HUDSON’S BAY COMPANY

SOCIAL MEDIA & INTERNET POLICY

(CANADA BASED ASSOCIATES)

Hudson’s Bay Company (“HBC” or the “Company”) encourages Associates to act responsibly and
in a professional manner, and in accordance with the Code of Business Conduct when using
social media and other online platforms. To that end, the purpose of this Social Media Policy (the
“Policy”) is to set out expectations, guidelines and best practices concerning the use and
application of social media.

HBC has created the Policy:

• To ensure Associates understand that the posting of negative comments about the
Company, its products or vendors, or the posting of harassing or bullying comments will
not be tolerated;
•
• To protect the integrity of HBC’s good will, image, reputation and intellectual property; and

• To make certain that its Property is managed correctly, remains exclusive to HBC, and
solely accrues to HBC’s benefit.

To confirm, HBC respects the rights of Associates to use the internet as they wish on their own
time. In general, what you do on your own time is your affair. With that said, please keep in mind
that Associates can be viewed by those outside the Company as representatives of the Company,
and that your personal and business personas may intersect online. Accordingly, customers and
other stakeholders may associate your personal posts to HBC. When you engage in social media,
please act with common sense and good judgment, and always refrain from posting anything you
have doubts over posting.

Scope

This Policy applies to:

• All HBC Associates, agents, bloggers, and other individuals who engage in social media,
whether they are engaged by HBC directly or through an agency.

• Statements and/or comments made about or on behalf of HBC or its intellectual property
during or outside work hours, after active employment/engagement ceases, and whether
or not you intend the communication to be public.

For the purpose of this Policy:

• “Social media” refers to social networking services, internet forums, message boards,
web logs (blogs, wikis, pod casts, photo and video sharing services and any other service
that enables you to post messages or make statements or comments online, including
but not limited to hbc.com, thebay.com, saksfifthavenue.com, saksoff5th.com, Facebook,
Twitter, Instagram, Pinterest, Google+, Google Maps, Vine, LinkedIn, YouTube, and My

Hudson’s Bay Company reserves the right to amend policy or procedure at its discretion. When appropriate, material modifications to a policy
or procedure will be communicated to the parties with a need to know. Updated May 2020. Canada-Based Associates only.
 Space.

• “Intellectual property” refers to HBC’s name, brand, banners, marks, logos, images, and
all other proprietary information.
• “Confidential information” consists of non-public information that is intended for use by
employees, associates, contractors and other third parties when conducting Company
business.

Standards of Conduct

If it is part of your job description or role to use social media or other online tools for clientele or
to solicit sales, it is imperative that you exercise good judgment and that you treat as paramount
importance the privacy of HBC’s customers.

The following standards of conduct apply to all social media and internet use falling under this
Policy:

• Adhere to the Code of Business Conduct and all other applicable policies including but
not limited to the Information Security Policy.

• Do not under any circumstances make any statements that are defamatory,
discriminatory, harassing, bullying, that a reasonably objective reader may consider
offensive, or that may be considered injurious to HBC’s good will, image or reputation.
When online, you are responsible for your own actions and are expected to use good
judgment and common sense when using social media. When in doubt, do not post.

• Unless your job description or role dictates otherwise, do not react or respond directly to
any negative comments or criticism about the Company and its products or vendors,
whether made by a customer or another Associate. At the same time, even if you are not
an official spokesperson, you are our most vital asset for monitoring the social media
landscape. If you come across such remarks that you believe should be brought to the
Company’s attention, please contact your Human Resources Representative or reach out
to HBC Corporate Communications at hbc.communications@hbc.com.

• Do not post about celebrities or public figures, either as customers of or otherwise in

connection with HBC or its products or vendors. A post of this nature could be
misconstrued by the public as a celebrity endorsement of HBC or a brand that the
Company carries, and may subject the Company to legal challenges. Nothing herein
prohibits Associates from reposting, retweeting, etc. a post, tweet, etc. from an official
HBC social media account, even if that posting includes the content of paid celebrity
endorsements. Any repost, retweet, etc. is bound by this Policy and must be posted in
accordance with the guidelines set forth herein, including the Disclosure Requirements
below.

• Do not make unauthorized use of the Company’s intellectual property. Not only can this
negatively affect HBC’s reputation and good will but it may also affect licensing
agreements HBC is a party to.

• Unless your job description or role dictates otherwise, do not use personal social media
to conduct HBC business or create or manage an online presence for HBC or any of its

Hudson’s Bay Company reserves the right to amend policy or procedure at its discretion. When appropriate, material modifications to a policy
or procedure will be communicated to the parties with a need to know. Updated May 2020. Canada-Based Associates only.
 Property or specific stores. Let the subject matter experts do so. It is important that HBC
and its intellectual property are represented in a consistent and uniform manner.

• Do not take customer credit card information or any personally identifying information,
including but not limited to social insurance numbers and addresses, through social media
postings, private messaging or e-mails. All sales and transactions must follow the
Companies’ Point of Sale policies and procedures, including but not limited to the
Information Security Policy.

• Do not disclose HBC’s confidential or proprietary information. For example, you may not
disclose or discuss sales information, inventory results, business plans or practices,
Executive messages or any communications intended for internal purposes only, or
information about promotions that have not been announced to the public. If you aren’t
certain whether information is confidential or proprietary, please contact the Legal
Department. If you are not certain whether a promotion has been publicly announced,
please contact the Marketing Department.

• Do not post any material, non-public information about HBC.

Disclosure Requirements

When you post about HBC or any of the products it sells on social media, your connection to the
Company may not otherwise be obvious to a reasonable person. Under these circumstances, you
must clearly disclose your connection to the Company in your post. You must use your HBC e-
mail account to communicate with customers or clients. For example:
a. If you are an HBC Associate, you must disclose that fact. For example: “I work for Hudson’s
Bay . . . .”

• If you work for an agency engaged by HBC, you must disclose that fact. For example: “I
work for an agency engaged by HBC . . . .”

• If you have received any product, payment, or other incentive from HBC or an agency,
you must disclose that fact. For example: “Hudson’s Bay sent me this product to review .
. .”

In some cases, the Company may ask you to make specific disclosures. All disclosures must be
made in a clear and conspicuous manner so that they are likely to be seen, read, and understood
by the target audience.

As above, unless you are authorized to speak on behalf of the Company, you must always
disclose in any statements about HBC that your views do not necessarily represent those of the
Company.

HBC Sponsored Social Media

Unless your job description or role dictates otherwise, you are not required to participate in any
social media sponsored by HBC. Participation is entirely voluntary, intended for your own
enjoyment and information, and you will not be compensated for participating.

Press Inquiries

Statements you make or content you post may generate media coverage. If a member of the
media requests information of any kind regarding HBC, please do not respond directly on behalf
Hudson’s Bay Company reserves the right to amend policy or procedure at its discretion. When appropriate, material modifications to a policy
or procedure will be communicated to the parties with a need to know. Updated May 2020. Canada-Based Associates only.
of the Company. Instead, please contact Tiffany Bourre, DVP, Communications at
tiffany.bourre@hbc.com for guidance.

Privacy Expectation

HBC reserves its right, in its sole discretion and subject to applicable law, to monitor its websites
and all other online content and material mentioning or concerning the Company, including
Associates’ social networking activities where such activities are made public.
By using the Company’s electronic equipment, network or systems, Associates consent to
monitoring, review, and reproduction of any business-related or personal materials or messages
viewed, received or distributed through those means, subject to applicable law.

Code of Business Conduct

This Policy supplements HBC’s Code of Business Conduct and all other Company policies
including those contained in HBC’s Associate Handbook, which governs Associate conduct and
use of company resources.

Violations

An Associate who engages in inappropriate commentary or information sharing on any social

media site will have their employment terminated for cause. The Company, in its sole discretion,
may also or alternatively impose other discipline on Associates and former Associates, subject to
legal action and/or possible criminal investigation. Inappropriate commentary or information
sharing includes:
• Sharing the Company’s confidential or proprietary information such as sales or inventory
results, and business plans;

• Making unauthorized use of the Company’s intellectual property;

• Making statements that constitute harassment or bullying;

• Making inflammatory comments or actions that sully the Company’s reputation or possibly
put the best interests of the business in jeopardy;

• Making derogatory comments directed at the Company or its Associates, customers, or

business partners, such as dissatisfaction of products, services, or management;

• Using a personal social media site(s) for conducting HBC business; and

• Failing to return, retire, or discontinue a social media site/account/handle that relates to

HBC business.

Questions

Please contact your Human Resources Representative or the Communication or Legal

Departments if you have any questions about this Policy, or if you are aware of a possible violation
of this Policy.

Effective Date

Hudson’s Bay Company reserves the right to amend policy or procedure at its discretion. When appropriate, material modifications to a policy
or procedure will be communicated to the parties with a need to know. Updated May 2020. Canada-Based Associates only.
This Policy is effective immediately and was last updated May 2020

Acknowledgment

I acknowledge that I have reviewed the Social Media Policy, that I fully understand it and that I
agree to abide by its terms including that any violation of it may lead to disciplinary action up to
and including termination of my employment for cause.

Margarita Diez Lopez

Name (Please Print): ____________________
Date: 24-October-2022
____________________
Signature: ____________________

Hudson’s Bay Company reserves the right to amend policy or procedure at its discretion. When appropriate, material modifications to a policy
or procedure will be communicated to the parties with a need to know. Updated May 2020. Canada-Based Associates only.