A.Purpose
It is The Home Depot¡¯s intention to provide all stakeholders with the highest degree of confidence that its financial control systems are implemented and maintained by Senior Financial Officers who exhibit the highest degree of integrity and are free from actual or apparent conflicts of interest. Therefore, The Home Depot has adopted a specific Code of Ethics for Senior Financial Officers (¡°Financial Code of Ethics¡±), which is in addition to this Business Code of Conduct and Ethics.

B.Standard of Conduct
This Financial Code of Ethics applies to all Senior Financial Officers of the Company. The term ¡°Senior Financial Officer¡± shall mean the Chief Executive Officer, Chief Financial Officer, Controllers, Treasurer, all Vice Presidents in the Finance Department and other designated financial Associates. Under this Policy, the Company¡¯s Senior Financial Officers are expected to conduct the financial, accounting, reporting, and auditing activities of the Company in compliance with all laws and regulations and in accordance with the highest ethical standards. Each Senior Financial Officer is also responsible to do the following:
• Act in all Company financial and accounting matters as a model of honesty, integrity and fair dealing;
• Owe and fulfill the highest duty of care to the Company over any personal, other professional or third party interests;
• Avoid becoming involved in or approving any transaction or project that creates an actual or apparent conflict of interest between the Senior Financial Officer, his or her family, other third parties and the Company;
•To the maximum extent possible, take actions and develop financial and accounting procedures that ensure that the Company¡¯s books and records are accurate, and in conformance with recognized and required accounting standards, nationally and internationally;
•Report any proposals or attempts by others to record transactions inaccurately or to keep transactions off the Company¡¯s books and records, and never approve, permit, or engage in such accounting practices;
•Report any proposals or attempts by others to cause you to engage in any negotiations for intended off-the-books transactions, activities or projects;
•Never approve, authorize or participate in any activity that involves the falsification of documents or accounts, the making of misleading or intentionally incomplete entries into the Company¡¯s books and records, or in any documents provided to external auditors or government agencies, or other authorized third parties;
•Report any proposed changes in Company accounting policies and practices to appropriate Company Officers, including a specific statement of why the accounting change has been proposed and your recommendation as to whether and on what basis it should be approved or implemented;
•Provide assurance, that the financial and accounting aspects of all proposed project activities, reports, or other business is lawful, accurate, complete, in conformance with corporate policy and procedure and not characterized or developed to mislead;
•Ensure to the maximum extent possible that no Officers or Directors use Company funds or assets for personal benefit, the benefit of their relatives or other third parties;
•Provide full, fair, timely, accurate and understandable disclosure in the periodic reports required to be filed by the Company and of, as appropriate, any violation of Company financial and accounting policies or procedures;
•Engage in dealings with outside and internal auditors that are open, honest, and non-misleading, and which do not seek to exert undue influence on their work for the Company;
•Provide periodic assurance to the Disclosure Committee, in an agreed upon format, that internal financial control systems are adequate to detect fraud in the financial books, records and accounts of the Company;
•Comply with rules and regulations of federal, state, provincial and local governments, and other appropriate private and public regulatory agencies;
•Respect the confidentiality of information acquired in the course of work except when authorized or otherwise legally obligated to disclose;
•Proactively promote ethical behavior as a responsible partner in the work environment and the community; and
•Achieve responsible use of and control over all Company assets and resources.

The Financial Code of Ethics for Senior Financial Officers is not limited to the actions described above, nor is it intended to address or anticipate all situations involving Senior Financial Officers with respect to the reliability and accuracy of company books, records, and accounts, as well as the integrity of all financial disclosures and financial dealings of the Company.

C.Confidential Disclosure and Monitoring Procedures
All Associates have the responsibility to inform the General Counsel, Corporate Compliance, any member of the Enterprise Risk Council, Disclosure Committee or Board of Directors of observed or suspected violations of law, Company Policy, or this Financial Code of Ethics for Senior Financial Officers, as well as any activity that might constitute financial fraud or financial misconduct. If you have a question about the Business Code of Conduct and Ethics Policy or the application of such policy to a particular situation, please contact the Corporate Compliance Department at (770) 433-8211, ext. 14098 or via email at corporate_compliance@homedepot.com. If you observe potential violations, please talk to your manager, the Corporate Compliance Department or call the Home Depot AwareLine at (800) 286-4909. Failure to follow the provisions of this Financial Code of Ethics for Senior Financial Officers can lead to discipline, up to and including termination.