Business Conduct Guide

Dear Target Corporation Team Members:

Because of you, Target Corporation enjoys a strong reputation in our communities and in our industry not only as an outstanding and innovative retailer, but also as a corporation with values and beliefs that are at the core of our business success. We are committed to ethical and legal business practices and we expect you to share this commitment.

This Business Conduct Guide reference card is provided to equip you with the tools you need to make sound business decisions that meet the ethical and legal standards by which Target Corporation lives.

It is your responsibility to read, understand and comply with these Business Conduct Guidelines and our policies and procedures.

No guide can cover all our policies or all laws. To help you when you are uncertain how to act or wish to report a situation, remember that Target Corporation provides other tools to help you. Your supervisor or Human Resources representative are often the best and fastest way to raise and resolve problems. In addition you can anonymously call the Employee Relations and Integrity Hotlines at 1-800-541-6838. Outside the United States, you can call 704-556-7046.

Your adherence to the core values in this document will help us become the Best Company Ever for our guests, team members, shareholders and communities.

Sincerely,

Bob Ulrich

Chairman and Chief Executive Officer

Target Corporation

Advertising

Our advertising will provide clear and accurate information to help guests make buying decisions. Our advertising will comply with the law.

Antitrust

We must compete vigorously and fairly in the marketplace using our independent judgment to make the best decisions for the Company.

Bribery

No assets of the Company may be used to bribe or influence any decision by an official, person or entity.

Communications

Each team member is responsible for maintaining the Company's brand image when communicating. Electronic communications should comply with the Company's e-mail policy.

Company Assets

Company assets are to be purchased, used and disposed of solely for the benefit of the Company. Confidential information must be protected.

Conflict of Interest

All team members and their immediate families are required to act in a manner that will avoid loss or embarrassment to the Company.

Credit

We must provide accurate disclosure of credit terms and meet all requirements relating to fair credit reporting and equal credit opportunity.

Disclosures - Prompt and Accurate

We are committed to full, fair, accurate, timely and understandable disclosure for required and voluntary disclosures.

Environmental Laws

We strive to do business in an environmentally responsible manner and must operate the Company in compliance with all environmental laws.

Financial Integrity and Reporting and Related Controls

The Company must keep books and records that accurately reflect its business transactions and assets as well as ensure the accuracy of our financial records and audits.

Imports/Customs

All products purchased by the Company must comply with all U.S. Customs Service laws and regulations governing the purchase, importation and sale of imported merchandise.

Intellectual Property

Team members are expected to take appropriate steps to protect the Company's copyrights, trademarks and other intellectual property, and to respect the intellectual property rights of others.

Personnel Related Laws; Non-Discrimination and Harassment

We are an equal opportunity employer and we will adhere to all laws relating to non-discrimination, wages, hours, working conditions, pension and welfare benefits plans, sexual harassment and other terms and conditions of employment. Discrimination is strictly prohibited and will not be tolerated.

Political Activities

Team members may not make any contributions on behalf of the Corporation or agree to contribute Company money, property or services to any political party, organization, committee or individual or for any other political purpose.

Privacy

We value the trust our guests and team members place in us when they share information with us. That's why we have extensive safeguards and privacy policies to keep such information secure. All team members must comply with these safeguards.

Product Safety

The Company is committed to providing high quality safe products to our guests.

Securities Laws

No team member possessing material, non-public information may buy or sell Target Corporation securities, take advantage of that information, or pass that information on to others.

Vendor Standards

Our Standards of Vendor Engagement set out Target Corporation's commitment to do business with suppliers/vendors who do business ethically and legally. Suppliers/vendors who fail to meet these standards are subject to termination.

Violations of Law or Company Policy

To help protect the company and individual team members, it is essential that you promptly and fully report any situation that may violate the law or company policy - whether you are involved in the situation or not.

1. For company policy violations, report the violations to your manager or Human Resources.

2. For violations of the law, you can report the violation in any of the following ways:

Contact your supervisor

Call the Employee Relations and Integrity Hotline at 1-800-541-6838. Outside the United States, you can call 704-556-7046.

Contact your compliance officer (the Chief Financial Officer of your operating company)

All reported violations will be investigated and acted on appropriately.

When you report a violation, you may choose to remain anonymous. If you choose to identify yourself, your identity will be protected as much as possible, based on the need to prevent potential harm to others, to comply with the law and to conduct a complete investigation. You will not be subject to retaliation for reporting a suspected violation in good faith. You will receive confirmation that your report was received and, in most instances, you will be notified of the action the company took.

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Last modified: March 9, 2004

Disclaimer: This website is the sole responsibility of Mike McMahon. It does not represent any official opinions, statement of facts or positions of the Alameda Unified School District. Its sole purpose is to disseminate information to interested individuals in the Alameda community.