies and/or their employeeswho sell products to them. Home Depot Board members, senior executives and associates responsible for solicitingcontracts with state or local governments should check with the General Counsel or the Company's Government RelationsDepartment before making personal political contributions at the state and local level.The Political Activity and Government Relations Policy and most current annual report of corporate contributions to politicalcandidates, parties, committees and other entities operating under Section 527 of the Internal Revenue Code is available under the "Corporate Governance > Overview." Do you want to learn more about The Home Depot’s involvement in the political process? Visit, read the Political Activity and Government Relations Policy available on myApron or by calling Corporate Compliance.GOVERNMENT CONTRACTINGThe rules imposed on the Company when it sells to the government are often different from, and more restrictive than, therules that apply to purely commercial transactions. As a government contractor, we are committed to complying with theserequirements and view doing business with the government as a special trust and responsibility. To learn more about doing business with the government, read the Government Contracting Policy available on myApron or by calling Corporate Compliance.THE FOREIGN CORRUPT PRACTICES ACT (FCPA)AND ANTI-BRIBERYIt is against our policy to participate in any form of corruption.Neither we, nor outside parties acting on the Company’s behalfwill bribe another party to gain any benefit for the Company. Among other things, U.S. law and the foreign laws of countrieswhere we do business make it illegal to offer or pay a bribeto a foreign official for a business favor or to gain an improperbusiness advantage. The term “foreign official” includes Q. A foreign customs official detains importemployees of any government agency, government-owned product due to incorrect paperwork but offers tobusiness (such as state-owned enterprises), or political party, release the goods for a payment. You are told thisplus any political candidate. Bribes go beyond giving cash is customary in the country. Is this allowed?payments and may also include giving gifts or other items ofvalue. Our policy also prohibits giving facilitating or expediting A. No. You must fix the paperwork. Providingpayments to foreign officials. Since The Home Depot can be money, gifts or entertainment to the foreign officialheld liable for payments made by third parties, outside parties would be a bribe and violate local law and theengaged directly or indirectly by The Home Depot who may FCPA.interact with foreign officials on the Company’s behalf must beapproved by Legal, be thoroughly screened before being hired 12
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and must contractually agree to comply with The Home Depot's Foreign Corrupt Practices Act (FCPA) and Anti-Bribery DOING THE RIGHT THING FOR OUR COMMUNITIESPolicy and these laws.Given the complexity of the FCPA and anti-bribery laws, we have a robust training program in place to ensure awarenessand compliance. Associates should contact the Legal Team with any questions concerning obligations to comply with thispolicy at For more information about conducting business in compliance with anti-bribery laws, read The Home Depot Foreign Corrupt Practices Act (FCPA) and Anti-Bribery Policy available on myApron or by calling Corporate Compliance. 13


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Introduction: My name is Virgilio Hermann JD, I am a fine, gifted, beautiful, encouraging, kind, talented, zealous person who loves writing and wants to share my knowledge and understanding with you.