PDF CODE OF BUSINESS ETHICS

CODE OF BUSINESS ETHICS

BEST BUY CODE OF BUSINESS ETHICS

The Best Buy Code of Business Ethics (referred to herein as the "Code") applies to Best Buy Co., Inc., its subsidiaries, affiliates, joint ventures and agents. Any waiver of the Code for executive officers or directors may be made only by the Board of Directors or a Board committee and will be promptly disclosed to shareholders. Any waiver of the Code for any other employee may be made only by the Enterprise Ethics Office. Use of the Code is intended for Best Buy's business purposes only. The Code is not intended to describe legal relationships.

TABLE OF CONTENTS

Message From Best Buy

Introduction How Do I Act Ethically When To Seek Guidance Partnering To Stop Misconduct The Code And The Law Get Answers To Your Questions Or Report Your Concerns Confidentiality Zero-Tolerance Policy On Retaliation

Resolving Your Concerns ? The Process

Responsibility To Each Other Honoring Our Differences Harassment-Free Workplace Data Privacy Health & Safety Environment Wage & Hour Standards Asset Protection

Responsibility To Our Customers Retail Sales & Advertising Selling Products & Services Honoring Our Customers' Differences Customer Privacy

2

Responsibility To Our Business Partners

14

4

Competitve Intelligence Gathering

14

4

Antitrust & Competition

14

4

Fair Dealing

15

4

Corporate Opportunities

15

5

Conflicts of Interest

15

5

Gifts & Vendor Relations

16

5

Responsibility To Our Communities

17

5

Charitable Contributions

17

Involvement In Political Activities

17

6

Reporting Political Contributions

17

Government Requests & Inquiries

17

International Business Operations

18

7

Anti-Bribery / Anti-Corruption & FCPA

18

7

Employment & Labor Issues

18

7

International Trade

18

7

7

Special Ethical Obligations For Employees

19

8

With Financial Reporting Responsibilities

8

Finance Code of Ethics

19

8

Global Resources

20

9

Open & Honest

20

9

9

10

10

Responsibility To Our Shareholders

11

Maintaining Financial Integrity

11

Information Disclosure

11

Fair Disclosure

11

Securities Trading & Material

Non-Public Information

11

Protection & Proper Use of Company Assets 12

Protecting Intellectual Property

12

Use of Social Media

13

BEST BUY CODE OF BUSINESS ETHICS | 1

A MESSAGE FROM BEST BUY PRESIDENT AND CEO HUBERT JOLY

Dear Colleagues, Our shared vision is to be the leading provider of products, services and solutions as measured by our customers, employees, vendors, investors and communities. To be successful, it is essential that we keep our Values at the center of all that we do. To help ensure we have a clear and common understanding of how our Values apply to key business decisions, we have developed the Best Buy Code of Business Ethics. It is intended to provide all employees, a set of standards and principles that reinforce and uphold our Values. The Code includes company policies, questions and answers as well as a list of resources for reporting ethical concerns. Please take the time to familiarize yourself with these resources. Thank you for your commitment to our Values and to working together to achieve our mission to ignite human potential through technology. Cordially, Hubert Joly President and CEO Best Buy Co., Inc.

BEST BUY CODE OF BUSINESS ETHICS | 2

VALUES

EVERYTHING THAT BEST BUY IS NOW ? AND STRIVES TO BECOME ? ULTIMATELY TIES BACK TO OUR CORE VALUES AS A COMPANY:

UNLEASH THE POWER OF OUR PEOPLE

LEARN FROM CHALLENGE AND CHANGE

SHOW RESPECT, HUMILITY AND INTEGRITY

HAVE FUN WHILE BEING THE BEST

EMPLOYEES COME AND GO. BUSINESS STRATEGIES MORPH OVER TIME. THE WORLD AROUND US IS IN CONSTANT TURMOIL. BUT BEST BUY'S VALUES AS A COMPANY WILL NEVER CHANGE.

BEST BUY CODE OF BUSINESS ETHICS | 3

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