Business Code of Conduct and Ethics

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RSP Highlights -

2021.06.21.msg

THE HOME DEPOT

BUSINESS

CODE OF

CONDUCT

AND ETHICS

U.S. ENGLISH

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Doing the right thing each and every day for the benefit of our

associates, customers, vendors, suppliers, service providers

and the communities we serve is critical to our ongoing

success.

Each day we are challenged to be fair and consistent, to

comply with the laws that govern our activities, and to notify

others when something needs to be corrected. Our Business

Code of Conduct and Ethics provides you with guidance in

making the right choices when called upon to do so. Please

become familiar with our Code, as well as all of our Corporate

Compliance Policies and Standard Operating Procedures. As

you review these materials, please keep in mind that it is not

simply the letter of the Code, but the spirit that we all must

embrace.

If you are faced with a situation where you think our Company

values or compliance with the law may be in question, you

should bring this to the attention of your immediate manager or

supervisor, your Human Resource partner, Corporate

Compliance, or, if you prefer, you may anonymously report

your concern through THD AwareLine at 800-286-4909 or

thdawareline.com.

Working together, we will maintain our values and ensure the

success of The Home Depot.

Thank you.

Sincerely,

Ted Decker, Chair, President and Chief Executive Officer

DOING

THE RIGHT

THING

The Home Depot has a

strong commitment to

ethics and integrity, and

our core values define the

means by which we do

business.

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OUR HOME DEPOT FAMILY

OUR CODE OF CONDUCT APPLIES TO OUR HOME DEPOT

FAMILY WORLDWIDE

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INTRODUCTION .........................................................................................................................................1

OUR CORE VALUES ..............................................................................................................................1

COMPLYING WITH THE CODE AND THE LAW ...................................................................................2

THE OPEN DOOR POLICY ....................................................................................................................2

ZERO TOLERANCE FOR RETALIATION .............................................................................................2

WAIVERS TO THIS CODE ......................................................................................................................2

GETTING ANSWERS TO YOUR QUESTIONS OR REPORTING A CONCERN .................................3

DOING THE RIGHT THING FOR OUR ASSOCIATES..............................................................................4

SAFETY ...................................................................................................................................................4

LABOR AND EMPLOYMENT .................................................................................................................5

Alcohol and drug abuse ................................................................................................................................................... 5

Fair employment practices/discrimination..................................................................................................................... 5

Harassment ....................................................................................................................................................................... 5

Violence in the workplace ............................................................................................................................................... 6

ASSOCIATE ASSISTANCE ....................................................................................................................6

CONFLICTS OF INTEREST ....................................................................................................................7

Financial interests ............................................................................................................................................................ 7

Personal relationships ..................................................................................................................................................... 7

TABLE OF

CONTENTS

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Gifts and entertainment ................................................................................................................................................... 8

DOING THE RIGHT THING FOR OUR CUSTOMERS ............................................................................ 10

ANTITRUST AND FAIR COMPETITION .............................................................................................. 10

CONFIDENTIALITY, PRIVACY AND INFORMATION PROTECTION ................................................ 11

DOING THE RIGHT THING FOR OUR SHAREHOLDERS ..................................................................... 13

PROTECTING THE COMPANY'S ASSETS AND INTELLECTUAL PROPERTY .............................. 13

INSIDER TRADING ............................................................................................................................... 13

FINANCIAL INTEGRITY AND REPORTING ........................................................................................ 14

RECORDS RETENTION ....................................................................................................................... 15

DOING THE RIGHT THING FOR OUR COMMUNITIES ......................................................................... 16

ENVIRONMENTAL RESPONSIBILITY ................................................................................................ 16

GOVERNMENT INTERACTIONS ......................................................................................................... 17

Political involvement ...................................................................................................................................................... 17

Government contracting ................................................................................................................................................ 17

The Foreign Corrupt Practices Act (FCPA) and anti-bribery ................................................................................... 18

HAVE A QUESTION? WE’RE HERE TO HELP

The Corporate Compliance Team can provide guidance in situations where you are unsure of the

right thing to do. We understand that doing the right thing at work is not always as easy as it may

sound. Just send us an email with your question to corporate_compliance@homedepot.com.

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INTRODUCTION

This Business Code of Conduct and Ethics (the Code) is intended to provide you straightforward

information about The Home Depot’s operating principles and offer tools to help you make decisions

that align with our ethical expectations and legal obligations. All associates are expected to act with

honesty and integrity. Adhering to the highest ethical standards and doing the right thing are the driving

forces behind The Home Depot’s success and have been a core component of how we have done

business since the beginning. Inside you will find examples of ethical decisions you may face as an

associate as well as references to our global Corporate Compliance policies. You will also find

information on what to do if you have questions or concerns regarding ethical conduct.

This Code applies worldwide to all Home Depot associates, inclusive of business operating units,

subsidiaries and all members of the Board of Directors. This Code is designed to provide a broad

overview and scenarios on how to conduct Company business in a manner consistent with our core

values. As it cannot cover every potential scenario you may encounter,

remember that in most situations your own good judgment is the

best gauge when facing a potential ethical issue.

OUR CORE VALUES

Our values reflect the beliefs, principles and standards that

form the groundwork of our behavior and should be drawn

on when making decisions. We believe in Excellent

Customer Service, Building Strong Relationships,

Entrepreneurial Spirit, Respect for All People, Creating

Shareholder Value, Doing the Right Thing, Giving Back and

Taking Care of Our People.

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COMPLYING WITH THE CODE AND THE LAW

We have operations in countries around the world, and our associates are citizens of these various

countries. As a result, our operations are subject to a diverse set of local laws and cultures. Associates

are expected to comply with this Code and all applicable laws and regulations. If local law ever conflicts

with this Code, seek the guidance of Corporate Compliance or your Legal partner for resolution.

Board members, officers and associates are expected to report suspected or observed violations of this

Code, Company policies or applicable laws and regulations to Company management. Failure to follow

the provisions of this Code can lead to discipline, up to and including termination.

THE OPEN DOOR POLICY

We each have a right and responsibility to ask questions about issues that are not clear to us. The

Home Depot’s Open Door Policy provides you access to two-way, honest and respectful

communications. This Policy is intended to create an atmosphere that encourages you to voice your

concerns, express doubts, discuss problems, ask questions, make observations and offer suggestions

about workplace issues. You should feel comfortable approaching your immediate supervisor, any

other supervisor/manager, human resource associate, corporate officer or any other Company resource

at any time.

ZERO TOLERANCE FOR RETALIATION

If you suspect wrongdoing, including violations of this Code, Company policies or the law, report it

immediately. Retaliation against anyone who reports a good faith concern is prohibited and will not be

tolerated. Good faith means that your concern is honest and accurate to your knowledge, regardless of

whether it is discovered at a later date that you were mistaken. Allegations made maliciously in bad

faith may be subject to disciplinary action.

WAIVERS TO THIS CODE

For associates, Executive Vice Presidents may authorize an exception to certain provisions of this

Code or may designate a Senior Vice President or Vice President to review and approve such

exceptions on their behalf. All exceptions must be approved in advance and must be submitted to

Corporate Compliance at corporate_compliance@homedepot.com.

For Board members and Executive Officers, waivers of the Business Code of Conduct and Ethics may

be granted only by the Audit Committee or the full Board of Directors and will be subject to applicable

laws and regulations regarding disclosure to shareholders.

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GETTING ANSWERS TO YOUR QUESTIONS OR REPORTING A

CONCERN

If you have questions or concerns, speak up. The Home Depot provides several options to report

potential violations of this Code, Company policies or applicable laws and regulations.

Depending on your concern, often it is best to speak first with your immediate manager or supervisor.

Your immediate manager or supervisor is best suited to respond to your issue immediately and may

already be familiar with the concern you are reporting.

If you feel uncomfortable talking with your immediate manager or supervisor for any reason, contact

one of the following resources:

• Contact your HR partner

• Contact the 24-hour THD AwareLine at 800-286-4909 or thdawareline.com, where you can

choose to remain anonymous

• Contact Corporate Compliance at corporate_compl[email protected]m

I reported a concern about fraud in our store to my supervisor, Bob. Since reporting my

concern, Bob has stopped including me in certain meetings. Is this retaliation?

Significant changes in how you are treated after reporting a potential issue can be

perceived as retaliation. If you feel you are being treated differently since reporting

an allegation, raise your concern by notifying your HR partner, THD AwareLine or

Corporate Compliance.

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DOING THE RIGHT THING FOR OUR

ASSOCIATES

SAFETY

We are committed to providing our associates and customers a safe working and shopping

environment. As an associate, you are expected to comply with all safety standards and demonstrate

safe behaviors in everything you do. If you are concerned or have questions, comments or feedback

regarding safety or environmental compliance in your workspace, notify your supervisor immediately.

The Home Depot should never ask or expect an associate to perform any task that is considered

unsafe.

Marcus, a department supervisor, asked Tonya to use a forklift to help move some pallets,

unaware that Tonya was not properly trained to operate lift equipment. What should each

party do in this situation?

Realizing the potential safety issue, Tonya should tell Marcus she is not properly

trained. Marcus should advise Tonya not to operate the forklift, find another

associate to help and ensure Tonya gets the necessary training so she can assist in

the future.

To learn more about Home Depot’s commitment to the safety and health of its customers

and associates, read the Safety Policy available on myApron or by contacting Corporate

Compliance.

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LABOR AND EMPLOYMENT

The Home Depot believes that all people should be treated with dignity, and we will not accept conduct

that fails to show appropriate respect to others. Our core value of Respect for All People exemplifies

how we should treat our fellow associates, customers, suppliers, vendors and service providers.

Any conduct that fails to show appropriate respect to others, including fellow associates, customers,

professional customers, vendors, suppliers and service providers, violates the Company’s values. The

following are examples of unacceptable conduct: insults; threats; intimidation; ridicule; vulgarity;

discrimination; harassment; physical or verbal abuse; sexually explicit humor, conversation or behavior;

slurs or stereotyping; unwelcome sexual advances; unwelcome touching or invasion of personal space;

ignoring the rights of others; and insensitivity to the beliefs and customs of others.

ALCOHOL AND DRUG ABUSE

We are committed to providing a safe, healthy and drug-free workplace. Using illegal drugs at any time,

using alcohol when on the job or on Company premises or coming to work under the influence of

alcohol or drugs is strictly prohibited. This prohibition is a condition of employment. Any associate found

in violation of this condition of employment is subject to immediate termination. Please refer to THD’s

Standards of Performance for further detail.

FAIR EMPLOYMENT PRACTICES/DISCRIMINATION

The Home Depot is an equal opportunity employer committed to ensuring all associates work in an

environment of mutual respect. We will not discriminate against any associate or applicant with regard

to race, color, religion, creed, national origin, ancestry, citizenship status, disability (actual or perceived

physical or mental disability), medical condition, pregnancy or perceived pregnancy, genetic

information, marital status, sex, gender, gender identity, gender expression, transgender status, age,

sexual orientation, reproductive health decision-making, military and veteran status, or any other basis

prohibited under applicable law.

HARASSMENT

The Home Depot will not tolerate harassment in the workplace. Harassment or disrespectful behavior

can be verbal, non-verbal or physical. Examples include:

• Verbal harassment (e.g., epithets, derogatory comments or slurs)

• Physical harassment (e.g., assault, impeding or blocking movement, or any physical

interference with normal work or movement, when directed at an individual)

• Visual forms of harassment (e.g., derogatory posters, cartoons, or drawings, or inappropriate

messages or photographs sent via text message, email, or any other means)

• Sexual favors (e.g., unwanted sexual advances, or the conditioning of an employment benefit

upon an exchange of sexual favors)

• Threats or intimidation

• Bullying behavior, including but not limited to threats, intimidation, coercion, ridicule, insults, or

belittling

• Scheduling in a punitive manner

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VIOLENCE IN THE WORKPLACE

We have a zero-tolerance policy for actions that threaten our associates, customers, suppliers,

vendors, service providers, visitors or property. Examples of threatening actions include verbal threats

of violence, physical assaults or the intentional destruction of Company property or merchandise. If you

observe a situation that could become potentially violent, report the issue immediately to Human

Resources or a member of management. The incident should then be reported by the manager to the

Global Security Operations Center (GSOC) at 1-877-436-3376 as soon as possible.

I think I was passed up for a promotion due to my race. What should I do?

If you feel you have been discriminated against due to race or any other legally

protected characteristic, you should raise your concern by notifying your HR partner,

or by contacting THD AwareLine or Corporate Compliance.

My co-worker circulated an email that was offensive to me. What should I do?

First ask the co-worker to stop sending you these types of emails. If you are not

comfortable speaking directly with the co-worker, or the co-worker does not stop

sending these types of emails, you should contact your immediate supervisor, HR

partner, THD AwareLine or Corporate Compliance.

ASSOCIATE ASSISTANCE

Carelon Wellbeing is a free, confidential Employee Assistance

Program (EAP) providing support and/or guidance in a number

of areas, including:

• Uncertainty

• Stress

• Depression

• Substance use

• Family challenges

• Burnout

• Anxiety

• Life changes

• Domestic violence

All associates, spouses and children of associates and household members of associates have free

and confidential access to 6 sessions per situation per year.

For information or assistance, please call Carelon Wellbeing at 888-275-0021 or visit

livetheorangelife.com/carelon.

Want to learn more about Home Depot’s Labor and Employment standards? Read the Labor

and Employment Policy or the Standards of Performance available on myApron or by

contacting Corporate Compliance.

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CONFLICTS OF INTEREST

You have a responsibility to make decisions based on the interests of The Home Depot without regard

to how they might benefit you. A conflict can occur when your personal interests interfere in any way –

or even appear to interfere – with the interests of the Company. Even if you did not intend for your

actions to create a conflict, the perception of a conflict by others can be just as damaging to you or The

Home Depot. Be on the lookout for situations that may create the appearance of a conflict and avoid

them whenever possible.

Questions concerning conflicts of interest should be referred to Corporate Compliance.

For further information, see the Conflict of Interest Policy, available on myApron or by

contacting Corporate Compliance.

FINANCIAL INTERESTS

Your personal financial interests, or those of your family, should not conflict with your responsibilities to

The Home Depot. In particular, financial interests in a Home Depot current or prospective supplier,

vendor or service provider, as well as any instance in which you or a family member may receive

personal gain through opportunities discovered through Home Depot, may present a conflict of interest.

If you have the authority to award business to or control decisions regarding a particular supplier,

vendor or service provider, or supervise others who have that authority, you (and your immediate family

members) should not have a direct financial interest (including debt and all forms of equity such as

shares of common or preferred stock, options, warrants, LLC membership interests, etc.) in that entity,

unless you receive approval from Corporate Compliance.

Additionally, associates should not have a financial interest that creates a competing interest against

The Home Depot. If you are unsure if a financial interest creates a conflict of interest, contact Corporate

Compliance or read the Conflict of Interest Policy available on myApron for guidance.

Financial investments where you have no direct investment (e.g., mutual funds, 401k investments, etc.)

are not considered conflicts of interest for the purpose of this Code.

PERSONAL RELATIONSHIPS

Social, family and romantic relationships with current or prospective suppliers, vendors, service

providers and other associates can create an appearance of a conflict of interest and, in the worst case,

could interfere with your ability to perform your job objectively. If you have a social, family or romantic

relationship with a supplier, vendor or service provider for which you have direct and primary

responsibility for the business relationship, disclose the relationship to Corporate Compliance. If you

have a close personal or romantic relationship with a direct report or supervisor, either current or within

the previous twelve months, you must disclose it to Corporate Compliance, and we will partner with the

appropriate HR resource to review. If you are unsure whether a relationship creates a conflict, contact

Corporate Compliance for guidance.

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In addition, if you are asked to serve as a board member, consultant, advisor or employee of any

current or prospective third-party that may do business with Home Depot, you must have Corporate

Compliance review the relationship for any potential conflicts of interest prior to accepting the position.

Associates cannot have a compensated role on the board or advisory council of a current Home Depot

vendor, supplier or service provider.

The Home Depot expects its suppliers, vendors and service providers to act ethically and in a manner

that meets or exceeds the standards set forth in this Business Code of Conduct and Ethics.

GIFTS AND ENTERTAINMENT

The acceptance of gifts and entertainment from current or potential suppliers, vendors or service

providers can cause a conflict of interest or give the appearance that you put your personal interests

ahead of The Home Depot’s best interests.

As a general rule, you should not accept gifts and entertainment except for the limited situations,

described below, in which gifts and entertainment may be accepted as part of normal business

activities or common courtesies between business partners.

Gifts and entertainment should never be solicited and when accepted, should be infrequent and a

reasonable dollar value. Gifts and entertainment should never influence or appear to influence a

business decision. If you have a question about a situation, discuss it with your supervisor or Corporate

Compliance.

The following examples of gifts and entertainment are never allowed:

Cash or cash equivalents such as gift cards or gift certificates

Free or discounted merchandise or services not available to the general public

Vendor product samples for personal use

Travel or lodging for an associate or an associate’s family member

The following examples of gifts and entertainment are allowed when infrequent and reasonable:

Meals that are associated with business activities

Admission to industry events such as conferences and trade shows and related activities

during the event (meals, giveaways under $100, etc.) as long as it is provided to multiple

clients or potential clients

Continuing professional education or development opportunities, such as product

knowledge training or other activities to further associate knowledge and skills

Tickets to sporting or cultural events offered to associates with a market value under $100

if the offer is for the associate (not family members) to attend the event with the supplier,

vendor or service provider (in no case should an associate solicit tickets)

Gift baskets and other perishable items, provided they are shared with other associates at

your work location

Other nominal gifts under $100

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Financial or in-kind donations made directly to The Home Depot Foundation are not considered to be a

form of gifts and entertainment and are therefore not subject to this policy.

What to do if you receive an unsolicited gift that is not listed above?

If you receive an unsolicited gift that is not allowed above, advise your immediate supervisor and return

the gift with a letter explaining our guidelines. You can find a Gift Return Letter template on the

Corporate Compliance page on myApron or by contacting Corporate Compliance.

There are some situations when refusing a gift would be inappropriate, awkward or cause professional

embarrassment. Certain gifts may also be impractical to return. If you are faced with these situations,

contact Corporate Compliance to determine proper disposition of the gift.

If you are a store associate and receive an unsolicited gift that is not allowed above, check with your

Store Community Captain or Store Manager and they will help donate the item to a nonprofit partner in

your area.

Approval of gifts and entertainment

Approvals are not needed for any items allowed above. If there is a business reason why you should

accept a gift or entertainment that is not explicitly allowed, complete a Gift Approval Form and return it

to Corporate Compliance. You can find a Gift Approval Form on the Corporate Compliance page of

myApron or by contacting Corporate Compliance.

Giving gifts and entertainment

Gifts and entertainment for customers, suppliers, vendors and service providers should be supported

by a valid business purpose and should be reasonable under the circumstances. We should always be

respectful of the policies of our customers, suppliers, vendors and service providers when considering

potential gifts or entertainment.

Any gifts or entertainment for foreign government officials or employees of foreign state-owned

enterprises must comply with The Home Depot Foreign Corrupt Practices Act (FCPA) and Anti-Bribery

Policy. Providing anything of value to local, state or federal officials in the U.S. must comply with The

Home Depot Political Activity and Government Relations Policy. More information about these topics

can be found in the Doing the Right Thing For Our Communities section of this document.

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DOING THE RIGHT THING FOR OUR

CUSTOMERS

ANTITRUST AND FAIR COMPETITION

The Home Depot competes vigorously and lawfully to serve our customers in the competitive

environment in which we operate and always acts with integrity and a spirit of fair dealing in doing so.

Accordingly, all associates are required to comply with antitrust and related competition laws in

jurisdictions in which we do business. These laws in the United States and other countries typically

restrict and/or regulate competitive business practices in order to preserve fair, honest and vigorous

competition. Violations of these laws can result in damage to our reputation, severe monetary penalties,

and criminal penalties for those involved.

It is important to collect information about our competitors to compete effectively; however, such

collection must be done in a lawful and ethical manner. Associates are prohibited from engaging in

illegal business practices, including entering into agreements, reaching “understandings” or exchanging

information with competitors about how we do business and sharing confidential and proprietary

business information with or requesting such information from competitors. In addition, pricing decisions

must be made independently of our suppliers, vendors or service providers. If you are dealing with a

potential antitrust issue, seek the advice of the Legal Team at legal_question@homedepot.com.

To learn more about fair competition and how to interact with competitors, read the Antitrust

Policy available on myApron or by contacting Corporate Compliance.

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CONFIDENTIALITY, PRIVACY AND INFORMATION PROTECTION

Much of the information with which we come into contact at work each day is confidential. Confidential

information is not generally known to competitors and others outside the Company and may include:

financial information, including but not limited to information about sales, earnings, expenses and

investments; pricing information; supplier, vendor or service provider lists; customer data; plans for

future store/facility locations; business development materials; costs of goods; personnel files,

Company policies, manuals, guidelines, procedures and SOPs; computer software; design documents

and specifications; videos; and memos. Confidential information is critical to our competitive advantage

and must not be disclosed, except as specifically authorized or legally required. Information that has

been made public by the Company, such as press releases, news articles or advertisements, is not

considered confidential and does not require protection. It is the responsibility of each of us to use

discretion in handling Company information so that we do not inadvertently reveal confidential

information to competitors, suppliers, vendors, service providers, friends and/or family members. If you

are unsure about whether certain information is confidential, presume that it is.

We respect the privacy of our customers and associates and are committed to the responsible

collection, use and disposal of their Personal Information. Personal Information includes any

information that identifies, relates to, describes, or is reasonably capable of being directly or indirectly

associated with or linked to a specific individual, including household information. Some examples of

Personal Information include a person's name in combination with their credit card number, driver’s

license number and/or social security number. All associates are expected to safeguard Personal

Information in accordance with our Privacy & Information Protection Policy and applicable laws. For

more details and suggestions on how Personal Information should be properly handled, refer to the

Company’s Privacy & Information Protection Policy.

If you identify a loss, theft or misuse of any Personal Information, report it immediately to

Cybersecurity@homedepot.com.

The Home Depot maintains a large variety of assets including physical assets and valuable proprietary

and confidential information assets. Proprietary and confidential information may be maintained in

either hardcopy or electronic formats. It is vital to our reputation that all associates ensure this

information is adequately protected and controlled. Examples of ways to protect proprietary or

confidential information include:

• Password protect proprietary or confidential information on a shared computer drive

• Lock your computer screen when away from your computer

• Properly dispose of documents or media containing Personal Information (e.g., securely shred)

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A department manager asked me to send her a list of everyone in her department who

worked on a recent Team Depot event so that she can thank them for their participation. I

want to help her out, but I am very busy. Is it ok if I just send her a spreadsheet I prepared

for HR that lists the names of everyone in our department and circle the Team Depot

participants? Does it matter that the spreadsheet also includes other information, such as

associates’ social security numbers, phone numbers, addresses and emergency contact

information?

No, the spreadsheet should not be shared. Associates should always be on alert for

situations in which they might be handling Personal Information and protect it

accordingly. This responsibility includes limiting access to this kind of information to

only those who have a legitimate business need to see it. Here, the spreadsheet

contains additional Personal Information, including Sensitive Personal Information

such as social security numbers, which the department manager does not need to do

her job. Only the minimum amount of information necessary for the department

manager to do her job should be shared.

I cannot find a thumb drive I used to store some files I was working on for my job. Thumb

drives are not that expensive, so I think it will be faster and easier if I just pay to replace it

myself. The files on the thumb drive may have contained some customer information. Do I

still need to tell someone that I lost the thumb drive?

Yes. Personal Information should not be stored on flash or thumb drives as they are

easily lost or stolen. Any lost or stolen Personal Information should be immediately

reported to your manager and Cybersecurity@homedepot.com.

Want to learn more about how to protect personal and business information? Read the

Privacy & Information Protection Policy available on myApron or by contacting Corporate

Compliance.

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DOING THE RIGHT THING FOR OUR

SHAREHOLDERS

PROTECTING THE COMPANY'S ASSETS AND INTELLECTUAL PROPERTY

While at work you will have access to important Company property and information. All associates

should protect The Home Depot's property in order to avoid theft, carelessness and waste as these

have a direct impact on our profitability. All Company assets should be used for the benefit of The

Home Depot and never used to promote your own interests or those of another person or company.

Our intellectual property must be used properly and protected from infringement by others. The Home

Depot family of logos, Homer, advertisements and computer software are examples of assets that

make up our intellectual property. Inventions, discoveries, ideas, concepts, written material and trade

secrets that are created by associates using Company time, resources or materials are also the

property of The Home Depot.

INSIDER TRADING

We comply with federal and state securities laws and do not tolerate insider trading. Insider trading

means trading securities on the basis of material, non-public information or sharing material non-public

information with another person so they can trade. "Material" information is information that a

reasonable investor would likely consider important when making a decision to buy, sell or hold

securities. Some examples of material, non-public information would include the following if not

otherwise publicly disclosed:

• Earnings, revenues or other financial information

• Business conditions or strategies, including sales volumes, margins and conditions affecting our

industry

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• Potential mergers, acquisitions, tender offers, joint ventures or changes in assets

• Introduction of significant new products or services or business development initiatives

• Developments regarding customers or suppliers, including the gain or loss of customers or

suppliers

• Changes in the control or management of The Home Depot

• Borrowing activities or issues related to liquidity

• Events related to our securities (e.g., stock splits, dividend changes, share repurchases)

It is unethical and illegal to buy or sell stock or other securities on the basis of material non-public

information. It also is illegal to communicate non-public information to any other person so that they

may trade.

In addition, neither associates nor members of the Company’s Board of Directors may enter into

hedging or monetization transactions designed to limit the financial risk of ownership of Home Depot

securities. These include prepaid variable forward contracts, equity swaps, collars, exchange funds and

other similar transactions, as well as speculative transactions in derivatives of Home Depot’s securities,

such as puts, calls, options (other than those granted under a Home Depot compensation plan) or other

derivatives.

I am good friends with Jack, a vendor representative at ABC Company. Jack told me that

ABC Company just landed a big sale with The Home Depot. Although an official

announcement has not been made, can I purchase shares of ABC Company?

No. This could be considered trading on the basis of material, non-public information

and a violation of Company policy, as well as federal securities laws.

To learn more about insider trading restrictions including who to call about a potential trade,

read the Securities Laws Policy available on myApron or by contacting Corporate

Compliance.

FINANCIAL INTEGRITY AND REPORTING

Accurate business records are essential to the management of the Company and maintaining the

Company’s reputation and credibility. It is the responsibility of each associate to maintain complete and

accurate financial and business records. These records include financial statements as well as time

sheets, bills, invoices, expense reports, payroll and benefits records and other essential Company data.

The Home Depot is committed to providing full, fair, accurate, timely and understandable reports and

disclosures to regulatory authorities and the public. Associates must comply with all government laws,

rules and regulations and the requirements of other appropriate private and public regulatory authorities

applicable to our financial and business records. This includes making sure that our financial

statements conform with generally accepted accounting principles, the Company’s accounting policies

and its system of internal controls. Associates are expected to report any observed or suspected

violations of law or regulation, Company Policy or activity that might constitute financial fraud or

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financial misconduct to the General Counsel or another member of senior management, Internal Audit

or Corporate Compliance. If you are uncomfortable approaching a member of management, Internal

Audit or Corporate Compliance, you can contact THD AwareLine on a confidential basis. Any proposed

change in Company accounting policies must be reported to and approved in advance by the

Company’s Chief Accounting Officer and Controller or his or her designee.

To learn more about the Company’s commitment to maintaining accurate books and

records, read the Financial Controls Policy available on myApron or by contacting Corporate

Compliance.

RECORDS RETENTION

You may collect large amounts of information as part of your daily job, such as emails, spreadsheets

and contracts that may need to be retained for business or legal reasons. It is important to keep this

information for the period of time required and then properly dispose of it thereafter.

The Home Depot maintains a Records Management Policy that provides guidance on what documents

are business records and how long they should be maintained. Associates should consult this policy

before destroying business records.

To determine the required retention time for your documents, see the Records Management

Policy available on myApron or contact Records Management at

records_management@homedepot.com.

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DOING THE RIGHT THING FOR OUR

COMMUNITIES

ENVIRONMENTAL RESPONSIBILITY

We are committed to complying with environmental laws and regulations and acting responsibly to

reduce the impact of our operations and products on the environment. We work closely with our

suppliers to develop sustainable products and packaging to minimize the impact on the environment.

The Home Depot focuses on the areas where we can have the greatest impact by promoting our five

environmental pillars: carbon emissions, sustainable forestry, circularity, water conservation and

responsible chemistry. We expect our associates, suppliers and other business partners to join in our

efforts to preserve our environment, and we encourage our customers to do likewise.

An associate spilled fertilizer in a store aisle. The associate swept up the spilled fertilizer

and threw it in the trash. Was this the correct way to handle the spill?

Certain fertilizers can be hazardous materials. The associate should follow the Safety

SOP located on myApron regarding the correct steps to take when dealing with and

disposing of hazardous waste.

To learn more about the Company’s commitment to the environment, visit the Responsibility

page of Home Depot's website at corporate.homedepot.com/responsibility

INTERNAL USE

GOVERNMENT INTERACTIONS

The Home Depot demands the highest standards of professional conduct and ethics in our interactions

with government officials. We strictly prohibit the giving of money, gifts, services or entertainment to

government officials in exchange for official action or otherwise to gain an improper business

advantage. In addition, potential business transactions involving government officials or their family

members can raise special regulatory and ethical concerns. Any requests from government officials or

their family members for payments by, business relationships with, or benefits from the Company for

the officials or their family members should be brought to the attention of the General Counsel or

Corporate Compliance. Additional detail on specific aspects of interactions with government officials is

provided below.

POLITICAL INVOLVEMENT

In an effort to ensure that federal, state and local governments of those countries in which we conduct

business act responsibly and in the best interest of our customers and associates, The Home Depot

actively participates, and encourages its associates to participate, in the political process. In doing so,

Home Depot demands the highest standards of professional conduct and ethics from our associates.

All associates are required to comply with the Company’s Political Activity and Government Relations

Policy, which contains standards of conduct for participation in the political process.

The Home Depot sponsors The Home Depot Political Action Committee (PAC), which supports public

officials and candidates who understand the issues affecting The Home Depot and promote a favorable

business climate for the Company. Participation in the PAC is strictly voluntary and has no effect on

one's employment with The Home Depot.

Some state and local governments have laws that restrict political contributions from companies and/or

their employees who sell products to them. Home Depot Board members, senior executives and

associates responsible for soliciting contracts with state or local governments should check with the

General Counsel or the Government Relations Department before making personal political

contributions at the state and local level.

The Political Activity and Government Relations Policy and most current annual report of corporate

contributions to political candidates, parties, committees and other entities operating under Section 527

of the Internal Revenue Code is available at ir.homedepot.com under Corporate Governance.

To learn more about The Home Depot’s involvement in the political process, read the

Political Activity and Government Relations Policy available on myApron or by contacting

Corporate Compliance.

GOVERNMENT CONTRACTING

The rules imposed on the Company when it sells to the government are often different from, and more

restrictive than, the rules that apply to purely commercial transactions. As a government contractor, we

are committed to complying with these requirements and view doing business with the government as a

special trust and responsibility.

INTERNAL USE

To learn more about doing business with the government, read the Government Contracting

Policy available on myApron or by contacting Corporate Compliance.

THE FOREIGN CORRUPT PRACTICES ACT (FCPA) AND ANTI-BRIBERY

It is against our policy to participate in any form of corruption. Neither we, nor outside parties acting on

the Company’s behalf, will bribe another party to gain any benefit for the Company. U.S. law and the

foreign laws of countries where we do business make it illegal to offer or pay a bribe to a foreign official

for a business favor or to gain an improper business advantage. The term “foreign official”, i.e., non-

U.S. government officials, includes employees of any government agency, government-owned

business (such as state-owned enterprises), public international organization, or political party, plus any

political candidate. Bribes go beyond giving cash payments and may also include giving gifts or other

items of value, such as charitable donations. Our policy also prohibits giving facilitating or expediting

payments to foreign officials. Since The Home Depot can be held liable for payments made by third

parties, outside parties engaged directly or indirectly by The Home Depot who may interact with foreign

officials on the Company’s behalf must be approved by Legal, be thoroughly screened before being

hired and must contractually agree to comply with The Home Depot's Foreign Corrupt Practices Act

(FCPA) and Anti-Bribery Policy and these laws. Finally, it is our policy to comply with the statutory duty

the FCPA imposes on public reporting companies to maintain accurate books and records as well as an

adequate system of internal accounting controls.

Given the complexity of the FCPA and anti-bribery laws, we have a robust training program in place to

ensure awareness and compliance. Associates should contact the Legal Team with any questions

concerning obligations to comply with this policy at legal_questi[email protected]m.

A foreign customs official has detained import product due to incorrect paperwork but is

offering to release the goods for a payment. I am told this is customary in the country. Is this

allowed?

No. You must fix the paperwork. Providing money, gifts or entertainment to the

foreign official would be a bribe and violate local law and the FCPA.

For more information about conducting business in compliance with anti-bribery laws, read

The Home Depot Foreign Corrupt Practices Act (FCPA) and Anti-Bribery Policy available on

myApron or by contacting Corporate Compliance.