The objective of this Code of Conduct is to establish a work environment that allows and encourages all employees to perform their duties in an efficient, effective, respectful, and safe manner. Our Code is an important statement about who CoreLogic (the “Company”) is and what is important to us as a company.
CoreLogic believes every employee must do the right thing at all times. Every employee can make a difference, so it is essential that all employees act ethically and with integrity. Following this Code, CoreLogic policies, procedures, and applicable laws, rules, and regulations will ensure the right choices are made. Our ethical behavior ensures the continued trust that CoreLogic has built with customers, employees, and others who have a stake in the success of the Company. We must earn that trust every day.
While this Code may not cover every situation, it is a valuable resource for deciding the right thing to do. Use good judgment in everything you do and ask for help if you are ever unsure of the right course of action.
This Code applies to all employees, executives, officers, managers, leaders, and certain third parties with whom CoreLogic conducts business. All parties must:
We look to our leaders to set the tone for an ethical workplace, and to mentor, coach, and guide employees on how to conduct business in line with our CORE values and in compliance with this Code. Leaders must:
CoreLogic expects each employee to act with the highest integrity and use good judgment in all situations. If ever faced with an ethical dilemma, CoreLogic employees can ask themselves the following questions to guide them throughout the decision-making process:
If you can answer “yes” to all of the questions, you can safely consider the action and its effect on CoreLogic constituents. However, if the answer to any of the questions is “not sure” or “no,” you should reconsider your action before proceeding. It is never wrong to ask for help.
No one, regardless of their position at CoreLogic, is exempt from any part of this Code. However, waivers to this Code may be granted in a manner permitted by law, with review and approval from the Chief Legal Officer. The Board must approve any waiver of this Code for the CEO, CFO, and any other executive committee member.
Failure to comply with this Code of Conduct may result in consequences, including corrective action or termination of employment or relationship.
As a CoreLogic employee, you are required to report suspected violations to this Code, our policies, or any applicable laws and regulations. You are the Company’s first line of defense. Follow the rule: if you see something, say something. Reporting violations and concerns helps CoreLogic keep its employees and its brand safe and can assist in minimizing or preventing harm to CoreLogic, to our customers, and to consumers or other stakeholders. You must report, through an appropriate channel, any misconduct you have observed or have become aware of, whether the violation involved you, another CoreLogic employee, or a third party who is working on behalf of CoreLogic or conducting business with CoreLogic. Report violations or suspected violations to one of the following resources:
Note: The Ethics and Compliance Hotline is operated by an independent reporting service that allows you to report your concern anonymously (where permitted by law) and confidentially any time, day, or night.
We know it takes courage to come forward and share your concerns. CoreLogic will not retaliate or permit retaliation against anyone who makes a good faith report about possible misconduct or legal violations, or against anyone who assists in investigations of such matters. Acting in good faith means that all reports of possible violations are made sincerely and honestly, regardless of whether they can be substantiated.
You can be assured your concern will be handled promptly and appropriately. CoreLogic will treat your report with sensitivity and disclose information only to those who need it in order to conduct an appropriate investigation. Reports will be investigated in a respectful, professional manner as promptly and confidentially as possible. If you are asked to participate in an investigation, you are required to cooperate fully and maintain the required degree of confidentiality.
CoreLogic takes its responsibility to comply with laws, rules, and regulations seriously. While certain relevant laws are addressed in this Code, there are many additional laws, rules, and regulations that may apply to CoreLogic and its employees. Therefore, CoreLogic expects you to become reasonably informed and to comply with the laws, rules, and regulations applicable to you.
As a provider of services to the financial industry, certain consumer financial laws may apply to certain CoreLogic products and services. As a CoreLogic employee, you are required to know and comply with all applicable federal consumer financial laws. See the Federal Consumer Financial Laws Policy for more information.
We believe in a thriving marketplace with free, fair, and open competition. Each of us must deal fairly with our customers, vendors, resellers, and competitors to sell our products and services. Fair competition and anti-trust laws help prevent agreements and activities that limit free trade and competition in the market. You must comply with and understand these laws whenever you do business. Generally, these laws prohibit:
CoreLogic is committed to being honest and truthful with its customers, vendors, and other business partners. We will not misrepresent the quality, features, or availability of CoreLogic products and services, or do anything illegal or unethical to gain business. You must adhere to the basic principles of fair business dealing. Some examples of prohibited conduct include, but are not limited to:
Note: Although generally bundling products and services for a packaged price may be acceptable, sometimes it is necessary to make them available separately. Contact the Legal Department if you are ever unsure if bundling is appropriate.
Never accept bribes, offer bribes, or let others bribe for you, and act to prevent bribery by others who conduct business on our behalf. Bribery occurs when an individual provides something of value to another with the intention of influencing the recipient’s actions. For more information, refer to the CoreLogic Anti-Bribery Policy.
Occasional gifts and offers of entertainment can help build and solidify working relationships with customers and business partners and are often viewed as a normal part of doing business. However, there are instances when receiving or accepting any form of gift can cross the line and create a conflict of interest or unfair bias that may influence current and future business decisions. You must not offer or accept meals, entertainment, or gifts if providing or accepting them could unduly influence a decision or create an appearance of improper purpose. Always use good judgment and follow the guidelines in place to identify circumstances under which an offer is okay. Gifts or entertainment given or received should:
Employees can only offer support and contributions to political groups in a personal capacity. Unless you receive approval in advance, do not use or donate CoreLogic funds or assets (including facilities, equipment, or trademarks) for any political endeavor. The Company may make political contributions only when approved by the Executive, Global Head of Public Policy and Industry Relations, Chief Legal Officer, and Chief Executive Officer.
In the spirit of our shared mission, vision, and CORE values, CoreLogic encourages its employees to make a difference and show that CoreLogic is a leader in the communities in which we live and work. You are encouraged to be a part of our shared social purpose and to participate at one or more of the many initiatives CoreLogic supports through our philanthropic partnerships and employee engagement programs. We also support and encourage your personal involvement in charitable activities. In general, employee contributions and participation in charitable events must be made on your own time and from your own personal funds, unless using the allotted paid volunteer time with appropriate approvals. See the Employee Handbook for more information.
We value the privacy of our employees, consumers, and others with whom we conduct business, and we handle their personal information with care. Personal information includes any information that could be used to identify someone, either directly or indirectly, such as a name, employee ID, address, account number, or phone number. We are committed to the responsible collection, storage, use, transfer, and disposal of personal information. Employees with access to personal information of consumers or other employees are required to protect the information that is entrusted to them. You must not access, use, or disclose such information except as authorized for appropriate business purposes, and you must protect the confidentiality and security of that information. This includes practicing good cybersecurity. You must follow the processes and practices in place to protect our networks, computers, programs, and data from attack, damage, or unauthorized access.
Many details about how the Company operates need to be kept confidential in order for CoreLogic to remain competitive and successful. Confidential information includes all non-public information or information governed under a Non-Disclosure Agreement that provides CoreLogic a competitive advantage or may be harmful to CoreLogic, or its business partners, if disclosed. Examples include, but are not limited to, plans for future development of products and applications, business strategies, employee information, client lists, market conditions, financial results, product designs and concepts, pricing, and any database of aggregated public data. Such information must be kept secure and shared only with other employees who need to know the information to perform their duties. You must never use this information for your personal benefit, or disclose it to others, including family members, friends, or anyone else who does not have a need to know it. Any confidential information or trade secrets should never be disclosed outside CoreLogic without approval from a Managing Director and the Legal Department.
In the course of doing business, sometimes you will learn confidential information about clients, vendors, consumers, and other business partners. You must keep such information confidential and secure. Sharing this information with the wrong source could provide an improper advantage to the third party or its competitors and may violate the agreements CoreLogic has with third parties.
CoreLogic respects the intellectual property (IP) rights of others, which may include, but is not limited to, patents, trademarks, copyrights, trade secrets, brands, logos, ideas, inventions, images, designs, drawings/block diagrams, methods, processes, systems, know-how, confidential technical/financial/business information, data, and software. You must follow the applicable laws to obtain proper permission prior to using, soliciting, or accepting the IP of others. Please contact the CoreLogic Legal Department if there is any question regarding the use of any intellectual property of others.
A conflict of interest is a situation where an opportunity for personal gain is contrary to the best interest of CoreLogic. A conflict of interest can exist any time your personal investments, activities, interests, or associations — or those of your family members or others with whom you have a personal relationship — compromise your loyalty to CoreLogic. When making decisions related to CoreLogic, you have a duty to act in the best business interest of CoreLogic and avoid even the appearance of a conflict. While it is impossible to list every situation that could present a conflict, there are certain situations where conflicts typically arise. It is important to be able to recognize a potential conflict to help avoid one. A conflict can happen when:
As an employee, officer or director of CoreLogic you have an obligation to not take for yourself personal opportunities that are discovered through the use of Company property, information or position. You are also prohibited from using Company property, information or your position for personal gain or from competing with the Company. Each employee, officer and director owes a duty to the Company to advance its legitimate interests when the opportunity to do so arises.
Physical and electronic assets such as furniture, equipment, tools, inventory, Company records, computer hardware, and software are Company property and provided for you to do your job. Occasional personal use of these assets is permitted as long as the use, if appropriate, does not interfere with your work and does not violate Company policies or applicable laws. Be aware that these assets belong to CoreLogic, and anything you write, send, download, or store on the Company’s systems becomes Company property; all information generated by employees, including their notes, belongs to CoreLogic. CoreLogic may monitor, review, and disclose the use and data as deemed necessary, so you should not have any expectation of privacy when using CoreLogic systems. Use good judgement in your online and electronic communications. You must never violate a law, harass others, disclose confidential information, download, install or attach software or hardware that may compromise the security of the asset; disable installed security tools or system files. or interfere with network users, servicers, or equipment, and never duplicate, install, or use software in a way that violates the copyright or applicable license terms.
Our Intellectual Property (IP) is among the most valuable assets of CoreLogic and includes, but is not limited to, patents, trademarks, copyrights, trade secrets, brands, logos, ideas, inventions, images, designs, drawings/block diagrams, methods, processes, systems, know-how, confidential technical/ financial/ business information, data, and software. You are obligated to protect IP in accordance with CoreLogic policies and applicable laws, even if you should stop working for CoreLogic. You must never use CoreLogic IP for any external business or commercial venture without proper approval. Keep in mind that any IP you create for CoreLogic or while using CoreLogic resources are the property of CoreLogic, even if you no longer work for CoreLogic. Any misappropriation of IP could result in civil or criminal liability and penalties. Please contact the CoreLogic Legal Department with any questions regarding CoreLogic IP or to request assistance in the protection of CoreLogic IP which you create.
In addition to protecting CoreLogic Intellectual Property, the protection of CoreLogic’s physical, financial, and technology assets is a critical responsibility. Each of us is entrusted to respect and protect these assets from loss, damage, theft, and improper use.
CoreLogic will not tolerate employee theft or fraud of CoreLogic assets. Misrepresentation, stealing, and deception have no place at CoreLogic. Keep in mind theft goes beyond just stealing physical assets and includes misrepresenting expenses on expense reports or falsifying receipts. Immediately report any suspicion of improper use, theft, loss, or abuse of Company assets. CoreLogic will investigate and, where appropriate, prosecute reported incidents. CoreLogic reserves the right to seek repayment or restitution from those who steal.
Demonstrating financial integrity and fiscal responsibility at all times is critical to retaining the high degree of trust placed upon us by our lenders, customers, vendors, regulatory entities and other financial stakeholders. Accurate and complete financial records are necessary to fulfill our financial obligations, provide reliable insights into our financial health and comply with various laws and other regulations. All employees with roles involving our financial records and related controls must ensure such records are complete, accurate, and comply with applicable policies and standards, and that our system of financials controls is maintained. Further, every employee must ensure that money is appropriately spent, and that business transactions are undertaken in accordance with our polices and are fully documented.
Our financial records provide important visibility into the Company’s health, keep us accountable to financial stakeholders, and are the basis upon which we make important business decisions. You must record transactions accurately, completely, and in appropriate detail to facilitate full accounting of the Company’s finances. If you are involved in the preparation of a CoreLogic financial statement, you must also adhere to the relevant policies, processes, standards and controls such that the financial statements fairly and completely reflect the operations and financial condition of the Company.
Special Obligations for the Chief Executive Officer and Senior Financial Officers
Our Chief Executive Officer, Chief Financial Officer, Treasurer and Controller/Principal Accounting Officer are held responsible by our Board for ensuring the integrity of financial reports provided to our investors. These officers must promptly bring to the attention of the Audit Committee any information they may have concerning significant deficiencies or material weaknesses in key financial controls or external reporting practices and standards. To comply with the Code, these officers are encouraged to engage in an active and open dialogue with the Audit Committee and to discuss with the Audit Committee any concerns or suggestions that they may have regarding the Company’s financial controls and reporting practices. The Company takes its financial reporting obligations very seriously. Therefore, violations of this Code are likewise taken seriously and can result in termination of the offending officer. The Board will determine the appropriate punishment, considering its fiduciary duty to the Company’s investors, and considering all facts and circumstances surrounding the violation.
Employees are expected to spend Company money wisely and in compliance with the Company’s Business Travel and Expenses policy. When submitting an expense for reimbursement or spend money on behalf of CoreLogic, ensure that the cost is reasonable, directly related to Company business, and supported by appropriate documentation. Employees are required to accurately and timely track and record all business expenses. If you are uncertain whether you should spend money or submit an expense for reimbursement, consult with your Leader.
Each time you enter into a business transaction on behalf of the Company, there must be documentation recording the agreement. Never sign any contract on behalf of CoreLogic unless all of the following are met:
The creation, storage, maintenance, and proper disposal of records is important in helping CoreLogic maintain its financial integrity and remain in compliance with legal, tax, and regulatory requirements. You must keep records for as long as is required by law, rule, regulation, or the Record Retention Policy. Records include, but are not limited to, emails, instant messages, voicemails, or any documentary material, regardless of physical form, that is generated or received by CoreLogic in connection with business transactions or legal obligations. Records that have met their retention requirements and are not subject to litigation hold must be properly destroyed.
You may receive notification that you are in possession of records relevant to litigation, investigation, or an audit. Do not conceal, alter, or destroy any documents subject to these holds unless the Legal Department authorizes you to do so. See the Records Retention Policy for more information.
When contracting with vendors for products and services, always strive for the best possible deal for CoreLogic. Consider the total cost of ownership as well as other pertinent evaluation dimensions such as quality, reliability, flexibility, sustainability, risks, and terms and conditions of the deal before making a final decision. The lowest price may not always be the best option for the Company. Always follow the defined sourcing and procurement process when dealing with Vendors. All business conducted by Vendors must be conducted lawfully and with integrity. See the Vendor Management Policy for more information.
CoreLogic is committed to ensuring all employees work in an environment that promotes diversity and inclusion. CoreLogic is an Equal Employment Opportunity employer, and as a federal contractor, it is the Company’s policy to take affirmative action to employ and advance the employment of minorities, females, veterans, and individuals with disabilities. Employment here is based solely upon individual merit and qualifications related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of age, sex or gender, marital status, race, religion or religious creed, color, national origin, natural hair styles or textures associated with race or ethnicity, ancestry, gender identity, gender expression, transgender, genetic information (including characteristics and testing), medical condition (including cancer and genetic characteristics), pregnancy (including childbirth, lactation and related conditions), physical or mental disability, sexual orientation, uniformed service member status, military and veteran status or any other classification protected by federal, state or local law. We are also committed to providing reasonable accommodations for qualified persons with disabilities. Take steps to create an inclusive culture that makes every employee feel welcome.
We treat others with respect and dignity, and we do not tolerate discrimination, harassment, and bullying of any form — verbal, physical, or visual. Sexual harassment, abusive language, demeaning words or actions, aggressive acts, and disorderly conduct, as well as threats and intimidation, should all be reported promptly, whether directed at you or someone else. We strongly encourage CoreLogic employees to report incidents of bullying or harassment immediately to your direct Leader or Human Resources. These same standards of acceptable behavior extend to anyone who does business with us, including customers and vendors, and apply in both work-related settings and work-related activities, even when outside the office.
We are committed to the safety and security of all CoreLogic employees. Our employees are the greatest assets the Company has, so all safety procedures, policies, and trainings must be followed fully. You are encouraged to take immediate action if you witness a situation that could put others at risk. Substance abuse can also create safety hazards and put you and your coworkers at risk. Illegal drugs and the unauthorized use of alcohol and prescription drugs is strictly prohibited on CoreLogic property, Company time, or at Company-sponsored events. There may be instances where drinking alcoholic beverages while conducting Company business is allowed, but you must comply with all laws and Company policies, and always exercise moderation and good judgement.
We have a zero tolerance for violence or threats of violence. All employees are responsible for recognizing and resolving existing or emerging issues before they escalate to threats or violence. CoreLogic relies on you to report any acts or potential acts of violence, including, but not limited to, verbal or intimidating threats, destruction of CoreLogic property, or possession of firearms, bombs, or weapons. If you see something, say something.
CoreLogic is committed to ensuring accurate and complete information is conveyed to the public in a consistent, timely, and professional manner. Communication with investment communities and the media must be managed carefully, so CoreLogic has designated individuals with authorization to speak on behalf of CoreLogic. Do not speak or make any statements on the behalf of CoreLogic unless you are authorized to do so. You must refer all media inquiries about the Company, any of its subsidiaries, or any of its business lines to the Marketing and Communications Department by email [email protected] or calling 877.849.1023 and selecting option 2. You must obtain approval from the Corporate Marketing and Communications Department before accepting a public speaking obligation or opportunity. If you are authorized as a spokesperson for CoreLogic, you must not disclose proprietary, confidential, or any customer information learned in the course of your work, except as specifically authorized.
CoreLogic recognizes the growing use of social media as a means for exchanging ideas and building relationships, but you are responsible for using good judgement in your online activity and complying with all applicable laws. If you are not authorized to speak on behalf of CoreLogic, you must be clear that your statements do not reflect the opinion of the Company.
You are responsible for the content you publish and must not:
CoreLogic complies with requests for information by government and regulatory agencies as required by law and fully cooperates with internal and external investigations or audits. If you receive an inquiry from a government official or agency or if you receive a subpoena or other legal process request for information that might reasonably relate to your employment at CoreLogic, you must immediately contact the Legal Department. Do not provide any information unless and until you have obtained permission to do so.
If you are questioned or asked to provide information related to an internal or external investigation or audit, and are authorized to provide the information, you have a duty to cooperate and must provide truthful, accurate, and complete information. If you are involved or have information relating to an audit or investigation, do not discuss it with unauthorized internal or external parties.