Operating Ethically

Each team member — regardless of role, entity or location — has a responsibility to make ethical business decisions that align to our values. Target team members are required to follow the law, our Code of Ethics and all applicable company policies. 

Target provides ethics and compliance trainings, which are tailored by role and location, and routinely refreshed. For members of management, this includes anti-bribery training. 

We have processes for identifying and addressing reported concerns and regularly provide team members with information on how to report concerns or possible violations. Team members have a responsibility to report any actual concern or suspected violations to the Code of Ethics, and may do so through a variety of open-door channels, such as their leader, human resources, the ethics team or our third party-managed, 24/7 Integrity Hotline which includes anonymous reporting options. 

We evaluate and address all reports received and have escalation procedures for concerns that should be investigated by legal counsel. If an investigation is required, the case is assigned to an investigation team. All Target team members are protected by the company’s non-retaliation policy. 

As part of the ongoing monitoring of our ethical culture, we regularly review the volume of reports received, types of allegations reported and outcomes of investigations conducted. This data is reviewed at a total company level, by business unit and by location. We also look for fluctuations in volume and category themes, as compared to historical internal data and external benchmarks. 

Additionally, the Code outlines each team member’s responsibility to report any potential conflicts of interest immediately as they arise. Select team members must complete Target’s Conflicts of Interest Statement annually.