Business Ethics Policy

The following is a summary of Ace Hardware's Business Conduct Policy relating to vendors.

Gift

Ace Hardware staff will not accept gifts or services of any value whether delivered to work, home or some other place by an actual or potential supplier, competitor or manufacturers’ representative. This includes travel accommodations, prizes and awards, meals, outings or samples.

Entertainment

Entertainment of Ace employees may sometimes be offered by actual or potential suppliers or competitors. Ace Hardware staff will not accept any entertainment offers of any type

The only exceptions to the gift and entertainment policy are:

Business Travel

Where factory trips and the complementary transportation are disclosed in advance and approved by the Merchandise Manager for the area. The trip is limited to two days duration and the purpose of the trip is entirely business.

Business Meals

Meals are only acceptable from vendors in conjunction with industry shows, industry functions, factory visits, Ace shows, or office visits.

Product Samples

Samples which become the property of Ace Hardware to test or document will be donated to charity.

Purchases from Vendors

Ace Hardware staff may purchase merchandise:

• Direct from authorized Ace vendors on an employee approved purchase order at the same price that an Ace Dealer would pay and only if it is billed through Ace accounts payable department.
• At trade shows sponsored by the company and at other trade shows that the company attends, Ace employee’s and their guests may not purchase merchandise from vendors unless the merchandise is offered for general sale to all attendees equally.