Investments & External Activities

Handling Insider Information

Our jobs sometimes give us access to non-public information about Realogy or other companies. You cannot trade in the stock of Realogy or any other company on the basis of material non-public information. Not only are such activities against company policy, they are also illegal. When in doubt, consult with Realogy’s Insider Trading Policy or the Legal department.

Additionally, we must not share material non-public information with anyone, including family members, or advise others to trade stock on the basis of this information. Do not disclose material non-public information to any outside person, or speak to media, investment professionals, market analysts or shareholders about company business unless explicitly permitted under Realogy’s Investor Communications Policy.

Handling Public Relations and Investor Relations

If you receive a request from the media, such as questions from a reporter seeking comment from the company, or a request for an interview with company representatives or photos, please refer it to our Communications department. We must take care not to disclose any confidential information through public or casual conversations with the media or other third parties.

You may not speak to investment professionals, market analysts and shareholders about Realogy, its performance or any related matters, including the housing market or other companies in the industry, unless you are explicitly authorized to do so. You should refer any inquiries from investment professionals, market analysts or shareholders of Realogy to the Investor Relations department if you are not authorized to speak with them.

Engaging in Political Activity

Realogy encourages you to engage in your communities and to participate in the political process. However, in doing so, you should separate your personal political activities from those of Realogy. Supporting these personal political activities cannot be conducted on company time, with any company resources or as a representative of Realogy. You may not make political contributions or conduct lobbying activities on Realogy’s behalf, unless you are expressly authorized to do so and have cleared the contribution through the Legal department.

Responding to Legal or Regulatory Inquiries

We must immediately consult with our Legal department if, as a representative of Realogy, we receive any claim, demand, summons, subpoena, inquiry or other similar communication. We also must fully and truthfully cooperate and/or assist with Realogy’s response to legal and regulatory inquiries whenever we are instructed to do so.

Key Terms

MATERIAL NON-PUBLIC INFORMATION

Information that a reasonable investor would consider important in making a decision to buy or sell securities but that has not been publicly disclosed. Examples include unannounced financial results, merger or acquisition information, changes in senior leadership, new products and developments in pending litigation.

REMEMBER

There are strict rules and laws that govern how we use and communicate financial and other material non-public information. Our Corporate Communications and Legal departments are designed to handle such responsibilities, and the Ethics & Compliance department is always available to provide guidance when you are unsure about a course of action.

I found a draft press release on a printer disclosing that we are purchasing another company that is publicly traded. Can I buy stock in the other company before the news is announced?

No. That information would likely be considered material non-public information. Trading stock in either Realogy or the other company with that information would be against company policy and could be illegal. Provide the document to your Ethics & Compliance officer or Legal department.

As an employee…

I will:

Keep confidential any material non-public information that I come across in my work.

I will not:

Trade Realogy’s or another company’s stock based on knowledge of material non-public information.

Refer media requests for company information to the Communications department. Speak on behalf of the company unless given the authority to do so.
Use only personal time and resources to pursue community and political activities. Claim to represent the company or use company time or assets while advancing my personal political interests.