A deep commitment to legal compliance and ethical business practices is firmly embedded in JCPenney's history and company culture.

Our commitment, in fact, is as old as the Company. When James Cash Penney founded the Company in 1902, he named his first store The Golden Rule Store. The name proclaimed his unique stance as a merchant: doing business by the high standard of the Golden Rule. His ideals were embodied in a set of core principles, known as The Penney Idea, that he and his partners adopted in 1913. They still govern the Company¡¯s practices today. His ideals also underlie the JCPenney Statement of Business Ethics, which guides the day-today business conduct of our Associates.

Our suppliers have been selected, in part, because we believe they share our commitment to legal compliance and ethical business practices. Our suppliers are required not only to honor this commitment in their dealings with JCPenney but also to ensure that all their contractors do so as well - this commitment to this concept is confirmed in all contractual agreements.

In the JCPenney Supplier Legal Compliance Program brochure, first published in 1996, we restate the basic principles that have always defined our mutual understanding of legal compliance and ethical business practices. This current edition is a product of our continuing efforts to promote increasingly higher levels of compliance and vigilance on the part of our suppliers and their contractors.

As always, we encorage our suppliers to discuss our program at all appropirate levels of their company and to provide copies of it to all their contractors, and to make sure that all concerned fully understand what is required of them.