Safeway (SWY)

Accuracy and Integrity of Financial Reports

So that Safeway can effectively control its affairs, maintain the integrity of its financial reporting and comply with legal requirements, all financial transactions and funds must be properly recorded and accounted for on the Company’s books, supported by adequate documentation. Records must be accurate, complete and auditable. They must conform to the law, generally accepted accounting principles and Company policy. Each employee is responsible for preserving the confidentiality of a variety of information that, if released to an unauthorized person or organization, may lose its value or hurt the Company’s competitive position. This includes business and financial information, customer account information, new project and marketing plans, cost data, salary information, personnel information and medical records.

The Company’s principal financial officers and other employees working in the accounting and internal audit departments have a special responsibility to ensure that all of our financial disclosures are full, fair, accurate, timely and understandable. These employees must understand and strictly comply with generally accepted accounting principles and all standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts.

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Records and books will be audited from time to time to be sure all financial and operating information is complete and reliable, and complies with applicable laws, regulations and Company policies. It is specifically prohibited to make false or misleading statements to the Company’s auditors.