A Quick Reference Guide

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STARBUCKS MISSION STATEMENTAND GUIDING PRINCIPLES

To establish Starbucks as the premier purveyor of the fi nest coff ee in the world while maintaining our uncompromising principles as we grow.

Th e following six Guiding Principles will help us measure the appropriateness of our decisions:

• Provide a great work environment and treat each other with respect and dignity

• Embrace diversity as an essential component in the way we do business

• Apply the highest standards of excellence to the purchasing, roasting and fresh delivery of our coff ee

• Develop enthusiastically satisfi ed customers all of the time

• Contribute positively to our communities and our environment

• Recognize that profi tability is essential to our future success

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BUSINESS ETHICSAND COMPLIANCE

Starbucks Business Ethics and Compliance program:

• Supports Starbucks values and Guiding Principles

• Helps ensure compliance with the law

• Promotes ethical decision-making

We do it by:

• Distributing the Standards of Business Conduct• Providing mechanisms for partners to speak up — including a helpline for partners to ask for guidance or report concerns

• Investigating sensitive issues and reviewing potential confl icts of interest

• Facilitating legal compliance and ethics training to help partners make good decisions

• Supporting the compliance eff orts of other groups, including Internal Audit, Finance and Legal

• Providing insights into partner concerns, issues and trends that impact our business

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What this means for you:

• You are empowered — You can deliver great customer experiences, knowing that Starbucks supports you in doing the right thing and conducting business with integrity.

• You have responsibility — You play a critical role in ensuring that Starbucks is a great work environment and in protecting our culture, our reputation and our brand.

• You have help — If you are unsure what to do in a situation, you have resources available to you, including the Standards of Business Conduct and the Business Conduct Helpline.

• You have a voice — When you believe something isn’t right, you can speak up and share your concerns knowing that Starbucks wants to hear them, and does not tolerate retaliation against partners.

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A POCKET GUIDE TO THESTANDARDS OF BUSINESS CONDUCT

We are judged every day by our actions and by the decisions we make. Th e areas highlighted below are intended to provide you with guidelines for handling diffi cult situations that may arise at work. More detailed information and examples can be found in the Standards of Business Conduct on www.starbucks.com.

Gifts

A gift of nominal value may be exchanged with a vendor or business associate if it is a common business courtesy, such as coff ee samples, a coff ee cup, pens or a similar token — although even small gifts to government offi cials are prohibited under most circumstances. (Please see “Government Agents and Agencies” on page 6.)

As a general rule partners should limit gifts to or from any one vendor or business associate to $75.00 USD per year. More detailed guidelines may be available from business units or local leadership.

A gift of money should never be given or accepted. However, during traditional gift-giving seasons in areas where it is customary to exchange gifts of money, such as in China, Japan, Malaysia and Th ailand, partners should not solicit but may exchange cash with non-governmental business associates in nominal amounts up to the equivalent of $20.00 USD.

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A gift or favor should not be given or accepted if it might create a sense of obligation, compromise either party’s professional judgment or create the appearance of doing so. In deciding whether a gift is appropriate, consider its value and whether public disclosure of the gift would embarrass you or Starbucks.

If you are off ered an out-of-policy gift and you cannot respectfully decline it, you may not keep it and must disclose it to your manager. Consider with your manager possibilities such as donating the gift to charity or putting it on display in a common area.

Entertainment

Partners may off er or accept a meal or entertainment if it is reasonable and customary, occurs infrequently, and is not expensive.

Prohibited

ExpensiveIntended to Infl uence

To/From Government Agents

Proceed with Caution

Personal Benefi tFeelings of Obligation

Expectations of Return Favor

Allowed

NominalInfrequent

Within Policy

Gifts and Entertainment

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Government Agents and Agencies

Dealings with government offi cials and authorities are subject to special considerations, so it’s important to recognize when you are interacting with such an entity and to know the applicable rules.

Payments to government agents should always be strictly for offi cial services rendered and should be reasonable in amount given the nature of those services. Partners must request receipts and record payments for all services rendered by government offi cials. Employees of government-owned companies should also be treated as government agents.

Starbucks is responsible for third party actions on our behalf so use caution when hiring consultants or other intermediaries for matters involving government agencies.

Gifts should not be exchanged with government offi cials. It is also against Starbucks policy and may violate anti-bribery and other laws to off er or make a payment or gift of any kind in order to facilitate a local process or to infl uence a local government offi cial.

If you believe that you have a compelling reason to give or receive a gift to or from a government offi cial, or to make a facilitating payment, you must fi rst receive approval from Starbucks chief compliance offi cer and all gifts or payments will be subject to strict record-keeping requirements. (Please see “Make the Right Call” on page 10 for information on contacting the chief compliance offi cer.)

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Confl icts of Interest

Confl icts of interest should be avoided.

A confl ict of interest exists when a personal interest or activity interferes or merely appears to interfere with the duties that a partner performs at Starbucks. An actual or potential confl ict can cloud a partner’s judgment or call a partner’s integrity into question and may violate company policy or the law.

A confl ict of interest almost always arises if, for example:

• You own, operate or work for another company that does, or desires to do, business with Starbucks or that competes with Starbucks (for example, working in a competitor’s coff ee shop)

• You or a close family member serves as an adviser or has a substantial direct investment in such a company

• You hire or arrange for a family member to perform services for Starbucks

If you think you have a potential confl ict, you must disclose it to the Business Ethics and Compliance program. (Please see “Make the Right Call” on page 10 for information on contacting the Business Ethics and Compliance program.)

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Confi dential Information and Insider Trading

In the course of your work, you may have access to signifi cant, non-public information about the company and its operations. It is a violation of company policy and the law to:

• Misuse confi dential information

• Disclose that information to unauthorized parties

• Buy or sell stock (including selling shares after exercising stock options) on the basis of such information

Examples of confi dential information may include:

• Starbucks decision to enter, expand within or withdraw from a market

• Non-public fi nancial information, performance measures and targets

• Th e development of new products or services

• Th e acquisition or loss of a major supplier or customer

• A proposed acquisition, joint venture or merger

• Government investigations

• Changes in key personnel

• Sales of signifi cant assets

• Names of suppliers and vendors

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Th ird-Party Confi dential Information

Just as we take care to protect our information, Starbucks respects the information of others. Mishandling or misusing others’ information can lead to legal liability and put our integrity at risk.

Here are some basic rules to follow:

• DON’T bring any papers or computer records from prior employers to Starbucks

• DON’T accept or use anyone else’s confi dential information

• DON’T solicit confi dential information from another company’s present or former employees or suppliers

• DON’T agree to review new product ideas or proposals if the submitter has not signed an appropriate release from the legal department

If you suspect you have information from an unauthorized source, stop your review immediately and send it promptly (marked “confi dential”) to the Law and Corporate Aff airs department.

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MAKE THE RIGHT CALL

It’s natural to have questions. Your manager, Partner Resources team, and/or the Standards of Business Conduct may have the answer. If you can’t fi nd an answer, have a compliance, legal or ethical concern, or need to reach the chief compliance offi cer, please contact the Business Ethics and Compliance program. Th e program may be reached 24 hours a day, seven days a week, via the Business Conduct Helpline numbers on the opposite page.

Starbucks does not tolerate retaliation against or the victimization of any partner who raises concerns or questions regarding a potential violation of the law or any Starbucks policy that he or she reasonably believes to have occurred.

Please be aware that calls to the Helpline are directed to our Helpline operator in the United States.

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Australia

Canada

Costa Rica (Agronomy Office)

Germany

Hong Kong (APAC Support Center)

Netherlands (EMEA Head Office and Roasting Plant)

Republic of Ireland

Switzerland (Starbucks Coffee Trading Company)

United Kingdom

United States

Areas that do not yet have a local Helpline number

1-800-45-4956 or 1-800-154-867

1-800-611-7792

0-800-011-0928

0800-182-2581

800-90-8032

0800-022-2214

1-800-55-8618

0800-56-1170

0800-028-3528

1-800-611-7792

Email: BusinessConduct @Starbucks.com, or to place a free call to the Helpline, please contact your local operator and advise him or her that you would like to place a “reverse charge” or “collect” call to the United States, number 678-250-7560. If you would like to place your call anonymously, please say “Miss Starbucks” or “Mister Starbucks” when the operator requests your name.

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ETHICAL DECISION-MAKING

Th e “right” thing to do isn’t always obvious — sometimes we fi nd ourselves in a gray area where competing priorities can cause tension. And yet, we all have to make diffi cult decisions every day. By relying on a few simple resources, you can be comfortable knowing that you are making good choices. As a fi rst step you should follow the ethical decision-making framework presented below. If you need additional guidance, talk to your manager or contact the Business Ethics and Compliance program.

1) Identify the ethical problem.

2) List possible solutions (what could you do?) and any obstacles to resolving the problem.

3) Seek input from others, if appropriate.

4) Determine the best approach (what should you do?).

• Is it consistent with our Guiding Principles, the Standards of Business Conduct and any applicable law or regulation?

• Would your approach embarrass you or Starbucks?

• How would your approach look published in the newspaper?

• Would you be comfortable with the example it sets for future decisions?

5) If the path isn’t clear, ask for guidance.

6) Follow through on your decision.

© 2007 Starbucks Coffee Company. All rights reserved.Printed in the USA on recycled paper made from 100% post-consumer waste.

BEC Quick Reference Guide v 1.2E