Gifts and Gratuities

Academy’s core principles are honesty, fairness, and respect, and its culture is based on making good decisions and doing the right thing. To follow these beliefs, it is critical that our Team Members make business decisions based on what is best for Academy, such as price, selection, quality, value, and service. We want to avoid even the appearance of making business decisions based on any improper factors. For this reason, each Team Member should have a clear understanding of the playing field – the rules governing how we make business decisions at Academy, and what we consider fair and foul play.

Academy understands the delicate balance between avoiding the appearance of impropriety through the exchange of gifts or benefits, and the important role that such exchanges can play in relationship building and other aspects of our business. In certain cases, gifts and benefits are a necessity, such as product samples for merchandising, food and drink for business meetings, and activities for relationship building. In other cases, gifts and benefits cross the line and become a material and improper influence on decision making. Our goal is to draw this line carefully so that Team Members can operate their business effectively while at the same time avoiding situations that may put their judgment and Academy at risk. The Ethics and Code of Conduct Policy and Anti-Corruption and Anti-Bribery Policy should be reviewed to determine whether a gift is appropriate.

These policies apply to situations where anything of value given, received, or exchanged for less than fair market value or the usual and customary cost. This includes, but is not limited to, gifts, gratuities, samples, donations, favors, travel, meals, and entertainment. In addition, these policies cover anything of value given by others to members of your family, to those with whom you have a close personal relationship, or to charities designated by you.

When to Use this Form - Please obtain required written approvals prior to completing disclosure form.

Recognition Gifts $100 or over.
When the total value of the exchange is greater than $100 and less than or equal to $500 USD.
When the total value of the exchange is greater than $500 USD.
When you receive any Prohibited Gift, even if the gift has been returned.
When a vendor or other business contact has offered tickets to major events that might not otherwise be available to the general public (for example, the Super Bowl, World Series, etc.).
Samples purchased, outside of a sample sale, that are greater than $1,000 USD.
When samples are removed from the storage or sale area for any reason, including donations.
When you are conducting business with a government official, including but not limited to employees of state-owned business enterprises, any time you are considering or proposing to offer or give that individual anything, regardless of form or value, prior to making the offer or giving the item.
When a vendor or other business contact has offered an item, meal or entertainment that exceeds the value guidelines in the Ethics Policy.

Items marked with a diamond ♦ are required fields.

Your Information (You, the person completing the form)

	Save “Your Name & Contact Information” for future use. (By checking this box you agree to allow NAVEX Global to store your information in a “Cookie” on this computer.)

Your Name & Contact Information	♦ First Name M.I. ♦ Last Name ♦ Job Title ♦ Department Name / Store # Phone Number Include the area code, extension, and/or dialing codes if applicable. Email (Format: username@domain.com)

Reporter (The Team Member involved in this exchange.)

Reporter	♦ Are you entering report on your own behalf or that of another Team Member? On my own behalf On behalf of another Team Member (Select One) ♦ What was the reporter's role in this exchange? Presenter Recipient (Select One)

Attention!	During the exchange, if you are both a recipient and a presenter, you will need to complete separate disclosure for each role.

Reporter Name & Contact Information	♦ First Name M.I. ♦ Last Name ♦ Job Title ♦ Department Name / Store # Phone Number Include the area code, extension, and/or dialing codes if applicable. Email (Format: username@domain.com)

Location

Team Member, Vendors, Government Officials or Other Third Parties

Team Member	♦ Is another Team Member, Team Member's relative or a contractor, agent or consultant involved in this exchange? Yes No (Select One)

Vendors, Government Officials or Other Third Parties	♦ Is a vendor, government official or other third party involved in this exchange? Yes No (Select One)

Details of Exchange

Dates	Testing date(s) or Event date(s) ♦ Date of Exchange / Receipt Start Date End Date

Location	Location of event (if applicable)

Purpose	♦ What is the business purpose?

Items Exchanged

Additional Details	♦ Have you solicited the item(s)? Yes No (Select One) ♦ Will the item(s) influence your business judgement? Yes No (Select One) ♦ Will you be expected to return a favor for the item(s)? Yes No (Select One)

Approval (if needed)

Executive Committee Member’s Approval	! Team Member must copy email approval here. Approval Date

Chief Merchant Officer and SR VP/General Merchandising Manager Approval (for sample purchases only)	! Team Member must copy email approval from CMO/SR VP/GMM here. Approval Date

Acknowledgement

Acknowledgements	♦ Acknowledgement I hereby represent that the information contained in this report is true and accurate, and I have not intentionally included any false or misleading information. By completing and submitting this disclosure form, I understand the information will be made available for review by Academy’s Legal team and Ethics Committee.

File Upload

File Upload	If you have related documents (e.g., photos, screenshots, emails), please upload them here. After you have selected your file, click the Add File button. You will need to wait until the file count changes before submitting the form. Select a file File Description Files Uploaded: Space Remaining: Max File Size: Errors:

Follow-Up & Password

Follow-Up	After you submit this report you will be issued a 10-digit “Report Key”. Using this report key, and the password you create below, you will be able to access the Follow-Up functionality of this report. Follow-Up will allow you to: Upload/Attach documents to this report Respond to follow-up questions/comments Provide additional information

Password	Create a password to access the Follow-Up functionality of this report. ♦ Password ♦ Re-Enter Password (Passwords must be at least four(4) characters in length.)

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Gift & Gratuities Exchange Disclosure