Conflicts of Interest
All associates are expected to make decisions based on sound business judgment, not personal gain. A conflict of interest happens when your personal interests—or those of your immediate family—interfere, or appear to interfere, with your ability to act in Lowe’s best interest.
Conflicts of interest are not always intentional, but they can create questions about whether decisions are being made fairly and objectively. Even the appearance of a conflict can harm your reputation and Lowe’s reputation.
You are required to follow Lowe’s Global Conflicts of Interest Policy and avoid both actual and perceived conflicts. Common areas of conflict include:
GIFTS, BENEFITS AND ENTERTAINMENT
You may offer or accept certain gifts, benefits or entertainment involving vendors, potential vendors or customers, but you are required to follow the disclosure and approval process for anything over $100 USD using a gift authorization form.
All gifts and entertainment must be:
- Reasonable in value
- Infrequent
- Related to a legitimate business purpose
You may never offer or accept:
- Cash or cash equivalents
- Anything offered during an audit, inspection, bidding, proposal or line review process
FINANCIAL INTERESTS AND INVESTMENTS
You cannot have a material financial interest in any vendor, potential vendor or competitor. Material financial interest includes direct ownership stake and/or the ability to make decisions on this vendor or competitor’s behalf.
You must also disclose if an immediate family member has a material financial interest in any vendor, potential vendor or competitor.
TRANSACTIONS INVOLVING IMMEDIATE FAMILY
You must not take part in transactions or business dealings where an immediate family member works in certain roles for a vendor or potential vendor.
PERSONAL RELATIONSHIPS WITH VENDOR PARTNERS
You must disclose any immediate family, personal or romantic relationship with a vendor, potential vendor or their personnel if it overlaps with your responsibilities at Lowe’s.
COMPETING WITH LOWE’S
Lowe’s recognizes the rights of associates to take part in financial, business or employment activities outside of their jobs at Lowe’s. These activities must be lawful and not create any potential conflicts with your responsibilities at Lowe’s.
CORPORATE OPPORTUNITIES
You must not take for yourself any business opportunity that belongs to Lowe’s.
PERSONAL GAIN
You must not use Lowe’s property, information or your position for personal gain or for the benefit of your immediate family.
PERSONAL RELATIONSHIPS
All associates are responsible for reporting any personal and/or family relationships within their reporting line to their HR business partner or functional head.
EXTERNAL OPPORTUNITIES
Salaried associates are required to disclose and receive approval before accepting certain outside roles, including part-time positions, board memberships or business opportunities with another company.
This includes roles with vendors, competitors, customers, partners, beneficiaries or any role related to your work at Lowe’s.
Hourly associates are not required to disclose or receive approval before accepting outside roles, as long as the external opportunity does not interfere with their responsibilities to Lowe’s.
PUBLIC OFFICE
You must inform the Office of Business Integrity if you hold or plan to seek any public office that could influence Lowe’s or its competitors.
Immediate family members include your spouse, domestic partner, parents, stepparents, children, stepchildren, siblings, in-laws or anyone (other than a domestic employee) who lives in your home.
A vendor is any individual or organization that does business with Lowe’s, including suppliers, service providers, consultants, trade associations and other partners.
A personal relationship is dating, cohabitating (regardless of the circumstances) or participating in romantic or sexual relationships.
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Protection and Proper Use of Company Assets
Lowe’s assets include physical property, technology and intellectual property.
You are responsible for protecting these assets and using them only for legitimate business purposes.
Misuse, theft, fraud or carelessness can harm Lowe’s reputation and financial performance. Physical assets include items such as merchandise, equipment, vehicles and cash.
Technology assets include computers, systems, mobile devices and software. Protect systems and use them responsibly.
INTELLECTUAL PROPERTY
Lowe’s intellectual property is a valuable asset and must be protected.
This includes:
- Logos and trademarks
- Patents and copyrights
- Trade secrets and proprietary information
Do not allow others to use Lowe’s intellectual property without proper approval from the Legal Department. Additionally, do not use the intellectual property of other entities without proper approval from the Legal Department.
Unless otherwise agreed to, any work you create as part of your job belongs to Lowe’s, as allowed by law.
CONFIDENTIAL INFORMATION
Confidential information is any non-public information related to Lowe’s business.
This includes:
- Customer and associate information
- Financial and pricing data
- Business strategies and plans
You are expected to protect confidential information and only use it for business purposes. Do not share it without proper authorization. These limitations on the use of confidential information do not prohibit associates from engaging in activity or speech otherwise protected by the National Labor Relations Act, including discussing terms and conditions of employment.
Data Protection
DATA SECURITY
You are expected to protect company, customer and supplier data from unauthorized disclosure, access or misuse.
Report any suspected unauthorized disclosure or access immediately to the Information Security Group at [email protected].
DATA PRIVACY
Lowe’s collects and uses personal information as part of its business. This may include names, contact details, financial information and other personal data of our customers, associates or business partners.
You must handle the collection, use and storage of this information responsibly and in accordance with all applicable privacy laws and policies, including Lowe’s Privacy Statement.
Responsible Use of Emerging Technology
You are expected to use emerging technology assets, including applications or tools, responsibly and in away that protects Lowe’s information, assets and reputation.
Only use Lowe's authorized systems and technology when performing your work. Do not input or share confidential, proprietary or personal information in unapproved tools or systems. You are responsible for ensuring that any technology used for business purposes complies with Lowe’s policies.
Technology must not be used in ways that violate Lowe’s policies, applicable laws or ethical standards, including the misuse of data, intellectual property or the creation or sharing of misleading or inappropriate content.
When in doubt, seek guidance before using new or unfamiliar technology in your work.
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Fair Dealing and Fair Competition
FAIR DEALING
Lowe’s acts with integrity in all business interactions. We do not:
- Misrepresent facts
- Conceal important information
- Use confidential information improperly
- Seek unfair competitive advantages
FAIR COMPETITION
Lowe’s complies with all antitrust and competition laws.
You must not make agreements with competitors to:
- Share pricing information
- Divide markets or customers
- Manipulate bids
- Boycott suppliers or customers
- Limit hiring or compensation competition
- Violate the law
Competitively Sensitive Information
You must not share Lowe’s non-public, competitively sensitive information with any third party unless it is necessary for legitimate business dealings with that party. You must also not share a third party’s non-public, competitively sensitive information with others.
Competitively sensitive information includes:
- Prices, costs, rebates and promotional programs
- Sales or purchase volumes
- Terms and conditions of sale
- Vendor or product selection processes
- Business strategies, market focus and future plans
- Labor rates and similar information
BRIBERY AND CORRUPTION
Lowe’s does not pay bribesortolerate corruption.
Never offer, give or accept anything of value to gain an unfair business advantage. This includes interactions with government officials and private businesses.
This behavior ensures Lowe’s stays in compliance with all anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA).
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Learn More
What if:
A: Possibly. Accepting gifts and/or entertainment from vendors may be appropriate, but can depend on many factors including the value, frequency, business purpose and specific vendor relationship. In this situation, fill out a gift authorization form. If you have any additional questions reach out to the Office of Business Integrity for guidance.
A: No, gift cards are considered a cash equivalent and may not be accepted.
A: Immediately contact Information Security to ensure company information on the device is protected.
A: No. Lowe’s does not allow the use of Lowe’s name or logo for our vendors’ marketing purposes, unless exceptional circumstances apply. Contact Lowe’s Legal Department for further guidance.
A: No, you may not utilize confidential information for personal gain.
A: If you shared your username and password with someone claiming to be from IT, treat it as a suspected security incident. Change your password immediately and report the incident to the Information Security Group right away for investigation. Lowe’s Information Technology and Information Security will not ask you to disclose your password.
A: If you choose to access Lowe’s email on your personal device, you must allow Lowe’s to install mobile device management software to ensure Lowe’s data is protected. See Lowe’s Acceptable Use Policy and the Technology Asset Protection Standard for more information.
A: No. The suggestion that you should manipulate information to gain a business advantage is dishonest and unacceptable. You must report this to Office of Business Integrity.
A: Yes, you did the right thing by publicly objecting to and stopping an inappropriate discussion. If it continues, you should announce you are leaving and not take part in any further discussions. You should then inform the inform the Office of Business Integrity and Compliance about what about what took place.
A: The merchant should immediately stop the conversation and make it clear Lowe’s does not discuss or agree on pricing with vendors or competitors in ways that could violate fair competition laws. The incident should be reported to the Office of Business Integrity.
A: No. Providing anything of value (which can include charitable donations) to the foreign official to gain a business advantage could be in violation of the FCPA and other anti-corruption laws. You must immediately alert the Office of Business Integrity and Corporate Compliance.
A: The associate should refuse the offer immediately and report the incident to the Office of Business Integrity. Accepting personal payments or favors in exchange for influencing business decisions is commercial bribery, which is not allowed.