Code of Business Conduct for Employees

3. Retaliation is Prohibited

     3.1. It is our policy to foster an environment that allows employees to report violations of the Tully’s Code of Business Conduct without the fear of retaliation or retribution. Employees must never be discouraged from using any available channel within the organization. Each employee must be able to choose whichever method is most comfortable to communicate his or her concern to the Company.

     3.2. Any employee who retaliates against another employee for reporting known or suspected violations of our legal or ethical obligations will be in violation of the Tully’s Code of Business Conduct and may be subject to disciplinary action, up to and including dismissal. Retaliation may also be a violation of the law and could subject the offender to legal liability.

     3.3. Additional questions about retaliation should be directed to Tully’s President, Company Compliance Officer or to Human Resources.

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