Business Practices Policy

8/17/2019 Business Practices Policy

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Business Practices

Policy


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Pulte Homes, Inc. i Business Practices Policy

Table of Contents

Our Policy............................................................................................................................................................ 1

Our Commitment to Fairness............................................................................................................................ 2

Anticompetitive Behavior................................................................................................................................ 2Bribes and Kickbacks ...................................................................................................................................... 2

Settlement Services.......................................................................................................................................... 2Gifts and Gratuities.......................................................................................................................................... 2

Conflicts of Interest ......................................................................................................................................... 3Your Purchase of a Pulte Residence................................................................................................................ 4

Our Company Records and Reporting............................................................................................................. 5

Financial Accounting Records......................................................................................................................... 5

Tax Laws ......................................................................................................................................................... 5Records Retention............................................................................................................................................ 5

Our Assets ........................................................................................................................................................... 6

Expenditures.................................................................................................................................................... 6

Finance Manual ............................................................................................................................................... 6

Bribes, Kickbacks and Gifts ............................................................................................................................ 6Loans ............................................................................................................................................................... 6

Political Contributions..................................................................................................................................... 6

Non-business Use............................................................................................................................................ 7

Our Securities ..................................................................................................................................................... 8

Material Information........................................................................................................................................ 8

Blackout Periods.............................................................................................................................................. 9

Trading Pulte Stock ......................................................................................................................................... 910b5-1 Trading Plans....................................................................................................................................... 9

Our Communications with the Public .............................................................................................................. 11

Our Customers.................................................................................................................................................... 12

Non-discrimination.......................................................................................................................................... 12Confidentiality................................................................................................................................................. 12

Our Employees.................................................................................................................................................... 13

Equal Opportunity ........................................................................................................................................... 13Confidentiality................................................................................................................................................. 13

Harassment ...................................................................................................................................................... 13

Non-retaliation................................................................................................................................................. 13

Health and Safety............................................................................................................................................. 13

Environmental Compliance ............................................................................................................................. 14Drugs and Alcohol........................................................................................................................................... 14

Duty to Cooperate and Keep Confidential....................................................................................................... 14

Our Proprietary Rights...................................................................................................................................... 16

Confidential Information................................................................................................................................. 16Trade Secrets ................................................................................................................................................... 16

Inventions, Works and Other Contributions.................................................................................................... 16

Assignments .................................................................................................................................................... 16

Exclusive Rights.............................................................................................................................................. 16Infringement .................................................................................................................................................... 16

Our Electronic Communications....................................................................................................................... 17

Email Communications ................................................................................................................................... 17Internet Usage.................................................................................................................................................. 17

Your Expectation of Privacy ........................................................................................................................... 17

Protocol for Waivers for Executive Officers and Board of Directors............................................................ 19


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Business Practices Policy 01/07 Pulte Homes, Inc. Page 1

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


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Page 2 Pulte Homes, Inc. Business Practices Policy 01/07

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 andsimilar 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 theRESPA 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 anAffiliated 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.


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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 financeofficer 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” ariseswhen 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 aquestion 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 shallimmediately disclose that fact to your supervisor and your Area Vice President of Finance or the CompanyController.

• 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 toaccept 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 performrenovations, 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 allPulte employees in your operation. When building your own home or performing renovations you may notuse 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.


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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 pricingof 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


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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 theSecurities 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 wehave 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 orunderstanding 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 Retention

A variety of laws that govern our accounting, tax and business operations require us to follow proper recordsretention 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 a Records

Retention Policy that details the period of time for which you are required to retain records and the time at whichyou must destroy them. You are required to comply with this Records Retention Policy with respect to materials in

your filing cabinets, in your office or workspace and on your computer.

In addition, regardless of the retention period specified in the Records Retention 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 Retention – Office of the General Counsel


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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, leasedor 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.


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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



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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 mayalso 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 ofMaterial 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 locatedon the Company Intranet.


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Blackout Periods

Covered Employees

You may not purchase, sell, or trade Pulte Securities during the quarterly blackout period if you are a member of theBoard 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 theapplicability of this policy with their immediate supervisor.

“Officer” includes all Home Office, field and subsidiary officers, and all members of operations committees at theArea 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 aWednesday, and the New York Stock Exchange is open for trading on Thursday, the blackout period will end andthe 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 Fundduring 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 transactionsregarding 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.


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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


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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 anywebsite

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




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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 youare 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 amortgage, 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 Actand 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.



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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 equalopportunity 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 disabilitiesas 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 informationregarding our employees and/or their families.

Unauthorized use, disclosure, copying and/or misuse of confidential information is a serious breach of duty. Thisobligation 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 orrejection 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 inviolation 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


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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-ownedvehicle 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, oronto 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 theCompany'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, includingconservation 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 LawDepartment.

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 levelor 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 andappropriately 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


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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.



Executive Vice President-Human Resources


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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 prohibitedfrom 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 theexclusive 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 developedin 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 foryour 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.



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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 thatdirectly 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 attachmentto 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 anotheremployee’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 resourcesdepartment and/or Pulte’s attorneys (among others) whenever there is a suspected violation of this Policy.


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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 areaway from your computer.

Contact: Your immediate supervisor or your Area human resources representative



Executive Vice President-Human Resources


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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 committeeof 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.


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Certification

Business Practices Policy

Employee Handbook

Pulte Homes, Inc.

I received, read, and understand the Business Practices Policy and Employee Handbook.

I also read, understand, and agree to the Alternative Dispute Resolution Policy, including the provision requiring that any claim must be submitted within six months of the decision, event, or

employment action, or it is waived.

I certify that I have not violated, and will not violate, the spirit, intent, or provisions of the

policies stated in these materials. I agree to promptly report actual or potential violations of theBusiness Practices Policy and/or the Employee Handbook.

Employee Name (print):

Employee Signature:

Date:

Business Practices Policy

Documents

Transcript of Business Practices Policy