Safeway (SWY)

CONFLICTS OF INTEREST

A conflict of interest can occur when an employee’s private interest interferes, or appears to interfere, with the interests of the Company as a whole. Employees should avoid outside work, interests or activities that influence their ability to act in the interests of the Company or that may make it difficult to perform Company work objectively and effectively. Conflicts of interest also arise when an employee or member of his/her family receives improper personal benefit as a result of his or her position with Safeway. You must not use your Company position to obtain improper personal benefit for you or a member of your family.

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The Company requires that employees disclose any situations that reasonably would be expected to give rise to a conflict of interest. If you suspect that you have a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it to your supervisor or the Legal Division. Your supervisor and the Legal Division will work with you to determine whether you have a conflict of interest and, if so, how best to address it.