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centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
centex ethics_08/08
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centex ethics_08/08

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  • 1. THE C E N T E X W AY Your guide for decision making on business conduct issues S P E eA n te x Wa y P KU I t ’s T h Ce 1.877.313.4545 Look on page 36 for your Speak Up wallet card.
  • 2. Our Mission. We are Centex. One company. United around one goal. One purpose. One mission. A unified commitment to build the best. Build the best home. Build the best community. Build the best Centex. One company. One goal. One purpose. One mission. Build the Best.
  • 3. START 5 Message from Tim Eller 6 What Comes With the Territory Obligations We Share as Centex Employees Special Obligations of Centex Leaders 8 How We Do Things at Centex When In Doubt We Ask Key Business Conduct Spotlight Areas 32 Conflicts of Interest 10 What To Do If Issues Arise Dealing with Customers, Trade Partners and Others 16 Government Affairs 20 Centex Property and Information/ Communication 24 The Workplace 28 How We Keep On 34 Track and Improve The Speak Up 36 Hotline Wallet Card
  • 4. Dear Colleague: Excellence is a process, not just an outcome. We have to demand high standards in the work we do – building homes for families. Our homes must be more than “good enough.” They must be the best. And so must our approach, the way we do business and deal with people. The Centex Way embodies our company’s core values – Build Trust, Build Respect, Build Our Core Values. Relationships, Build Excellence, Build Value, and Build Excitement – and supports our “unified commitment to build the best.” Build Build Trust. the best home. Build the best community. Build the best career. Build the best Centex. Build Respect. A high caliber organization is a reflection of its people. Part of your job is to help set, Build Relationships. promote and enforce strong ethics. We have to develop, nurture, embrace and celebrate a Build Excellence. strong corporate conscience. The Centex Way reinforces our fundamental cultural principles and provides support in identifying cultural Build Value. and ethical traps. Build Excitement. I believe our core value of Build Trust says it 05 well: Do the right thing for our company, in all situations. Have integrity. Do what you say. We can’t win the struggle for high business standards if we just talk a good game…we’ve got to play a good game. Let’s continue to build our great company by following The Centex Way. It’s our path to continued success. Tim Eller Chairman and CEO
  • 5. What Comes With the Territory What Comes With the Territory OBLIGATIONS WE SHARE SPECIAL OBLIGATIONS AS CENTEX EMPLOYEES OF CENTEX LEADERS When you join Centex you accept certain obligations Centex holds each leader accountable to: and some of the most important of these relate to _Lead through example, role-modeling and ethical business conduct. business conduct. The Centex Way applies to all Centex directors, _Monitor and ensure employees (and third parties officers and employees. A waiver of these obligations acting on our behalf) follow The Centex Way. for executive officers or directors may be made only by the board or a board committee, and must be This includes: promptly disclosed to Centex shareholders. _Arranging for appropriate orientation and training in the relevant laws, requirements Centex expects each of us to: and processes. _Read and understand The Centex Way (as well as any business conduct policies specific to our _Being open and available to discuss concerns. business units). _Deal effectively with business conduct issues that _Behave ethically and in compliance with all laws, arise in their work group, consistent with The regulations and legal requirements. Centex Way. _Participate in education to ensure we understand Centex will not tolerate any harassment the laws, regulations and legal requirements relevant or retaliation against any employee for to our jobs. reporting, supplying information or assisting an investigation into a business _Seek guidance in resolving business conduct and conduct concern. Everybody makes ethics issues by following the processes described in 07 this booklet. honest mistakes, but there’s no such thing as an honest cover-up. _Honestly answer all questions asked in compliance certifications, and fully comply in internal Consult the “What To Do If Issues investigations, if asked. Arise” section on page 32 for guidance _Deal with departures from The Centex Way if you are concerned about whether through the processes described in this booklet. certain business conduct may violate The Centex Way. _Understand that there may be consequences for departures from The Centex Way, and for departures serious enough, consequences up to and including dismissal.
  • 6. How We Do Things at Centex WHEN IN DOUBT WE ASK MAP LEGEND You should seek advice from your supervisor if you are unable to answer “no” to any of these questions. The most common business conduct issues are addressed from three perspectives in this section. 1. Is this action inconsistent with The Centex Way, our Company’s core values or business unit policy? 2. Is the action likely to endanger anyone’s health Guiding Principle or safety? 3. Do I have any doubts about whether the action The Compass. For each is legal? issue, the principle that 4. Even if it is legal, do I have any doubts about should guide our action whether it also is the right thing to do? introduces the business 5. Would it be hard to defend this action with conduct topic. Principles my supervisor, co-workers, customers, trade are useful because they can partners or those in the community where we be used to guide actions in do business? In other words, would I or could many situations and can Centex be embarrassed if this action or situation reduce the need to have were reported in the newspaper, on TV or posted rules for each situation. on a Centex bulletin board? 6. Could I regret not having discussed this situation with my supervisor or others within Policies and Rules Centex before taking the action? Boundary Map. Rules are also necessary and useful, particularly where there are laws or policies that we must know about. Decision Considerations Navigation Aids. Since not all ethical questions are easily answered “yes” or “no,” good judgment is required. If there are special considerations to support your navigation through a “maybe” area, they are offered as the third element.
  • 7. How We Do Things at Centex CONFLICTS OF INTEREST Guiding Principle A conflict of interest is defined at Conflicts of Interest. You know Centex as any activity, investment or association that interferes or might appear that a trade partner is quietly to interfere with your judgment, objectivity performing remodeling work on or ability in performing your job in the best your supervisor’s home for free. interests of the Company and our shareholders. Your supervisor manages the We do not maintain relationships that could be relationship with the trade partner, detrimental to Centex’s best interests or that could create the appearance of divided loyalty. and says that using this partner saves the division a significant Examples of Potential Conflict of amount of money. He has told you Interest Situations that any employee who reports _An ownership interest in a Centex trade partner. this information is untrustworthy _A family member with an ownership interest in a and will be let go. What should Centex trade partner. you do? _Gifts of more than nominal value accepted from or given to a current or prospective trade partner. A. Investigate the situation yourself, then tell your _Doing work for a Centex competitor. supervisor that in the interest of fairness, the trade partner should be willing to perform free _Doing work for another employer during the work for you, too. work day, even if there is no direct relationship B. Report the situation to your supervisor’s between the other company and Centex. supervisor or your division president. If you are uncomfortable doing that, call Centex’s _Selling non-Centex products on Company Speak Up Hotline. You may choose to remain property. anonymous when you call the hotline. _Supervising or making or influencing C. Keep the information to yourself. Your employment decisions about a family member or supervisor is saving the company money. You an employee with whom you have an intimate or don’t have an obligation to report it, and you other substantial relationship. might lose your job if you do. Answer B. Employees should never accept a gift of goods or services on their house from a Centex trade partner. It’s every employee’s responsibility to raise business conduct concerns. Centex will not tolerate any harassment or retaliation against any employee for honestly reporting, supplying information or assisting an investigation into a business conduct concern. You shouldn’t conduct your own investigation before reporting a misconduct concern.
  • 8. How We Do Things at Centex CONFLICTS OF INTEREST Policies and Rules _Excepted are situations where family members are distant relatives (more remote Under No Circumstances than a first cousin). _You must never, either directly or _Always follow employment-related hiring indirectly (nor should any member of policies. your family), accept cash, or accept gifts or entertainment of greater than nominal value from _Engaging in a business relationship between any current or prospective trade partner, customer Centex and a company in which you or your or competitor. family member has an ownership interest or holds a position. This includes your participation (or a _You must not make or influence decisions at family member’s) in a company or other business Centex, including contract terms, whenever a association that agrees to sell land to Centex. If the business or person with whom you have an intimate transaction or relationship has already occurred, or other substantial relationship is involved. you must bring it to the attention of your direct supervisor and the top executive promptly after you _You should never accept a gift of goods or services become aware of it. on your house from a Centex trade partner. _This could happen because of a recent _You may not build a home in a manner that violates marriage or because you learn about the actions Centex’s policies with respect to the construction of of a family member after they have occurred. homes by employees. With the Knowledge of Your Supervisor With the Approval of Both Your Supervisor and the Top Executive of Your _You must inform your supervisor before accepting Business Unit any outside positions that involve substantial time commitments, and in fulfilling those commitments Permission must be granted before: you must not use Centex time, personnel or _Obtaining an ownership interest in, or position property to carry out the work. with, a Centex trade partner, customer or competitor. _There is an exception where the interest in the outside company is solely through the ownership of publicly traded securities that constitute less than 1% of the company’s outstanding public securities, and the investment is not a significant part of your assets. _Employing any family members where there is either a direct or indirect reporting relationship or a substantial amount of interaction between family members on the job.
  • 9. How We Do Things at Centex CONFLICTS OF INTEREST Decision Considerations _Is the gift personal, or is it something that can be used on the job and shared with co-workers? The decision about what constitutes gifts and entertainment of more _Is the reason I am accepting this gift merely because than nominal value requires “it always has been done this way?” judgment. Is the gift or entertainment valuable enough that it could affect decision making or _Will this action set a precedent? even appear to do so? If the answer is “yes,” the gift or entertainment is not nominal. And _Is the gift, service or entertainment something I even something of small value that actually could not afford to buy or provide myself? compromises good decision making is not nominal regardless of amount. _Is any effort being made to conceal the gift or offer? Frequency enters into the equation too. Occasional If your answer is “yes” or even “maybe” to any meals where the giver is present are generally within of these questions, then you should seek your the usual boundaries of good business conduct, supervisor’s advice. whereas repeated meals may be perceived as having greater than nominal value or may appear There also may be situations not specifically covered compromising. here that could involve a conflict of interest. If you believe you may have an outside interest that Here are some of the questions that could conflict with those of Centex, you should seek guidance from your supervisor. Your business you might ask yourself if you are unit may also have its own more narrowly defined unsure whether accepting a gift or policies on conflicts of interest. If so, you must entertainment is appropriate: comply with both the policy set out here and your business unit policy. _Is this gift being offered or given because my position enables me to influence a Centex decision in favor of the customer or trade partner? _Will my accepting this gift influence or affect what Centex pays or is paid for products and services? _By accepting this gift, will I put myself, or appear to put myself, in a compromised position with my peers or the general public? _Would providing the same gift in return be outside the boundaries of what is acceptable at Centex?
  • 10. How We Do Things at Centex DEALING WITH CUSTOMERS, TRADE PARTNERS AND OTHERS Dealing with Customers, Guiding Principle Trade Partners and Others. All of Centex’s dealings with outside parties must reflect our commitment Susan believes her division’s to “fair dealing. Fair dealing means that we: ” purchasing manager gave _Honor customer privacy with respect to the preferential consideration to new information customers provide to Centex, and not trade partners selected for division use the information for purposes other than for which it was intended. projects. She told the director of construction operations and he _Buy and sell products and services on the basis of said he would investigate. Susan their value, and do so without creating perceptions that bribes, personal incentives or kickbacks are hasn’t heard anything in three involved, or that competitive bids are rigged. months despite her requests for _Make honest representations about Centex and its updates. She’s afraid she might products, without misrepresentation or distortion lose her job if she further reports of facts. the problem. What should she do? _Do not use our position in the Company to obtain a personal benefit from a current or prospective trade partner. A. She reported the problem to a supervisor. She should now focus on her job and let others focus Examples of Potentially Unfair or on theirs. B. Because purchasing managers have certain Unlawful Dealings leeway when selecting partners, she should assume there is no impropriety. _Selling or giving non-public personal C. Because Susan believes her concern was not information about customers properly investigated, she should continue to others. to follow the steps in the “What To Do If Issues Arise” section of The Centex Way: tell _Providing personal gifts or the division president, call the Corporate making personal loans to Compliance Office or call Centex’s Speak customers to get business. Up Hotline. _Discussing pricing strategy with Answer competitors. C. Giving preferential treatment to prospective trade partners violates The Centex Way fair dealing principle. Every employee has the responsibility to raise concerns and to surface deviations from The Centex Way, and Centex will not tolerate retaliation against those who do.
  • 11. How We Do Things at Centex DEALING WITH CUSTOMERS, TRADE PARTNERS AND OTHERS Policies and Rules With the Approval of Both Your Supervisor and the Top Executive of Under No Circumstances Your Business Unit You must never: Permission must be granted before: _Enter into discussions with competitors _Discussing profits, costs, employee compensation, to fix prices or terms of sale, divide up market share, pricing or any other competitive markets or customers, limit production or rig a information with any competitor. (There may be competitive bidding process. narrow circumstances where such discussions could be appropriate, but this is an area where General _Discuss, agree to, or take any action to boycott a Counsel should be consulted for confirmation.) competitor, customer or trade partner. _Serving as a director or an advisor to a competitor _Give to or receive from a customer or any other organization. third party a gift, loan, cash or anything of value that could be viewed as: With the Knowledge of Your Supervisor _All gifts and payments made to third parties on _A bribe or kickback, or behalf of Centex must be properly recorded. _An attempt to improperly influence the _Any entertainment receipts must be properly relationship between Centex and the customer submitted for reimbursement. or other third party. _Provide a gift that knowingly violates the policies of the recipient’s employer. _Use information we receive from companies or individuals for purposes other than for which it was intended, or violate any restrictions we agree to by virtue of receiving the information. _Demand or accept payment or personal favors from current or prospective trade partners.
  • 12. How We Do Things at Centex GOVERNMENT AFFAIRS Guiding Principle Government officials and Government Affairs. Your government agencies should be dealt with using the same standards as other third division is building a new home parties; however, political contributions and for a City Council member, and lobbying are special categories of governmental it’s making an exception and dealings where specific laws apply. customizing the home by making We must always understand the laws before we make one of the garages into an office. political contributions or engage in lobbying, and act in accordance with these laws. You’ve heard that the council member won’t be charged for Examples of Potentially Unlawful Dealings the customization. It’s very _Entertaining or making gifts to government officials difficult for the division to get or their family members. land entitlements without good _Providing resources (money or in-kind value) to relationships with elected officials, political candidates, political parties or committees. and you suspect that division _Hosting political fund-raising events. leadership has made this special _Coercing employees or trade partners to support concession to gain favor with the candidates or engage in political activity. council member for future votes. _Seeking reimbursement from Centex for What should you do? political contributions. A. Wait and see whether the council member pays market value for the customization of the home. If you find out that the council member didn’t pay for the customization, you can report it then. B. Report your concern now following the process in the “What To Do If Issues Arise” section of The Centex Way. You don’t have to provide evidence of misconduct when you report your concerns. C. Don’t report anything. You may not have all the facts, and it won’t do any good anyway. Answer B. Report your concerns promptly so Centex can investigate. Centex employees must never make payments or offer anything of value (even nominal value), directly or indirectly to government officials to obtain a particular result for the Company.
  • 13. How We Do Things at Centex GOVERNMENT AFFAIRS Policies and Rules With the Approval of Both Your Supervisor and the Top Executive of Under No Circumstances Your Business Unit You must never: _Funds or any other resources of the Company _Make payments or offer anything of (including “employee time”) may be used for value (even of nominal value), directly federal, state or local political campaign activity or indirectly, (as an individual or as an employee only with full confidence about the legality of group) to: the action. _Government officials, domestic or foreign, to Since laws in this area are complex and vary by obtain a particular result for the Company. jurisdiction, legality must be confirmed in advance by submitting a request form in accordance with _Any family member or friend of a Centex’s political activity policies and procedures, government official because of the official’s which provide for a review for compliance with status in order to obtain a particular result for federal, state and local laws. the Company. _Communications with government officials _Coerce, threaten, intimidate or otherwise to promote Centex or influence legislative or improperly induce any Centex employee to make administrative action on behalf of Centex may be or not make a political contribution or to engage or done only with: not engage in political activity. _Proper registrations, if required, and _Seek or accept reimbursement from Centex, directly or indirectly, for making a political _Full confidence about the legality of contribution. the action.
  • 14. How We Do Things at Centex CENTEX PROPERTY AND INFORMATION/ COMMUNICATION Centex Property and Guiding Principle Information/Communication. Centex owns both tangible (physical) At a meeting discussing a land property, such as computers and offices, and intangible (intellectual) property, deal, a new employee mentions such as trademarks and confidential information that his former employer and materials. As part of our jobs, we must properly use and protect Centex’s property. considered purchasing this same piece of land, and he has You are expected to: a report he could share with the _Be an active steward in protecting and preserving the value of Centex’s property. team. John, a land manager, recommends checking with Legal _Understand and abide by laws and Centex policies concerning the communication of information, and to determine if that’s appropriate. its protection from unauthorized disclosure. Several participants dismiss his Examples of Misuse or Improper comments, stating that because Disclosure of Information the other company is no longer _Using material, non-public information as the interested in the land, Centex basis for buying or selling Centex stock (or stock in would not be using competitive another company). trade secrets. In this situation, _“Tipping” or disclosing material, non-public John should: information that another person might use as a basis for buying or selling stock in Centex (or another company). A. Do nothing. The report probably consists of information that is publicly available or is _Falsifying vouchers, bills, payments or receipts. generally known in the market. B. Insist that Legal provide a recommendation _Maintaining “off-the-books” accounts. before reviewing the report. It’s better to get clarification than risk using confidential _Withholding pertinent information in internal or information from another company. external audits or investigations. C. Call the other company to confirm they are not interested in the land. _Revealing trade secrets at a conference. Answer _Acting as a spokesperson for Centex on financial matters (other than those specially designated). B. Centex employees should never use confidential information obtained from other companies or _Reviewing or discussing sensitive and proprietary previous employers. If you’re not sure whether or otherwise confidential information in public information is confidential or proprietary, places where others could see or overhear (e.g., on you should ask a Company lawyer or call the commercial airplane flights, elevators). Corporate Compliance Office. _Leaving portable computers unsecured.
  • 15. How We Do Things at Centex CENTEX PROPERTY AND INFORMATION/COMMUNICATION Decision Considerations Policies and Rules Property Under No Circumstances You must never: “Treating company property as if it _Destroy or alter any records that may were our own” is an expression relate to pending or anticipated litigation, sometimes used to describe how we should audit or investigation or otherwise violate the preserve and protect Company property. Keep records retention policy. in mind however, that Company property is owned by Centex. As such, Centex reserves the _Falsify or misstate, even in a minor way, vouchers, right to inspect or search any Company property bills, payments or receipts or accounting records. at any time, with or without your presence, to ensure workplace safety and compliance with _Disclose to third parties what might be considered law and policy. “insider information” (non-public information on Centex operations, financial results or prospects). There should be no presumption or expectation of privacy related to any personal property that may _Buy or sell securities of a company, including be co-mingled with Company property, such as in Centex securities, while in possession of material office files, e-mails or voice mails. non-public information. Communication _Disclose or improperly discard confidential Our jobs often require us to discuss Company customer or employee information in violation of matters with third parties, such as when we Centex policy or legal requirements. are setting expectations with trade partners or customers; when we are describing Centex _Give Centex property to, or accept Centex property 27 culture to prospective employees; or when we are from, another employee. There is an exception, of responding to routine inquiries. course, for an employee’s official Centex salary and incentive compensation. There are three questions that you should keep in mind for which the answer always should be “yes” Only With the Approval of the Top before you share information about Centex: Executive of Your Business Unit _Disclose to third parties valuable internal _Am I providing accurate and credible information? information (including trade secrets, processes, data, know-how, techniques and strategies). _Is the information generally known to the public or in the industry (e.g., not insider information or a _Issue press releases referencing Centex. All press trade secret)? releases must be coordinated through Centex Corporate Communications. _Am I the right person to be providing the information? (For example, only designated _Produce and distribute external communications employees are authorized to discuss Company materials that refer to another Centex business unit. financial matters with investors.) _Establish or modify a Centex-related Internet site, When in doubt about any of these, your business home page or hyperlink. unit communications leader and the VP of Corporate Communications are good resources for _Endorse any products or services using your job advice, especially with respect to press inquiries. role or title, or on behalf of Centex.
  • 16. How We Do Things at Centex THE WORKPLACE Guiding Principle Centex must be a place where The Workplace. You have every employee can do his/her job to the best of his/her abilities. This means each recently seen a trade partner’s employee has an obligation to do his/her part to employee pay a lot of attention maintain a safe and secure work environment to a new female employee in a free of discrimination, harassment and violence. Centex sales office, saying things Examples Counter to the Principle that cross the line of proper _Promotion decisions based on anything other than businesslike behavior. The woman job qualifications, competence and merit. seems annoyed, and you’re _Display of offensive materials. concerned that she may be afraid _Inattention to resolving workplace safety hazards. to confront the trade partner’s employee because her supervisor _Fighting or threatening behavior. has a good relationship with him. _Being under the influence of alcohol or drugs What should you do? at work. _Remarks that are offensive or that could be viewed A. Advise the woman to ignore the trade partner’s as harassment. employee. That’s all you can do because the trade partner’s employee doesn’t have to _Unwelcome physical contact. comply with The Centex Way. B. Confront the trade partner’s employee and tell him to stop harassing the woman and to leave her alone. C. Report your concern. You have an obligation to report concerns, but you’re not responsible to handle misconduct yourself. Answer C. Centex does not allow our agents, customers or trade partners to harass any Centex employee. Harassment means verbal or physical abuse, unwelcome contact, advances or propositions, displays of offensive materials or other acts that create a hostile work environment. You should report your concern promptly so that Centex can handle it.
  • 17. How We Do Things at Centex THE WORKPLACE Decision Considerations Policies and Rules What may be offensive, Under No Circumstances threatening or intimidating to You must never: one person may not be to _Discriminate on the basis of age, color, another. The simple rule of race, religion, disability, gender, sexual thumb is “if any employee thinks my behavior orientation or national origin. is, then it is, and hence it should trigger ” sincere re-examination. _Use hiring tests that are not directly related to job requirements or that have not been specifically The questions that you should ask validated for the job group. yourself are: _Harass or allow our customers or trade partners to _Is my behavior fully conducive to others doing harass Centex employees. Harassment means verbal their best work? or physical abuse, unwelcome contact, advances or propositions, displays of offensive materials or other _Is my behavior relevant to meeting workplace acts that create a hostile work environment. goals? _Allow unsafe working conditions or environmental _Is there anything about my behavior that does hazards to go unreported to your supervisor. not imply dignity and respect for the individual, including respect for personal privacy? _Make threats of violence, engage in acts of violence, or otherwise intimidate other employees. If you cannot answer “yes” to all these questions, then the behavior probably is inappropriate. _Use, possess, distribute, manufacture or transport on Centex property, or on company business, or during working hours, any of the following: _Illegal drugs, equipment or paraphernalia related to illegal drugs, or prescription drugs other than by those for whom they were prescribed. _Alcoholic beverages, except as specifically authorized for company functions. _Use or carry any lethal weapons or allow any customers or trade partners to use or carry lethal weapons on Centex property (unless they are police officers, appropriately licensed security guards or others with prior written consent from Centex, or except to the extent applicable law may prevent Centex from prohibiting the possession of firearms for lawful self-defense). Only With the Approval of the Top Executive of Your Business Unit _Allow family members or guests to visit non-public Company facilities unaccompanied by an employee.
  • 18. What To Do If Issues Arise It is impossible to conduct business 5. If the process breaks down in any way or if you feel without facing business conduct issues. a need to raise concerns anonymously, Centex has established the Speak Up Hotline as an alternative Most issues are fairly straightforward avenue for raising concerns. The Speak Up Hotline to resolve, but sometimes the issues number is 877-313-4545. are more complicated. The basic steps for resolving any business conduct issue, It is every employee’s responsibility to raise concerns whether it is complicated or not, are the same. and to surface deviations from The Centex Way, including violations of law by Centex employees (or When you confront an issue or have a those who are acting on Centex’s behalf). question, the following sequential steps are advised: _No Retaliation. Centex will not tolerate retaliation 1. First, consult the appropriate section of The against any employee who raises a business conduct Centex Way or your business unit’s policies as key issue or reports a violation of the law or of Centex reference guides. policy. You may not discharge, demote, suspend, threaten, harass, discriminate or retaliate against 2. If you still have questions about what to do, seek a person who alleges misconduct or provides your supervisor’s counsel and guidance. Your information in good faith in an investigation. supervisor may also suggest other people to go to for assistance, such as someone in the legal If you feel that you have experienced retaliation department or in human resources. as a result of making a complaint or providing information you should report it to your supervisor, 3. If your supervisor is unable to guide you or if you other management personnel, the legal department, feel your supervisor’s advice is compromised in human resources, the Corporate Compliance Office some way, you have two options. or the Speak Up Hotline. 33 _One is to approach your supervisor’s boss Centex will investigate allegations of retaliation, with the matter (or even higher levels and violations will result in consequences up to as required). and including termination of employment. _The other is to call the Centex Corporate _False Claims. Employees who make claims Compliance Office at 214-981-6822. This that they know to be false will be subject to path also remains available if moving up the disciplinary action. business channel proves unsatisfactory. _Confidentiality. Centex will make every effort to 4. In the special case of questionable accounting or protect the confidentiality of individuals who report auditing matters, you have two additional avenues violations of the law or Company policies, although for resolving the issue or question. it may not be possible to do so in every case, such as when disclosure is required by law. _By calling the Centex VP of Internal Audit at 214-981-6336. _By calling 877-313-4545 and requesting that your concern go to the Centex Board of Directors Audit Committee Chairperson.
  • 19. How We Keep On Track and Improve The Centex Way is not just a code of _The business conduct issue themes and challenges conduct. It is a process for ensuring most important to the business. everyone in the Centex family “knows _What is occurring in the business to ensure we the way” and “follows the way” It is . keep on The Centex Way. part of what distinguishes us as a great organization that consistently This enables Centex to: operates at the highest standards of _Ensure proper focus is maintained. business conduct in everything we do. _Communicate the importance placed on Our process for keeping on track entails steps in business conduct. each of our work groups, steps as a company and steps for us individually. _Make good decisions about priority setting. In Our Work Group _Have a well-informed basis for reporting to the Since each business unit faces distinct challenges, Centex Board of Directors on this key we should expect the key business conduct issues in governance accountability. each business unit to have a different emphasis. Each of Us Individually At least once each year Centex expects you will have As a Centex employee, you are required to the opportunity to: promptly and honestly complete an annual _Refresh (and deepen) your understanding about questionnaire that asks important questions about how The Centex Way applies specifically to your your business conduct and the business conduct work group. you have observed at Centex over the past year. One of these questions is whether you have had _Surface business conduct topics most needing an opportunity over the past year to discuss The preventive attention and maintenance. Centex Way in your work group. The answers to this question are tabulated and status is provided _Develop action plans appropriate to your business. to business leaders. _Assess progress made on those action plans. The purpose of this step is to ensure the key business conduct issues in The Centex Way are kept Each business unit individually determines top of mind for veteran employees and are properly how these discussions occur and cascade in the introduced during orientations for new employees. organization, and how action planning and follow- up occur. Commonly, The Centex Way is a staff There is also a compliance benefit to this step meeting agenda item, assisted by a Leaders Tool Kit. that is in keeping with good governance best practices, but the primary purposes at Centex are As a Company communication, process control, diagnosis Each year at one of the quarterly reviews of business and improvement. strategy execution, business unit executives share with Centex corporate senior management:
  • 20. Please carry your Speak Up Hotline card in your wallet or purse. 1.877.313.4545 Ask yourself, does it: SPEAK UP It’s the Centex Way Build Trust. Build Respect. Obligations We Share as Centex Employees When you join Centex you accept certain obligations Build Relationships. and some of the most important of these relate to business conduct. 1. Read and understand The Centex Way (as well as any business conduct policies specific to your Build Excellence. business unit). 2. Behave ethically and in compliance with all laws, regulations and legal requirements. Build Value. 3. Participate in education to ensure you understand the laws, regulations and legal requirements relevant to your job. Build Excitement. 4. Seek guidance in resolving business conduct and ethics issues by following the processes described in The Centex Way. 5. Honestly answer all questions in compliance certifications or in internal investigations. 6. Deal with departures from The Centex Way through the processes described in this booklet. 7. Understand that there may be consequences for departures from The Centex Way and, for departures serious enough, consequences up to and including dismissal.
  • 21. About Our Company Dallas-based Centex, founded in 1950, is one of the nation’s leading home building companies. Its leading brands include Centex Homes, Fox & Jacobs Homes and CityHomes. In addition to its home building operations, Centex also offers mortgage, title and insurance services. Centex has ranked among the top three builders on FORTUNE magazine’s list of “America’s Most Admired Companies” for nine straight years and is a leader in quality and customer satisfaction. The Centex Way articulates what it means to be a Centex employee with respect to exemplary business conduct, a critical dimension of how we measure success. © 2003-2008 Centex Corporation REV 07/08

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