Contents

INTRODUCTION.................................................................................. Error! Bookmark not defined.

Culture................................................................................................ Error! Bookmark not defined.
Product Categories ............................................................................. Error! Bookmark not defined.
Stores Index ....................................................................................... Error! Bookmark not defined.
CSR .................................................................................................... Error! Bookmark not defined.
How we continue to grow a greener company............................... Error! Bookmark not defined.
Diversity......................................................................................... Error! Bookmark not defined.
HUMAN RIGHTS POLICY.............................................................. Error! Bookmark not defined.
VENDOR SELECTION .................................................................... Error! Bookmark not defined.
Vendor Requirements ........................................................................ Error! Bookmark not defined.

Sears
Sears, Roebuck and Co., a wholly owned subsidiary of Sears Holdings Corporation (NASDAQ:
SHLD), is a leading integrated retailer providing merchandise and related services and is part of
Shop Your Way, a social shopping experience where members have the ability to earn points and
receive benefits across a wide variety of physical and digital formats through shopyourway.com.
Sears, Roebuck offers its wide range of home merchandise, apparel and automotive products and
services through Sears-branded and affiliated full-line and specialty retail stores in the United
States. Sears, Roebuck also offers a variety of merchandise and services through sears.com,
landsend.com and specialty catalogs. Sears, Roebuck offers consumers leading proprietary
brands including Kenmore, Craftsman, and DieHard among the most trusted and preferred
brands in the U.S. The company is the nation's largest provider of home services, with more than
14 million service and installation calls made annually.

Culture

SHC will continue to thrive, grow and succeed, as we focus on achieving four Key Results. We
strive to:
Deliver a Wow experience to customers and members
Build a team of engaged associates who embrace change & technology
Achieve operational excellence to drive profitable sales
Become the worlds greatest retailer
As a roadmap to achieving personal and shared goals, we ask each of our associates to
understand and embrace the following pillars of success. These behaviors guide our every action
and interaction with customers, each other and the community.
Think: Members First
I deliver a wow experience to each member by understanding their specific needs and offering
them the right products and services.
Own It
I take accountability to close the gaps as I See It, Own It, Solve It and Do It.
Embrace Feedback
I am open, honest, and respectful in my communications, and constantly seek, accept and offer
feedback.
Show Pride
I am an engaged member. I demonstrate passion and pride by leading by example.
Learn and Innovate
I learn new ways to serve members and do my job better by embracing innovation and technology.
Earn Trust
I work hard to earn the trust of every member I serve and every co-worker I interact with.

Be Authentic
I am genuine in all my interactions, ask questions to understand and align my words and action to
achieve the key results.

Product Categories

Apparel
Appliances
Auto, motorcycles and supplies
Camping and recreational equipment
Farm, lawn and garden equipment
Firearms
Furniture and home accessories
Miscellaneous
Tools and hardware

About Sears Brands

Throughout its history, Sears has committed itself to quality private-label brands. For Sears, its
brands are more than just the names of product lines. They are symbols of the company. Sears
stakes its reputation on the strength of its brands. Products must meet the most rigorous standards
of quality and safety before they earn the right to bear such names as DieHard, Kenmore, and
Craftsman.
Over the years, many popular Sears brands have come and gone, leaving behind them proud
legacies of many satisfied customers and significant cultural impact. Brands such as J.C. Higgins
sporting goods, David Bradley farm implements, Harmony House furniture, Coldspot appliances,
Silvertone guitars and many others have all carved their niches in history. Other brands have
survived the test of time at Sears. In 2002, both Kenmore and Craftsman celebrated their 75th
anniversaries, and DieHard celebrated its 35th anniversaryand all did so with a series of new
products plus reputations that outpace all of their competitors.

Stores Index
The first Sears retail store opened in Chicago on February 2, 1925. This store included an optical
shop and a soda fountain. Today, Sears operates more than 2,300 Sears-branded and affiliated
stores in the U.S. and Canada, which include approximately 870 full-line and 1,300 specialty stores
in the U.S.

CSR
How we continue to grow a greener company
Protecting the environment and inspiring our members to do the same is important to us at Sears
Holdings. It is through key partnerships with our many stakeholders that we are able to strive for

operational excellence as a company, build a team of engaged and passionate associates, and
deliver a "wow" experience to each member by understanding their needs and offering them the
right products and services that fit their lives.
For more than 100 years, Sears and Kmart have been integral members of the communities in
which they operate. Our 2014 Corporate Responsibility & Sustainability Report shares our efforts
as an organization continuously working towards social and environmental stewardship. We
recognize our responsibility to the communities we serve and believe that great value can be
driven by the responsible management of our environmental, social and economic resources.
While we are pleased to present to you our accomplishments for 2014, we are equally as excited
to look to the future and identify opportunities for success and value for our multiple stakeholders.
The following represents a few of our 2014 highlights:
2014 ENERGY STAR Partner of the Year Sustained Excellence Award:
Sears Holdings was recognized by the U.S. Environmental Protection Agency with the ENERGY
STAR Partner of the Year Sustained Excellence Award in both retail and energy management
categories. This marked our fifth year of consecutive recognition in retail, and our third year of
consecutive recognition for energy management. Our longstanding efforts exemplify an ongoing
commitment to leverage our integrated retail capabilities for maximum energy efficiency in the
marketplace.
Energy Savings:
Sears Holdings makes energy management a focus to drive operational excellence. By continually
monitoring our facilities' energy usage and trends, we continue to have success in reducing our
energy consumption. In 2014, we reduced electricity usage by more than 300 million kilowatthours, an 11 percent savings over the previous year.
Recycling Efforts:
In an effort to promote environmental sustainability and conservation, Sears Holdings recycles a
variety of materials used throughout our operations. We continue to develop our waste diversion
efforts to promote operational excellence in our facilities and stores. We recognize the importance
of these efforts and work to continually improve upon our processes to decrease operational costs
and reduce environmental impacts. In 2014, we recycled approximately:
125,000 tons of corrugated cardboard
1,500 tons of mixed plastic
3,100 tons of metal
Responsible Appliance Disposal program:
As the nation's top home appliance retailer, Sears Holdings is committed to protecting the ozone
layer, keeping our communities clean and saving energy through the responsible recycling of
household appliances. Sears became the first broad line retailer to join the Environmental
Protection Agency's (EPA) Responsible Appliance Disposal (RAD) program in 2007, and we have
proudly continued this partnership for the last eight years.
Through the RAD partnership, Sears Holdings hauls away and responsibly discards our members'
old refrigerators, freezers, AC units and dehumidifiers when they purchase new, energy-efficient
products. This means SHC recovers and properly disposes the ozone-depleting chemicals from
the discarded appliances, reducing CO2 emissions and other greenhouse gases. In 2014, as a
RAD partner, SHC processed and responsibly disposed of more than 366,000 refrigerators,
freezers, AC units and dehumidifiers, which has helped prevent the equivalent of greenhouse gas
emissions from more than 150,000 cars in one year.
Paper & Packaging:
Our packaging and procurement teams are responsible for our packaging solutions and paper
purchasing activities, respectively. These teams frequently partner with our corporate sustainability
team to incorporate environmental considerations into their work. In 2014, we reduced our paper
and packaging footprints in the following ways:

Reduced the need for an estimated 31 tons of glue through our redesigned, glue-less shoe box
construction
Increased the recycled content in our Canyon River Blues brand hang tags and labels from 30
percent to 100 percent
Increased the recycled content in our Outdoor Life brand hang tags and labels from 30 percent to
80 percent
Redesigned our Sears Universal Care Label to 100 percent recycled polyester
Replaced paper signs with digital displays in the Home Appliance section of more than 300 Sears
stores
Product Selection:
In 2014, more than 5.3 million ENERGY STAR certified products were sold through Sears and
Kmart. This resulted in more than 600 million kilowatt-hours of electricity saved and more than
$100 million in electricity cost savings for our members.
Responsible Supply Chain:
In 2014, our Global Sourcing team initiated a pilot survey to better understand the environmental
impacts of our top 20 direct sourced apparel vendors, representing more than 130 fabric mills, dye
houses and printing houses.
Policies:
Over the years, we have developed and implemented several policies to support our sustainability
efforts, including an environmental policy, paper procurement policy and PVC policy. In 2014, we
reviewed these policies and updated them as necessary. To view them in their entirety, please
click on the links below:

Global Compliance Program for Merchandise Vendors and

Factories
The Sears Holdings Global Compliance Program for merchandise vendors and factories is
designed to help ensure that Sears and Kmart production facilities operate according to the
Program requirements and all applicable local laws governing such issues as child labor, wages,
benefits, working hours, harassment, health and safety and factory security.
One of the benefits of the Global Compliance Program is fewer or less frequent audits for factories
with high compliance performance levels and effective internal systems to manage labor and social
issues. Additionally, the Program places a strong emphasis on ways that we can support
remediation and continuous improvement within the Sears and Kmart supply chain.
The Program was established to protect the integrity of the Sears Holdings brands, and to hold all
factories accountable to a set of generally accepted employment standards and workplace
practices that we refer to as the Global Compliance Program Requirements. This document
provides a description of each requirement and is available in 26 different languages. It must be
posted in every factory producing merchandise for Sears and Kmart.
The Global Compliance GUIDEBOOK to Program Requirements was developed to help production
facilities understand the details of our Global Compliance Program and what is necessary to
improve compliance levels. The manual provides indicators of compliance and non-compliance for
each requirement, and outlines good management practices for factories.
While we expect adherence to the Sears Holdings Global Compliance Program requirements as
outlined in the GUIDEBOOK, we understand that full compliance can be challenging for some
factories. Therefore, our goal is to work with factories that are honest and transparent, and

committed to making continuous improvements. However, factories that fail to be honest and
transparent or show limited response to outstanding compliance issues will be terminated.

Diversity
Our Commitment to Diversity
At Sears Holdings Corporation, diversity is much more than a business practice. In fact, it's
considered to be 'business as usual.' As one of America's iconic companies, SHC is proud that our
people and our culture are representative of the diverse customers and communities we serve.
Our Promise to You
We pride ourselves on being an Equal Opportunity Employer and do not discriminate in any aspect
of employment on the basis of race, color, religion, gender, gender identity, age, national origin,
disability, citizenship status, sexual orientation, veteran status, marital status, ancestry, pregnancy,
ethnicity, or any other legally protected status in accordance with the requirements of federal, state
and local law. We will endeavor to make a reasonable accommodation to the known physical or
mental limitations of a qualified applicant or employee with a disability unless the accommodation
would impose an undue hardship on the operation of our business.
Additionally, Sears Holdings Corporation, our leadership, and our people are committed to
honoring and valuing diversity as we continue to build long-lasting relationships with all those we
serve, including our:
Customers
Associates
Shareholders
Company
Community
Our Culture

SHC will continue to thrive, grow and succeed, as we focus on achieving four Key Results. We
strive to:
Deliver a Wow experience to customers and members
Build a team of engaged associates who embrace change & technology
Achieve operational excellence to drive profitable sales
Become the worlds greatest retailer

HUMAN RIGHTS POLICY

SHC is committed to respecting the human rights of all people involved in its business and in all
aspectsof its supply chain. As such, SHC is committed to working with and encouraging all of our
partners touphold the principles as described in the International Labor Organizations (ILO)
Declaration onFundamental Principles and Rights at Work in order to prevent and mitigate adverse
human rightsimpacts resulting from our business activities. We also place special value on our
ongoing collaborationwith a broad range of interested constituencies, including socially responsible
investors, industry andpeer groups, advocacy groups, concerned individuals, and governmental,
inter-governmental and nongovernmentalorganizations.

This Human Rights Policy is intended as an informational resource regarding SHCs policies with
respectto these matters for all of our stakeholders customers, associates, stockholders, and
community andgovernment leaders.
The California Transparency in Supply Chain Act
We disclose our efforts to eradicate slavery and human trafficking within our supply chain.
Child Labor
SHC maintains a zero-tolerance policy for underage labor, and prohibits the hiring of workers
under the
age of 15, or if higher, the local legal minimum age for employment, or the age for completing
compulsory education. Manufacturers employing young persons who do not fall within the
definition of
children will also comply with all local legal restrictions placed on young workers.
Compensation
SHC expects workers to be compensated by wages, including overtime pay and benefits, which
satisfy allapplicable laws and regulations.
Conflict Minerals Policy
SHC is committed to ensuring that all tin, tungsten, tantalum and gold ("Conflict Minerals")
contained in our private label and exclusive products are obtained in a socially responsible
manner. As such, we areworking to implement and ensure compliance with Section 1502 of the
Dodd-Frank Street Reform andConsumer Protection Act, enacted by Congress in 2010, related to
trade in Conflict Minerals.
Discrimination
We prohibit discrimination in employment, including recruitment, hiring, training, working
conditions,job assignments, pay, benefits, promotions, discipline, termination, or retirement on the
basis ofgender, race, ethnicity, social or national origin, religion, age, disability, sexual orientation,
or politicalopinion.
Forced Labor
SHC prohibits the use of all forms of forced labor, including prison labor, indentured labor, bonded
labor, and mandatory overtime. This includes practices that create a legal or practical limitation on
aworkers ability to leave their employment at will.
Harassment or Abuse
Manufacturers will treat each employee with dignity and respect, and will not use punishment or
threats of violence, or any form of physical, sexual, psychological, or verbal harassment or abuse.
Health and Safety
Conditions in all work facilities must be safe, clean, and consistent with all applicable laws and
regulations. All residential facilities provided for employees must ensure this same standard of
healthand safety.
Human Trafficking
SHC does not tolerate the involvement of its suppliers in human trafficking and slavery. We will
investigate all reports alleging human trafficking and slavery in the supply chain, and will take swift
anddecisive action against any supplier acting improperly in this regard.
Migrant Labor
We expect all workers, including migrant workers, to be provided wages, benefits, and working
conditions that are fair and in accordance with local law. Factories are prohibited from holding
migrantworker passports, charging excessive fees for employment, or requiring the payment of a
penalty upontermination of a contract.

Protection of the Environment

As a company, we adhere to all local laws protecting the environment, and our suppliers must
conductbusiness so as to minimize the impact on the environment.
Uzbekistan Cotton
Based on the human rights issues associated with the forced labor which continues to be used in
thecotton fields of Uzbekistan, SHC will not knowingly accept products that contain cotton
harvested inUzbekistan. We prohibit vendors from using cotton harvested in Uzbekistan in any
phase of theproduction process, or from doing business with companies that are either invested in
the cotton sectorin Uzbekistan or using Uzbekistan cotton for any production.

VENDOR SELECTION
Sears Holdings Corporation and its subsidiaries, including Sears Holdings Management
Corporation, Sears, Roebuck and Co., and Kmart Corporation (together Sears
Holdings), are committed to conducting business in accordance with the highest ethical
standards and in compliance with all applicable laws. Sears Holdings expects the same
commitments from each of its vendors.
Sears Holdings conducts business worldwide with vendors in many countries with
different legal, ethical, and cultural systems and beliefs. This Code describes the
minimum standards of conduct that Sears Holdings insists that its vendors, regardless of
their country of domicile or origin, comply with scrupulously and without exception as a
condition to doing business with Sears Holdings. This Code is mandatory, and if a
vendor does not comply with it Sears Holdings may terminate immediately its business
relationship with the vendor and take any other action Sears Holdings may deem
appropriate under the circumstances. If this Code establishes a standard of legal or
business-ethics conduct that is higher than local legal or business-ethics requirements,
this Code will always apply to vendors that desire to do business with Sears Holdings.
Each Vendor shall provide training about this Code to all of its employees who will
conduct business with Sears Holdings.
When we refer to vendors in this Code we mean each business enterprise, regardless of
its form (such as a corporation or company, partnership, or sole proprietorship) that
engages or participates, directly or indirectly, in the sale, consignment, or other provision
of goods or services to Sears Holdings. Vendors includes agents, subcontractors, and
other third parties, and vendors cannot avoid the responsibilities and obligations imposed
by this Code by using, or associating with, agents, subcontractors, or other third parties.
When we refer to applicable law in this Code we mean the law, including regulations,
judicial decrees, and other governmental actions that have the force of law, in effect at
each location where a vendor conducts operations with respect to, or that affect, the
vendors business with Sears.

Vendor Requirements
No Improper Influence. Vendors shall not attempt to influence a Sears
Holdings associate, agent, or representative (each a Sears Representative) with
respect to any business arrangement through bribery, kickbacks, favors, gifts, sporting or
entertainment events, offers of future employment, or similar conduct. This prohibition
means that vendors shall not engage in an action if it is intended to improperly influence,
or could create the appearance of improperly influencing, a Sears Representative. This
prohibition extends to the relatives of a Sears Representative and to each other person

with whom a Sears Representative has a significant personal relationship. A vendors

cash payment, or the vendors giving of a non-cash item with a value over $50, to a Sears
Representative for personal use will violate this prohibition.
No Conflicts of Interest. Vendors shall not enter into any relationship with a
Sears Representative that creates, or reasonably could be expected to create, an actual or
a potential conflict of interest for the Sears Representative. For purposes of this Code a
conflict of interest arises, or reasonably could be expected to arise, when a material
personal interest of the Sears Representative is inconsistent with, or adverse to, the Sears
Representatives responsibilities to Sears Holdings. Vendors shall not assign its
employee, agent, or representative to conduct business with a Sears Representative if the
assigned employee, agent, or representative was employed by Sears Holdings within the
preceding twelve months.
No Unfair Business Practices. Vendors shall not engage in bid collusion or
customer or market allocation with other Sears Holdings vendors. Vendors shall comply
with all applicable antitrust, trade-regulation, and competition laws.
No Unauthorized Activities. Vendors shall not engage in any activity on behalf
of Sears Holdings, including without limitation projects, transactions, political
contributions, charitable donations, lobbying, and appearances before government
entities, officials, and representatives.
Confidentiality. Vendors may have access to Sears Holdings confidential (nonpublic)
information, such as historical sales results, sales projections, customer and
member information, associate information and agreed pricing for merchandise or
services offered or sold to Sears Holdings. Vendors shall hold this confidential
information in the strictest confidence and shall not (except as required by law) disclose it
to anyone without Sears Holdings approval and then only on a need-to-know basis.
Sears Holdings retains exclusive ownership of its confidential information. Vendors shall
not buy or sell Sears Holdings equity or debt securities based on, or otherwise take
advantage of, material, non-public information relating to Sears Holdings or its
businesses.
Sears Holdings Code of Conduct. Vendors shall familiarize themselves with,
and support, the Sears Holdings Code of Conduct and the obligations and responsibilities
of Sears Holdings associates under the Code of Conduct. Vendors shall not take any
action, or refrain from taking any action, that the vendor reasonably could expect would
result in, or would facilitate or assist the commission of, a violation by a Sears Holdings
associate of the Code of Conduct or any other relevant Sears Holdings Policies.
G. Other Compliance. Vendors shall comply with all other Sears Holdings
policies, processes, and procedures applicable to vendors, including without limitation
Sears Holdings Global Compliance Program for Merchandise Vendors and Factories
(which applies only to merchandise vendors) and travel, communication, and bidding
policies, processes, and procedures. Vendors shall not attempt to subvert Sears Holdings
procurement policies, processes, or procedures including without limitation by making
unauthorized contact with Sears Representatives. Vendors shall comply with all other
laws applicable to its business with Sears Holdings including without limitation the U.S.
Foreign Corrupt Practices Act.