TO OUR ASSOCIATES AND DIRECTORS:
The public and all who scrutinize business behavior expect a high degree of integrity from
every business organization. Companies that do not take steps to ensure appropriate associate
conduct will be penalized by their constituents and erode public confidence in our freeenterprise system.
As a retailer providing millions of Americans with their daily food and as a publicly owned
company, The Kroger Co. has a special obligation to comply with the law and deal ethically
with customers, suppliers, associates, and shareowners. The Kroger Co. Policy on Business
Ethics, adopted by Kroger’s Board of Directors and applicable to all associates and members of
the Board, helps us identify and resolve some of the ethical issues that may arise in the conduct
of our business. Our Core Values express our commitment to responsible behavior and are
outlined on the next page. We designed our principles and disclosure processes stated in this
Policy to encourage transparency and dialogue among our associates.
The requirements of ethical behavior transcend the particulars of a policy or law. The
underlying spirit of this Policy and our Values is as important as their specific contents. The
best way to instill an ethical spirit throughout the Kroger organization is for each of us to set a
good example through our own behavior.
Kroger's integrity is our most important asset. Each of us bears a responsibility for
protecting Kroger's good name. By adhering to the spirit, principles, and practices outlined in
this document, each of you will help safeguard our reputation.
Rodney McMullen
Chairman and CEO