WALGREENS

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WALLGREENS USA ( MEDICARE SPECIALITY STORE)

Walgreens Code of Business Conduct

Table of Contents

A message from Greg Wasson ................................................................................... A message from Laura Merten................................................................................... Our Code and Your Responsibilities The purpose of our Code of Business Conduct ....................................................... Key principles ........................................................................................................... Publication and amendments................................................................................... We are all accountable ............................................................................................. Team leaders have additional responsibilities .......................................................... Where we can seek help........................................................................................... No retaliation policy .................................................................................................. Open Door Policy ..................................................................................................... What happens if we violate our Code?..................................................................... A Foundation of Trust for Our Customers ................................................................. We uphold our trustworthy reputation through product safety ................................ We provide quality, dependable services our customers can count on ................... We market our products and services honestly ....................................................... We expect our suppliers to uphold our values ......................................................... We protect the private information and intellectual property of others .................... We uphold the competition and antitrust laws that apply to our work..................... We obtain competitive information fairly .................................................................. We work on government contracts lawfully and ethically ........................................ We maintain appropriate relationships with healthcare professionals...................... A Foundation of Trust for Our Company and Our Fellow Team Members ............. We foster diversity and inclusion in our workplace .................................................. We respect each other and do not tolerate harassment .......................................... We strive to create a safe and healthy work environment ........................................ We work to protect our company’s assets ............................................................... We safeguard each other’s personal information ..................................................... We use our computer systems appropriately ........................................................... A Foundation of Trust for Our Investors .................................................................... We keep honest, accurate nancial books and records........................................... We maintain records in compliance with the law and company policy .................... We avoid con ict of interest situations ..................................................................... Gifts and entertainment ............................................................................................ Doing business with friends and relatives ................................................................ Outside positions...................................................................................................... Business opportunities ............................................................................................. We uphold Insider trading laws ................................................................................ A Foundation of Trust for Our Communities ............................................................. We follow healthcare laws ........................................................................................ We comply with the Federal False Claims Act ......................................................... We work to build sustainable supply chains ............................................................ We follow international trade laws ............................................................................ We do our part to protect the environment .............................................................. We support our local communities ........................................................................... We communicate with a single voice ....................................................................... Waiving Our Code of Business Conduct .................................................................. Asking Questions and Raising Concerns..................................................................

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A message from Greg Wasson

Dear team member: Throughout our 110-year history, Walgreens has always based our success on our strong values— honesty, trust and integrity among ourselves and with our customers, suppliers, the communities we serve and our shareholders. In fact, values are the strong foundation Charles R. Walgreen Sr. built his company on. In the mid-1950s, Mr. Walgreen’s son—and our second CEO—Charles R. Walgreen Jr., took his father’s commitment to values further by adopting the Four Way Test in 1955. Its four questions— “Is it the truth? Is it fair to all concerned? Will it build good will and better friendship? Will it be bene?cial to all concerned?”—continue to in?uence and drive our business decisions and internal and external relationships. Maintaining integrity is absolutely a team effort, and it’s important for everyone to make business decisions without compromising our company’s ethics. Failing to do this puts Walgreens reputation at risk—as well as undercuts our ability to both grow our business and serve our customers. Every one of us is responsible for our actions; and each of us contributes to fostering Walgreens culture of trust. A key part of our code of conduct—that everyone should be aware of—allows team members to report known or suspected violations or concerns without fear of retaliation. It is critical that we all work to maintain an environment where complying with company policies and applicable laws is a part of our DNA. This Code of Business Conduct spells out the standards we follow at Walgreens—responsibility, solid ethics, integrity and trust. Accordingly, it is important that you take the time to read through the Code and make it a part of your everyday actions—both internally and externally. As a Walgreens team member, you represent our company, and together we can work to maintain the ?ne reputation we enjoy. Thanks for taking personal responsibility to always live up to our company’s values. Greg Wasson President and CEO
Greg Wasson

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A message from Laura Merten

Dear team member: As chief compliance of?cer, my role is to support the development, operation and monitoring of our corporate compliance program. Compliance is our ability to follow company policies, as well as the laws and regulations that apply to every part of our business. I work with a compliance team that assists in the implementation of the program. I’m also a member of our Compliance Committee, which is made up of representatives of the company all dedicated to upholding the highest standards of business conduct and ethics. At Walgreens, we are committed to our high standards of good citizenship and integrity. The objectives of our compliance program are to: • Develop and continue to update our Code of Business Conduct procedures described in the following pages • Support adherence to the Code of Business Conduct through education and training programs • Provide status reports to the Compliance Committee and the Audit Committee of the Board of Directors • Investigate compliance issues and questions submitted to my of?ce and provide recommendations, answers or solutions • Lead change in the company related to compliance activities We stand steadfast to our values, but like our business operations, we continue to adapt our Code of Business Conduct when change is necessary. That’s why we will continue to revise our Code periodically and post the most current version on our website at www.walgreens.com in the “Investor Relations” section under “Code of Business Conduct.” This will be a helpful resource when you’re looking for guidance on compliance issues. As you read through our Code, I want to assure you that I support our policy of open communication that provides you with an opportunity to use our Open Door Policy to present ideas, raise concerns and ask questions without fear of retaliation. I also encourage you to use the Walgreens hotline at 1-800-666-5677 to report issues or concerns. Laura Merten Chief Compliance Of?cer
Laura Merten

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Our Code and Your Responsibilities

The purpose of our Code of Business Conduct Our Code of Business Conduct is a guide to the ethical and legal responsibilities we share as members of the Walgreens family of companies (collectively “Walgreens”). We use this code for guidance and direction to resources to help us make the right decisions. It helps us choose the right action to take. We all encounter situations that force us to make decisions at work, and sometimes the most ethical response is not always the most obvious choice. As we cannot address every decision you must make, our Code is not a summary of all laws and policies that apply to Walgreens business. Instead, it is a starting point to help us determine when and where to seek help when we are unsure.

A Foundation of Trust for Our Customers

A Foundation of Trust for Our Company and Our Fellow Team Members

Each of us is responsible for following the principles outlined in our Code.

A Foundation of Trust for Our Investors

A Foundation of Trust for Our Communities

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Our Code and Your Responsibilities

Each of us is responsible for following the principles outlined in our Code. We are all expected to be familiar with and follow company policies, as well as the laws and regulations in every location where we do business. By reviewing and understanding our Code and policies, we become better prepared to handle ethical issues as they arise. Key principles Each of us is responsible for: Integrity and compliance – Achieving our goals with integrity and in compliance with company policy and legal requirements Open communication – Encouraging open, honest and full discussion about our policies and procedures Raising questions – Raising and resolving questions about ethical business conduct Reporting violations – Reporting actual or perceived Code, policy or legal violations to management, the chief compliance of?cer, the general counsel or the company hotline Cooperation – Assisting with any audit, compliance assessment, legal or other internal inquiry with candid, accurate and complete information Non-retaliation – Ensuring that no punishment or retaliation occurs against anyone for raising a good-faith concern.

Team leaders have additional responsibilities Performing honestly and with integrity is an obligation we all share. Team leaders, however, are expected to perform beyond our usual high standards, to lead by example and act as role models. If you are a team leader, you can do this by: • Reinforcing the Code and ensuring it is consistently applied • Making sure each team member has completed all required training • Communicating relevant policies to team members and helping them to understand the policies • Encouraging all team members to raise any questions or concerns • Dealing with reports of misconduct promptly and properly • Never ignoring any type of misconduct or retaliation against a team member Team leaders must strive to create a positive work environment where team members feel comfortable asking for help and raising concerns about this Code. Team leaders must also be alert to any situations or actions that may violate the letter or spirit of the Code or company policy or that may damage our company’s reputation. It is important that, as a team leader, you take immediate action to address such situations. When team leaders receive reports of a situation that may be unethical or potentially damaging to our company’s reputation, or suspect that one exists, he or she must promptly notify the chief compliance of?cer, general counsel or vice president of Employee Relations and work to resolve the issue. Team leaders who know about, or should know about, misconduct and do not act promptly to report it and cooperate with the compliance of?ce, general counsel or vice president of Employee Relations to correct the situation will be subject to disciplinary action. Where we can seek help If you are unsure about how to proceed, keep in mind our company’s Four-Way Test. Ask yourself: Is it the truth? Is it fair to all concerned? Will it build good will and better friendship? Will it be bene?cial to all concerned? Answers to those questions will often lead you to the most ethical answer. If you are ever unsure about the best course of action, however, there are many company resources available to help you.

Publication and amendments The current version of the Code of Business Conduct is posted and maintained on the Walgreens website at www.walgreens.com >Investor Relations >Corporate Governance >Code of Business Conduct. Amendments are also posted on the website, as required by applicable law. Because the Code is revised periodically, please check the website for the most recent version. We are all accountable Whatever our role is with Walgreens, our actions represent the company, and we must always do our best to uphold Walgreens reputation. Our success as a company depends on each of us accepting personal responsibility for always doing the right thing. We must accept the obligation to stop or prevent actions that could harm our customers or our company’s reputation and to report any such actions as soon as we learn of them.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 4

Our Code and Your Responsibilities

If you become aware of or even reasonably suspect any violations of our Code or company policy, you are encouraged to report your concerns to your direct team leader, the chief compliance of?cer, general counsel, vice president of Employee Relations or the company hotline. Speaking up when you sense any activity that could violate our core values helps maintain Walgreens culture of trust and integrity and our responsibility to uphold our company’s high moral standards. There are a number of ways to raise issues. If you believe that a law has been violated or an ethical violation has occurred, contact the chief compliance of?cer or general counsel immediately. For other matters, you can talk to your team leader or any other member of management within our company. Sometimes, just talking to your team leader will help clarify the situation and answer your questions. If you still have concerns after talking with your team leader, you can always contact the chief compliance of?cer, general counsel or vice president of Employee Relations. • The chief compliance of?cer at 847-964-6519 • The general counsel at 847-315-3004 • Employee Relations at 847-315-4455 No retaliation policy Walgreens does not tolerate retaliation against anyone who participates in an investigation, raises a legal or ethical concern, or reports misconduct in good faith. “Good faith” means that the report was made out of genuine concern for the company or team members involved. Open Door Policy Our Open Door Policy is a key part of our culture. It encourages You can also call the Walgreens hotline, a toll-free telephone line reserved speci?cally for team member calls on ethics and compliance issues. The Walgreens hotline can be reached at 1-800-666-5677. The hotline is staffed 24 hours a day, seven days a week, 365 days a year by an outside ?rm experienced in handling sensitive calls and accepting calls in many languages. Callers may report anonymously. Anonymous callers should know, however, that it is sometimes more dif?cult to follow up on issues raised by individuals who don’t identify themselves. If you reside outside the United States you can seek guidance or report misconduct by accessing the compliance web portal at www.tnwgrc.com/walgreens. What happens if we violate our Code? Our company is committed to reviewing, evaluating and responding to all reports of misconduct – big or small. To the extent practical, considering our need to investigate and comply with company obligations, Walgreens will make every effort to protect the con?dentiality of any person who comes forward with information, as well as the information itself. To maintain the highest standards of integrity, we must dedicate ourselves to complying with our Code, company policies and procedures and applicable laws and regulations. Violations of our Code not only damage our company’s standing in the communities we serve—they may also be illegal. Team members involved in violating our Code will likely face negative consequences. Walgreens will take the appropriate disciplinary action in response to each case, up to and including termination. In addition, team members involved may be subject to government ?nes or criminal or civil liability. us to present ideas, raise concerns and ask questions—including those of a legal or ethical nature—without fear of retaliation. You are encouraged to address situations ?rst with your team leader, who is often best able to resolve the issue. You can avoid many potential violations by simply asking for guidance before acting. In certain cases, you may feel uncomfortable discussing a matter with your team leader, or you might be unable to reach a satisfactory solution. If this is the case, you may speak with any other member of management, the chief compliance of?cer, general counsel, vice president of Employee Relations or you may call the company hotline. You will never be punished or retaliated against for making good faith use of our Open Door Policy. No. We must all obey the law. If you think you have been asked to do something that is against the law, you have a duty to report the situation. You can use the Open Door Policy or go to another team leader, the chief compliance of?cer, general counsel or vice president of Employee Relations, or call the Walgreens hotline. Remember that all good faith reporting is protected from retaliation. My team leader asked me to do something that I don’t believe is in compliance with the law. Should I follow my team leader’s instructions?

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 5

A Foundation of Trust for Our Customers

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A Foundation of Trust for Our Customers

Walgreens team members must always follow the highest standards of integrity and ethics when interacting with our customers and patients. Even team members who do not interact with customers must be aware that the decisions they make and the work they perform ultimately affect our customers. We uphold our trustworthy reputation through product safety Our customers count on us to sell safe reliable products that meet the highest quality and safety standards. In our company’s long history, we have earned our customers’ trust by sticking to this principle. As part of our commitment to exceeding our customers’ expectations, we must also ensure that we purchase only the highest quality products from our suppliers. If you become aware of any defective products or other issues that could pose a health or safety risk, you have a responsibility to report the matter immediately. Our marketing materials and company communications are meant to inform our customers about our products and services. They are expected to meet all industry standards that govern advertising and promotion. As such, we must follow all relevant laws and reguAs a store manager, I received a notice from the company that a certain product is being recalled due to safety concerns. I have some reports that I’d like to complete before pulling the product from the ?oor. Is that okay? I’m having trouble meeting my sales goals. I’ve tried No. Our customers trust us to provide safe, quality products. The recalled item should be pulled from the ?oor immediately. You should focus on maintaining our customers’ safety and complete the reports later. many selling techniques, but I still can’t meet the company’s expectations. My team leader said that we should “do what it takes” to meet sales targets. My team leader becomes eligible for incentives with sales success, and team members earn rewards for sales results. I’ve heard that some team members in other areas have been meetWe provide quality, dependable services our customers can count on Due to our unique standing as both a retailer and a healthcare provider, we must maintain our commitment to the integrity of our products and services. Many of our customers rely on our pharmacists and other healthcare providers for advice and dependable service. Those professionals are required to maintain current licenses, certi?cations or registrations and follow standards of ethics that correspond with their occupations. Further, you may not give any type of medical, pharmaceutical or other professional advice unless you are licensed to do so. We market our products and services honestly We must preserve Walgreens principles of integrity and honesty when we market our products—whether in any advertising, promotions, packaging, or labeling. Our customers’ trust is one of our most valuable assets, and we are committed to maintaining that con?dence. You should not engage in any improper sales practices to meet these goals. You also should never misrepresent products or services to a customer or issue unauthorized discounts. You have a number of alternatives available to you. For instance, you can speak to your colleagues or team leader for help in meeting your goals. You can also review sales training or practice your use of sales techniques, maybe with a team leader or colleague. You should also report the rumors you have heard about other team members using improper sales techniques to the chief compliance of?cer, general counsel or the company hotline. ing sales goals by overstating the bene?ts of our services or issuing unauthorized discounts to offset costs for the customer. I feel I’m on the verge of disciplinary action for my lack of success in sales. What should I do? lations regarding the marketing of our products, services and the Walgreens brand. In addition, we must never falsely represent any of our competitors’ products or services or engage in any deceptive marketing practices.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 7

A Foundation of Trust for Our Customers

We expect our suppliers to uphold our values We rely on our suppliers’ and other business partners’ integrity in all our dealings, and we expect them to assure the safety and performance of their products and services. We pursue legally compliant ways to make the most reliable purchasing decisions based on cost, product and quality, so that we can deliver quality goods at competitive prices to our customers. Walgreens develops lasting relationships with suppliers who meet our high standards of business ethics. Our standing in the communities we serve is based on the trust that those communities place with us. To maintain that trust and continue to deliver the best products to our customers, we follow all company procurement policies in our purchasing interactions. We will not purchase products from a supplier who uses involuntary labor, prison labor or child labor. We respect all applicable laws establishing a minimum age for employment to support the We must never knowingly violate the intellectual property rights of others. Those of us with marketing or advertising responsibilities should be particularly careful when preparing advertising or promotional materials that use the name, printed materials, or trademarks of another company. As a general rule, we may not make unauthorized copies of any copyrighted material. Further, we may not install or distribute software products on companyowned computers without an appropriate license. In addition, you should not disclose the con?dential information or trade secrets of others, including your former employers. If Our company expects its vendors to comply with the standards outlined in the Walgreens Vendor Responsibility Standards. Any team member who becomes aware of a supplier violating this policy must immediately report the supplier to our chief compliance of?cer or general counsel. If the report is veri?ed, Walgreens will notify the vendor and require that it take steps to immediately comply with our policy. If the vendor fails to comply with our policy, or its conduct or rehabilitation efforts are not in Walgreens best interests, we will terminate the business relationship. We protect the private information and intellectual property of others Our relationship with customers is one of our most valuable assets. It is vital to our success as a company that we treat customers with the highest amount of respect. As healthcare providers, our customers entrust us with health information, which is protected under state and federal law. It is essential that we keep this private data— including names, addresses, dates of birth, social security numbers, phone numbers, prescription histories and health condition— secure and con?dential consistent with company policy. It is important to use good judgment when handling this type of data, and never disclose a customer’s protected health information to a third party without the customer’s express permission. Our customers value our discretion with their legally protected information. There are strict competition and antitrust laws in place to ensure fair competitive business practices. Walgreens counts on each of us to obey these laws. Speci?cally, we never discuss with competitors any information we may know about pricing, suppliers, promotional strategies, territories or any other sensitive marketing
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 8

I often communicate with our healthcare providers by e-mail. If they request patient information that is private and con?dential, is it okay to send it electronically? Patient information may be sent by e-mail, but only if the e-mail is encrypted. Be sure the provider has signed the appropriate agreements to receive protected health information. In addition, send only the information requested.

Our customers’ trust is one of our most valuable assets, and we are committed to maintaining that con?dence.

end of child labor worldwide and we expect our suppliers to do the same.

anyone at Walgreens asks or pressures you to do so, you should report the matter to your direct team leader, another member of management, the chief compliance of?cer or general counsel. Never use or share any information divulged to you by a third party—whether intentionally or unintentionally—unless you know it is not con?dential or a trade secret. If you are unsure of how to use information you have received, contact your direct team leader, another member of management, the chief compliance of?cer or general counsel. We uphold the competition and antitrust laws that apply to our work Throughout our history, Walgreens has been dedicated to robust competition. However, we believe in competing solely on merit— never through deceptive or dishonest practices. In this regard, we must always be accurate and truthful in our dealings with suppliers and other business partners, and we expect the same from them. While we compete actively, we do not misrepresent, manipulate, or conceal any material information to gain a competitive advantage. We promote our products and services based on their high standards, and never by making disparaging or false allegations about our competitors.

A Foundation of Trust for Our Customers

information. We never discuss or make agreements about boycotting third parties or allocating markets or customers. If a competitor tries to engage you in a discussion on any of the above-mentioned topics, even informally, you must end the conversation immediately and report the incident to the general counsel. We should be especially mindful during trade association meetings or conferences where we are likely to have more frequent interactions with our competitors. Remember, we must avoid even the appearance of unethical business practices. Antitrust laws can be challenging to grasp, and violations carry serious penalties—both civil and criminal—for the team members involved and our company. If your job involves sales, marketing or procurement, you must know and understand these laws as they apply to your work. For further guidance, please contact the general counsel. We obtain competitive information fairly Remaining current on market practices and developments is vital to the continued success of Walgreens. While we recognize the importance of obtaining information about our competitors, however, we must only do so in a lawful and ethical manner. This means we obtain information only through publicly available resources. We also protect any information provided to us in con?dence by our suppliers and other business partners. We must not ask our colleagues to disclose any con?dential information about their previous employers. If we lawfully obtain con?dential information from suppliers or other business partners, we must take care to protect it as we would our company’s own proprietary data. We work on government contracts lawfully and ethically Many of our customers rely on our ability to provide the services they need through government-backed healthcare programs such as Medicare, Medicaid and other federal and state programs. When working on potential or existing government contracts or funded programs, it is critical that we adhere to all of the laws, regulations and procedures that apply to these contracts and programs. These rules are often much stricter and more complex than those that govern our other contracts. If your work involves government contracts, government-funded programs, or complying with government program parameters, you have a duty to familiarize yourself with the relevant laws and regulations that affect your job. To seek help in doing so, contact the compliance of?ce or Health Law Department. Please note that violations of these rules can result in substantial penalties, the loss of future government contracts, exclusion from government funded
To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 9

programs and even civil liability and/or criminal prosecution for the team members involved and our company. We maintain appropriate relationships with healthcare professionals Our relationships with healthcare professionals are heavily regulated and the rules are strictly enforced. A healthcare professional is any individual or entity, directly or indirectly involved in the delivery of healthcare who can purchase, prescribe, lease, recommend or use our healthcare products or services. The federal and state laws that govern paying, providing or offering anything of value to healthcare professionals such as gifts, meals, entertainment or grants are complex and highly regulated. The consequences for failing to comply with these laws can result in signi?cant monetary and even criminal penalties. It is important that you understand and comply with these laws and company policy when dealing with healthcare professionals. If you have questions or need assistance determining whether a particular relationship is appropriate, contact the chief compliance of?cer or Health Law. A local physician hinted that if I made a donation to his foundation, he would increase the number of prescriptions directed to my location. What should I do? Decline the physician’s offer and inform your team leader, the chief compliance of?cer or the general counsel. Our relationships with healthcare professionals prohibit us from making improper payments that in?uence business decisions. This prescriber is putting our company at risk by soliciting for donations, and making this type of donation could subject us to serious consequences.

A Foundation of Trust for Our Company and Our Fellow Team Members

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A Foundation of Trust for Our Company and Our Fellow Team Members

We foster diversity and inclusion in our workplace We believe fostering diversity and promoting inclusive hiring practices in the workplace encourages a wider range of abilities and experiences, and helps us attract the best talent possible. Diversity helps inspire the innovation that drives our business and helps enhance the ideas that provide our competitive advantage as we serve consumers from all walks of life. Our hiring decisions are based solely on merit. We never make any employmentrelated decisions based upon a person’s race, color, gender, age, religion, disability, sexual orientation, veteran status, marital status or any other basis protected by law. Diversity and inclusion are key aspects of Walgreens strong value system and culture, which have carried us through more than a century of service to our communities. We respect each other and do not tolerate harassment By working for Walgreens, we are committed to treating each other with respect. Each of us is responsible for ensuring that our workplace is free from any type of harassment. Harassment is any unwelcome conduct that creates an intimidating or offensive work environment—whether it is of a sexual nature or not. Harassment can include physical actions, spoken or written remarks and pictures or videos. In any case, harassment is offensive and may expose the individuals involved and Walgreens to legal liability. Therefore, our company will not tolerate harassment of any kind. If you experience or witness any act of discrimination or harassment, you should report it immediately. You will not face retaliation for making a report in good faith. We strive to create a safe and healthy work environment Certain safety laws and standards are in place to ensure each of us enjoys a healthy work environment. It is up to all of us to uphold these laws and standards, and to follow any safety guidelines speci?c to our jobs. In addition, we should report any concerns we have about misconduct or hazardous conditions that may threaten the safety of our workplace. Violence and threats of violence are prohibited. Walgreens will not stand for any threatening behavior, even if made in a seemingly joking fashion. In that regard, we must never bring any weapons into the workplace. Drugs and alcohol impair judgment and in the workplace can affect everyone’s safety. You may not possess, distribute or be under the in?uence of alcohol or drugs, including certain prescription drugs, while on the job or while conducting company business. If you have any questions or need assistance with a substance abuse problem, please contact Employee Relations.

We believe fostering diversity and promoting inclusive hiring practices in the workplace encourages a wider range of abilities and experiences, and helps us attract the best talent possible.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 11

A Foundation of Trust for Our Company and Our Fellow Team Members

My team leader has asked me not to report a minor injury that recently occurred at work. I didn’t miss any work as a result of the incident, and my team’s safety award depends on our incident rate going down. Is it okay not to report it? No, this is never okay. You must report all workrelated injuries, no matter how minor. Tracking injuries, including those where no one was seriously hurt or missed work, helps us spot trends that could lead to incidents that are more serious.

disabilities, leaves of absence, prescription drug history, and online purchases (i.e. Walgreens.com, drugstore.com). We may only use such data for relevant and appropriate business purposes. We must not share this information with anyone inside or outside our company who does not need to know it. If your job entails having access to this type of information, you must take special precautions to keep the data private in accordance with Walgreens policies and the law. You can be assured that our company is committed to keeping our personal information secure at all times, whether on paper or in electronic format.

We work to protect our company’s assets Our shareholders trust us to protect our company’s assets—both physical and intangible. Our physical assets include computers, products, equipment and the like. We must be considerate while utilizing these assets, and protect them at all times from loss, damage, theft and misuse. Intangible assets include our reputation, the Walgreens brand and any sensitive or con?dential information about our company. Your obligation to protect this information continues even after your employment ends. Our company’s intellectual property is an equally valuable asset. “Intellectual property” includes copyrights, patents, trademarks, trade secrets, logos and other intangible industrial or commercial property. These creations are protected by law, and we are obligated to protect them. Also, keep in mind that—to the extent permitted by law—the rights to all intellectual property are assigned to Walgreens. This applies to any such materials we create on our company’s time and expense or within the scope of the duties we perform for Walgreens. We are also expected to protect the intellectual property of our vendors and suppliers, which we may encounter during the normal course of our business dealings. We are able to provide top-quality products because we have cultivated strong relationships with our vendors and suppliers. It is therefore critical that we maintain those relationships by honoring our vendors’ and suppliers’ proprietary information and protecting it from unauthorized disclosure or misuse. We safeguard each other’s personal information In keeping true to our values of trust and integrity, Walgreens strives to safeguard the private personal information of all team members. During the course of our employment, we each provide sensitive personal, medical and ?nancial information to our company. Additionally, some of us may have access to information regarding our colleagues’ salaries, performance reviews,

I know that some of the information I work with is con?dential. Does this mean I can’t talk about it with anyone, even other team members? Con?dential means that you should keep the information secure. You should discuss such information only with those who need to know about it for company business purposes. If you have any questions about who you can discuss the information with, you should ask your team leader.

We use our computer systems appropriately While limited personal use of our computer and network systems is acceptable, it should not detract from our work for Walgreens. We should also never use our company computers or network systems for inappropriate conduct, such as viewing obscene or sexually explicit materials, spreading profanity or derogatory remarks or communicating harassing or discriminatory statements. Walgreens reserves the right to block access to inappropriate sites. Please also be aware that our company may monitor all data and communications to the extent permitted by local law. Walgreens also retains the right to report any suspected or actual violations of the law to the appropriate authorities. We always need to use our computer and network systems appropriately. This means composing e-mails and other electronic communications professionally. All business communications may later be reviewed and interpreted by other parties, so take care in how you compose your thoughts because electronic messages can be forwarded without your consent. In addition, we may not post our company’s con?dential information to Internet chat rooms, message forums or any other public forum. It is important to keep in mind that none of us should have any expectation of privacy when using company computers or network systems.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 12

A Foundation of Trust for Our Company and Our Fellow Team Members

By working for Walgreens, we are committed to treating each other with respect.

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A Foundation of Trust for Our Investors

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A Foundation of Trust for Our Investors

We keep honest, accurate ?nancial books and records We are committed to making accurate, timely, complete, fair and clear disclosures in our reports to the U.S. Securities and Exchange Commission and other regulatory bodies. It is our duty to ensure that our business records re?ect an honest and accurate picture of our ?nancial standing. For this reason, it is important to keep accurate records of receipts, sales, expenses, corporate assets and corporate liabilities. If you become aware of any accounting or auditing irregularity, you have a duty to report it immediately so that Walgreens can take the appropriate steps to resolve the matter. Furthermore, each of us must cooperate with requests by auditors or government investigators. If management, auditors or government authorities request information, we must not conceal, alter or destroy any of those requested records. Falsifying business records can lead to termination and even criminal prosecution. If you become aware or suspect that our company is under investigation, you are required to involve the general counsel immediately.

We avoid con?ict of interest situations To uphold our company’s reputation, we must be alert to any situations that may create a con?ict of interest, whether real or perceived. A con?ict of interest occurs when there is an actual or apparent interference with our ability to make objective business decisions because of our personal relationships or loyalties. Certain situations are more likely to hinder our capabilities in making good judgment calls, and we must take care to avoid those circumstances. If you have knowledge about a situation that may be a con?ict of interest, you should immediately disclose it to your team leader, the chief compliance of?cer or the general counsel, or call the company hotline. Con?icts of interest could include: • Serving as an of?cer or director of or having ownership interest in another company that does business or competes with Walgreens • Having a family member that has ownership interest in another company that does business or competes with Walgreens • Using Walgreens information for your own personal gain,

I worked quite a bit of overtime last week. My team leader told me that I could miss a day of work this week if I don’t record last week’s overtime on my timesheet. This seems like a good solution because Walgreens won’t have to pay me for overtime, and I can get some extra time with my family. Is this okay? No. You need to ensure that all of the records you submit are complete and accurate. Team leaders should never place pressure on their team members to do otherwise. You should report the situation to Employee Relations.

to bene?t a family member or another company for which you serve as an of?cer or director, or in which you have ?nancial interest • Participating in business transactions for your own personal gain based on information or relationships developed as a Walgreens team member • Failing to disclose that you are closely related to someone, such as a vendor or customer who has sought or is seeking a ?nancial relationship with Walgreens • Having a romantic relationship with a team member that you supervise or that is in your line of supervision If a team member wishes to engage in a transaction or activity,

We maintain records in compliance with the law and company policy There are many laws and regulations that govern how we maintain company documents, including business, ?nancial and healthcare records. Each of us is responsible for ensuring that company records are retained and disposed of in accordance with all applicable laws and regulations, as well as licensing and accreditation requirements. Records include information stored in various formats, including paper, electronic, audio and video. The length of time to retain records depends on the content and type of record involved. We are each responsible for understanding the retention schedule for our records.

which is, or potentially may be a con?ict, the team member must ?rst make a full written disclosure to the general counsel, who, along with the chief compliance of?cer, will evaluate the written disclosure and make a determination. Following this procedure will ensure that con?ict of interest provisions are not violated. Below are additional common con?ict of interest situations, as well as guidelines you should follow in dealing with them. Please remember that these guidelines also apply to members of your “immediate family.” This includes your spouse, domestic partner, parents, children, siblings, in-laws and anyone who resides in your home.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 15

A Foundation of Trust for Our Investors

Gifts and entertainment A vendor has offered me tickets to a local sporting event that they cannot use. Can I accept? No. Accepting tickets to a sporting event or other recreational activity is inconsistent with our Code and gift policy.

approval of the general counsel. Gifts to foreign businesses cannot be made without prior notice and approval by the chief compliance of?cer. Additional information regarding gifts and entertainment can be found in our Gift Policy. If your role involves gifts in any way, you should become familiar with this policy. If you have any questions, please contact the general counsel. Doing business with friends and relatives Another common con?ict of interest can occur when doing business with or while supervising family or friends. We are not permitted to directly oversee immediate family members. If you are put in such a situation, you should disclose it to your team leader immediately so that reassignments can be made. In addition, you may not enter our company into a business relationship with a friend or family member or a business owned or operated by a friend or family member without the prior approval of the general counsel. You must avoid any scenario where you stand to gain personally from Walgreens-related dealings or where there may be any appearance of favoritism. My department is in the process of choosing a vendor. One of my team members recommended a company owned by his sister. I have heard good things about this company from other sources. Can I consider this company even though one of my team members is related to the owner? The vendor can compete for the work, but the team member who is related to the owner cannot be involved in decisions about choosing the supplier. Nor can the team member be involved in managing the supplier, if chosen. Your team member should also understand that he cannot provide any con?dential company information to his sister that would help her company be selected.

Business gifts and entertainment are common courtesies in many business circles. They can, however, also become inappropriate if the gifts or entertainment are too lavish or too frequent, or if the courtesies are used to in?uence a business decision. Our policy is that team members may not accept any gifts from individuals or companies doing or seeking to do business with Walgreens. With prior approval of the responsible corporate vice president, however, meals and entertainment may be offered or accepted when both the team member and the representative of the other company are present, and a substantial business discussion takes place directly before, during or after the activity. When this type of activity is related to your attendance at a company approved trade show, convention or seminar, prior approval by a corporate vice president is not required. As a general rule, do not offer a business gift or courtesy if doing so would give the appearance that you are attempting to in?uence a business decision. You may offer a gift, favor or entertainment to others at company expense if it meets all of the following criteria: • Nominal in value • Consistent with accepted business practice • Not against the law or in violation of our company’s high standards of integrity • Not against the policies or standards of the recipient’s company • Not in a form that could give the appearance of a bribe (i.e., no cash or cash equivalent) • Not something that would embarrass our company if it was disclosed Keep in mind that rules governing the giving of gifts, favors and entertainment to any U.S. or foreign public government of?cial (or their family members), or healthcare providers/referral sources (or their family members) are much stricter than those set forth in this section. No gifts, favors, or entertainment can be given to any domestic or foreign government of?cial without prior written

Outside positions We may have outside business interests or employment, as long as those interests do not interfere or con?ict with our current position and responsibilities for Walgreens. In general, this means we may not work for or have a signi?cant ?nancial interest in a competitor, supplier or customer. A con?ict of interest may also exist if any member of your immediate family is, or has ownership interest in, a competitor, supplier or customer of the company. We must immediately disclose any such situations to the general counsel.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 16

A Foundation of Trust for Our Investors

There are many laws and regulations that govern how we maintain company documents, including business, ?nancial and healthcare records. Each of us is responsible for ensuring that company records are retained and disposed of in accordance with all applicable laws and regulations, as well as licensing and accreditation requirements.

You may not serve as a director, trustee or of?cer of another company, or in a similar paid or unpaid position, other than with Walgreens, without prior approval of the general counsel. This rule does not apply to public, political, non-pro?t or social organizations, or to residential boards whose activities do not con?ict with our company’s interests. You may join industry or trade associations with the approval of your team leader, as long as you ensure that any related activities are consistent with our company’s interests. Business opportunities We may not accept business opportunities, commissions or advantageous ?nancial arrangements from a customer, supplier or business partner of our company. In addition, we may not purchase the goods or services of our company’s vendors for personal use on terms other than those available to the general public or established by company policy. If you become aware of any business opportunities in which Walgreens might be interested, you are required to bring them to the attention of your team leader and not take advantage of those prospects for your personal gain.

company or one of our publicly traded suppliers or competitors. Insider information is not generally available to the public and could, if publicly known, reasonably in?uence a person’s decision to buy or sell that company’s securities. Insider information can be shared only after it has been of?cially disclosed to the public and a reasonable waiting period has passed to allow the information to be absorbed by the marketplace. Using this type of information in determining whether to buy or sell a stock (also known as “insider trading”) is illegal. This applies to stock, shares, options or other securities of Walgreens or another company, as well as to transfers into or out of stockbased retirement plans. If you have any question about whether the nonpublic information you possess is material, do not make trades based on that information. Rather, seek guidance from the general counsel. We must also refrain from disclosing insider information to others—including friends and family—to use for their own ?nancial bene?t (also known as “tipping”). The consequences for violating insider-trading laws are severe, and punishment may include ?nes and imprisonment, as well as termination. Team members who have access to “insider information” are

We uphold insider trading laws While working for Walgreens, it is possible that you could become aware of insider information. This information could be about our

required to be familiar with our Insider Trading Policy.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 17

A Foundation of Trust for Our Communities

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A Foundation of Trust for Our Communities

We follow healthcare laws Because we are a healthcare provider, many of our services are heavily regulated by various governmental and regulatory agencies. We are all responsible for ensuring compliance with any clinical and regulatory standards that apply to our work. In addition, as a healthcare company, we are regulated by many laws that are designed to prevent, detect and punish fraud, waste and abuse. This includes laws and regulations such as the Federal Anti-Kickback Statute, Stark Law, Federal Civil False Claims Act (FCA) and Federal False Statements Act. In general, these laws seek to: • Prevent any false or fraudulent claims to federal healthcare programs, such as Medicare and Medicaid • Ensure that decisions made by healthcare providers about patient treatment or product use are not in?uenced by personal gain • Reduce the cost of healthcare to support patients and promote the quality of healthcare services We comply with the Federal False Claims Act The Federal False Claims Act prohibits knowingly submitting a false or fraudulent claim for payment to the Federal government. The Act is intended to reduce fraud, waste and abuse of federal funds. Many states have enacted similar laws. The Act allows individuals to ?le suit on behalf of the government against people or businesses alleged to have committed fraud. The Act also provides whistleblower protection for those who report violations. Walgreens will never retaliate against team members who exercise their rights under the Federal False Claims Act—or any other federal or state anti-fraud laws. We must all comply with the Federal False Claims Act, and any applicable state false claims acts. We must never make false claims or statements to the Federal government or to any state government. We work to build sustainable supply chains We want to ensure that people doing work for Walgreens around the world are being treated fairly—not only by our company, but also by our suppliers. We expect our suppliers to follow the same high standards that we have set for ourselves. Therefore, we only purchase from suppliers who respect basic human rights wherever they operate. In addition, we only work with suppliers who maintain our company’s commitment to freedom of association and fair wages and hours for all workers. If you suspect or know of any of Walgreens suppliers who do not act in accordance with our standards, you have a duty to our company to report it. We follow international trade laws The United States has a number of laws controlling the importation of goods. For example, it is illegal to trade with certain countries speci?ed by the U.S. government or with individuals and organizations against which the United States has imposed embargoes. U.S. customs laws also place restrictions on the importation of goods into the United States. If your job entails I noticed an unusually high incidence of a certain reimbursement code for a particular item. It’s possible that these are legitimate claims, but I’m suspicious. What should I do? Report your suspicions to your team leader, the chief compliance of?cer or the general counsel. Disregarding this situation could make you and our company liable under the False Claims Act. If you ever suspect that a claim is incorrect or fraudulent, you must report it. trade with other countries, you need to be familiar with the processes and requirements that apply to your work. Each of us must be vigilant to ensure that we comply with trade laws and regulations—both in the United States and in the countries where we do business. Consequences for violations of these laws are severe for both our company and the team members involved. In addition, we are prohibited from engaging in or appearing to support boycotts against certain countries or companies. We are required by law to report any requests to participate in an unsanctioned boycott to the U.S. government. For that reason, if you believe you have received a boycott request or have any questions about boycott activities, it is crucial that you notify the general counsel immediately. If you have any questions or concerns involving the various healthcare laws that apply to your area of work, please consult your team leader, the compliance of?ce or the Health Law Department. The auditors have requested a certain range of ?les, and when I was scanning them, I realized there are some documents missing. I don’t think the documents are critical, but I know the auditors will look for them. Can I recreate the missing documents for the audit? No. Recreating records might be viewed as an improper attempt to alter existing records. Speak to your team leader about this situation so it can be properly disclosed to the auditors.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 19

A Foundation of Trust for Our Communities

As a good corporate citizen, Walgreens takes pride that its team members are leaders in our communities. Each of us is encouraged to be involved in community, volunteer and charitable activities.

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A Foundation of Trust for Our Communities

As part of our company’s commitment to honesty, we also refuse to offer, authorize, give or promise bribes or any questionable payments. A bribe is providing something of value—including gifts, cash, and favors—in order to in?uence a business decision. In the United States, we are governed by and must follow the Foreign Corrupt Practices Act (FCPA) and all other laws, treaties and regulations that make it illegal to bribe government of?cials. Government of?cials include any elected of?cial or any federal, state or local government employee or contractor, as well as any of?cial of a foreign government. The consequences for violating anti-bribery laws are severe, including ?nes, termination and imprisonment. You are required to report any government of?cial who requests a bribe. Further, if you suspect a fellow team member is engaging in unethical or questionable conduct as it relates to bribery or kickbacks, you should report the behavior to our general counsel immediately. We do our part to protect the environment Our goal is to comply with all relevant environmental laws, rules and regulations in the places where we do business. We strive to ensure that our products and processes are safe and of the highest quality. If you become aware of any violation by the company of environmental laws or regulations, you should immediately notify your team leader, the chief compliance of?cer, or the general counsel, or call the company hotline.

In fact, there are many opportunities for participating in volunteer efforts through your employment at our company. We should, however, not identify ourselves as representatives of Walgreens at community events without prior approval from a team leader. Likewise, Walgreens encourages us to support the well-being of our communities by participating in the political activities that interest us. However, our involvement in political activities needs to be on our own time and at our own expense. We will not be reimbursed by the company for any political donations we make. In addition, we must not use company time or resources while participating in or contributing to political or charitable causes. We should also never use our company’s name while taking part in these activities, and no company funds, property, or services are to be used to support any political party or candidate without the prior approval of the general counsel. We may pool personal funds in the Walgreen company Political Action Committee (PAC), though participation is voluntary. Through the PAC, we can support candidates running for elective of?ce who share our company’s views on important public policy issues. We must never use our position of authority to compel or pressure another employee to participate in any political event or cause. Please speak with your team leader if you need further guidance. We communicate with a single voice We have built a reputation of trust over the many years we have

I’m a company accountant and I read a news article claiming that a Walgreens supplier is violating environmental protection laws. I know we are committed to protecting the environment, but my job responsibilities don’t deal directly with our environmental programs. Is it okay to put aside the article, because it’s likely someone who deals with this issue directly also read the article? By not contacting anyone about the article, you are not violating any policy or law, but we all are responsible for upholding our company’s values and commitments. Instead of ignoring it, you should share the article with your team leader or with the appropriate department so that the matter can be investigated and the appropriate action can be taken to protect Walgreens and our commitment to the environment.

been in business. A part of maintaining that trust means communicating to our various stakeholders with a consistent and singular voice. To ensure our corporate communications are reliable and give a clear picture of the message we want to convey, any external communications must be made only by authorized representatives. If you receive any analyst inquiries, you should refer them to Investor Relations. Any media requests should be directed to Corporate Communications. If you have any further questions about whom to refer an outside inquiry on any topic, you should contact the chief compliance of?cer or general counsel. Waiving our Code of Business Conduct In extremely limited circumstances, Walgreens may ?nd it appropriate to waive a provision of our Code of Business Conduct. All waivers require the written pre-approval of the Board of Directors, the chief executive of?cer or the general

We support our local communities As a good corporate citizen, Walgreens takes pride that its team members are leaders in our communities. Each of us is encouraged to be involved in community, volunteer and charitable activities.

counsel. All waivers and exceptions will be promptly disclosed when required by regulation or law.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677 21

Asking Questions and Raising Concerns

If you want your voice to be heard, Walgreens needs to hear from you. If you ever feel your integrity or the integrity of the company is being compromised, talk with your team leader, a Loss Prevention team member, your district manager, the chief compliance of?cer or the general counsel. By the same token, support those who raise concerns in good faith and cooperate with investigations when they happen. Educating yourself about the right choices is a big part of making integrity real every day. As mentioned earlier, our Open Door Policy is a key part of our culture. It is in place to encourage us to present ideas, raise concerns and ask questions—including those of a legal or ethical nature—without fear of retaliation. You are encouraged to address situations ?rst with your team leader, who is often best able to resolve the issue. You can avoid many potential violations by simply asking for guidance before acting. In certain cases, you may feel uncomfortable discussing a matter with your team leader, or you might be unable to reach a satisfactory solution. If this is the case, you should speak with any other member of management, the chief compliance of?cer, general counsel, or vice president of Employee Relations or you may call the company hotline. You will never be punished or retaliated against for making good faith use of our Open Door Policy. Most concerns can be resolved by working with your team leader, but you also have the option to report issues or concerns by contacting: • The chief compliance of?cer at 847-964-6519 • The compliance of?ce mailbox at [email protected] • The Walgreens Hotline at 1-800-666-5677 • The general counsel at 847-315-3004 • Employee Relations at 847-315-4455 • The compliance web portal if you reside outside the United States at www.tnwgrc.com/walgreens.

Walgreens hotline is managed for Walgreens by an independent company that provides reporting services for hundreds of companies worldwide. It is available 24 hours a day, seven days a week. You may remain anonymous, and whether or not you give your name, your call will not be recorded. Information received by the independent company is relayed to Walgreens compliance of?ce for further investigation and review as appropriate. Use the hotline to ask a question, obtain guidance, or report an integrity concern. Remember: You have a responsibility to report unethical business conduct and known or suspected violations of the Code of Business Conduct or other Walgreens policy. An issue cannot be addressed unless it is brought to the proper person’s attention. Keep in mind that Walgreens does not tolerate retaliation against anyone who participates in an investigation, raises a legal or ethical concern, or reports misconduct in good faith. Good faith means that the report was made out of genuine concern for the company or team members involved. All statements contained in this Code are intended to re?ect general policies, principles, and procedures. They do not represent contractual commitments on the part of the company, and may be changed at any time without notice. Without limiting the generality of the foregoing, nothing in this Code should be construed to grant to any team member any right to continued employment or bene?ts under any employee bene?t plan, program, or arrangement. Violations of this Code may result in disciplinary actions, including, if appropriate, termination of employment.

To ask a question or report a suspected violation of the Code, call the Walgreens Hotline 1-800-666-5677



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