This excerpt taken from the SWY 8-K filed Mar 15, 2005.
Safeway conforms to the highest legal and ethical standards wherever we do business. This Code of Business Conduct and Ethics contains general guidelines for conducting the business of the Company consistent with these standards. Our hard-earned reputation must not be compromised, and any action that could appear to do so is unacceptable. As a Safeway employee, you are expected to take affirmative steps to carry out these standards. You must conduct all aspects of Safeways business honestly, ethically and fairly, including your relationships with co-workers, customers, suppliers and competitors.
This Code applies to all of our corporate directors, officers and employees. We refer to all persons covered by this Code as Company employees or simply employees. This Code is intended to qualify as a code of ethics within the meaning of Section 406 of the Sarbanes-Oxley Act of 2002 and the rules promulgated thereunder.
Throughout this Code, the terms Safeway and the Company refer to Safeway Inc. and its majority owned or controlled subsidiaries, and to operations wherever we do business. These principles apply to all of the foregoing.