Fair Competition and Antitrust
Realogy’s integrity gives us a competitive edge. We compete vigorously and fairly, and attract clients, independent sales associates and customers who believe in our ethical principles. As a Realogy employee, you may not seek or use confidential information about our competitors and cannot enter into any formal or informal agreements or discussions with competitors that could be interpreted as collusion or other anti-competitive behavior. If you have questions about whether a course of action may violate global competition laws, be sure to consult the Antitrust Compliance Policy and seek guidance from the Legal department before proceeding.
We win in the marketplace by acting with integrity, candor and honesty and engaging in truthful and accurate sales and marketing processes. It is never the right decision to take unfair advantage of our clients, vendors or competitors through manipulation, abuse of confidential information, misrepresentation of material facts or any other unfair or deceptive practice. In all of your work for Realogy, remember our ethical principles and act according to them.
Avoidance of Unlawful Transactions
We conduct business only with reputable clients involved in legitimate business activities. Global trade compliance laws provide guidelines on identifying unlawful or prohibited transactions for our business. We do not accept payments that may be generated by illicit financing or that may represent attempts to launder money obtained through criminal activity. Realogy does not conduct business with individuals, entities, or companies, or within countries, prohibited by applicable trade compliance laws. For more information on how to avoid unlawful transactions, including your business unit’s procedures, consult Realogy’s Global Trade Compliance Policy. If you have concerns about a particular transaction or business relationship, raise them to the Ethics & Compliance department.
Avoidance of Improper Payments and Corruption
We win business with honesty and transparency and do not engage in any form of bribery anywhere in the world. Realogy’s Anti-Bribery Policy prohibits the offer or acceptance of a bribe anywhere in the world and includes a prohibition against facilitating payments. We comply fully with the Foreign Corrupt Practices Act, the UK Bribery Act and all other applicable global anti-bribery laws. If you have questions about or want to report a violation of our anti-bribery policy or the law, contact the Ethics & Compliance department.
During a recent negotiation, the client joked that the process would go a lot more smoothly if I could get her daughter a job at our company. Since she’s not asking for money, it is not really a bribe, right?
WRONG. The request or offer of a bribe will usually appear very innocent. A bribe usually does not involve an envelope full of cash, nor does the bribe need to be provided directly to the client. Offering a bribe to a family member, associate or entity related to the client would still violate global anti-bribery laws.
A bribe can be anything of value or any type of advantage, financial or otherwise. Bribes can take many forms, including: property, gifts, stock, lavish entertainment, meals or events, job offers, vacations, scholarships, charitable contributions or political contributions.
A bribe can also take the form of a discount or an opportunity, as well as a tangible item of value.
The word “bribe” itself is rarely used in a bribery situation. So be aware of situations where someone offers or requests a favor in exchange for an advantage.
The offer, solicitation or acceptance of any improper payments, gratuities, gifts or favors to obtain or retain business.
Small payments made to foreign government officials to expedite routine government services. Sometimes called “grease payments,” this practice is very narrowly allowed under the Foreign Corrupt Practices Act, but violates the UK Bribery Act and most other global anti-bribery laws. Facilitating payments are prohibited by Realogy as a company policy.
COMPLIANCE ISSUES AT A GLANCE
|What is the Issue?||What does it Mean?||What is an Example?||What Should I Do?|
|Fair Competition and Antitrust||Avoiding conduct that could hurt consumers by limiting competition in the marketplace, which could result in higher prices and limited choices for consumers.||While at an industry meeting, an acquaintance who works for a competitor suggests that you each take a different territory so as not to compete directly with each other.||Leave the discussion immediately, making it clear that you will not participate. Report the incident to your Legal department or the Ethics & Compliance department.|
|Fair Dealing||Engaging in sales and marketing practices that are truthful, accurate and ethical.||At a social event, you meet someone who is a client of your direct competitor. She begins to complain about your competitor and offers to forward confidential pricing terms of their current contract for you to match.||While you may discuss the client’s complaints about her current provider, do not accept any confidential material or use that information to gain an unfair sales or marketing advantage over your competitor. Report the incident to your Legal department or the Ethics & Compliance department.|
|Money Laundering||Trying to hide the existence, nature or source of illegally obtained funds in order to make the money appear legitimate.||A client wishes to make payment for a transaction in cash.||This may be an attempt by the client to illegally launder money. Obtain approval from the Ethics & Compliance department before moving forward with the transaction.|
|Prohibited Transactions||Avoiding transactions that may involve individuals, entities, companies or countries prohibited by international trade compliance laws.||My business unit wants to start conducting business in a country for the first time.||You should consult the Global Trade Compliance Policy to ensure we are not restricted from doing business in this country. Contact the Ethics & Compliance department with any concerns or questions you have.|
|Bribery and Corruption||The giving or receiving of something of value with the intent of influencing a business decision or official action.||While negotiating a contract, the prospective client hints that the deal would be signed if you take him on an all-expense paid golf outing.||Do not provide the outing. Immediately report the incident to the Ethics & Compliance department.|
These trade-related laws are highly complex, and the right thing to do may not be clear. Before taking action, ask yourself whether that action upholds our standards of integrity and ethics. Remember that the Ethics & Compliance department and the Code of Ethics Line are always available to provide guidance when you need it.