Costco Confidential Ethics Hotline for Suppliers

We have implemented a global confidential ethics hotline as part of our continuing efforts to assure compliance with our Code of Ethics, our Vendor Code of Conduct, and other legal and ethical policies. Costco Ethics Point

This is a confidential tool available for use by any supplier who has reason to believe a Costco employee or supplier is in violation of these policies. (Transactional issues, such as deliveries, payments or other related items should not be addressed through this channel.)

We encourage supplier reports of possible violations of policy and other misconduct, including violations of:

• Antitrust and competition laws;
• Canada's Corruption of Foreign Public Officials Act;
• The U.S. Foreign Corrupt Practices Act;
• Insider trading restrictions;
• Accounting, financial reporting, and internal control rules;
• Health, safety, and environmental laws; and
• Costco's Vendor Code of Conduct.

The hotline also allows suppliers to raise issues involving personal misconduct by Costco employees or employees of Costco suppliers, including:

• Conflicts of interest;
• Gifts, favors, entertainment, and other payments;
• Confidential information;
• Political contributions; and
• Discrimination and sexual harassment.

Contacts can be made confidentially. Reports will go the Office of the General Counsel and the Chief Compliance Officer, who will investigate and discuss with the appropriate senior executive officer.

Gratuities

Costco employees cannot accept gratuities from suppliers, members/customers, or service agencies with whom Costco presently does business, has done business with in the past, or any firm that may be considered for future business. Gratuities are interpreted to include gifts, moneys, trips, meals, lodging or special favors. Costco also restricts its employees from giving gratuities.