Code of Business Conduct for Employees

8. Our Communities

     8.1. We Choose Suppliers and Consultants Using Proper Criteria

          8.1.a. Tully’s is fair in our choice of suppliers and consultants and honest in all business interactions with them. We choose our suppliers and consultants based on appropriate criteria, such as qualifications, competitive price, and reputation. Anyone responsible for buying or leasing materials or services on behalf of Tully’s must conscientiously guard his or her objectivity. In practice, this means no employee may accept any benefit from a supplier or consultant, or a potential supplier or consultant, that might compromise (or appear to compromise) his or her objective assessment of appropriate criteria.

          8.1.b. Tully’s also expects our suppliers, agents, brokers, consultants, and others who do business with us or on our behalf to conduct their business in relation to, or on behalf of, Tully’s in compliance with all applicable laws and regulations and in accordance with the highest ethical standards.

     8.2. Political Activities and Contributions are Subject to Restrictions

          8.2.a. Participation in the political process is one of the most basic rights of every citizen. Tully’s encourages all Tully’s employees to be informed voters, but personal participation in the political process, including contributions of time or financial support, is completely voluntary.

          8.2.b. Federal election laws prohibit campaign contributions by corporations, whether by direct or indirect use of company funds or resources. Many state and local laws also prohibit corporate contributions to state or local political campaigns. In accordance with these laws, Tully’s does not make direct contributions to any candidate for federal office, or to any candidate for state or local office where state or local law makes such contributions illegal.

          8.2.c. Contributions to political campaigns must not be (or appear to be) made or reimbursed by Tully’s. This prohibition includes, but is not limited to, use of Company facilities, supplies, Company letterhead, phones, equipment and merchandise. Employee work time is also considered a contribution by Tully’s and the Company cannot pay employees for any time spent campaigning for a political candidate or a political party. Similarly, Tully’s employees who hold or seek to hold political office must do so on his or her own time (vacation, unpaid leave, after hours, or weekends). Additionally, employees must obtain permission from the President of the Company prior to running for political office in order to avoid a potential conflict of interest.

     8.3. Conducting International Business Has Special Requirements

          8.3.a. International business is vital to Tully’s. Tully’s is committed to conducting its business abroad in compliance with all applicable laws. Among other things, these laws regulate Tully’s interaction with foreign governments and officials, restrictive trade practices, and import and export shipments. All employees involved in Tully’s international business must comply with these requirements.

          8.3.b. To promote good government and the fair, impartial administration of laws, we may not promise, offer, or make payment in money or anything of value to a foreign government official or political party in order to obtain, retain, or conduct business or obtain any improper advantage. Tully’s is subject to the U.S. anti-bribery laws that include the Foreign Corrupt Practices Act (FCPA) and all such laws of the countries in which we operate. The definition of “foreign government officials” includes a broad cross section of government, military, and political positions.

          8.3.c. A "boycott" is when one person, group, or country refuses to do business with certain other people or countries. Tully’s operations must comply with U.S. laws pertaining to foreign boycotts. U.S. anti-boycott laws generally prohibit U.S. companies from participating in or cooperating with any international boycott (except for economic sanctions and trade embargoes imposed or approved by the U.S. with which we must comply). Anti-boycott laws also require U.S. companies to report any requests they receive to engage in a boycott. Questions about boycotts, embargoes, and restrictive trade, and all requests to participate in such practices should be directed to the Company Compliance Officer.

          8.3.d. All import and export shipments are subject to regulation by Customs and other government agencies in the originating and destination countries. These laws ensure imported products are properly admitted into the country to safeguard the public and domestic industries and to ensure the proper collection of duties, taxes, and fees. Tully’s is responsible for submitting accurate information about import shipments to Customs and other applicable agencies.

          8.3.e. Various U.S. government agencies administer programs restricting export and import of certain goods. These restrictions include embargoed countries and designated entities that have violated U.S. export laws or participated in activities deemed critical to U.S. national security.

     8.4. Environmental Protection is Our Responsibility and Priority

          8.4.a. Tully’s is committed to conducting our businesses in a manner that protects the environment. Every Tully’s employee must support our effort to protect the environment. We continually seek opportunities to improve our environmental performance.

          8.4.b. Tully’s expects all employees to support our environmental responsibilities in the performance of their jobs, including (where applicable):

• Properly storing, handling, and disposal of waste;
• Managing wastewater and storm water in compliance with applicable regulations;
• Monitoring and maintaining the integrity of underground storage tanks;
• Complying with laws regarding clean air;
• Protecting against and appropriately responding to spills and releases; and
• Seeking ways to minimize waste and prevent pollution.

          8.4.c. In addition, Tully’s must provide timely, truthful, and accurate information required in connection with applications for environmental permits and other reports called for under permits or regulatory requirements.

Table of Contents