Ethical behavior is a vital part of JCPenney’s values and our way of doing business. How we conduct ourselves each day with associates, customers, stakeholders, and vendors forms the basis of our reputation. Each associate commits to upholding our ethical standards by certifying to act in accordance with our Statement of Business Ethics (Code of Conduct). JCPenney routinely evaluates its policies and procedures to ensure our standards are aligned with the current state of the business, developing laws, and cultural and social developments. We also maintain an independent hotline, JCPLine, which is available around the clock for associates or vendors to raise concerns. JCPenney values the trust placed with us when customers, employees, service providers and other representatives provide us with their personal information. For JCPenney, privacy is a matter of respect for an individual as well as compliance with federal and state privacy regulations. As such, JCPenney has expectations for employees and business partners who handle personal information to take reasonable measures to maintain the confidentiality of personal information and to do so in accordance with our policies and the law.