2. November 2007
Dear Fellow Associates:
AutoNation is committed to achieving its goal to be America’s most successful
automotive retailer by doing business in accordance with the highest standards of
business conduct. AutoNation’s newly updated Business Ethics Program reflects the
high standards of business ethics that we must maintain. For AutoNation, simply
complying with the law is not enough. Our customers and co-workers must be able to
count on AutoNation’s integrity in “always doing the right thing” when selling and
servicing vehicles.
Your updated Business Ethics Program materials are enclosed. It is your responsibility
to become thoroughly familiar with these materials. If you should have any questions
about ethics issues, what the law requires or how to comply with the law, we strongly
encourage you to seek guidance from management, Human Resources or the Legal
Department.
AutoNation’s Business Ethics Program, which includes the Code of Business Ethics and
related Company policies, protects you by preventing unethical or illegal sales
practices, discrimination and harassment in the workplace and other violations of law
and Company policy. It is your responsibility to report suspected violations of law or
policy so that we can take appropriate action to ensure that everyone meets our high
standards.
We do not tolerate retaliation against any associate for reporting, in good faith, a
suspected violation of law or policy. You can and should be proud of our Company’s
standards of business conduct.
These standards are designed to enable associates to reach their full potential, and
will preserve, protect and enhance AutoNation’s reputation and its future.
We thank you for your continuing cooperation and contributions.
Michael J. Jackson Michael E. Maroone Jonathan P. Ferrando Michael J. Short
Chairman & Chief President & Chief Executive Vice President, Executive Vice President &
Executive Officer Operating Officer General Counsel & Chief Financial Officer
Secretary
3. CODE OF
BUSINESS ETHICS
Setting the highest standards
Today, AutoNation, Inc.1 (“AutoNation” or the “Company”) — the largest automotive retailer in America —
operates in many different markets and under many laws and regulations. As the industry leader, we are
committed to setting the highest standards of business ethics and conduct. This commitment requires that
we conduct our business not only in compliance with all the laws and regulations that apply, but also in
accordance with the highest standards of business conduct.
AutoNation’s Business Ethics Program consists of those policies, procedures and practices that help us
understand and comply with the law and the Company’s standards of business conduct. Some of the
elements of the Business Ethics Program include the Business Ethics Policies, this Code of Business Ethics,
which contains a summary of the basic principles and policies that all of us at AutoNation must follow, the
ACT-AlertLine, and various related handbooks and policy manuals. This Code, our Business Ethics Policies,
and the entire Business Ethics Program are designed to help us build on the confidence and continued
support of our customers, investors, suppliers, regulatory agencies, law enforcement agencies, the courts,
and the public. Because our business depends on the reputation of all of us for integrity and principled
business conduct, the policies contained in this Code and the more detailed Business Ethics Policies in many
instances go beyond the requirements of the law.
It is the obligation of each associate to know, understand and comply with all of the Business Ethics Policies
summarized, as well as the guidelines contained, in AutoNation’s Code of Business Ethics. You must also
report policy violations and other improper or unlawful behavior. The Code cannot and is not intended to
cover every applicable law or provide answers to all questions that might arise. It does, however, contain the
general principles that guide our conduct for AutoNation and directs us to those resources that we can turn
to when we are uncertain about the right thing to do in any situation. You should seek guidance whenever
faced with ethical or legal questions or issues. When you have questions regarding proper conduct in a
particular situation, you should review the specific Business Ethics Policy and contact your manager,
Corporate or Region Human Resources, AutoNation’s Legal Department or a member of the AutoNation
Business Ethics Committee. Members of that Committee include the President and Chief Operating Officer,
Chief Financial Officer and General Counsel. AutoNation encourages you to seek guidance first from your
manager for routine workplace issues that do not involve violations of law or ethical conduct.
Call the ACT-AlertLine at 1-800-597-0094 if the suspected or known violation involves your manager or
other management, is a violation of law or the Business Ethics Policies, involves questionable auditing or
accounting practices, if you need additional assistance after speaking with your manager and providing an
opportunity for your manager to address your concern, or if you are not comfortable reporting to the
resources listed above.
We at AutoNation are committed to being the best automotive retailer in America.
Abiding by the policies set forth in the Code will help us achieve this goal.
1
When referred to hereinafter in any Business Ethics Policy, the Code of Business Ethics or any other related materials and communications (collectively, “Business Ethics Program”), the terms “AutoNation, Inc.,”
“AutoNation” and/or the “Company” will include all subsidiaries and affiliates of AutoNation, Inc. Also, for ease of reference, the Business Ethics Program will also refer collectively to all employees (associates) of the
subsidiaries and affiliates of AutoNation, Inc. as “AutoNation associates,” “our associates,” “associates,” “we” or use similar terms; however, all associates are employees of the separate and distinct dealership or other
entity for which the associate works and which pays the associate.
4. Business Ethics Program Oversight
and Implementation (See Policy No. 1)
The responsibility for overseeing, implementing and interpreting the
Business Ethics Program is assigned to AutoNation’s Business Ethics
Committee. Determinations of the Business Ethics Committee on ethical Everything that we do and
and compliance questions or policies are final. This Committee must
stand for as America’s largest
approve all changes to the Business Ethics Program.
automotive retailer is
Business Ethics Program Education
characterized by our unique
and Certification (See Policy No. 2)
and ongoing pursuit of
This Code of Business Ethics will be distributed to all associates and is also
excellence. Our Business
available on the Company website and DealerCentral. You may obtain
copies of any Business Ethics Policy from your manager, the Legal
Ethics Program, which is
Department, Human Resources, the Business Ethics Committee, on the
described in our Code of
Company website, or on DealerCentral. You must also certify that you have
received and read these important documents, understand their contents
Business Ethics as well as our
and agree to abide by the letter and spirit of each.
Business Ethics Policies,
Reporting and Investigating Violations
provides all of us with the
and Seeking Guidance (See Policy No. 3) guidelines we need in “doing
AutoNation requires all associates to report violations of AutoNation’s
the right thing”–ethically and
Business Ethics Program or any applicable law. In addition, we are each
responsible for promptly reporting complaints or concerns regarding legally– in our pursuit of
accounting, internal accounting controls or auditing matters (“Accounting
excellence. We want our vast
Issues”). AutoNation appropriately investigates all such reports. The
Company strictly prohibits any retaliation for making good faith reports of family of associates and our
suspected or known violations of the law or the Business Ethics Program.
shareholders to be proud of
As part of our Open Door Policy, you should direct routine workplace issues
the stature of our Company,
or questions on a particular policy first to your manager--or to another
manager with whom you feel comfortable speaking--or to Human
the manner in which we
Resources, unless your concern involves the manager or other
conduct our business and the
management, or is a violation of law or the Business Ethics Policies.
many ways in which we serve
Examples of more routine workplace issues include work schedules and
smoking or dress code violations. In contrast, concerns about deceptive or
our customers.
fraudulent sales practices, sexual or other harassment, or illegal
discrimination, for example, are not considered routine. Any suspected or
known violations of law or AutoNation policy should be reported
immediately.
If you have further questions or wish to report violations of the law, or of
AutoNation’s Business Ethics Code or Policies, you should contact corporate
or region management or Human Resources, the Legal Department or a
member of the Business Ethics Committee. You can also report violations
by calling the AutoNation ACT-AlertLine. Reports regarding Accounting
Issues should be made by email to businessethics@autonation.com or in
writing to the Audit Committee, c/o Corporate Secretary, AutoNation, Inc.,
110 SE 6th Street, 29th Floor, Fort Lauderdale, FL 33301, and can also be
made to the ACT-AlertLine. Reports will be treated confidentially to the
extent reasonably possible, given the need to conduct an investigation and
appropriately resolve any issues. Reports to the ACT-AlertLine may be
made without giving your name, although identifying yourself makes the
follow-up investigation easier. Complaints or concerns regarding Accounting
Issues will be forwarded to the Company’s Audit Committee in accordance
with applicable procedures.
5. Non-Retaliation (See Policy No. 4)
Any reports of suspected or known violations of the law, the AutoNation
Business Ethics Program or the Business Ethics Policies will be investigated
appropriately. The Company prohibits retaliation against associates for
making a good faith report of suspected misconduct. Examples of
retaliation include making untrue reports or statements about that
individual, harassment, demoting or firing an associate, or withdrawing It is absolutely forbidden for any
benefits because of the associate’s making a good faith report.
associate to punish or conduct
Business Ethics Program reprisals against any other
Discipline (See Policy No. 5) associate for reporting a
Discipline, up to and including termination, may be imposed for violating violation in good faith. Such
either the law or the AutoNation Business Ethics Program, which includes
retaliation is a serious violation
the Code of Business Ethics and Business Ethics Policies. Discipline is to be
applied in a reasonable and consistent manner. Disciplinary decisions of Company policy and will result
depend on many factors, however, and the appropriate form of discipline is
in discipline, up to and including
specific to each situation. Determining whether there is a violation of the
law or the Business Ethics Program is, perhaps, the most important step in
termination.
enforcing the Business Ethics Program. All reported violations will be
investigated appropriately and treated confidentially to the extent
reasonably possible.
Auditing and Monitoring of
Business Ethics Program (See Policy No. 6)
AutoNation’s Business Ethics Program requires all associates to comply
with high standards of business conduct. AutoNation seeks to maintain an
effective Business Ethics Program through regular monitoring of the
Program. The Business Ethics Committee, whose members are senior
executives, has the responsibility to oversee administration and
enforcement of the Program. In order to implement its Business Ethics
Program, AutoNation requires that associates contribute to monitoring the
success of the Program. The Company expects associates to cooperate fully
with any and all of the Company’s attempts to gather information about
how the Business Ethics Program is operating. It is also the policy of
AutoNation to encourage associates to express their concerns about the
effectiveness of the Business Ethics Program. AutoNation prohibits
retaliation against associates for expressing such concerns in good faith.
“Today we are the largest automotive
retailer in America, and I’m proud to say
that, as the industry leader, we’ve always
been committed to setting the very highest
standards of business ethics.”
— Michael J. Jackson
Chairman & Chief Executive Officer
6. Equal Employment
Opportunity (EEO) (See Policy No. 7)
AutoNation will provide equal employment and promotional opportunities
for all associates as well as any individual applying for employment without
regard to race, color, religion, sex, pregnancy, sexual orientation, national
AutoNation
origin, age, disability or any other basis protected by law. Illegal
discrimination or harassment will not be tolerated from any associates,
and its Associates
including supervisors and managers, or from any outsider dealing with
AutoNation.
Policy Prohibiting Harassment AutoNation’s associates are its
(See Policy No. 8)
AutoNation is committed to maintaining a work environment free from greatest asset. The Company has
sexual and other harassment for all of us. Unwelcome sexual advances,
identified a number of ethics and
requests for sexual favors and other forms of verbal, physical, written or
visual conduct that constitutes sexual harassment will not be tolerated.
compliance issues and developed
AutoNation managers and supervisors are required to take reasonable
specific Business Ethics Policies to
actions to prevent conduct at work that creates an intimidating, hostile or
offensive work environment.
protect all associates and to
Drugs and Alcohol (See Policy No. 9) provide an environment in which
AutoNation is committed to a drug-free working environment. AutoNation
we are each able to reach our full
prohibits the unlawful possession, use, sale, manufacture, distribution or
dispensation of illegal or controlled substances by any associate while on potential. AutoNation strives
Company premises or on Company business, except, as to alcohol, at
daily to be an employer of
appropriate business functions, as authorized.
choice by offering all associates
Prevention of
opportunities for career growth
Workplace Violence (See Policy No. 10)
and personal fulfillment in a
No associate may bring firearms, explosives, incendiary devices or any
other weapons into the workplace or any work-related setting, regardless of supportive business environment.
whether or not you are licensed to carry such weapons. AutoNation
The following principles and
reserves the right to conduct searches on Company property to ensure that
dangerous materials or items are not present. Similarly, the Company will
policies are designed to ensure
not tolerate any level of violence or intimidation in the workplace or in any
that we succeed in accomplishing
work-related setting.
Wage and Hour Laws (See Policy No. 11) these objectives.
Associates must follow the requirements of state and federal law in the
payment of minimum wages and overtime compensation. Proper records
for wages, hours and overtime compensation must be kept. We must report
and record accurately and completely all required wage and hour
information. In no circumstances may any associate falsify any record
relating to wages or hours worked.
Background Verifications (See Policy No. 12)
It is AutoNation’s policy to conduct background verifications of all associate
candidates, as well as, where appropriate, existing associates who may be
considered for promotion or assigned additional responsibilities. Additional
background checks will be determined on a case-by-case basis. AutoNation
will disclose the results to an applicant or associate as required by law.
“Each and every associate has a
contribution to make to our Company’s
success, and we want each of you to be
driven every day to do your very best.”
– Michael J. Jackson, Chairman & Chief Executive Officer
7. Finance & Insurance
Sales Practices (See Policy No. 13)
We must conduct ourselves in accordance with the highest standards of
business ethics in connection with the sale of finance and insurance (F&I)
products. It is AutoNation’s policy to document properly, represent
AutoNation’s
accurately and disclose fully the consumer cost for each F&I product. This
applies to every AutoNation associate in an F&I department as well as any
Operations
other associate engaging in or assisting with the sale of an F&I product. We
must sell F&I products based on AutoNation’s menu-based sales process
and comply with all applicable laws, and we may not sell F&I products for
more than the applicable maximum selling price. AutoNation’s Code of Business
Ethics, Business Ethics Policies
Parts and Service and entire Business Ethics
Sales Practices (See Policy No. 14) Program are designed to ensure
that we conduct our business
We must conduct ourselves in accordance with the highest standards of
business ethics in connection with the sale of parts and service. It is consistently according to the
AutoNation's policy to disclose accurately and fully to the consumer the cost
law and the highest standards
to the customer of Parts and Service, and to perform properly and charge
of business ethics. The Business
only for necessary repairs and service. In addition, we must document
Ethics Program was developed
properly any consumer agreement to purchase Parts and Service, and
otherwise comply with all laws that apply to the sale of Parts and Service. to protect and guide us as
This policy applies to every AutoNation associate in a Parts or Service
individuals and to safeguard our
department or standalone collision center or body shop, as well as any other
Company’s business and
associate engaging in or assisting with the sale of Parts and Service.
reputation. We must deal fairly
Gifts, Gratuities and with the Company’s customers,
suppliers and competitors and
Entertainment (See Policy No. 15)
our fellow associates. We must
AutoNation does not want the receipt of gifts, gratuities or favors to
never take unfair advantage of
interfere with our ability to make decisions solely in the best interests of
others or engage in unfair
AutoNation. No associate may accept a business-related gift that exceeds
dealing practices. We seek to
$250 in value without receiving the approval of the associate’s manager.
AutoNation associates may offer or accept only infrequent meals, apply the Company’s ethical
entertainment or gifts of reasonable value that are customary and
standards in all of our business
commonly accepted business courtesies. Gifts in cash are never to be
dealings, adhere to all AutoNation
offered or accepted. Offering, giving, soliciting or receiving any form of
policies and procedures and
bribe or other inducement is prohibited.
comply with all laws that apply to
Procurement (See Policy No. 16) the sale and marketing of
AutoNation purchases and leases millions of dollars worth of goods and automotive vehicles. It is the
services every month. The Company purchases products and service based
responsibility of each of us to
on price, quality, timeliness of delivery and general merit, regardless of the
know, understand and comply
manufacturer or provider. Kickbacks, group boycotts, restrictive
fully with these critical policies
agreements, and exclusive dealing agreements are strictly forbidden.
and principles applicable to our
Environmental Laws business operations and our
and Regulations (See Policy No. 17) conduct.
AutoNation’s objective is to comply with all environmental laws and
regulations and conduct business in a manner that protects the
environment, all associates and the general public. AutoNation has
implemented an Environmental, Health and Safety compliance program and
provided each store with a related policy manual to enhance our
compliance with all laws and regulations. Training and consulting support
are also provided at every store.
8. Workplace Safety and Health (See Policy No. 18)
We must work together in providing a safe and healthy workplace for all
associates and for visitors to Company premises. We must maintain
facilities free from recognized hazards and obey all Company health and
safety rules as well as applicable laws and regulations. We must operate
equipment safely with all safety devices in place and wear personal
protective equipment wherever required. You must report to your manager
any injuries or suspected violations of health and safety policies, laws or
regulations.
Conflicts of Interest and Misappropriation
of Corporate Opportunities (See Policy No. 19)
We each owe a duty to the Company to advance its legitimate interests
when the opportunity to do so arises and to make decisions based on the
Company’s – and not our own personal - interests. A Conflict of Interest
occurs when your personal interests conflict or interfere in any way, or
even appear to conflict or interfere, with the interests of the Company.
Examples of transactions that present actual or potential Conflicts of
Interest include you or a family member owning an interest in or serving as
an employee or consultant of a supplier, wholesale vehicles business or a
vendor that provides services to the Company such as computer repairs,
software or landscaping services. A Corporate Opportunity is a potential
business opportunity that an associate discovers through the use of
Company property or information or the associate’s position at AutoNation.
It can also be using the Company’s property, information or position for
personal gain. Examples of improperly taking Corporate Opportunities
include seeking a dealership franchise from an auto manufacturer for a
family member to operate separately from AutoNation, or purchasing real
estate or other facilities that you have reason to know that the Company
may be interested in.
Associates must not enter into a transaction or engage in an activity giving
rise to a Conflict of Interest or that involves a Corporate Opportunity
without making prompt and full disclosure in writing to any member of
AutoNation’s Business Ethics Committee and obtaining the prior written
approval of the Business Ethics Committee, the Corporate Governance
Committee or the Board of Directors. Executive officers must make full
disclosure to and obtain the prior written approval of the Corporate
Governance Committee or the Board of Directors before entering into any
such transaction or engaging in any such activity.
“AutoNation simply will
Protection of Company Property not tolerate any improper,
unethical or illegal
and Information (See Policy No. 20)
financial activities. You
Each of us is responsible for protecting Company Property and Confidential
must contact us if you
Information from misuse, theft, fraud, waste, carelessness, loss,
suspect there’s a
unauthorized use, disclosure or disposal and for ensuring efficient use of
Company Property. Except as authorized by the Company, we may not use
problem.”
Company Property or Confidential Information for any use other than
— Michael J. Short
AutoNation business. Company Property and Confidential Information
Executive Vice President &
should be used for legitimate business purposes. As a general rule,
Chief Financial Officer
associates should presume that any information they receive about
AutoNation or its customers is Confidential Information and, therefore,
should be protected from disclosure.
9. Accurate Books and Records (See Policy No. 21)
Associates must complete all Company documents accurately, truthfully and in
a timely manner and record the Company’s financial activities in compliance
with all applicable laws and accounting practices. It is Company policy to make
full, fair, accurate, timely and understandable disclosure in compliance with all
applicable laws and regulations in all reports and documents that the Company
Privacy
files with, or submits to, the Securities and Exchange Commission and in all
Considerations
other public communications made by the Company. AutoNation is also
committed to maintaining complete and accurate records for the time periods
Trust is essential to
needed for AutoNation’s business purposes and as required by law.
the success of AutoNation,
If you learn of a subpoena, or a pending or contemplated litigation or
government investigation, you should immediately contact AutoNation’s both within our Company
Legal Department. You must retain and preserve ALL records that may be
and with our customers,
responsive to the subpoena or relevant to the litigation or that may pertain to
the investigation until you are advised by the Legal Department as to how to suppliers, clients, business
proceed. You must not destroy or alter any such records in your possession or
partners and others.
control. You must also affirmatively preserve from destruction all relevant
records that without intervention would automatically be destroyed or erased,
Protecting the privacy and
such as e-mails. Destruction of such records, even if inadvertent, could
confidentiality of certain
seriously prejudice the Company and could result in criminal prosecution or jail
time. If you have any questions regarding whether a particular record pertains
information is a critical
to a pending or contemplated investigation or litigation or how to preserve
particular types of records, you should preserve the records in question and element in maintaining that
ask the Legal Department for advice.
trust. Each of us at
Handling Information Requests AutoNation must treat
from News Media and confidential information in a
responsible and ethical
the Financial Community (See Policy No. 22)
manner in accordance with
As a publicly held company, AutoNation has a responsibility and an interest in
providing accurate and timely disclosure of information. To help ensure that the law and the following
external communications about the Company are accurate, consistent and in
policies and principles.
compliance with applicable laws and regulations, the Company has appointed
designated spokespersons who are the only personnel authorized to discuss
information about AutoNation with persons outside the Company. No one else
in the Company is authorized to speak on behalf of AutoNation. Associates
should instead refer requests for information from persons outside of
AutoNation to the Corporate Communications, Investor Relations or Legal
Departments, and should then inform the appropriate manager or department
head of the request.
Antitrust Law and Competitive
Practices (See Policy No. 23)
All of us must strictly observe the requirements of all federal and state
antitrust laws. Any violations may have far-reaching effects for the
Company, and the individuals involved can face potential criminal
prosecution, even resulting in jail time. You should contact AutoNation’s
Legal Department immediately if you are aware of any agreement that
even potentially raises questions about price-fixing, market or customer
allocations, service limitations or boycotts of particular companies or
organizations.
10. Insider Trading and Tipping (See Policy No. 24)
All AutoNation associates and Board members must comply with all
applicable laws and regulations relating to insider trading. Federal law
prohibits associates and others from buying and selling AutoNation
securities while aware of information not publicly known that could affect
the price of the securities. Associates and Board members also are
prohibited from providing information that is not publicly known to others if
it is reasonably foreseeable that the person will misuse the information by
trading in securities or passing the information to others for the purpose of
trading (quot;tippingquot;).
Confidentiality of
Customer Information (See Policy No. 25)
We must protect customer information from misuse, theft, loss, disclosure
and unauthorized use. We may not reveal any information regarding an
AutoNation customer to others outside the Company without first obtaining
the permission of the customer or as required by law. We must also guard
against disclosure of customer information to fellow associates whose
duties do not require that they be given the information.
Intellectual Property and
Information of Others (See Policy No. 26)
Intellectual Property includes copyrights, patents, trademarks, trade secrets
and other confidential information. We must help maintain AutoNation’s
reputation as a fair competitor, ensure the integrity of Intellectual Property
in the marketplace and comply with the laws regulating Intellectual
Property and industrial espionage. This commitment to fairness includes
respecting the Intellectual Property rights of our suppliers, customers,
business partners, competitors and others.
Information Technology Security (See Policy No. 27)
All users of AutoNation’s Information Technology (IT) and everyone who
works at or for AutoNation, including associates, consultants, vendors and
business partners, must comply with IT security policies, and use these
resources in a professional, lawful and ethical manner. We are each
responsible for the privacy and confidentiality of our computer accounts
and secret passwords. It is everyone’s responsibility to report violations to
management. We may access only those systems and that data for which
“To succeed in our
we are authorized. Disclosure of data is to occur only to other persons
authorized to have access to the same data. business, you have
to have a passion for it…
All IT resources to which AutoNation provides or gives you access are for
purposes of Company-approved business use, and all data stored on
But you must also have
Company systems is Company property. You should, therefore, have no
the guts to do the right
expectation of personal privacy in connection with your use of any IT
resources. The Company makes no representation whatsoever of privacy in thing… And that is what
e-mail or voicemail messages or any computer file, despite any designation
AutoNation’s Business
of quot;PRIVATEquot; or similar comment on such message or file. AutoNation
Ethics Program is all
reserves the right to monitor use of business communication systems.
Personal use of electronic mail and telephones is permitted on a limited
about!”
basis so long as such use is appropriate and reasonable and does not
— Michael E. Maroone
interfere with job performance. Even personal messages on the Company’s
email and voicemail systems are Company property. The Company also has President & Chief Operating
the right to use software that can identify and block access to Internet sites Officer
that it considers inappropriate in the workplace. All users have the
responsibility to use these resources in a professional, lawful and ethical
manner.
11. Government Investigations
and Interviews (See Policy No. 28)
AutoNation is committed to cooperating with government agencies. When
doing so, the Company’s two primary goals are 1) to provide government
agents and investigators complete and accurate information, and 2) to
AutoNation and the
protect AutoNation’s legal rights. To accomplish these goals, associates are
Government
encouraged (but not required) to notify the Legal Department about
requests for interviews by the government. Associates must notify the
How AutoNation conducts
Legal Department immediately upon receipt of a government subpoena or
search warrant or notice of a government inspection. When dealing with business and relationships with
the government, associates must always be truthful and accurate.
the government, at all levels, is
Government Relations — of critical importance. At all
Dealing with Government times, we must conform to the
Regulators and Employees highest standards of ethical
(See Policy No. 29)
and legal conduct. It is the
You must comply fully with all regulations and laws governing contacts and
dealing with government regulators and employees and adhere to the
important responsibility of
highest ethical and legal standards of business conduct.
each of us to know, understand
Government Relations — Political
and comply fully with the
Contributions and Activities (See Policy No. 30) following policies and
It is AutoNation’s policy to comply with all federal, state and local laws
principles to help guide us
regarding political contributions and activities. You may not make any
political contribution of Company funds, property or services to any through often complex
political party or committee or to any candidate for or holder of any office
situations and issues related to
of any government without prior review and approval of AutoNation’s
General Counsel or his designee. dealing with the government.
Government Contracts (See Policy No. 31)
You may not enter into a contract with a government agency without first
obtaining the approval of AutoNation’s General Counsel. In contracting
with the government, it is absolutely essential that AutoNation and its
associates comply strictly with the laws and regulations that apply to
government contracting. It is also critical that the terms of any government
contract be met.
Conclusion
AutoNation relies on every associate to help ensure compliance with the
law and to protect the Company’s good name and reputation. We are
committed to conducting business activities in an ethical and forthright
manner and in accordance with applicable laws and regulations. Ultimate
responsibility to ensure that we, as a Company, comply with the many laws,
regulations and ethical standards affecting our business rests with each of
us. This Code is intended to help you better understand how to comply with
the law and AutoNation’s ethical principles and requirements.
No Rights Created. Nothing contained in this Code, the Business Ethics Policies or other Business Ethics
Program communications creates or implies an employment contract or term of employment. Employees of
the Company are employed at-will, except when covered by an express, written employment agreement. This
means that you may choose to resign your employment at any time, for any reason or for no reason at all.
Similarly, the Company may choose to terminate your employment at any time, for any legal reason or for
no reason at all, but not for an unlawful reason. This Code is not intended to and does not create any
obligations to or rights in any associate, client, supplier, competitor, shareholder or any other person or
entity. AutoNation continuously reviews its Business Ethics Program; this Code and the Business Ethics
Policies, therefore, are subject to modification.
Waivers of the Code. Waivers of the Code for directors and executive officers may be made only by the
Board of Directors and will be disclosed as required by law or regulation.
