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pulte homes business practice updated

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pulte homes business practice updated

  1. 1. Business Practices Policy
  2. 2. Table of Contents 1 Our Policy............................................................................................................................................................ 2 Our Commitment to Fairness............................................................................................................................ Anticompetitive Behavior................................................................................................................................ 2 Bribes and Kickbacks ...................................................................................................................................... 2 Settlement Services.......................................................................................................................................... 2 Gifts and Gratuities.......................................................................................................................................... 2 Conflicts of Interest ......................................................................................................................................... 3 Your Purchase of a Pulte Residence ................................................................................................................ 4 5 Our Company Records and Reporting............................................................................................................. Financial Accounting Records......................................................................................................................... 5 Tax Laws ......................................................................................................................................................... 5 Records Management ...................................................................................................................................... 5 6 Our Assets ........................................................................................................................................................... Expenditures .................................................................................................................................................... 6 Finance Manual ............................................................................................................................................... 6 Bribes, Kickbacks and Gifts ............................................................................................................................ 6 Loans ............................................................................................................................................................... 6 Political Contributions..................................................................................................................................... 6 Non-business Use ............................................................................................................................................ 7 8 Our Securities ..................................................................................................................................................... Material Information........................................................................................................................................ 8 Blackout Periods.............................................................................................................................................. 9 Trading Pulte Stock ......................................................................................................................................... 9 10b5-1 Trading Plans....................................................................................................................................... 9 11 Our Communications with the Public .............................................................................................................. 12 Our Customers.................................................................................................................................................... Non-discrimination.......................................................................................................................................... 12 Confidentiality ................................................................................................................................................. 12 13 Our Employees.................................................................................................................................................... Equal Opportunity ........................................................................................................................................... 13 Confidentiality ................................................................................................................................................. 13 Harassment ...................................................................................................................................................... 13 Non-retaliation................................................................................................................................................. 13 Health and Safety............................................................................................................................................. 13 Environmental Compliance ............................................................................................................................. 14 Drugs and Alcohol........................................................................................................................................... 14 Duty to Cooperate and Keep Confidential....................................................................................................... 14 16 Our Proprietary Rights...................................................................................................................................... Confidential Information ................................................................................................................................. 16 Trade Secrets ................................................................................................................................................... 16 Inventions, Works and Other Contributions .................................................................................................... 16 Assignments .................................................................................................................................................... 16 Exclusive Rights .............................................................................................................................................. 16 Infringement .................................................................................................................................................... 16 17 Our Electronic Communications....................................................................................................................... Email Communications ................................................................................................................................... 17 Internet Usage.................................................................................................................................................. 17 Your Expectation of Privacy ........................................................................................................................... 17 19 Protocol for Waivers for Executive Officers and Board of Directors ............................................................ Pulte Homes, Inc. i Business Practices Policy
  3. 3. Business Practices Policy Our Policy At Pulte Homes, we and our Board of Directors believe that sound business practices start with an absolute commitment from each of our employees to act ethically in carrying out our business, and to comply with the laws and regulations that impact our business. This commitment helps ensure that the reputation of Pulte Homes continues to be one of its most valuable assets. It also ensures that we maintain a positive, open and productive environment for our employees. With this commitment in mind, we have developed this Business Practices Policy, which governs all of the companies in the Pulte Homes family (which we refer to collectively as “Pulte” or the “Company”). There may be additional policies that relate to your job, but this Business Practices Policy will control in the event that other policies are inconsistent with this Policy. Pulte reserves the right to modify this Policy at any time. We expect that you will personally comply with this Policy. We also expect that you will immediately report any person or situation that deviates from this Policy. Pulte welcomes such reports, and will not tolerate retaliation against anyone who makes such reports. We further realize that reporting illegal or unethical conduct to your manager or supervisor is not always possible or comfortable. To address this situation, we remind you to use the Pulte Ethics and Compliance hotline to comply with your reporting requirement (the number is located on the Company Intranet). Finally, we expect that you will have a general knowledge of the laws and regulations that govern your job, and will seek guidance on any matter on which you have a question. You should be aware that your failure to observe this Policy may result in disciplinary action by Pulte, up to and including termination. You may also be subject to such consequences if you permit others to violate this Policy and you do not report the situation in a timely manner. To the extent you are involved in or aware of illegal or fraudulent activity, you could also personally suffer legal penalties and/or criminal sanctions. This Policy will guide you in your role as a Pulte employee, but no policy can anticipate every possible scenario or question. Pulte has therefore established support systems to answer questions, provide advice and assist employees in interpreting this Policy. In each section of the Policy, we will provide you with the proper contact person(s) in the event you have questions or need to report certain activities. Contact information can be found, along with this Policy, on our Company Intranet. Richard J. Dugas, Jr. President and CEO Business Practices Policy 05/07 Pulte Homes, Inc. Page 1
  4. 4. Our Commitment to Fairness If you are a decision maker at Pulte, it is your job to help Pulte choose vendors, trade contractors, suppliers and other business partners on the basis of quality, service, price and similar competitive factors. As outlined below, it is a violation of this Policy to make business decisions on any other basis, or to solicit or accept favors in exchange for business decisions. Anticompetitive Behavior Antitrust laws are designed to maintain an open, competitive marketplace. These laws prohibit a wide range of practices that could restrain trade or limit competition. You should not participate in any agreements or understandings of any kind with our competitors or suppliers to fix, stabilize or control prices in violation of the antitrust laws, nor should you enter into any agreement or understanding with competitors to boycott customers or suppliers in an effort to affect market prices. Bribes and Kickbacks Bribes and kickbacks, which can arise when dealing with vendors, trade contractors, suppliers, customers, bankers, employees, government officials or others, are illegal. They are prohibited by both this Policy and other laws, including the Foreign Corrupt Practices Act, and they are prohibited whether the funds or assets are received directly or indirectly, and whether the funds or assets used are those of Pulte or a third party. Settlement Services The Real Estate Settlement Procedures Act (RESPA) governs our relationship with mortgage companies, title agencies, and other settlement service providers, whether or not these companies are part of Pulte. Among the RESPA rules are the following: • You are prohibited from splitting the fee that a settlement service provider receives for its settlement services unless you perform appropriate services for which your fee is fair value. • You are prohibited from receiving a kickback or a referral fee from a settlement service provider for merely referring the business. • If your job involves the provision of settlement services (for example, mortgage or title services), you are prohibited from giving any other person or company a kickback or referral fee for merely referring the business to Pulte. • You must have every customer that both purchases a Pulte home and uses a Pulte settlement service sign an Affiliated Business Arrangement Disclosure form. Gifts and Gratuities Business judgment regarding vendors, suppliers or trade contractors can also be compromised by gifts and gratuities that are excessive. At the same time, Pulte recognizes that gifts and sponsored social events are a natural part of business. The following guidelines should be used when you are offered a gift or an opportunity to attend a sponsored social event: • Personal gifts, such as goods, services or event tickets for your personal use, including gifts from homeowners, should not exceed nominal value. • Third-party sponsored social events, such as golf outings, meals and sporting or other events, should also be nominal in value and should not compromise good business judgment or Pulte’s reputation. Page 2 Pulte Homes, Inc. Business Practices Policy 05/07
  5. 5. Personal gifts and sponsored social events should only be accepted periodically. When deciding whether value is “nominal,” consideration should be given to the cumulative annual value received from a single vendor. Exceptions to this Policy can only be made by 1) the President of your business unit or 2) the appropriate finance officer in your business unit. If you are the President of your business unit, you must clear any exceptions through the General Counsel or the Company Controller. Conflicts of Interest Employees of Pulte, and their immediate family members, must avoid doing anything that creates a conflict of interest, or the appearance of a conflict of interest, with their responsibilities to Pulte. A “conflict of interest” arises when an employee’s personal interests are inconsistent with Pulte’s interests, or when an employee’s judgment may be compromised because of the potential for personal gain. The problem is not a simple one. No policy, however comprehensive, can cover all possible scenarios. If you have a question as to whether an existing or contemplated business situation involves a conflict of interest, you should resolve any doubt in favor of full disclosure of the facts to the appropriate Pulte contact. Here are some examples that we consider a conflict of interest: • You may not work for, or invest in, another business that competes with Pulte, such as a homebuilder or mortgage or title company, or do work that interferes with your ability to perform your Pulte duties. This investment prohibition does not apply to a non-controlling investment in a public company that competes with Pulte. • Neither you nor someone in your immediate family may provide goods or services to Pulte. If you wish to engage in business with Pulte, you must obtain the approval of your supervisor and your Area Vice President of Finance or the Company Controller. • You should avoid investing in, or having any financial interest in, any vendor, supplier or trade contractor if you have meaningful control over Pulte’s decision to work with that company (other than through a mutual fund or a non-controlling investment in a public company). If you or anyone in your immediate family has a prohibited ownership interest in a Pulte vendor, contractor or trade contractor, you shall immediately disclose that fact to your supervisor and your Area Vice President of Finance or the Company Controller. • You may not accept a discount from a Pulte vendor, supplier or trade contractor unless that discount is generally made available to all Pulte employees in your operation. If you are unsure as to whether to accept a discount, check with your Area Vice President of Finance. • If you are considering building your own home or performing a major renovation, you should utilize the services of a general contractor in order to avoid undue distraction and interference with your job responsibilities. If you use a Pulte vendor, supplier or trade contractor to build your own home or perform renovations, you must pay reasonable commercial rates for such services and document those payments with invoices and receipts. If a Pulte vendor, supplier or trade contractor offers you a discount for such goods or services, you may not accept that discount unless that discount is generally made available to all Pulte employees in your operation. When building your own home or performing renovations you may not use Pulte building materials or require Pulte employees to assist or perform such renovations. This provision does not prohibit customary construction or warranty work on a Pulte home. • If you learn of a business opportunity in the course of your work with Pulte, you may not take advantage of that opportunity, even if you believe Pulte would decline it. Before you take advantage of such a business opportunity, you must disclose your plans and confirm with the General Counsel or the Company Controller that the business opportunity was, in fact, declined by Pulte. Business Practices Policy 05/07 Pulte Homes, Inc. Page 3
  6. 6. Your Purchase of a Pulte Residence We hope that many of you become Pulte customers. To avoid the appearance of impropriety, the following policy applies to the purchase of a Pulte residence: • You may purchase any available home to occupy as your primary or secondary residence, or if a member of your “immediate family” will occupy it as his or her primary or secondary residence. The terms and pricing of the purchase should be pre-approved by an independent higher-level manager (in most cases, the President or head of your business unit head or top finance officer). The term “immediate family” includes your or your spouse’s parents, grandparents, children, siblings or grandchildren. • If you wish to purchase a Pulte residence that will not be occupied by you or a member of your immediate family, you must have the prior permission of both your Area Vice President of Finance and the Company Controller. Additional policies issued by Human Resources govern each employee’s purchase of a Pulte residence. You are responsible for understanding and adhering to those policies, whether you are the purchaser or are otherwise involved in the employee purchase transaction by virtue of your position. Contact: Appropriate business unit President or Finance Officer. Special situations or further questions: Office of the General Counsel Company Controller Page 4 Pulte Homes, Inc. Business Practices Policy 05/07
  7. 7. Our Company Records and Reporting There are many laws and rules that govern our obligations to accurately track, record and report our financial and other data. These include state and federal securities laws, regulations of the Securities and Exchange Commission, the Foreign Corrupt Practices Act, the Internal Revenue Code, the rules of the New York Stock Exchange and the Sarbanes-Oxley Act. This latter law requires senior executives to personally certify that our financial records are complete and accurate, and that we have gathered and retained all required documentation. It is therefore imperative that everyone at Pulte take personal responsibility for proper record keeping and reporting. Financial Accounting Records You are expected to observe and comply with generally accepted accounting principles, and to follow the system of internal accounting controls established by Pulte requiring that company books and records accurately and fairly reflect, in reasonable detail, the transactions and disposition of the assets of Pulte. You must observe the following: • You may not make false, misleading or artificial entries on any books, or in any records or reports for any reason. • All information regarding company funds or company assets must be disclosed, regardless of their purpose. • You may not make or approve payments from company funds or other assets with the intention or understanding that any part of such payment is to be used for any purpose other than that described by the documents supporting the payment. • All payments must be supported with appropriately approved invoices or receipts, expense reports or other customary documents, all in accordance with established policy. Tax Laws You are obligated to adhere to the Internal Revenue Code, as well as any state or local tax laws that affect your job. Records Management A variety of laws that govern our accounting, tax and business operations require us to follow proper records retention procedures. All documents and records that you receive or generate in the course of your work are the property of Pulte. These records, which include both physical and electronic documents, are subject to the Records Management Policy that details the period of time for which you are required to retain records. You are required to comply with this Records Management Policy with respect to all business records in your possession regardless of their format or storage location. In addition, regardless of the retention period specified in the Records Management Policy, you are prohibited from destroying documents and records that pertain to ongoing litigation or to a government investigation, or to any matter in which litigation or a government investigation is reasonably foreseeable. Contacts: Company Controller Director - Corporate Audit Records Management – Office of the General Counsel Business Practices Policy 05/07 Pulte Homes, Inc. Page 5
  8. 8. Our Assets It is your responsibility to help safeguard our hard assets, such as cash, inventory, tools, equipment, records, computers and other valuable items, whether owned, leased or borrowed by the Company. You should use and maintain such assets with care and respect, while guarding against waste and abuse. Expenditures All items you expense to Pulte, such as travel or meals, must be legitimate business expenditures made for the benefit of Pulte. You should review and follow any additional policies regarding expenditures in your operation, including travel policies. Finance Manual If your job involves the negotiation of financing arrangements or leases, you are expected to know and adhere to the policies and procedures set forth in Pulte’s Finance Manual. In addition to other parameters, the Finance Manual will guide you as to whether a financing arrangement or lease must be pre-approved by your Area Vice President of Finance, the Company Treasurer, the Company Controller, and/or the Chief Financial Officer. Among other requirements, the Finance Manual also provides that: • A guaranty by Pulte’s parent company or another Pulte entity of an affiliate’s financial commitment or contractual performance requires pre-approval by the Company Treasurer or the Chief Financial Officer. • In all circumstances, the acquisition or formation of an entity, or the formation of a joint venture, regardless of the purpose, must be pre-approved by the General Counsel. Bribes, Kickbacks and Gifts No Pulte assets may be used to pay bribes or kickbacks to a third party, or to a Pulte employee under any circumstances. If you use Pulte assets for a personal gift or for entertainment expenses, whether for a third party or a Pulte employee, the gift must be nominal in value and must be properly booked on Pulte’s financial and payroll records. Any gift of greater than nominal value may not be given without permission of the top finance officer in your business unit or the President or head of your business unit. Loans Unless pre-approved by the Company Controller or the General Counsel, you may not make or accept any personal loan from Pulte, other than loans from Pulte’s mortgage affiliate(s). In addition, neither the members of the Pulte Board of Directors, nor the officers of Pulte’s parent company who are deemed “executive officers” by the SEC may accept a loan from Pulte, including any loan from Pulte’s mortgage affiliate(s). Political Contributions Any political contributions made directly on behalf of Pulte must be approved in advance by the General Counsel. You may not seek reimbursement for political contributions made with personal funds. In part, this Policy is designed to ensure that the Company’s contributions are lawful under the various governing state and local laws, regulations and reporting requirements. For purposes of this Policy, we consider political contributions to include money, services or other items of value given to candidates for office, government officials, political parties, political action committees, and referenda or political education funds. Page 6 Pulte Homes, Inc. Business Practices Policy 05/07
  9. 9. Non-business Use You may not use Pulte facilities or assets for a purpose unrelated to Pulte business without the permission of your supervisor. Contacts: Company Controller Chief Financial Officer Company Treasurer Office of the General Counsel Business Practices Policy 05/07 Pulte Homes, Inc. Page 7
  10. 10. Our Securities As an employee of a publicly traded company, you must observe certain rules regarding buying, selling and trading of Pulte Securities. “Pulte Securities” include: Pulte Homes’ stock; employee, director, and publicly traded stock options; Pulte Homes’ publicly traded debt; and the Pulte Stock Fund in the 401(k) Plan. Violation of the following policy may also subject you to personal civil and criminal liability. Material Information You may never engage in the purchase, sale or trading of Pulte Securities if you possess Material Information that has not been previously disclosed to the investing public. “Material Information” is any information that a reasonable investor would consider important in an investment decision regarding Pulte Securities. Examples of Material Information include, but are not limited to: • Significant internal financial information that departs in any way from what the market would expect. • Significant changes in sales, earnings, or dividends. • Significant non-ordinary course financing transactions. • Stock splits or other transactions relating to Pulte stock. • Significant mergers, tender offers or acquisitions of other companies, or major purchases or sales of assets. • Significant changes in management. • Significant sales or purchases by Pulte of its own securities. • Significant litigation. • Significant transactions with other companies, such as joint ventures or licensing agreements. Note that this list is merely illustrative and not exhaustive. Also keep in mind: • All Pulte employees and members of the Pulte Board of Directors are subject to this restriction. • This restriction includes elections made through your 401(k) while you are in possession of Material Information not previously disclosed to the public. • This restriction does not apply to trades made pursuant to a pre-approved 10b5-1 trading plan (see “10b5-1 Trading Plans” below). Unless specifically authorized, you may never share such nonpublic Material Information (“tipping”) with anyone outside Pulte, including members of your family. Employees should become familiar with the Pulte Homes, Inc. Disclosure Policy which requires that disclosures comply with applicable law and New York Stock Exchange rules and regulations. The Disclosure Policy is located on the Company Intranet. Page 8 Pulte Homes, Inc. Business Practices Policy 05/07
  11. 11. Blackout Periods Covered Employees You may not purchase, sell, or trade Pulte Securities during the quarterly blackout period if you are a member of the Board of Directors, an officer (defined below), or a Home Office or field manager/professional staff member (collectively “Covered Employees”) who has access to nonpublic Material Information, as described above. Because of the possible attribution to you, members of your family or other persons living with you should also adhere to these blackout periods. Administrative support reporting directly to any Covered Employee should discuss the applicability of this policy with their immediate supervisor. “Officer” includes all Home Office, field and subsidiary officers, and all members of operations committees at the Area and Division levels. Blackout Periods “Blackout periods” begin every quarter on January 1, April 1, July 1, and October 1, and end following the first business (trading) day after the day on which Pulte has publicly released its earnings report for the preceding quarter. For example, if Pulte issues a press release with quarterly financial information at any time on a Wednesday, and the New York Stock Exchange is open for trading on Thursday, the blackout period will end and the trading window will reopen as of the opening of the market on Friday morning. Pulte reserves the right to impose additional blackout periods from time to time. • This restriction includes elections made through your 401(k) plan with respect to the Pulte Stock Fund during the blackout period. The Company will regularly monitor trading in the Pulte Stock Fund in the 401(k) Plan. • This restriction does not apply to trades made pursuant to a pre-approved 10b5-1 trading plan. Trading Pulte Stock You may never engage in trading, short sales, trading in options or other speculative investment transactions regarding Pulte securities. “Trading” means a combination or pattern of substantial or continuous buying and selling of Pulte securities or options with the primary objective of realizing short term gains. • All Pulte employees and members of the Pulte Board of Directors are subject to this restriction. • This restriction includes elections made through your 401(k) plan. 10b5-1 Trading Plans The prohibitions on trading at a time when you possess nonpublic Material Information or during a blackout period do not apply to transactions that are made pursuant to a properly established Rule 10b5-1 trading plan. To comply with Pulte’s insider trading policy, a 10b5-1 trading plan: • Can only be established (or amended) at a time when the insider does not possess nonpublic Material Information. • Cannot be established (or amended) during a blackout period. • Must specify the amount, pricing, and timing of transactions in advance or delegate complete discretion on these matters to an independent third party. • Cannot be established, terminated, or amended without the advance approval of our General Counsel. Business Practices Policy 05/07 Pulte Homes, Inc. Page 9
  12. 12. Once a 10b5-1 trading plan is adopted, the insider cannot exercise any influence over the amount of securities to be traded, the price at which they are to be traded, or the trade date. ****** Certain officers and members of the Board of Directors are also subject to the trading procedures described in the Company’s “Officers and Directors Insider Trading and Confidentiality Policy.” If you are interested in establishing, or would like more information about, a 10b5-1 trading plan, or if you have any questions regarding this policy, please contact our General Counsel. Contact: Office of the General Counsel Page 10 Pulte Homes, Inc. Business Practices Policy 05/07
  13. 13. Our Communications with the Public All inquiries from the press should be directed to the person in your market or community designated to handle press inquires, or to the Company’s Investor Relations department. Unless it is part of your normal job duties, you should not do the following without permission from the proper Pulte resource: • Respond to any questions from a reporter or the press • Issue press releases or make arrangements for publicity • Speak on behalf of Pulte via any media • Comment about Pulte on the Internet, in “chat rooms,” on bulletin boards or on any website • Respond to any comments about Pulte on the Internet, in “chat rooms,” on bulletin boards or on any website If you are confronted with a crisis or an emergency situation, refer to the Company’s Crisis Communications Plan and immediately contact the Company’s Investor Relations department. If you are concerned about comments you see in the media or on the Internet regarding Pulte, please bring those matters to the attention of the Company’s Investor Relations department or the General Counsel. Inquiries from security analysts or investors should always be referred to the Company’s Investor Relations department. Primary Contact: Vice President, Investor and Corporate Communications Special situations or further questions: Office of the General Counsel Business Practices Policy 05/07 Pulte Homes, Inc. Page 11
  14. 14. Our Customers Our customers are our most valuable assets. You should always be fair, honest, and respectful whenever dealing with customers. If your job involves sales and marketing you are expected to be familiar with the laws, regulations and policies applicable to your job. Non-discrimination It is a violation of this Policy and the law to discriminate in any aspect in the sale of a home or the provision of a mortgage, title policy or settlement service due to a person’s race, color, religion, national origin, gender, disability, family status or other status protected by the Fair Housing Act, Fair Lending laws, the Equal Credit Opportunity Act and other applicable laws. Confidentiality In some cases, laws will prevent us from sharing customer information with third parties, or even with affiliates. Information about our customers, including their names and contact information, should not be shared with third parties without due consideration of applicable laws and business considerations. You should understand the laws and policies that govern sharing customer information in your employment context. Contact: Office of the General Counsel Page 12 Pulte Homes, Inc. Business Practices Policy 05/07
  15. 15. Our Employees Equal Opportunity Pulte is an equal opportunity employer. Our policy is to maintain a workplace environment free from discrimination on the basis of race, age, color, religion, gender, sexual orientation, national origin, disability, veteran status or other legally protected status. This equal opportunity policy covers all aspects of the employment relationship, including hiring, pay, benefit programs, opportunities and termination. Pulte will make every effort to reasonably accommodate employees or applicants with mental or physical disabilities as defined under the Americans with Disabilities Act. It is the individual responsibility of every manager to be mindful of non-discrimination and reasonable accommodation in making employment decisions. Confidentiality Pulte Homes provides our employees with the level of privacy and confidentiality required under the law. Therefore, all employees are prohibited from using, disclosing or disseminating to anyone any company-related information regarding our employees and/or their families. Unauthorized use, disclosure, copying and/or misuse of confidential information is a serious breach of duty. This obligation to maintain the confidentiality of information continues after your employment relationship terminates. Harassment Pulte is committed to providing a workplace free of sexual harassment as well as harassment based on race, color, religious creed, national origin, ancestry, age, medical condition, marital status, physical or mental disability, sexual orientation, or any other basis prohibited by applicable federal or state law. Pulte will not tolerate harassment of employees. Harassment includes verbal, physical or visual conduct that creates an intimidating, offensive or hostile working environment or that unreasonably interferes with job performance. Additionally, sexual harassment includes: • Employment decisions regarding promotions, pay or scheduling based on an employee’s submission or rejection of sexual advances • Conditioning employment or continued employment upon submission to a sexual advance, whether stated explicitly or not. Any incident of harassment by any employee or any other person (including a vendor, trade contractor or homeowner) shall be promptly reported to the employee’s immediate supervisor or to Human Resources. Every reported harassment complaint will be investigated thoroughly, promptly, professionally and confidentially. Non-retaliation Pulte will not tolerate retaliation against anyone who reports in good faith a person or activity believed to be in violation of these employment standards. Pulte will also not tolerate any form of retaliation against any employee cooperating in the investigation of a complaint. Health and Safety You are responsible for attaining and maintaining a safe work environment, and you are expected to perform your duties in accordance with all health and safety laws, regulations and Pulte policies. You are also responsible for Business Practices Policy 05/07 Pulte Homes, Inc. Page 13
  16. 16. immediately bringing to your supervisor’s attention any harassment, injury, occupational illness or hazardous conditions in the workplace. You are prohibited from bringing firearms and weapons to any Pulte site, even if you are properly licensed to do so by the laws of your state. This prohibition extends to your vehicle if it is parked on a Pulte site, or any Pulte-owned vehicle wherever it is located. Environmental Compliance Pulte's facilities and operations are subject to numerous environmental requirements. These statutes and regulations govern air emissions, discharges of water to surface and groundwater, handling and disposal of waste, including hazardous substances, and work place practices. They also focus on the release of pollutants to the air or water, or onto or under the ground. Such a release, even if accidental, must often be reported to governmental authorities. Pulte's policy is to comply fully with all applicable environmental laws and regulations. Each employee must be sensitive to regulatory requirements and must exercise good judgment regarding the environmental effect of the Company's operations. If you become aware of any violation of environmental law or any action that may appear to conceal such a violation, you must immediately report the matter to your manager or to the Pulte Law Department. Employees are also encouraged to identify opportunities for improving our environmental performance, including conservation and recycling. If you become aware of any violation of environmental law or any action that may appear to conceal such a violation, you must immediately report the matter to your manager or to the Pulte Law Department. Drugs and Alcohol Pulte strives to maintain a drug-free and alcohol-free workplace. Employees must report for work free of alcohol or illegal drugs in their bodies or in their possession. Pulte strictly prohibits the use, sale, purchase, transfer, distribution, possession or manufacture of illegal drugs and narcotics or (except as discussed in the next paragraph) alcoholic beverages on Pulte Homes premises and work sites or during any working time outside the workplace while representing Pulte Homes. Upon approval from the Division President, an exception exists to possess alcohol on Pulte premises for the limited purpose of providing gifts to customers, and not for consumption by Pulte employees, provided that the use or possession complies with all applicable laws. In addition, a manager at or higher than the Division President level or its equivalent (e.g. Corporate Vice Presidents) may approve alcohol use by employees in appropriate Pulte business or social situations provided that the employee’s use or possession complies with all applicable laws. In situations where Pulte or its vendors sponsor social events at which alcohol is present, you should do nothing to compromise Pulte’s reputation, and you alone are responsible for your actions. You are expected to act lawfully and appropriately for the business context. This policy applies to all employees, independent contractors, consultants and anyone on property owned or leased by Pulte Homes, including parking lots, Pulte-owned vehicles and any location being used to conduct Pulte Homes business or social events. Implementation of this policy is intended to comply with local, state, and federal laws and regulations. No employee should consider the use of alcohol a business obligation at any time. Employees may be required to take a test to determine the presence of drugs or alcohol. Testing positive for illegal drugs or alcohol, or refusing to take a test when requested, is a violation of this policy and will result in disciplinary action up to and including termination of employment. Any applicant who tests positive on any drug test required by the Company may not be hired. Duty to Cooperate and Keep Confidential Any employee involved in an investigation must cooperate and keep any information related to the investigation confidential. To conduct a thorough investigation, your cooperation, complete candor and confidentiality are Page 14 Pulte Homes, Inc. Business Practices Policy 05/07
  17. 17. required. This obligation to maintain the confidentiality of information continues after your employment relationship terminates. Contacts: Your immediate supervisor or your Area human resources representative. Special situations or further questions: Office of the General Counsel Executive Vice President-Human Resources Business Practices Policy 05/07 Pulte Homes, Inc. Page 15
  18. 18. Our Proprietary Rights Confidential Information You may, during the course of your employment, become familiar with confidential information that belongs to Pulte. This includes information about Pulte Homes’ customers, purchasing or other business methodologies, business plans (including land), pricing, marketing, sales methods, information systems, consultants, products, product development, and/or trade secrets, technological improvement plans, strategic plans, policy manuals, training manuals and financial information. All employees are prohibited from using, disclosing or disseminating to anyone any confidential information. Unauthorized use, disclosure, copying and/or misuse of confidential information is a serious breach of duty. This obligation to maintain the confidentiality of information continues after your employment relationship terminates. Trade Secrets If you contribute to the development of anything that Pulte considers a trade secret during the course of your employment, that trade secret will always remain the exclusive property of Pulte. Inventions, Works and Other Contributions All rights pertaining to your inventions, works of authorship or other contributions related to the businesses operated by Pulte (known as “intellectual property”) created during the time you work for Pulte will always remain the exclusive property of Pulte. Pulte can freely use that intellectual property for any purpose with no obligation to compensate you. It is within Pulte’s sole discretion whether to seek trademark, copyright or patent protection for the intellectual property you create during your time at Pulte, and Pulte would have the exclusive ownership of those rights. You do not have any legal or equitable rights to that intellectual property. Assignments From time to time, you may be required to execute documents that demonstrate that intellectual property developed in the course of your work at Pulte actually belongs to Pulte. You must execute such documents promptly whenever requested. Your failure to execute these documents will not provide you with any rights to this intellectual property, but may give rise to disciplinary action, up to and including your termination. Exclusive Rights You may not furnish anyone except Pulte an idea, invention or suggestion related to the businesses operated by Pulte that you develop during your employment with Pulte. You may not use such ideas, inventions or suggestions for your own personal benefit. Infringement You are not permitted to use any third party’s trade secrets, or their protected ideas, inventions or their original work without authorization. If you discover that Pulte has incorporated any third party’s trade secret, idea, invention or original work into a work product, you must promptly notify the appropriate person so that proper action may be taken. Contact: Office of the General Counsel Page 16 Pulte Homes, Inc. Business Practices Policy 05/07
  19. 19. Our Electronic Communications Our electronic communication systems, including email, Internet service and other tools, are intended to facilitate Pulte’s business. Like any other business tool, they must be used appropriately. Use of these systems for personal business should be very limited, should not interfere with job performance and must be in compliance with this Policy. Contractors who use Pulte’s electronic communication system are subject to this Policy. Email Communications Prohibited email communications include, but are not limited to: • Offensive materials, such as pornography, sexually suggestive content, racial slurs or offensive language • Derogatory comments regarding another person, particularly as to that person’s age, sexual orientation, religious or political beliefs, national origin or disability • Chain letters, advertisements or other mass mailings • Solicitations on behalf of any religious, political or personal cause • Discussions or debates of personal, political or religious topics • Communications made for the benefit of other organizations or individuals • Communications under another person’s name (unless explicitly authorized) • Email “alerts” and subscription services, with the exception of general news or communications that directly pertain to your job • Communications that are prohibited by law or designed to encourage illegal or improper behavior We expect that you will not send out prohibited communications, whether in the form of a message or an attachment to a message. To avoid receiving such communications whenever possible, you should not provide your Pulte email address to those who send such material or to entities that might share your email address with third parties. Internet Usage Any non-business use of the Internet should be extremely brief and sporadic. In addition, you may never use Pulte’s electronic communications system to: • Access offensive material, such as pornography or sexually suggestive content • Improperly take or use copyrighted material • Communicate Pulte’s proprietary or confidential information, or its trade secrets • Engage in illegal activity Your Expectation of Privacy All emails sent into or out of Pulte’s email system are the property of Pulte, and may be intercepted or reviewed (with or without your knowledge) by authorized individuals at Pulte at any time. An employee may review another employee’s emails only with the permission of his or her supervisor and Area Human Resources management. In addition, Pulte constantly monitors Internet activity to determine which users are accessing which sites and for how long. Information regarding Internet activity may be shared with your supervisor, the human resources department and/or Pulte’s attorneys (among others) whenever there is a suspected violation of this Policy. Business Practices Policy 05/07 Pulte Homes, Inc. Page 17
  20. 20. You should also note: • Communications that are “erased” or “deleted” can often still be retrieved • You will be considered responsible for any activity that occurs under your password. Keep your password confidential. Log off your desktop or laptop or use a password protected “screen save” whenever you are away from your computer. Contact: Your immediate supervisor or your Area human resources representative Special situations or further questions: Office of the General Counsel Executive Vice President-Human Resources Page 18 Pulte Homes, Inc. Business Practices Policy 05/07
  21. 21. Protocol for Waivers for Executive Officers and Board of Directors Waivers for executive officers (including Covered Senior Officers as defined in the Code of Ethics adopted by the Board of Directors) or directors of Pulte Homes, Inc. may be granted only by the Board of Directors or a committee of the Board. Any waivers for executive officers (including Covered Senior Officers) or directors of Pulte Homes, Inc. will be promptly disclosed as required by law, by the Securities and Exchange Commission or the New York Stock Exchange. If you have any questions or concerns, contact the Office of the General Counsel, at 248.433.4607. Business Practices Policy 05/07 Pulte Homes, Inc. Page 19
  22. 22. Certification Business Practices Policy Employee Handbook Pulte Homes, Inc. Please read the Business Practices Policy and the Employee Handbook. Once you have completely reviewed them, you must fill out the information below and return it to your human resources representative. ____________________________ I acknowledge that I have received, read and understand the Business Practices Policy and Employee Handbook of Pulte Homes, Inc. and certify that I have not violated, nor will I violate the spirit, intent, or provisions of the policies set forth in these materials. Business Unit: Employee Name (print): Employee Signature: Social Security Number: Date:

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