Code of Conduct

Overview

The objective of this Code of Conduct is to outline some of the principles we follow at Cotality to allow and encourage all employees to perform their duties in an efficient, effective, respectful, and safe manner. Our Code is an important statement about who Cotality (the “Company”) is and what is important to us as a company.

Cotality believes every employee must do the right thing at alltimes. Every employee can make a difference, so it is essential that all employees act ethically and with integrity. Following this Code, Cotality policies, procedures, and applicable laws, rules, and regulations will ensure the right choices are made. Our ethical behavior ensures the continued trust that Cotality has built with customers, employees, and others who have a stake in the success of the Company. We must earn that trust every day.

While this Code may not cover every situation, it is a valuable resource for deciding the right thing to do. Use good judgment in everything you do and ask for help if you are ever unsure of the right course of action.

Section 1: We act ethically

1.1 Responsibilities

This Code applies to all employees, executives, officers, managers, leaders, and certain third parties with whom Cotality conducts business. All parties must:

Make responsible decisions and do the right thing.

Know and follow this Code of Conduct and Cotality policies, procedures, and guidelines.

Successfully and timely complete all required training.

Comply with all laws, rules, and regulations within the countries Cotality operates.

Promptly report suspicions of illegal or unethical behavior or behavior that may violate this Code.

Cooperate fully in any investigations of misconduct.

1.2 Leaders’ special obligations

We look to our leaders to set the tone for an ethical workplace, and to mentor, coach, and guide employees on how to conduct business in line with our Values and in compliance with this Code. Leaders must:

Act as an example and demonstrate there is no gap between expectations and actions.

Establish and maintain a workplace where employees feel comfortable meeting their obligation to come forward with questions or concerns.

Hold others accountable for acting in accordance with our values, our Code, and our compliance framework. Ensure direct reports are aware of our Code and policies and procedures.

Leaders are required to raise issues or suspicions of illegal or unethical behavior to Human Resources.

Encourage an environment of acting in good faith and maintain an atmosphere free from retaliation.

Refrain from conduct that could be considered an abuse of position or influence.

1.3 Decision-making framework

Cotality expects each employee to act with the highest integrity and use good judgment in all situations. If ever faced with an ethical dilemma, Cotality employees can ask themselves the following questions to guide them throughout the decision-making process:

Is it legal?

Does it comply with our policies?

Does it align with our values?

Would I feel comfortable if the action were published in the media?

If you can answer “yes” to all of the questions, you can safely consider the action and its effect on Cotality constituents. However, if the answer to any of the questions is “not sure” or “no,” you should not proceed until you can answer “yes” to all questions. It is never wrong to ask for help.

1.4 Code waivers

No one, regardless of their position at Cotality, is exempt from any part of this Code. Waivers to this Code should be extremely rare, and may be granted only in a manner permitted by law, with review and approval from the Chief Legal Officer. The Board must approve any waiver of this Code for the CEO, CFO, and any other executive committee member.

1.5 Violations of the code

Failure to comply with this Code of Conduct may result in consequences, including corrective action or termination of employment or relationship.

1.6 Reporting possible violations

As a Cotality employee, you are required to report suspected violations to this Code, our policies, or any applicable laws and regulations. You are the Company’s first line of defense. Follow the rule: if you see something, say something. Reporting violations and concerns helps Cotality keep its employees and its brand safe and can assist in minimizing or preventing harm to Cotality, to our customers, and to consumers or other stakeholders. You must report any misconduct you have observed or have become aware of, whether the violation involved you, another Cotality employee, or a third party who is working on behalf of Cotality or conducting business with Cotality. Report violations or suspected violations to one of the following resources:

Direct Leader, or another Leader

Human Resources Department

Create a ticket in the Help application of Workday

Any member of the Legal and Compliance Department

If you are not comfortable reporting through any of these channels, you may also use the Ethics and Compliance Hotline, which is operated by an independent reporting service that allows you to report your concern anonymously (where permitted by law) and confidentially any time, day, or night.

Non-retaliation

We know it takes courage to come forward and share your concerns. Cotality will not retaliate or permit retaliation against anyone who makes a good faith report about possible misconduct or legal violations, or against anyone who assists in investigations of such matters. Acting in good faith means that all reports of possible violations are made sincerely and honestly, regardless of whether they can be substantiated.

Investigations

You can be assured your concern will be handled promptly and appropriately. Cotality will treat your report with sensitivity and disclose information only to those who need it in order to conduct an appropriate investigation or to take appropriate remedial measures. If you are asked to participate in an investigation, you are required to cooperate fully and maintain the required degree of confidentiality to the extent permitted by law.

Cotality seeks to outperform its competition fairly and honestly through superior performance. You must be ethical and lawful in all business dealings or while representing Cotality in any capacity. Your communications and dealings with Cotality business partners, vendors, competitors, clients, or others can directly impact our reputation and our compliance with applicable laws.

Section 2: We act with integrity in our business practices

2.1 Compliance with laws and regulations

Cotality takes its responsibility to comply with laws, rules, and regulations seriously. While certain relevant laws are addressed in this Code, there are many additional laws, rules, and regulations that may apply to Cotality and its employees. Therefore, Cotality expects you to become reasonably informed and to comply with the laws, rules, and regulations applicable to you by promptly completing all required training.

For example, as a provider of services to the financial industry, certain consumer financial laws may apply to certain Cotality products and services. Cotality employees are required to know and comply with all applicable federal consumer financial laws.

2.2 Fair competition

We believe in a thriving marketplace with free, fair, and open competition. Each of us must deal fairly with our customers, vendors, resellers, and competitors to sell our products and services. You must comply with and understand the fair competition and anti-trust laws that apply to your role. Cotality requires that you act fairly by:

Never infringing intellectual property rights

Never using of market power to unfairly disadvantage competitors

Never entering into any agreement or understanding, formal or informal, with any competitor, customer, or client that is unfair, violates fair competition law, or creates the appearance of impropriety.

Examples of prohibited conduct include, but are not limited to, the following:

Participating in any form of collusion to secure a predetermined bid price

Dividing territories, markets, or customers

Preventing a company from entering the market

Entering into an agreement to refuse to deal with a customer or supplier

Entering into an agreement to raise, set, or hold a price on our products or services (also known as “price fixing”)

Coercing buyers to buy unwanted products by tying them to other products that must be purchased together

Restricting production, sales, or output

Agreeing with another company not to hire respective employees

Immediately stop conversations if they begin to develop into any of the acts listed above and report the issue to the Legal Department.

2.3 Fair dealing

Cotality is committed to being honest and truthful with its customers, vendors, and other business partners. We will not misrepresent the quality, features, or availability of Cotality products and services, or do anything illegal or unethical to gain business. You must adhere to the basic principles of fair business dealing. Some examples of prohibited conduct include, but are not limited to:

Taking unfair advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of material facts, or any other unfair dealing practices

Prohibiting our customers or vendors from dealing with any of our competitors as a condition of obtaining products and services from Cotality

Entering into tying arrangements where a customer is required, as a condition of purchasing one product, to have to purchase a second, distinct product

2.4 Anti-corruption, bribery, and kickbacks

Never accept bribes or kickbacks, offer bribes or kickbacks, or let others do so for you. You must also act to prevent bribery or kickbacks by others who conduct business on Cotality’s behalf.

Bribery occurs when an individual provides something of value to another with the intention of influencing the recipient’s actions.

2.5 Gifts and entertainment

Occasional gifts and offers of entertainment can help build and solidify working relationships with customers and business partners and are often viewed as a normal part of doing business. However, there are instances when receiving or accepting any form of gift can cross the line and create a conflict of interest or unfair bias that may influence current and future business decisions. You must not offer or accept meals, entertainment, or gifts if providing or accepting them could unduly influence adecision or create an appearance of improper purpose. Always use good judgment and follow the guidelines in place to identify circumstances under which an offer is okay. Gifts or entertainment given or received should:

Be nominal in value

Be infrequent

Satisfy a reasonable business purpose

Be consistent with acceptable business practices given the industry and geographical location

Be permitted by law and the policies of both the giver and receiver

Not reflect poorly on or embarrass Cotality

Be recorded accurately

Do not give anything of value to any government official without receiving approval in advance from the Legal Department. If you are ever unsure whether or not a gift is okay to accept or give, consult with Legal, Compliance, or Human Resources.

2.6 Political contributions and activities

Employees can only offer support and contributions to political groups in a personal capacity. Unless you receive approval in advance, do not use or donate Cotality funds or assets (including facilities, equipment, or trademarks) for any political endeavor. Cotality may make political contributions only when consistent with its policies and applicable law.

2.7 Charitable contributions

In the spirit of our shared mission, vision, and values, Cotality encourages its employees to make a difference and show that Cotality is a leader in the communities in which we live and work. You are encouraged to be a part of our shared social purpose and to participate at one or more of the many initiatives Cotality supports through our philanthropic partnerships and employee engagement programs. We also support and encourage your personal involvement in charitable activities. In general, employee contributions and participation in charitable events must be made on your own time and from your own personal funds, unless using the allotted paid volunteer time with appropriate approvals.

Information is one of the most valuable assets of Cotality. As employees we have an obligation to safeguard information about our Company, our coworkers, the consumer, and the companies with which we do business. The inappropriate use of information can cause considerable damage to our business and our stakeholders.

Section 3: We safeguard information

3.1 Personal information

We value the privacy of our employees, consumers, and others with whom we conduct business, and we handle their personal information with care. Personal information includes any information that could be used to identify someone, either directly or indirectly, such as a name, employee ID, address, account number, or phone number. We are committed to the responsible collection, storage, use, transfer, and disposal of personal information. Employees with access to personal information of consumers or other employees are required to protect the information that is entrusted to them. You must not access, use, or disclose such information except as authorized for appropriate business purposes, and you must protect the confidentiality and security of that information. This includes practicing good cybersecurity. You must follow the processes and practices inplace to protect our networks, computers, programs, and data from attack, damage, or unauthorized access.

3.2 Cotality information

Many details about how the Company operates need to be kept confidential in order for CoreLogic to remain competitive and successful. Confidential information includes all non-public information or information governed under a Non-Disclosure Agreement that provides CoreLogic a competitive advantage or may be harmful to CoreLogic, or its business partners, if disclosed. Examples include, but are not limited to, plans for future development of products and applications, business strategies, employee information, client lists, market conditions, financial results, product designs and concepts, pricing, and any database of aggregated public data. Such information must be kept secure and shared only with other employees who need to know the information to perform their duties. You must never use this information for your personal benefit, or disclose it to others, including family members, friends, or anyone else who does not have a need to know it. Any confidential information or trade secrets should never be disclosed outside CoreLogic without approval from a Managing Director and the Legal Department.

3.3 Third-party information

In the course of doing business, sometimes you will learn confidential information about clients, vendors, consumers, and other business partners. You must keep such information confidential and secure under the standards set above in Section 3.2.

3.4 Intellectual Property of Others

Cotality respects the intellectual property (IP) rights of others, which may include, but is not limited to, patents, trademarks, copyrights, trade secrets, brands, logos, ideas, inventions, images, designs, drawings/block diagrams, methods, processes, systems, know-how, confidential technical/financial/business information, data, and software. You must follow the applicable laws to obtain proper permission prior to using, soliciting, or accepting the IP of others.

In addition to protecting our information assets, the protection of the Company and our physical, financial, and technology assets is a critical responsibility. Each of us is entrusted to respect and protect these assets from loss, damage, theft, and improper use.

Section 4: We protect our company

4.1 Conflicts of interest

A conflict of interest is a situation where an opportunity for personal gain is contrary to the best interest of Cotality. A conflict of interest can exist any time your personal investments, activities, interests, or associations — or those of your family members or others with whom you have a personal relationship — compromise your loyalty to Cotality. When making decisions related to Cotality, you have a duty to act in the best business interest of Cotality and avoid even the appearance of a conflict. While it is impossible to list every situation that could present a conflict, there are certain situations where conflicts typically arise. It is important to be able to recognize a potential conflict to help avoid one. A conflict can happen when:

You own or do work for a company that competes, does business, or wants to do business with Cotality. This may include serving in an advisory role or on the board of directors of such a company.

You supervise or conduct business with someone with whom you have a close personal relationship.

You conduct outside activities that materially detract from or interfere with the full and timely performance of your job duties for Cotality, such as engaging in outside employment that directly or indirectly competes with Cotality.

You influence transactions that would have a negative impact on Cotality.

You take a business opportunity for personal gain that was intended for Cotality.

You have a continuing obligation to disclose circumstances or changes in circumstances that may pose a conflict as soon as you become aware of them. If you believe that you may have a conflict of interest, or if you are unsure on the proper course of action, you must submit an Employee Services Ticket in Workday for review, as required by our Conflict of Interest Corporate Policy. Many conflicts of interest can be easily avoided or addressed if they are promptly disclosed and properly managed.

4.1 Corporate opportunities

As an employee, officer or director of Cotality you have an obligation to not take for yourself personal opportunities that are discovered through the use of Company property, information or position. You are also prohibited from using Company property, information or your position for personal gain or from competing with the Company. Each employee, officer and director owes a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

4.3 Physical and electronic assets

Physical and electronic assets such as furniture, equipment, tools, inventory, Company records, computer hardware, and software that may be provided for you to do your job are Cotality property. Occasional personal use of these assets is permitted as long as the use, does not interfere with your work and does not violate Company policies or applicable laws. Be aware that these assets belong to Cotality, and anything you write, send, download, or store on the Company’s systems becomes Company property. All information generated by employees, including their notes, belongs to Cotality. Cotality may monitor, review, and disclose the use and data as deemed necessary, so you should not have any expectation of privacy when using Cotality systems. Use good judgement in your online and electronic communications. You must never violate a law, harass others, or disclose confidential information. The Information Privacy Corporate Policy establishes appropriate practices and requirements for maintaining the privacy of information managed or used by the Company. You must not download, install or attach software or hardware that may compromise the security of the asset, disable installed security tools or system files, or interfere with network users, servicers, or equipment. You must follow company policy when downloading or using any Artificial Intelligence (AI) tools. You must not duplicate, install, or use software in a way that violates the copyright or applicable license terms.

4.4 Intellectual Property

Our Intellectual Property (IP) is among the most valuable assets of Cotality and includes, but is not limited to, patents, trademarks, copyrights, trade secrets, brands, logos, ideas, inventions, images, designs, drawings/block diagrams, methods, processes, systems, know-how, confidential technical/ financial/ business information, data, and software. You are obligated to protect IP in accordance with Cotality policies and applicable laws, even if you should stop working for Cotality. You must never use Cotality IP for any external business or commercial venture without proper approval. Keep in mind that any IP you create for Cotality or while using Cotality resources are the property of Cotality, even if you no longer work for Cotality. Any misappropriation of IP could result in civil or criminal liability and penalties. Please contact the Cotality Legal Department with any questions regarding Cotality IP or to request assistance in the protection of Cotality IP which you create.

In addition to protecting Cotality Intellectual Property, the protection of Cotality’s physical, financial, and technology assets is a critical responsibility. Each of us is entrusted to respect and protect these assets from loss, damage, theft, and improper use.

4.5 Theft and fraud

Cotality will not tolerate employee theft or fraud of Cotality assets. Misrepresentation, stealing, and deception have no place at Cotality. Keep in mind theft goes beyond just stealing physical assets and includes misrepresenting expenses on expense reports or falsifying receipts. Immediately report any suspicion of improper use, theft, loss, or abuse of Company assets. Cotality will investigate and, where appropriate, prosecute reported incidents. Cotality reserves the right to seek repayment or restitution from those who steal.

Financial integrity and fiscal responsibility are critical to our future success and to maintaining the trust of our customers, vendors, and business partners.

Section 5: We demonstrate financial integrity and fiscal responsibility

Demonstrating financial integrity and fiscal responsibility at all times is critical to retaining the high degree of trust placed upon us by our lenders, customers, vendors, regulatory entities, and other financial stakeholders. Accurate and complete financial records are necessary to fulfill our financial obligations, provide reliable insights into our financial health and comply with various laws and other regulations. All employees with roles involving our financial records and related controls must ensure such records are complete, accurate, and comply with applicable policies and standards, and that our system of financials controls is maintained. Further, every employee must ensure that money is appropriately spent, and that business transactions are undertaken in accordance with our polices and are fully documented.

5.1 Financial integrity

Our financial records provide important visibility into the Company’s health, keep us accountable to financial stakeholders, and are the basis upon which we make important business decisions. You must record transactions accurately, completely, and in appropriate detail to facilitate full accounting of the Company’s finances. If you are involved in the preparation of a Cotality financial statement, you must also adhere to the relevant policies, processes, standards and controls such that the financial statements fairly and completely reflect the operations and financial condition of the Company.

5.2 Business expenses

Employees are expected to spend Company money wisely and in compliance with company policy. When submitting an expense for reimbursement or spend money on behalf of Cotality, ensure that the cost is reasonable, directly related to Company business, and supported by appropriate documentation. Employees are required to accurately and timely track and record all business expenses. If you are uncertain whether you should spend money or submit an expense for reimbursement, consult with your functional area leader.

5.3 Signing a contract

Each time you enter into a business transaction on behalf of the Company, there must be documentation recording the agreement. Never sign any contract, including click-through website terms on behalf of Cotality unless all of the following are met:

You are authorized to do so. The authority to execute contractually binding instruments on behalf of the Company is subject to company policy. Carefully review the relevant policy documents and consult with your functional area leader, your contracting team, or the Legal Department.

The contract has been approved by the Legal Department as well as other applicable approval authorities as required, for example, ARC, Finance, Accounting, Information Security, Compliance, Product, Pricing, Contracting, or Vendor Management. If you are using an approved Cotality form contract, you may not need further approval from the Legal Department unless you have made changes to the form or are using the form for other than its intended purpose.

You have studied the contract, understood its terms and implications, and decided that entering into the contract is in the best interest of Cotality.

5.4 Retaining records

The creation, storage, maintenance, and proper disposal of records is important in helping Cotality maintain its financial integrity and remain in compliance with legal, tax, and regulatory requirements. You must keep records for as long as is required by law, rule, regulation, or company policy. Records include, but are not limited to, emails, instant messages, voicemails, recordings or transcripts of meetings, or any documentary material, regardless of physical form, that is generated or received by Cotality in connection with business transactions or legal obligations. Records that have met their retention requirements and are not subject to litigation hold must be properly destroyed.

You may receive notification that you are in possession of records relevant to litigation, investigation, or an audit. Do not conceal, alter, or destroy any documents subject to these holds unless the Legal Department authorizes you to do so.

5.5 Hiring vendors

When contracting with vendors for products and services, always strive for the best possible deal for Cotality. Consider the total cost of ownership as well as other pertinent evaluation dimensions such as quality, reliability, flexibility, sustainability, risks, and terms and conditions of the deal before making a final decision. The lowest price may not always be the best option for the Company. Always follow the defined sourcing and procurement process when dealing with Vendors. All business conducted by Vendors must be conducted lawfully and with integrity.

We are One Cotality, and we represent many ideas, experiences, and backgrounds. We value each other’s contributions and believe that everyone should have an equal chance to succeed. Do your part to create a workplace culture that is diverse, inclusive, fair, safe, and respectful by driving a positive environment where employees have the opportunity to reach their fullest potential.

Section 6: We value each and every employee

6.1 Inclusive workplace

Cotality is committed to ensuring all employees work in an environment that includes everyone and promotes a sense of belonging for all employees.

Cotality is an Equal Employment Opportunity employer, and as a federal contractor, it is the Company’s policy to take affirmative action to ensure that applicants and employees are treated without regard to their race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or status as a protected veteran.

Employment here is based solely upon individual merit and qualifications related to professional competence.

6.2 Harassment and bullying

We treat others with respect and dignity, and we do not tolerate discrimination, harassment, and bullying of any form — verbal, physical, or visual. Sexual harassment, abusive language, demeaning words or actions, aggressive acts, and disorderly conduct, as well as threats and intimidation, should all be reported promptly, whether directed at you or someone else. Cotality employees should report incidents of bullying or harassment immediately to your direct Leader or Human Resources. (See Section 8 Resources). These same standards of acceptable behavior extend to anyone who does business with us, including customers and vendors, and apply in both work-related settings and work-related activities, even when outside the office.

6.3 Workplace safety

We are committed to the safety and security of all Cotality employees. Our employees are the greatest assets the Company has, so all safety procedures, policies, and trainings must be followed fully. You must take immediate action if you witness a situation that could put others at risk. Illegal drugs and the unauthorized use of alcohol and prescription drugs are strictly prohibited on Cotality property, Cotality time, or at Cotality sponsored events. There may be instances where drinking alcoholic beverages while conducting Company business is allowed, but you must comply with all laws and Company policies, and always exercise moderation and good judgement.

6.4 Workplace violence

Violence or threats of violence are not permitted. All employees are responsible for recognizing and resolving existing or emerging issues before they escalate to threats or violence. Cotality relies on you to report any acts or potential acts of violence, including, but not limited to, verbal or intimidating threats, destruction of Cotality property, or possession of firearms, bombs, or weapons. If you see something, say something. (See Section 8 Resources).

Every spoken, written, or electronic communication we deliver has an impact on the Cotality reputation and brand. We all have an obligation to ensure Company communications are consistent, accurate, and complete, and that no one speak on behalf of the Company without having authorization to do so.

Section 7: We are fair and honest in our communications

7.1 Speaking on behalf of Cotality

Cotality is committed to ensuring accurate and complete information is conveyed to the public in a consistent, timely, and professional manner. Communication with investment communities and the media must be managed carefully. Cotality has designated individuals with authorization to speak on behalf of Cotality. Do not speak or make any statements on behalf of Cotality unless you are authorized to. Refer all media inquiries about the Company, any of its subsidiaries, or any of its business lines to the Marketing and Communications Department by email. (See Section 8 Resources). You must obtain approval from the Corporate Marketing and Communications Department before accepting a public speaking obligation or opportunity. If you are authorized as a spokesperson for Cotality, you must not disclose proprietary, confidential, or any customer information learned in the course of your work, except as specifically authorized.

7.2 Social media

Cotality recognizes the use of social media as a means for exchanging ideas and building relationships, and you are responsible for using good judgement in your online activity and complying with all applicable laws. If you are not authorized to speak on behalf of Cotality, you must be clear that your statements do not reflect the opinion of the Company. Even where you make such a clarification, inappropriate comments that reflect poorly on Cotality or otherwise disrupt the workplace may violate Cotality policies.

You are responsible for the content you publish and must not:

Use social media to harass or bully employees or contacts you acquired based on your employment at Cotality.

Disclose anything that could violate another’s rights to personal privacy.

Disclose confidential information about the Company, customers, or third parties.

Make claims about Cotality products or services.

Endorse Cotality products or services without our permission.

Use the Cotality logo, trademarks, or copyright material without permission.

7.3 Audits and investigations

Cotality complies with requests for information by government and regulatory agencies as required by law and fully cooperates with internal and external investigations or audits. If you receive an inquiry from a government official or agency or if you receive a subpoena or other legal process request for information that might reasonably relate to your employment at Cotality, you must immediately contact the Legal Department. Do not provide any information unless and until you have obtained permission to do so.

If you are questioned or asked to provide information related to an internal or external investigation or audit, and are authorized to provide the information, you have a duty to cooperate and must provide truthful, accurate, and complete information. If you are involved or have information relating to an audit or investigation, do not discuss it with unauthorized internal or external parties.

7.3 Resources

Employee Services:

The Employee Services team is a central point for employees who are seeking guidance on a variety matters, from day-to-day questions to major life events. The team’s main objective is to assist employees in a professional and timely manner and educate them by providing resources and detailed directions on items that can be performed via self-service in the future.

Create a ticket in the Help Application of Workday or call at (866) 224-2086.

Workplace Violence Prevention Plan

Legal Department:

Contact your business unit’s coverage attorney or the Chief Legal Officer.

Compliance Department:

https://corelogic.sharepoint.com/sites/coreCompliance/SitePages/Compliance-Home.aspx

Information Security:

https://corelogic.sharepoint.com/sites/InformationSecurity

Marketing and Communications:

newsmedia@cotality.com

Cotality Company Policies:

https://corelogic.sharepoint.com/sites/CoreCompliance/sitePages/compliance.aspx

Ethics and Compliance Hotline:

If you’ve got a concern, we want to know.

The Ethics & Compliance Hotline is completely confidential and always available.