Do the Right Thing

Since our founding in 1992, Tully’s employees have been motivated by principles and values that have allowed them to work toward mutual goals. These principles and values remain as constant and as critical to our success as ever. The core of these values, which still inspire Tully’s employees today, is that Tully’s is a company of honesty, quality, and integrity. This legacy is fundamental to our ability to attract and retain the best employees, gain and keep the trust of our customers, create shareholder value, support the communities in which we operate, and protect our reputation.

Maintaining our reputation is more important than ever as a result of the many laws that regulate our business and the high expectations of our customers and general public about how we do business. It has always been and continues to be our policy to conduct business in compliance with all applicable laws and regulations and in accordance with the highest ethical standards. We continue to expect that Tully’s employees will comply with these principles.

These requirements may seem to be detailed and extensive, but they are all based around the expectation that our employees will "Do the Right Thing." Ask yourself if the action you are considering might embarrass you if you had to explain it to a close friend or family member or to a reporter on television. If the answer is "yes," then it probably is not the "Right Thing" and is likely prohibited by the Tully’s Code of Business Conduct.

When anyone within our organization fails to live up to the expectations outlined in the Tully’s Code of Business Conduct, we could all suffer by losing the loyalty of our customers, our employees, and our communities, and damaging our reputation. Any employee, regardless of his or her position in the Company, who violates our Code of Business Conduct, may be subject to discipline or other consequences.

Code of Business Conduct for Employees

Highlights of the Tully's Code of Business Conduct

This information highlights certain key points from the Tully’s Code of Business Conduct. Refer to the full text of this policy for more complete information and for other key points about how the Company and its employees work together to "Do the Right Thing."

The Tully’s Code of Business Conduct sets forth standards of conduct for all Tully’s employees. Additional guidelines are set forth in detail in other Company policies, programs and statements and in various laws and regulations.

The Tully’s Code of Business Conduct provides guidance on our legal and ethical responsibilities and assists employees in making the right decision. In particular, it sets forth and reinforces our responsibilities for:

  • Compliance with all applicable laws, rules and regulations;
  • Fair, ethical and courteous treatment of our employees, shareholders, customers and communities;
  • Honest and ethical conduct, including the avoidance of actual or apparent conflicts of interest (and handling conflicts of interest that cannot be avoided);
  • Protection of our assets and accurate record-keeping;
  • Compliance with our policies and internal controls;
  • Fair, full, accurate, timely and understandable reporting and disclosure of information to parties entitled to that information; and reporting violations of the Tully’s Code of Business Conduct.

If any aspect of the Tully’s Code of Business Conduct is unclear to employees, or if employees ever have any questions about legal or ethical compliance, it is their personal responsibility to communicate this concern to the Company.

Employees may use any available channel to communicate their concern to the Company. Employees who communicate concerns to the Company are supported, and should do so without fear of retaliation or retribution.

Non-compliance with the Tully’s Code of Business Conduct and other business conduct policies of Tully’s could result in disciplinary action including termination and could subject the employee and the Company to civil and/or criminal liability.

Employees may be required to execute written certifications of compliance with the Tully’s Code of Business Conduct.

Waivers from compliance with the Tully’s Code of Business Conduct may be granted in very limited circumstances and only by authorized personnel.

Policy

We comply with the Tully’s Code of Business Conduct. We manage our business in compliance with all applicable laws and regulations and in accordance with our Company's high standards of business conduct.

All employees are expected to comply with the Tully’s Code of Business Conduct, which is essential to maintaining our reputation for honesty, quality, and integrity. It is also each employee's responsibility to report to the Company any situation where our standards or the laws are being violated. Any employee disclosing, in good faith, violations or suspected violations of legal requirements or Tully’s business standards will not be subjected to retaliation or retribution. Likewise, failure to comply with the provisions of the Tully’s Code of Business Conduct will not be tolerated.

In summary, we "Do the Right Thing." The details of the Tully’s Code of Business Conduct are set forth in this policy memorandum.

Table of Contents

  • Administration of the Tully's Code of Business Conduct
  • Asking Questions and Voicing Concerns
  • Retaliation is Prohibited
  • Our Employees
  • Our Customers
  • Our Shareholders
  • Our Assets
  • Our Communities