Ethics for Employees
Realogy's Guide to Lawful & Ethical Behavior
The Code of Ethics of Realogy Corporation provides an overview of the important legal and ethical guidelines that everyone working for Realogy must strive to follow. The Code of Ethics sets forth Realogy’s aspirational goals for all of its employees, and is designed to help each of us know what the relevant compliance and ethics rules are and how they apply to our business. In addition, employees may be directed to other corporate resources for further information and assistance. For example, Realogy’s Key Policies provide more detailed information about certain laws and how they are applied and enforced. The Code of Ethics and The Key Policies are guidance and policy statements for business conduct and do not create an employment contract. The Code of Ethics and The Key Policies are binding on all Realogy employees to the extent permitted by law. A violation of The Code of Ethics, The Key Policies, or other policies developed by Realogy, may be grounds for Realogy to initiate disciplinary action that could lead to termination and, in some instances, result in civil and criminal liability. The Code of Ethics and The Key Policies apply to every employee (employees, executives and officers) of Realogy and its subsidiaries worldwide. Each employee must annually certify that they have completed Code of Ethics training and that they have received, read, understood, complied with and will continue to comply with The Code of Ethics and The Key Policies. Any employee who does not certify in a timely manner may be subject to discipline, including ineligibility for salary increases and/or discretionary bonus payments until he or she has done so. Any employee who refuses to certify may be subject to termination. An Overview of The Code of Ethics and Related Policies
Any employee who acts in good faith to seek advice, raise a concern, or report misconduct is following The Code of Ethics. Realogy will not tolerate direct or indirect retaliation of any sort against such individuals. Those who engage in retaliatory conduct will be subject to disciplinary action, which may include termination. Those who supervise others have the additional responsibilities of ensuring that those they supervise understand The Code of Ethics and The Key Policies, monitoring compliance, and supporting those who report a suspected violation. Specific Business Units, operating companies or departments within Realogy may have policies that exceed the standards set forth in The Code of Ethics. All Realogy attorneys will receive a supplement to The Code of Ethics addressing ethical issues unique to their positions and our Board of Directors will receive a Code of Ethics tailored to its role. As we move forward, additional supplements and/or certification processes for other groups or Business Units may also be issued. It is the obligation of each of us to understand and comply with any additional policies as they pertain to us as Realogy employees. There may be regulations or laws that apply to a specific business activity or geographic location that are not covered by The Code of Ethics. Even if these laws or regulations are not specifically addressed in The Code of Ethics, they are deemed to be included and must be complied with as if they are. In other words, The Code of Ethics requires that all Realogy employees act in a lawful manner and comply with all applicable laws, rules and regulations that impact their work for the Company.
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Making an Inquiry or Reporting a Suspected Violation
The success of any compliance and ethics program rests on the participation and cooperation of every employee. Realogy depends on each employee to ensure that its dealings with clients and society in general are trustworthy and ethical. In order to achieve this, it is incumbent upon each employee to take action whenever: He or she has a question about the lawful or ethical...
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