Good Corporate Citizenship

Report Suspected Violations

We have a collective responsibility to maintain Realogy’s reputation and integrity and report all suspected violations of the Code of Ethics. Realogy has the obligation to properly investigate and resolve all such reports. Realogy does not tolerate retaliation against anyone who makes a good-faith inquiry or report of a suspected violation. If you become aware of another employee reporting an allegation, we ask that you respect the confidentiality of the related investigation.

While we request confidentiality for our investigations, nothing in our Code or any Realogy policy or agreement prohibits you from reporting possible violations of federal, state or local law or regulation to any governmental agency or entity, including the Department of Justice, the Securities and Exchange Commission, the Congress, and any agency Inspector General, or making other disclosures that are protected under the whistleblower provisions of federal, state or local law or regulation. You do not need the prior authorization or approval from Realogy to make these reports or disclosures and you are not required to notify Realogy that you have made these reports or disclosures.

Accurate Books and Records and Financial Disclosures

Honest and accurate recording and reporting of financial information to our stakeholders is critical to our business. We have a duty to ensure the accuracy of Realogy’s financial information. Our financial statements conform to generally accepted accounting principles and must accurately reflect financial transactions and events. You must not falsify any record or document for any reason or establish any undisclosed or unrecorded funds or assets for any purpose. You have a responsibility to comply with Realogy’s system of internal controls and may not attempt to circumvent any such process or control. You must report any suspected fraud in the company’s financial reporting, disclosures or internal controls to the Code of Ethics Line in accordance with Realogy’s Anti-Fraud Policy.

Protecting Our Environment

We are committed to growing and advancing Realogy’s business with a focus on sustainable business practices. We strive to meet or exceed all health, safety and environmental requirements applicable to our operations and work continuously to minimize the environmental impacts of our operations by taking specific measures to recycle, conserve energy and natural resources, and reduce our carbon footprint.

Engaging in Our Communities

Realogy’s success is built on strong communities. Each year, the Realogy Charitable Foundation raises and donates funds to hundreds of charities. In addition, our employees, franchisees and independent sales associates contribute to their communities through philanthropic practices and by volunteering in charitable, social or political organizations. We are very proud of all the significant work accomplished by Realogy, its business units and its brands.

As you take part in these important efforts, please keep in mind that your role at Realogy may put you in a position to influence other employees (particularly those who report to you), your colleagues and the vendors you engage on Realogy’s behalf. In the spirit of respecting and encouraging diversity of all kinds and to avoid potential conflicts of interest, you should be careful to avoid imposing your beliefs on others or soliciting donations in the workplace for the organizations you support. You should not leverage your position at the company to benefit the charities you personally support.

Realogy supports our employees’ commitment to the causes they are passionate about and encourages all employees to become involved in their communities to make a difference for others.

Obtaining Exceptions

In rare circumstances, an exception to a particular Code of Ethics requirement may be granted by the Ethics & Compliance department. Exceptions must be requested and granted before the exception can be pursued. Exceptions for Executive Officers must be submitted to the Chief Ethics & Compliance Officer and approved by the Audit Committee of Realogy’s Board of Directors. Waivers granted for Executive Officers will be publicly disclosed as required by law or stock exchange listing rules.

KEY TERM

FRAUD

A deliberate false representation of company information or records. Examples include the false reporting of expenses or revenue, misappropriation of assets, improper time reporting, embezzlement of company funds, falsification or tampering with company records and falsifying personal credentials.

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REMEMBER

Being the industry leader requires that we act ethically and responsibly, both in the work that we do for Realogy and in how we interact with our environment and communities.