Safeway (SWY)

Equity Ownership Guidelines

We have established guidelines for stock ownership by our executive officers. We believe these guidelines, which are set forth in our Corporate Governance Guidelines, further link the interests of our executives and stockholders. Under these guidelines, the multiple of annual base salary to be owned in stock depends on the executive’s role in the Company, as follows:

28

Table of Contents

The executive officers have until the year 2011, or five years from the date of assuming the position (whichever is later), to meet these guidelines.

Equity Ownership Guidelines

In 2006, we established guidelines for stock ownership by our executive officers. We believe these guidelines, which are set forth in our Corporate Governance Guidelines, further link the interests of our executives and stockholders. Under these guidelines, the multiple of annual base salary to be owned in stock depends on the executive’s role in the Company, as follows:

The executive officers have until the year 2011, or five years from the date of assuming the position (whichever is later), to meet these guidelines.

4. Equity Ownership Guidelines

As set forth in our Corporate Governance Guidelines, we established in 2006 guidelines for stock ownership by our executive officers. We believe these guidelines further link the interests of our executives and stockholders. Under these guidelines, the CEO is to own an amount of our stock equal to ten times his annual base salary, each of the Executive Vice Presidents is to own an amount of our stock equal to four times his/her annual base salary and each of the Senior Vice Presidents is to own an amount of our stock equal to two times his/her salary. The executive officers have until the year 2011, or five years from the date of assuming the position (whichever is later), to meet these guidelines.