Safeway (SWY)

COMPLIANCE WITH LAWS AND REGULATIONS

Each employee has an obligation to comply with all laws, rules and regulations applicable to the Company’s operations. These include laws covering insider trading, antitrust prohibitions, information privacy, employment discrimination or harassment, bribery and kickbacks, copyrights, trademarks and trade secrets, illegal political contributions, offering or receiving gratuities, environmental hazards, occupational health and safety, false or misleading financial information or misuse of corporate assets. A general description of some of these laws and regulations is included in this Code. A more detailed discussion is available in the Policies.

If there is a federal, state or local law or a provision in a collective bargaining agreement applicable to your employment that supersedes a provision of this Code or any of the Policies, your conduct will be guided by the applicable law or collective bargaining agreement. You are expected to understand and comply with all laws, rules and regulations that apply to your job position. If any doubt exists about whether a course of action is lawful or in compliance with this Code or the Policies, you should seek advice from your supervisor or the Legal Division.

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