Supplier Code of Conduct

Effective November 12, 2015

CARFAX expects its suppliers, vendors, and other third-party companies that comprise the CARFAX supply chain (“Supplier(s)”) to conduct their business with integrity. We regard our Suppliers as a critical and necessary extension of our operations and future success. Failure to comply with the CARFAX Supplier Code of Conduct during the course of business with CARFAX may lead to your disqualification as an approved Supplier.

CARFAX Supplier Compliance Obligations

Compliance with Laws

CARFAX expects Suppliers to conduct CARFAX business in compliance with all applicable laws, rules and regulations (collectively, “Laws”) at all times. However, if local Laws are less restrictive than the principles set forth in this CARFAX Supplier Code, Supplier is expected to comply with the CARFAX Supplier Code of Conduct to the extent that such local Laws are less restrictive.

Anti-Corruption

The offering or acceptance of kickbacks, bribes and other illegal payments with the purpose of obtaining or retaining business or unduly influencing a business decision are not acceptable.

Conflicts of Interest

Suppliers must avoid any situation where its interests (financial or otherwise) conflict with the duties that it owes to CARFAX. A conflict may arise when a Supplier, its employees or family members of Supplier or employees receive improper benefits through Supplier’s relationship with CARFAX.

Data Privacy

Suppliers must implement appropriate physical, technical and administrative measures to protect any data received from and/or created or processed on behalf of CARFAX. This includes protecting data from accidental or unlawful destruction, loss or alteration, and unauthorized disclosure or access.

Fair Competition

Supplier’s employees involved in the sale or licensing of products and services and the negotiation of agreements with CARFAX must ensure that all statements, communications and representations to CARFAX are accurate and truthful.

How to Raise a Concern

Subject to local Laws and any legal restrictions applicable to such reporting, when a Supplier becomes aware of a possible violation of the CARFAX Supplier Code of Conduct, it must promptly report such possible violation to CARFAX at http://support.carfax.com/, whether or not the concern involves the reporting Supplier. The Supplier shall take such steps as CARFAX may reasonably request to assist it in the investigation. CARFAX forbids retaliation against any person reporting a concern.