O Star
O Star
O Star
INTRODUCTION
WORKPLACE STANDARDS
Attendance
Code of Business Conduct and Ethics
Dress Code
Equal Employment Opportunity
Non-Harassment
Working Hours
EMPLOYMENT PRACTICES
Employee Records
Employment Classifications
Service Bridging
Termination of Employment
CAREER DEVELOPMENT
Career Opportunities & Internal Transfer
Employee Development
Tuition Assistance
COMPENSATION & PAY
Base Pay Changes
California Meal Break and Rest Periods
Overtime
Severance
PERFORMANCE MANAGEMENT
Call Monitoring
Corrective Action
Performance Management
TIME OFF
Leave
Military Leave
Paid Time Off
EMPLOYEE WELL-BEING
Drug & Alcohol Free Workplace
Emergency & Inclement Weather Conditions
Safety in the Workplace
Workplace Violence
LEGAL
Anti-Corruption
Corporate Information & Insider Trading (Insider Trading)
Investor Communications
Proprietary Information and Trade Secret
TECHNOLOGY
Social Media
Use of Company Electronic Equipment, Systems and Networks
ACCOUNTING
Travel & Expense Guidelines
Purchasing
Introduction
At Costar, were working to build a world where our customers can reach their real estate goals
more efficiently and effectively with the best tools and information available. Since 1987, weve
been on a mission to create efficiency and transparency in commercial real estate. From our
earliest days, as the first company to offer real estate firms comprehensive, objective, reliable
information, to our recent expansion into operating some of the most active Internet marketplaces
for buying and selling commercial real estate, apartments, businesses and land, weve been
committed to excellence and creating the most inventive and insightful company in our industry.
CoStar Group is one of the most dynamic and fastest growing companies that invests in hiring and
developing the best talent in the industry. At CoStar, the expectations are high, the pace is fast and
change is a constant. We know our success depends on our people so we work hard to offer them
the kind of work environment, compensation and benefits package and development
opportunities that will help them reach their personal and professional goals.
All CoStar employees are part of a collaborative team of professionals who share a passion for our
industry. CoStar gives its employees the opportunity to learn from commercial real estate industry
experts, renowned researchers and leading edge technologists, on the job and through our inhouse online and classroom training programs.
We know we can only do our best when we feel our best. CoStar employees enjoy market leading
benefits, LEED-certified offices, onsite fitness activities and opportunities to contribute to the
community.
CoStar is committed to giving back to our local communities. Together, we make a difference and give back
to the communities we serve by donating our time and resources to the people, neighborhoods and
organizations in greatest need. Our presence and commitment to expand our reach within the local
community and beyond continues to grow as CoStar grows.
This Guide is effective July 1, 2015, and supersedes all other employee handbooks and related
policies previously distributed by the Company. Each policy is effective as of the dates noted on
the individual policy in the Guide. As our Company evolves, we will continue to review and revise
our policies as needed.
Policy: Attendance
Effective Date: 8/1/2015
1.0 Purpose:
This policy has been created to clearly communicate attendance expectations.
2.0 Eligibility:
All regular US employees of CoStar.
3.0 Policy:
Operating effectively as an organization takes cooperation and commitment from everyone.
Therefore, employee attendance and punctuality are very important. Excessive unplanned
absences as defined by each department, tardiness and early departures are disruptive to
the workplace and place an unfair burden on co-workers and managers and may affect
employee and organization performance. Any employee who has a concern regarding their
ability to meet the attendance requirements of their job should discuss any concerns with
their manager or Human Resources.
3.1 Requesting Planned Time Off
When time off from work is desired, employees should review and follow the Paid Time Off
Policy including the procedures to request time off. Employees must request time off in
advance and the approval for that time off is at the discretion of the employees immediate
manager.
3.2 Manager Notification for Unplanned Tardiness or Absence
CoStar recognizes that there are times when absences and tardiness cannot be avoided.
When this occurs, employees are expected to notify their manager as early as possible, but
at least 30 minutes before the start of their scheduled day. Employees must notify their
manager every day that they are absent and let them know the expected duration of their
absence.
3.3 Extended Absence (see the Leave of Absence Policy for more details)
Generally, if an employee is absent due to illness for 3 or more consecutive days, they may
be required to provide the Human Resources Department with a doctors note when they
return to work.
4.0 Consequences of Violating the Policy:
Frequent and or excessive absenteeism, tardiness or early departures may impact performance
and salary reviews and may result in corrective action up to and including termination of
employment (see the Corrective Action Policy for more details).
Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest that
create the appearance of bias;
Full, fair, accurate, timely and understandable disclosure in reports and documents CoStar files with, or
submits to, the Securities and Exchange Commission (the SEC) and in other communications made by
CoStar;
Compliance with applicable governmental laws, rules and regulations;
The prompt internal reporting of violations of this Code to the appropriate person or persons identified in
this Code;
Accountability for adherence to this Code; and
Adherence to a high standard of business ethics.
A.
CONFLICTS OF INTEREST
General. Employees are required to refrain from any action or interest that conflicts with, or may reasonably
be expected to conflict with, CoStars interests. A conflict of interest exists whenever an individuals private interests
interfere or conflict in any way (or even appear to interfere or conflict) with the interests of CoStar. A conflict
situation can arise when an employee takes actions or has interests that may make it difficult to perform his or her
work for CoStar objectively and effectively. Conflicts of interest may also arise when an employee or a member of his
or her family receives improper personal benefits as a result of his or her position with CoStar, whether from a third
party or from CoStar. A conflict of interest may also arise if an employee conducts business on behalf of CoStar with a
member of his or her family. Moreover, a conflict of interest may also arise if an employee conducts business on
behalf of CoStar with an entity in which the employee or a family member has an interest, including if the employee or
a family member works for an entity that conducts business with CoStar or is a competitor of CoStar, or if the
employee or a family member receives a financial or personal benefit from an entity that is a vendor or client of
CoStar, other than a benefit for a nominal amount.
Because conflicts of interest may not always be clear-cut, employees are encouraged to bring questions about
particular situations to the attention of CoStars Compliance Officer or the Vice President of Human Resources.
Corporate Opportunities. Employees of CoStar are prohibited from taking personal opportunities for
themselves that are discovered through the use of corporate property, or in which they anticipate that CoStar might
have an interest. No employee may use corporate property, information or position for improper personal gain and
no employee may compete with CoStar directly or indirectly.
Outside Employment. CoStar requires that each employee report in writing to his or her manager and his or
her Human Resources Business Partner any other current employment (including self-employment) that such
employee may have or may consider taking while continuing employment with CoStar. CoStar retains the right to
determine whether this outside employment creates an actual or potential conflict with CoStars policies and
procedures, the employees assigned duties at CoStar, scheduling assignments, or the employees ability to provide his
or her best efforts to CoStar business.
Romantic Relationships and Employment of Relatives.
CoStar strongly discourages romantic
relationships between managers and their direct reports or any subordinate. Specifically, managers should not retain
responsibility for performance evaluations, promotions or pay of a person with whom they are romantically involved.
Each participant in such a relationship must bring it to the attention of the Vice President of Human Resources, who
will then determine if it is appropriate for one of the employees to be moved to a new position. The employment of
immediate relatives or of persons in a romantic relationship is prohibited in any situation where there is an actual,
perceived, or potential conflict of interest.
Gifts and Favors. Giving and receiving gifts as part of business dealings can create conflicts of interest. The
purpose of gifts and favors is generally to create goodwill. If they do more than that, and unduly influence judgment
or create a feeling of obligation, they should not be given or accepted. You must not give gifts to, or receive gifts from,
CoStars business contacts, relatives, suppliers, vendors or others who have a business relationship with CoStar if they
create an actual or potential conflict of interest. In this context, CoStar will adhere to the following guidelines:
Giving gifts to U.S. government personnel: Federal, state and local government departments are governed by
complex laws and regulations concerning acceptance by their employees of entertainment, meals, gifts,
gratuities and other things of value. You should comply with any such laws and regulations, and also with the
policy outlined in this Code. Additional information regarding payments to foreign government personnel is
covered later in this Code and in detail in CoStars Anti-Corruption Compliance Policy.
Giving gifts to non-government personnel: You should use common sense and good judgment in offering
business courtesies and gifts to non-government personnel. Gifts, gratuities or other favors, are prohibited if
they are (a) not made in compliance with applicable law; (b) given in consideration or expectation of any
B.
action by the recipient; or (c) not consistent with customary business practices. Employees may offer meals
and business entertainment if the expense is reasonable and directly related to CoStar business.
Receiving gifts: Employees may not accept anything, including gifts, service or other consideration, from any
vendor or supplier or their employees, other than something that is nominal in amount or value. Employees
may accept meals and business entertainment if the expense is reasonable and directly related to CoStar
business.
CoStar, as part of its marketing efforts, may from time to time invite and pay for attendance by customers or
others at its corporate-sponsored events upon approval by CoStars Chief Executive Officer, Chief Financial
Officer, Executive Vice President of Sales, or Chief Marketing Officer (or person performing equivalent
functions). In addition, CoStars Chief Executive Officer, Chief Financial Officer, Executive Vice President of
Sales, or Chief Marketing Officer (or person performing equivalent functions) may in his discretion and not as
a waiver of this Code, permit attendance by CoStars employees at similar events sponsored by CoStar or
CoStars vendors, suppliers, customers, partners or other third parties in connection with the employees
duties with CoStar.
SPECIAL ETHICAL OBLIGATIONS FOR FINANCIAL REPORTING
CoStar requires honest, accurate and timely recording and reporting of information in order to make
responsible business decisions. All of CoStars books, records, accounts and financial statements must be maintained
in reasonable detail, must appropriately reflect CoStars transactions and must conform to applicable legal and
accounting requirements. Unrecorded or off the books funds or assets should not be maintained under any
circumstances. The accurate and timely reporting of our financial results and financial condition requires that all
financial information be recorded promptly and accurately, and that our systems for recording and reporting that
information be properly functioning and subject to regular and thorough evaluations. While not all of us may be
familiar with accounting procedure, we do need to make sure that every business record is accurate, complete and
reliable.
In addition, no officer or employee, or any person acting under the direction thereof shall take any action to
fraudulently influence, coerce, manipulate or mislead CoStars independent public accountants engaged in the
performance of an audit of CoStars financial statements for the purpose of rendering such financial statements
materially misleading.
All employees are responsible to report any concerns regarding questionable accounting or auditing matters
that may come to their attention either to CoStars Compliance Officer or the Audit Committee of the Board of
Directors through CoStars compliance hotline identified at the end of this section. This policy also applies to all
operating reports or records prepared for internal or external purposes. False, misleading or incomplete information
impairs CoStars ability to make good decisions, undermines trust in the long term, and may in some cases be illegal.
The Finance and Accounting Departments bear a special responsibility for promoting honesty, integrity, and
ethical conduct throughout the organization, with responsibilities to stockholders both inside and outside of CoStar.
The Chief Executive Officer, Chief Financial Officer, and other personnel have a special responsibility both to adhere to
these principles themselves and also to ensure that a culture exists throughout CoStar as a whole that ensures the fair
and timely reporting of CoStars financial results and condition.
Because of this special responsibility, the Chief Executive Officer, Chief Financial Officer and all other managers
in the Finance and Accounting Departments are bound by the following Financial Officer and Manager Code of Ethics,
and by accepting this Code, each agrees that he or she will: (1) act with honesty and integrity, avoiding actual or
apparent conflicts of interest involving personal and professional relationships; (2) provide information, both in
reports and documents filed with or submitted to the U.S. Securities and Exchange Commission (or other foreign
securities regulators) or other public communications, that is full, fair, accurate, complete, objective, timely and
understandable; (3) comply with rules and regulations of all governmental entities, as well as other private and public
regulatory agencies, to which CoStar is subject; (4) act at all times in good faith, responsibly, with due care,
competence and diligence, and without any misrepresentation of material facts; (5) act objectively, without allowing
his or her independent judgment to be subordinated; (6) respect the confidentiality of CoStar information, except
when authorized or otherwise required by law to make any disclosure, and avoid the use of any CoStar information for
personal advantage; (7) promote ethical behavior among employees under his or her supervision at CoStar; (8)
achieve responsible use of and control over all assets and resources of CoStar entrusted to him or her; and (9)
promptly report any conduct that the individual knows or suspects to be a violation of law or ethics or of any
provision of this Code.
If you know or suspect that a violation of the Financial Officer and Manager Code of Ethics has occurred,
please contact CoStars Compliance Officer. You may also report financial misconduct to the Audit Committee of the
Board of Directors through CoStars compliance hotline by calling 1-800-750-4972 in the U.S. or Canada, or by dialing
the AT&T Direct Access Code from the U.K. (currently 0800-89-0011) followed by 800-750-4972. It is against CoStars
policy to retaliate against any employee for good faith reporting of violations of this Code, including the Financial
Officer and Manager Code of Ethics, or for participating in any investigation relating to a known or suspected violation,
as described further in the last section of this Code.
C.
Obeying the law, both in letter and in spirit, is one of the foundations on which CoStars ethical standards are
built. All employees must respect and obey the laws of the various jurisdictions in which we operate. Although not all
employees are expected to know the details of these laws, it is important to know enough to determine when to seek
advice from managers or other appropriate personnel.
Insider Trading. All CoStar employees must comply with CoStars Policy Statement on Corporate
Information, Including Inside Information and Securities Insider Trading (Insider Trading Policy). Following is a brief
summary of CoStars policy on insider trading. In the course of employment with CoStar, employees may learn or
receive information about CoStar or other entities that is not available to the public. Because of the employment
relationship with CoStar, employees have certain responsibilities under the federal securities laws (or comparable
foreign securities or related laws) regarding insider information and the trading of securities. In short, CoStar
employees: (1) may not purchase or sell securities if aware of information about any entity in which such securities
are held, including, if the information pertains to CoStar, CoStar securities, that has not been made public and that may
be considered material; (2) may not disclose any non-public, material information to any other person; and (3) may
not trade CoStar securities during any period in which CoStars Compliance Officer has announced that the trading
window has closed.
Complete, Accurate And Timely Disclosure. CoStar is a publicly traded company whose shares are listed
for trading on The NASDAQ Stock Market. As a result, CoStar is obligated to make various disclosures to the public.
CoStar is committed to full compliance with all requirements applicable to its public disclosures. CoStar has
implemented disclosure controls and procedures to assure that its public disclosures are timely, compliant and
otherwise full, fair, accurate and understandable. All employees responsible for the preparation of CoStars public
disclosures, or who provide information as part of that process, have a responsibility to assure that such disclosures
and information are complete, accurate and in compliance with CoStars disclosure controls and procedures.
Discrimination and Harassment. CoStar is committed to fostering a work environment in which all
individuals are treated with respect and dignity. Each individual should be permitted to work in a business-like
atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including
harassment. Therefore, CoStar expects that all relationships among persons in the workplace will be business-like and
free of unlawful bias, prejudice and harassment. It is CoStars policy to ensure equal employment opportunity without
discrimination or harassment on the basis of any category protected by law. As such, all employees are expected to
comply with CoStars Equal Opportunity and Non-Harassment Policy.
Bribery, Kickbacks and Fraud. The United States and many other countries have laws that prohibit bribery,
kickbacks, and other improper payments. No funds or assets of CoStar (or from any other person or entity) shall be
paid, loaned or otherwise disbursed as bribes, kickbacks, or other payments designed to influence or compromise
the conduct of the recipient or to obtain business or an unfair advantage; and no employee of CoStar shall accept any
funds or other assets for obtaining business or for securing special concessions from CoStar. Any employee found to
be receiving, accepting, paying or condoning a bribe, kickback, or other unlawful payment, attempting to initiate such
activities, or attempting fraud or engaging in fraud will be subject to corrective action, up to and including termination
and possible civil and/or criminal proceedings against them.
Payments to Government Personnel. The U.S. Foreign Corrupt Practices Act (the FCPA) prohibits giving
anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to
obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country. The
FCPA also requires strict reporting of all payments to officials in a foreign country. In addition, the U.S. government
has a number of laws and regulations regarding business gratuities that may be accepted by U.S. government
personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other
gratuity in violation of these rules would not only violate company policy but could also be a criminal offense. State
and local governments, as well as foreign governments, may have similar laws, rules or regulations. Each employee
must maintain records of all payments and fully inform his or her manager of any and all payments to government
officials and representatives of foreign governments to ensure proper compliance with the laws and regulations. For
more details, please review CoStars Anti-Corruption Compliance Policy. In addition, CoStars employees in the United
Kingdom should become familiar with and are required to comply with the terms of the CoStar UK Limited AntiBribery Policy Statement. If you have any questions about this section, please consult CoStars Legal Department.
Third Party Intellectual Property Rights. It is the policy of CoStar to provide the most accurate,
comprehensive commercial real estate information in the marketplace, while respecting the intellectual property
rights of others, such as third-party trademarks, copyrights, trade secrets and confidentiality obligations, and website
terms of use. For more details, please review CoStars Third Party Intellectual Property Policy. If you have any
questions regarding the use of third party intellectual property, please contact CoStars Legal Department.
Competition and Fair Dealing. We seek to outperform our competition fairly and honestly. We seek
competitive advantages through superior products and services, not through illegal or unethical business practices.
Each employee should endeavor to respect the rights of and deal fairly with CoStars customers, suppliers,
competitors and employees. No employee should take unfair advantage of anyone through manipulation,
concealment, abuse of privileged information, misrepresentation of material facts or any other intentional unfairdealing practice.
CoStar operates in a competitive market. As a result, antitrust laws are an important aspect of everyday
business life. The antitrust laws are complex and must be strictly followed. Antitrust laws typically prohibit
restraints of trade, which is certain conduct involving competitors, customers or suppliers in the marketplace. Their
purpose is to ensure that markets for services operate competitively and efficiently, so that customers enjoy the
benefit of open competition. If any employee has questions concerning a specific situation, he or she should contact
CoStars Legal Department.
D.
All employees are responsible for safeguarding the tangible and intangible property of CoStar and its
customers and suppliers.
Company Proprietary and Other Confidential Information. All employees must comply with CoStars
Proprietary Information and Trade Secret Policy. Following is a brief summary of this policy. Much of the information
that employees develop or acquire while working at CoStar involves CoStars Proprietary Information, including trade
secrets and confidential information of CoStar. CoStars Proprietary Information is an extremely important asset of
CoStar. Because of its value and competitive importance, CoStars Proprietary Information must be protected through
reasonable and prudent secrecy measures. Each employee has a duty to keep CoStar Proprietary Information secret
and confidential, both during and after his or her employment with CoStar.
Please remember that since CoStars services are delivered electronically and consist of intangible intellectual
property, it is extremely important for each employee to safeguard access to these services and not allow
unauthorized people access to CoStars services. No employee should allow any third party to use or access the
subscription portions of CoStars services unless that party has signed a license agreement or unless expressly
approved by an officer of CoStar. In addition, the third partys use and access of CoStars services should not exceed
the scope of the license agreement. If an employee becomes aware of unlicensed users using CoStars services, or use
beyond the scope of the agreement, the employee should report the matter to his or her Manager and to CoStars Legal
Department.
Theft and Fraud. All employees are responsible for the proper use of CoStars physical resources and
property, as well as its confidential information. Any employee found to be engaging in, or attempting, theft of any
property of CoStar, including documents, products or services, equipment, intellectual property, personal property of
other employees, cash or any other items of value will be subject to immediate termination and possible criminal
proceedings against them. In addition, allowing third parties to use CoStars services without a proper license
agreement or outside the scope of the license agreement may constitute theft of CoStars intellectual property. All
employees have a responsibility to report any theft or attempted theft to their respective managers or to the
Compliance Officer
Pricing and License Controls. All sales personnel must comply with CoStars internal pricing policies and
with CoStars licensing policies. For example, CoStar generally establishes its contract rates based upon a clients
number of sites, number of users, organization size, business focus and the number of services to which such client
subscribes, and requires that each client company have its own license and that each user be identified. No employee
should submit false information on a contract to circumvent CoStars pricing or license controls, knowingly allow
access to CoStars services by non-clients (unless approved by an officer of CoStar), knowingly allow access to CoStars
services by competitors, or knowingly be involved with similar situations that harm CoStar. Any employee that learns
of any violation of this policy should report it to his or her manager or the Compliance Officer. Any employees found
to be violating these policies will be subject to corrective action up to and including termination and possible civil
and/or criminal proceedings against them.
Record-Keeping. CoStar requires honest and accurate recording and reporting of information in order to
make responsible business decisions. For example, only the true and actual number of hours worked should be
reported and all expense reports must contain only legitimate expenses. Whenever it becomes apparent that
documents of any type will be required in connection with a lawsuit or government investigation, all possibly relevant
documents should be preserved, and ordinary disposal or alteration of documents pertaining to the subjects of the
litigation or investigation should be immediately suspended. If an employee is uncertain whether documents under
his or her control should be preserved because they might relate to a lawsuit or investigation, he or she should contact
the Legal Department.
Customer/Third Party Information Privacy. CoStar takes the protection of privacy for our customers,
consumers, and other third parties that have entrusted us with information very seriously. All employees are required
to follow applicable laws and regulations directed toward privacy and information security. All employees must
safeguard confidential information our customers and other third parties share with us by ensuring that their
information is only used for the reasons for which the information was gathered. If an employee does not have a
business reason to access this information, the employee should not do so. Employees must also take steps to protect
confidential information against unauthorized use or release.
Employee Information Privacy. CoStar respects the privacy of our employees. Our company collects and
handles personal employee information only for business reasons consistent with applicable law. Access to personal
employee information is limited only to those who have a legal right to see the information, and then only on a needto-know basis for the performance of their job. Those who handle personal information are advised on a regular basis
of their duty to protect this information. All employees have the right to review and comment on information
contained in their personnel records maintained by CoStar, and may perform other actions with their records as
allowed by applicable data privacy laws.
WAIVERS OF THE CODE
Any waiver of this Code for an employee may be made only by an officer of CoStar after disclosure of all
material facts by the individual seeking the waiver. Any waiver of this Code, including the Financial Officer and
Manager Code of Ethics, for any officer of CoStar or for CoStars Vice President of Finance, Vice President of
Accounting or Controller (or persons performing similar functions) may be made only by the independent directors of
the Board of Directors. Such waiver will be promptly disclosed if required by law or by applicable stock exchange or
securities regulations.
COMPLIANCE WITH THE CODE
All employees of CoStar have a responsibility to understand and follow the Code and are expected to perform
their work with honesty and integrity in any areas not specifically addressed by the Code. A violation of this Code may
result in corrective action up to and including termination from employment for cause, without additional warning.
Nothing in this Code prohibits or restricts CoStar from taking any corrective action on any matters pertaining to
employee conduct, whether or not they are expressly discussed in this Code, and nothing in this Code creates any
employment contract between CoStar and any of its employees.
REPORTING SUSPECTED NON-COMPLIANCE
Complaint Procedure. If an employee knows or suspects that actions have taken place, may be taking place
or may be about to take place that violate or would violate this Code or any law, the employee must promptly bring
the matter to the attention of CoStar. Employees are encouraged to talk to their managers, the Vice President of
Human Resources or the Compliance Officer about observed or suspected illegal or unethical behavior and when in
doubt about the best course of action in a particular situation. Any manager who receives a report of a potential
violation of this Code must report it to CoStars Compliance Officer or the Vice President of Human Resources.
Reporting is important because failure to report criminal activity can itself be understood to condone the crime.
Failure to report knowledge of wrongdoing may result in corrective action against those who fail to report.
Employees are required to communicate any known or suspected violations of this Code to CoStars Vice
President of Human Resources or CoStars Compliance Officer, by any of the following methods: (1) in writing either
by internal mail or standard mail; (2) by e-mail; or (3) by telephone. CoStar has also contracted with a company to
provide a confidential and anonymous compliance hotline that can be accessed by telephone to report violations of
this Code, including but not limited to violations of CoStars accounting, auditing, internal controls and financial
reporting disclosure practices. The phone number of the hotline in the U.S. and Canada is 1-800-750-4972, and it can
be reached by our employees in the U.K. by dialing the AT&T Direct Access Code (currently 0800-89-0011) followed
by 800-750-4972. Any use of these reporting procedures in bad faith or in a false or frivolous manner will be
considered a violation of this Code. In addition, employees should not use CoStars compliance hotline for personal
grievances that do not involve (1) known or suspected violations of this Code, (2) known or suspected illegal or
unethical behavior, or (3) good faith claims of retaliation in accordance with the last section of this Code.
We would prefer employees identify themselves to facilitate the companys investigation of any report.
However, employees may choose to remain anonymous. We will use reasonable efforts to protect the identity of any
person who reports potential misconduct in good faith. We will also use reasonable efforts to protect the identity of
the person about or against whom an allegation is brought, unless and until it is determined that a violation has
occurred. Any person involved in any capacity in any investigation of a possible misconduct must not discuss or
disclose any information to anyone outside of the investigation unless required by law or when seeking his or her own
legal advice, and is expected to cooperate fully in any investigation.
Once a report is received, CoStar will investigate it promptly and thoroughly. All employees are expected to
cooperate in investigations fully and candidly. CoStar will take corrective action, as appropriate, based on the findings
of the investigation.
Protection Against Retaliation. It is the policy of CoStar to prohibit retaliation for good faith reports by
employees of misconduct or of violations of this Code or violations of law by others, or for providing assistance in the
investigation of ethical concerns or alleged misconduct. Further, in accordance with the U.K. whistle blowing regime,
CoStar prohibits retaliation against employees in the U.K. who report known or suspected illegal or unethical behavior
if the employee reasonably believes that the disclosure is in the public interest. Retaliation in any form against an
individual who reports a violation of this Code or of law in good faith (or in the case of a U.K. employee who reports a
violation of law, or other qualifying matter in accordance with the U.K. whistleblowing regime, if believed by the
employee to be in the public interest), even if the report is mistaken, or who assists in the investigation of a reported
violation, is itself a serious violation of this policy. Acts of retaliation should be reported immediately pursuant to the
complaint procedure outlined above. Indeed, any employees who engage in retaliation are subject to corrective action,
up to and including termination, and in appropriate cases, civil and/or criminal liability.
EMPLOYEE CERTIFICATION
1.
I certify that I have read and understand CoStars Code of Business Conduct and Ethics, including any
Exhibits applicable to my department, effective May 8, 2015 (collectively, the Code).
2.
3.
_________________
*If you have an exception(s) to items 2 and/or 3 above and wish to maintain confidentiality as to your
exception mark the box for no exceptions and report the potential violation(s) (1) in writing by delivering
your written communication directly to the Compliance Officer at the following address: CoStar Group, Inc.,
1331 L Street, NW, Washington, DC 20005 (Attn: General Counsel), or (2) by calling the compliance hotline in
the U.S. or Canada at 1-800-750-4972, and in the U.K. by dialing the AT&T Direct Access Code (currently
0800-89-0011) followed by 800-750-4972. You may report anonymously if you are unwilling to provide your
name.
__________________________
Signature
_________________
Date
__________________________
Name and Title (Please Print)
__________________________
Department
Note: Explanations of any provision of the Code and advice as to whether any specific set of circumstances
should be reported may be obtained from the Compliance Officer (General Counsel) or the Vice President of
Human Resources at CoStar Group, Inc., 1331 L Street, NW, Washington, DC 20005. The Compliance Officer
and the Vice President of Human Resources may also be reached by telephone at (202) 346-6500 or (800)
204-5960 or via e-mail at [email protected] or [email protected], respectively.
4.
5.
No CoStar employee shall engage in any of the prohibited acts set forth above unless explicitly approved, in advance,
by the VP of Customer Service, Executive VP of Sales, or the Chief Executive Officer of CoStar.
EXHIBIT FOR PRODUCT DEVELOPMENT & SYSTEMS
This exhibit to the Code of Conduct reinforces the Code of Conduct with the CoStar Product Development & Systems
Department. Specifically, examples of some acts that are prohibited by the Code of Conduct include, but are not limited
to, directly or indirectly engaging in any the following:
1.
2.
3.
4.
5.
6.
7.
8.
Unauthorized disclosure, use or copying of any portion of the CoStar databases, products, services,
software code, or other confidential or trade secret information.
Unauthorized installation, copying, or use of any software applications from outside vendors.
Inputting information or making changes to CoStars internal enterprise information management
system, currently known as Enterprise, that you know to be inaccurate.
Failing to independently develop any software code or product designs.
Copying someone elses copyrighted material without proper authorization.
Without express permission from your Manager, providing anyone outside of CoStar with screen
shots, exports, printouts, or other copies of any portion of Enterprise.
Sharing with any other person any User ID/password to the CoStar products.
Disseminating content from the subscription-only areas of CoStar products to anyone that doesnt
subscribe to the pertinent products and markets.
2.
3.
4.
5.
6.
7.
No CoStar employee shall engage in any of the prohibited acts set forth above unless explicitly approved, in advance,
by a VP of Research, a Regional Director of Research, the Executive VP of Operations or the Chief Executive Officer of
CoStar.
EXHIBIT FOR FIELD RESEARCH TEAM
This exhibit to the Code of Conduct reinforces the Code of Conduct with the CoStar Field Research Team. Specifically,
examples of some acts that are prohibited by the Code of Conduct include, but are not limited to, directly or indirectly
engaging in any the following:
1. Providing any third party with building information, photographs or video that you collected, or shot
during work hours or while using CoStar equipment.
2. Inputting information or making changes to Enterprise or Rover that you know to be inaccurate,
including, for example, submitting to CoStar a photograph that does not actually depict the assigned
property.
3. Failing to conduct your own independent research before inputting information, submitting imagery
or making other changes to Enterprise or Rover. Independent research generally consists of
obtaining information or imagery directly from one or more of the following:
i. an involved source in the transaction, such as the broker, owner, tenant or property
management firm, either via phone call, personal conversation, e-mail, fax, a company press
release, or specific referral to portions of a companys web site;
ii. public records; and
iii. personally inspecting a property.
4. Copying someone elses copyrighted material without proper authorization.
5. Providing anyone outside of CoStar with screen shots, exports, printouts, or other copies of any
portion of Enterprise or Rover.
6. Sharing with any other person any User ID/password to the CoStar products.
7. Disseminating content from the subscription-only areas of CoStar products to anyone that doesnt
subscribe to the pertinent products and markets; provided, that strictly for updating purposes, you
may provide a broker, property manager, owner or tenant with their own listings or tenant
information.
No CoStar employee shall engage in any of the prohibited acts set forth above unless explicitly approved, in advance,
by a VP of Research, VP of Field Research, Executive VP of Operations or the Chief Executive Officer of CoStar.
Policy: Non-Harassment
Effective Date: 8/1/2015
1.0 Purpose:
CoStar is committed to ensuring a professional, respectful environment where all employees feel
comfortable working.
2.0 Eligibility:
All regular US employees, contractors, and temporaries of CoStar.
3.0 Policy:
CoStar prohibits harassment based on actual or perceived race, color, religion, gender, age, disability,
national origin, genetic information, sexual orientation, gender identity, sex change and transgender status
or any other category protected by applicable federal, state or local law. This policy applies while in the
workplace, on CoStar property, in the field, or at any time while on Company business, Company- and nonCompany- sponsored events where CoStar employees are participating. No employee should ever threaten
or imply, even in jest, that an individuals submission to or rejection of sexual advances will in any way
influence any decision regarding that individuals employment, performance evaluation, pay, advancement,
assigned duties, or any other condition of employment or career development.
3.2 Retaliation
Retaliatory action taken against an individual who in good faith reports a perceived violation of this
policy will not be allowed. Individuals who participate in an investigation will be protected against
retaliatory actions.
Appropriate corrective action up to and including termination of employment (see the Corrective
Action Policy) will be taken against any individual found to have harassed another employee or to have
taken retaliatory action in violation of this policy.
Any employee, who believes that harassment or employment discrimination is occurring or has occurred,
must report the relevant facts immediately, whether or not it is directed at the employee. Complaints
should be promptly reported to the Vice President of Human Resources by calling X6772, (202) 346-6772
or toll free at (888) 496-0665 or by writing to the following address: CoStar Group, Inc., 1331 L Street NW,
Washington D.C. 20005, Attn: VP, Human Resources. If, for any reason, the employee is uncomfortable or
unable to speak to the VP, Human Resources, they are encouraged to report the complaint to the most
senior manager with whom they are comfortable discussing the matter. Any manager who receives such a
complaint must promptly report it to the VP, Human Resources.
If the employee is not comfortable speaking with someone in Human Resources or management, CoStar has
contracted with a company to provide a confidential compliance hotline to report violations of CoStars
policies, including the Code of Conduct. Employees who use the hotline may do so anonymously and all
employees will be provided confidential treatment. The phone number of the hotline is (800) 750-4972.
All complaints will be investigated promptly and fully with the highest level of confidentiality possible. All
employees must cooperate with investigations.
CoStar is committed to maintaining and protecting employee digital records, files and information in a
professional manner. This policy provides general guidance regarding the maintenance of such
information.
2.0 Eligibility:
All current and former regular US employees of CoStar.
3.0 Policy:
Human Resources securely maintains electronic records in the Company HRIS and files for each employee
in the HR area. An employee or their manager can have access and/or copies of an employee record:
by request during their employment and in the presence of a Human Resources representative at a
scheduled time;
former employees will be provided access and/or copies of files in accordance with applicable
state law
All requests for access to employee records should be referred to Human Resources by emailing
[email protected].
Requests for employee information from financial institutions or other organizations, or for verifications of
employment history, should be referred to Human Resources. A basic verification includes name,
employment status, most recent start or termination date, total time with the company, and job title. All
information will only be verified upon receipt of a signed release by the employee permitting the disclosure
of such information. CoStar complies with employment-related references for government entities who
request them. Requests for references should be directed to Human Resources. Managers and other
employees are not permitted to provide employment-related references regarding current or former
employees on behalf of the Company.
employees and are paid through the agencys payroll system. They are only eligible for
benefits, if any, offered through the agency.
4.0 Fair Labor Standard Act (FLSA) Categories:
All employees are categorized as either exempt or non-exempt and are defined as follows:
4.1 Non-Exempt Employees
Non-exempt employees are paid on an hourly basis and sometimes referred to as hourly. Nonexempt employees are entitled to overtime compensation in accordance with state and federal
law (see the Overtime Policy for more details).
4.2 Exempt Employees
Exempt employees are compensated on a salary basis and sometime referred to as salaried.
Exempt employees are not eligible for overtime and generally receive a guaranteed salary
intended to cover all hours worked including any hours in excess of 40 hours in a week.
CoStar values the knowledge, skill and experience that come with an employees service. The
purpose of this policy is to recognize a returning employees prior service and provide guidelines
on how that affects their re-employment with regard to benefits.
2.0 Eligibility:
Full-time, regular US employees of CoStar that have been rehired within 5 years of their most
recent termination date.
3.0 Calculation of Service:
A rehired employees amount of prior completed service with the Company will be added to the
start date of their subsequent period of employment to calculate total years of service.
3.1 Definition: Year of Completed Service
A Year of Completed Service is calculated from date of hire to the first anniversary date and from
anniversary date to anniversary date thereafter.
Employees in an approved status such as: FMLA status, military leave status, jury duty, approved
unpaid leave status, and short or long term disability status will have those periods of time credited
toward their length of completed service.
4.0 Policy:
Employees that have been rehired within 5 years of their employment termination date qualify for
amended service date benefits as listed in the table below. Rehires that are hired after more than 5
years have passed between their employment end-date and rehire date will be treated as new
hires with respect to their benefits.
Former employees who left CoStar in good standing will be considered for rehire opportunities.
To apply for a rehire opportunity, a former employee will need to satisfy the recruiting
requirements, including a background check, drug test and any other requirements for the
position for which the rehire candidate is applying.
Rehired employees will be treated like new hires except that those rehired employees who are
rehired within 5 years of their employment termination date qualify for the following CoStar
benefits:
Benefit
Vacation Accrual
Service Awards
Tuition Assistance
401k Match Vesting
2.0 Eligibility:
All regular US employees of CoStar.
3.0 Policy:
Every employee, in partnership with their manager, is responsible for their individual development and is
encouraged to participate in this process. Managers should provide support and guidance to employees in
identifying appropriate learning and development opportunities, coaching their employees, and providing
the time and budget for agreed upon development activities.
Development opportunities include planned, on the job experiences, coaching, mentoring and job
shadowing as well as formal classroom and online training. Activities should be job-related or
related to a relevant career opportunity at CoStar.
CoStar also supports development opportunities outside of CoStar. These opportunities should be
identified in concert with the employees manager who will need to seek approval for funding for
such activities, which will come from the departments budget.
Employees are encouraged to complete an Individual Development Plan (IDP) housed in Skyline.
Specified development objectives, actions and targeted completion dates should also be noted. The
manager and the employee need to reach agreement on the content of the IDP.
The Talent Development Manager and the HR Business Partner can provide additional assistance
to managers in creating the IDP.
While the employee is expected to assume ownership of their own development, the manager
plays a critical role in influencing an employees day-to-day activities. Managers have the greatest
opportunity to coach and provide ongoing feedback.
3.1 Types of Development Needs
The personal development needs of the employee are derived from five basic inputs:
3.1.1 Performance Related Development Needs
The identification of performance-related development needs is an output of the
performance management process, and tied to the employees personal objectives. If
actual job performance falls short of expectations, underlying causes should be
determined. If it is determined that further development would aid the improvement of
performance, the specific actions should be noted.
potential effect on work hours must be discussed with and approved by their manager in advance
of submitting their application. Applications submitted after the start date of the course may be
denied.
Promotions to the next highest role in a career path primarily occur during the common
performance review schedule.
The company provides additional opportunities during the performance period to consider
promotions and provide promotion increases. Promotions into an open requisition may
occur at any time. Please refer to the Career Opportunities and Internal Transfers Policy.
Managers are expected to manage promotion increases within the Companys promotion
increase budget, which is based on market surveys and trends and determined by Human
Resources, Finance and senior management.
Human Resources recommends that a market and internal equity review be completed to
support any market adjustments. Broader reviews allow all potential employees in the
same or similar roles to be reviewed for potential pay adjustments.
Managers may make market adjustment requests at any time during the year.
Human Resources recommends that the function or business unit executive be involved in
market adjustments to ensure alignment with budget and business needs.
Market adjustments are typically exceptions and not the norm.
8.0 Responsibilities:
Human Resources:
Partner with senior leaders to determine their business needs and consider ongoing
adjustments to the process and guidelines.
Design, recommend and establish ongoing merit, promotion, and market adjustment
increases and guidelines.
Communicate process and guidelines to senior leaders and managers.
Provide training, tools and support to managers during the annual merit process and when
managers propose merit, promotion and market adjustment increases.
Finance:
Review and approve proposed merit, promotion and market adjustment budgets.
CoStar Group recognizes that employees perform at their best when they have the rest and nourishment
they need. This policy provides guidelines under the California state regulations for determining when
employees are expected to take meal periods and rest breaks.
2.0 Eligibility:
Non-exempt (rest and meal breaks) and exempt (meal breaks) California employees.
CoStar Group provides meal periods and rest breaks according to guidelines set forth by Labor Code
Section 512 and the Wage Orders.
Non-exempt employees who work at least 3.5 hours per day are provided one 10-minute rest break for
every 4 hours or major fraction thereof worked. For purposes of this policy, major fraction means any
time greater than 2 hours.
For example, if an employee works more than 6 hours, but no more than 10 hours in a workday, he
or she is provided and should take two 10-minute rest breaks: one during the first half of the shift
and a second rest break during the second half of the shift. If an employee works more than 10
hours but no more than 14 hours in a day, he or she is provided and should take three 10-minute
rest breaks, and so on.
Rest breaks should be taken as close to the middle of each work period as is practical. Employees are
encouraged to take their rest breaks; they should not work during their rest breaks. Non-exempt
employees are paid for all rest breaks; therefore, employees do not need to clock out when taking a rest
break.
Employees who work more than 5 hours in a workday are provided an unpaid, off-duty meal period of
at least 30 minutes. If 6 hours of work will complete the days work, they may voluntarily waive their
meal period in writing. Contact your HR representative to sign and submit a form that waives this right
to a meal period (for working no more than 6 hours in a day). Employees who work more than 10
hours in a day are entitled to a second unpaid, off-duty 30-minute meal period. If an employee works
no more than 12 hours, the employee can waive his or her second meal period, but only if the first one
was not waived in any manner. Any waiver of the second meal period must be in writing and submitted
before the second meal period. See Contact your HR representative to sign and submit a form that
waives this right to a second meal period, as explained above. Employees who work more than 12
hours may not waive, and should take, their second unpaid, off-duty 30-minute meal period.
Employees are responsible for scheduling their own meal period, but it should begin no later than the
end of the fifth hour of work.
For example, an employee who begins working at 8 a.m. must begin his or her meal period no later
than 1:00 p.m.
Employees entitled to a second meal period should schedule it so it begins no later than the end of their
tenth hour of work.
When scheduling meal periods, employees should try to anticipate their work flow and
deadlines. Managers may stagger employees meal periods so ongoing operational responsibilities are
not compromised, so long as the applicable guidelines in this Policy are met. Employees are encouraged
to take their meal periods; they are not expected to work during their meal periods.
During a meal period, employees are relieved of all duties and should not work during this time. When
taking a meal period, employees should completely stop working for at least 30 minutes. Employees
are prohibited from working off the clock during their meal period. Employees are expected to clock
back in and promptly return to work at the end of any meal period. Unless otherwise directed by your
manager in writing, approval from or notification to your manager when taking a meal period is not
required.
3.3 Summary Chart:
Hours of Work
0 to 3.4 (less than
3.5)
3.5 to 4.0
More than 4.0 up to
5.0
More than 5.0 up to
6.0
More than 6.0 up to
10.0
More than 10.0 up
to 12.0
More than 12.0 up
to 14.0
4.0 Responsibilities:
All rest breaks and meal periods must be taken outside employees work areas. Employees should not
visit or socialize with employees who are working while taking their rest break or meal
period. Employees may leave the premises during meal periods.
Non-exempt employees are responsible for understanding their departments overtime management and
approval practices, recording all time worked including the time they begin and end work each day, as well
as lunch breaks or any time when they stop working or leave the facility (other than short rest periods
described above) using the Companys electronic timekeeping system. Failure to report time worked (e.g.,
working off-the-clock) will subject the employee to corrective action, as appropriate. Further, employees
should be advised that if anyone ever instructs them to work off-the-clock or not to record hours, then
they should immediately inform their Human Resources representative. Employees are protected from
retaliation from making such reports.
Employees are required to notify the Human Resources Department immediately if they believe they are
being pressured or coerced by any manager, supervisor or other employee to forego any portion of a
provided rest break or meal period.
California Employees classified as non-exempt receive pay at the rate of one and one half times the
regular pay rate for any hours worked over eight hours in one workday and any work in excess of 40
hours in one workweek and the first 8 hours worked on the seventh day of work in any one workweek.
Any work in excess of 12 hours in one day and any work in excess of 8 hours on the seventh day of a
workweek shall be paid no less than twice the regular rate of pay.
Overtime is calculated based on hours worked. Sick, personal, vacation, holidays, (or any other Paid
Time Off) do not count as hours worked.
4.0 Rest and Meal Periods:
Rest periods of short duration (5-20) minutes are considered time worked. Meal breaks of 30 minutes or
more are not work time under the FLSA, provided the employee is completely relieved of duty during this
time period. If the employee performs any duties (i.e. answers the telephone) during the meal break, the
employee should record it as time worked. Meal periods should be documented through the payroll system
or time sheets (CA based non-exempt employees should refer to the California Meals & Rest Breaks Policy).
Travel that is All in a Day's Work: Time spent traveling between different job sites
during the course of the regular workday or other time spent traveling as part of the
employees principal activities during the regular workday.
Home to Work on a Special One Day Assignment in Another City: For an employee who
regularly works at a fixed location in one city and is given a special one day assignment
in another city and returns home the same day, time spent traveling to and returning
from the other city, except the Company may deduct/not count that time the employee
would normally spend commuting to the regular work site.
Travel Away from Home Community: If travel keeps an employee away from home
overnight, any time that cuts across the employee's workday on regular working days
during normal working hours but also during corresponding hours on non-working
days.
Conditions may arise that necessitate the reduction of CoStars work force. In these situations
employees may be eligible for severance pay.
2.0 Eligibility:
Employees whose positions have been eliminated for reasons of budget, lack of work, or
reorganization will be eligible to receive severance payment in accordance with this policy.
Managers should seek guidance from Human Resources if they will need to take actions that might
trigger severance eligibility for one or more of their employees (see the Termination Policy).
3.1 Full-time Employees
Full-time employees who have been part of a reduction in force or position elimination will
terminate from CoStar on the effective date of notice. In exchange for a full release of claims,
such terminated employees will receive severance pay equal to two weeks of current base pay
for their first year or less of employment, plus one week current base pay for each completed
additional year of continuous service with CoStar (up to a maximum of 16 weeks).
3.2 Part-time Employees
Severance for part-time employees is calculated on a pro-rated basis based on their average
actual hours worked over the past year or any length of time therein. The rate of severance is
based on their current base pay and length of service.
3.3 At-Will Employment
Each employee of CoStar is an at will employee. Except as specifically provided by an
employment agreement, if any, CoStar is not liable to pay severance or any incentive/bonus at
the time of an employees termination, but has chosen in accordance herewith to pay
severance in limited circumstances. CoStar may amend, alter or terminate this severance policy
at any time, in its sole discretion.
consistency with other corrective actions made under similar circumstances with other
employees.
Managers are expected to receive approval from Human Resources regarding all formal corrective
actions (see section 5.0: Types of Corrective Action).
5.0 Types of Corrective Action:
At their discretion, managers may use any of the following corrective action techniques and are
encouraged to try informal corrective actions prior to formal corrective actions, when appropriate.
Managers are not, however, required to use all forms of corrective action, or to use them in any
particular order. This list of corrective action techniques is not meant to be exhaustive and
managers may use other techniques not listed if discussed first with Human Resources.
5.1 Coaching
Coaching is an informal type of corrective action that can be part of the regular, ongoing
interaction between a manager and his/her employee. The purpose of coaching is to
reinforce positive performance and behavior and correct performance and behavior issues
early, before a performance or behavior issue becomes a more serious problem. Since
coaching is considered informal corrective action, Human Resources does not have to be
involved and there is no official documentation required. Coaching is considered the least
severe of all corrective action types and should be the one that managers use most
frequently. If performance does not improve after repeated attempts at coaching, the next
possible step could be counseling.
5.2 Counseling
Counseling is another type of informal corrective action that can be used to help employees
recognize and correct work-related problems through direct feedback from the manager.
Counseling may be effective when behavior problems first occur because it is handled
through an informal discussion with the employee. Counseling may also be utilized when
coaching has not been successful to improve a performance or behavior issue.
5.3 Performance Improvement Plan (PIP)
A Performance Improvement Plan (PIP) formally documents performance issues and
timeframes for future evaluations and is provided to an employee so that expectations for
improvement and requirements to meet are clear. It can be provided to an employee if
his/her performance evaluation was less than meets expectations at his/her performance
review or at any time when the performance is no longer meeting expectations.
A PIP is a formal type of corrective action that requires the manager to receive approval
from Human Resources before administering. Since it is a formal document, it is part of the
employees record with CoStar and it is presented to the employee for his/her signature to
acknowledge receipt of the document.
The PIP includes an Action Plan that outlines steps that the employee and manager are
expected to take to improve the employees areas of development. A Progress Summary or
other written feedback should be used to assess and track the employees performance
against the goals of the PIP. The timeframe for PIP completion will vary based on the
employee. While on a PIP, the employee is expected to be an active participant in the
process. The PIP may be amended, extended or abbreviated by the manager as warranted
by any component of the employees performance or behavior.
In the event that the employee is not able to meet the required activities and results of the
PIP within the designated timeframe, the employment relationship may be reevaluated, up
to and including termination.
5.4 Written Warning or Final Written Warning
Written Warning and Final Written Warning are formal types of corrective action that
require the manager to receive approval from Human Resources before administering the
action. Since it is a formal document, it is part of the employees record with CoStar and it is
presented to the employee for his/her signature to acknowledge receipt of the document.
Written Warnings are typically only used to address behavior problems; however, they may
be used if an employee previously successfully completed a PIP and later the manager saw
another decline in performance. Depending on the situation, the manager may first counsel
the employee to improve his/her behavior before moving to a more serious level of
corrective action like a Written Warning. There may be some behavior issues that warrant
moving directly to a Written Warning or Final Written Warning due to the severity of the
behavior.
In the event that the employee does not correct his/her behavior as outlined in the Written
Warning, the employment relationship may be reevaluated, up to and including
termination.
5.5 Termination of Employment
Termination of employment may be most appropriate when reasonable efforts have been
made to inform an employee of a problem and expected corrective action or when the
employees performance or behavior, at the managers discretion, warrants termination.
Prior to communicating any involuntary termination of employment the Vice President of
Human Resources or designee must be notified (see the Termination Policy for more
details).
6.0 Corrective Action Meetings:
Corrective action meetings should always be conducted privately with the employee and should be
completed within a timely manner in relation to the behavior infraction or decline in performance.
Any type of formal corrective action involves speaking directly with the employee followed by
some form of written communication. The tone of these meetings should be constructive and
maintain a positive working relationship between the manager and the employee. The employee
should have a clear understanding of the action to be taken and the reason for the action, as well
as what the employee needs to do to correct the performance or behavior issue. Human Resources
or a member of management may participate in any corrective action meeting.
7.0 Documentation:
CoStar requires documentation for all formal corrective action as defined in Section 5. Any formal
corrective action will become part of the employees record with CoStar. Written formal
documentation should be presented to the employee and the employee is asked to sign and retain
a copy. The employees signature does not necessarily indicate agreement, but it acknowledges
that the employee has been informed of the formal corrective action taken. Documents are
forwarded to Human Resources.
Although not required, CoStar encourages managers to document informal corrective actions. This
type of documentation will not be considered part of the employees record.
8.0 Employee Recourse:
Employees have the right to challenge any corrective action by consulting with Human Resources
or their next level manager.
Performance management and development are a joint responsibility of managers and employees.
Employees are responsible for participating in the process by evaluating their performance,
identifying their developmental needs and taking advantage of opportunities to upgrade their
skills. Managers are responsible for providing employees with timely and accurate information on
the achievement of job objectives and/or responsibilities as well as specific suggestions on how to
improve performance.
Employees must use accrued vacation and sick time while on unpaid FMLA leave. The substitution
of paid time for unpaid FMLA leave time does not extend the length of FMLA leaves and the paid
time will run concurrently with an employees FMLA entitlement.
Upon written request, the Company will allow employees to use accrued vacation and sick time to
supplement any applicable paid disability or Workers Compensation benefits. Receipt of disability
benefits or Workers Compensation benefits does not extend the maximum amount of leave time to
which an employee is eligible under the FMLA.
4.8 Employer Responsibilities
Covered employers must inform employees requesting leave whether they are eligible under the
FMLA. If they are, the notice must specify any additional information required as well as the
employees rights and responsibilities. If they are not eligible, the employer must provide a reason
for ineligibility.
Covered employers must inform employees if leave is designated as FMLA-protected and the
amount of leave counted against the employees leave entitlement. If the employer determines that
the leave is not FMLA-protected, the employer must notify the employee.
4.9 Unlawful Acts by Employers
FMLA makes it unlawful for the Company to:
Interfere with, restrain, or deny the exercise of any right provided under the FMLA;
Discharge or discriminate against any person for opposing any practice made unlawful by
the FMLA or for involvement in any proceeding under or relating to the FMLA.
Concerns regarding a possible violation with respect to either of these obligations should be
reported to the Companys Human Resources Department.
4.10 Enforcement
Employees may file a complaint with the U.S. Department of Labor or may bring a private lawsuit
against an employer.
FMLA does not affect any Federal or State law prohibiting discrimination, or supersede any State or
local law or collective bargaining agreement, which provides greater family or medical leave rights.
An employee who is in need of time off from work and who is not eligible for FMLA leave can request a
Personal Leave of Absence. The approval of a Personal Leave of Absence and the length of time that the
employee may be on leave are at the discretion of the employees manager in consultation with Human
Resources.
The leave request will be considered on the basis of business need, the reasons for the requested leave, and
the individual's performance and attendance records. If circumstances change and an employee is unable to
return as anticipated on their return date, they must contact their manager and Human Resources to
request approval for an extension of the personal leave. It is critical for the employee to maintain contact
with their manager while on leave and return to work as agreed. Employees will be required to provide
medical certification and periodic recertification supporting the need for leave.
Employees must provide their manager and Unum 30 days advance notice of the need to take FMLA leave
or a Personal Leave of Absence when the need is foreseeable. When 30 days notice is not possible, the
employee must provide their manager and Unum notice of the need for the leave as soon as practicable and
generally must occur within 1 or 2 business days.
Employees must provide Unum sufficient information for the Company to determine if the leave may
qualify for FMLA protection and the anticipated timing and duration of the leave. Sufficient information
may include that the employee is unable to perform job functions; the family member is unable to perform
daily activities, the need for hospitalization or continuing treatment by a health care provider, or
circumstances supporting the need for military family leave. Employees also must inform Unum if the
requested leave is for a reason for which FMLA leave was previously taken or certified. Employees will be
required to provide Unum medical certification and periodic recertification supporting the need for leave.
During the leave, an employee should periodically follow up with their manager to reaffirm the intention
and timing of their return to work. An employee must communicate with their manager and Unum if their
return to work date has changed.
Employees are required to enter paid time off or leave without pay in Replicon (the Companys timekeeping
system), along with FMLA in the comments section.
2.0 Eligibility:
All regular US employees of CoStar.
3.0 Policy:
Employees who are called into active military service or who enlist in the uniformed services are eligible to
receive an unpaid military leave of absence in accordance with applicable federal and state laws. To be
eligible for military leave, the employee must provide management with advance notice of their service
obligations, unless they are prevented from providing such notice due to military necessity or it is
otherwise impossible or unreasonable to provide such notice.
Employees required to attend yearly Reserves or National Guard duty can apply for an unpaid temporary
military leave of absence not to exceed the number of days allowed by law (including travel). Such
employees should give management as much advance notice of their need for military leave as possible so
that we can maintain proper coverage.
Employees whose absence does not exceed applicable statutory limitations will retain reemployment rights
and accrue seniority and benefits in accordance with applicable federal and state laws.
Holidays that fall on weekends will be observed on either the preceding Friday or the following
Monday. Employees that have scheduled vacation booked over a holiday will receive holiday
pay and will not be charged vacation time for that day.
3.2 Personal Days
Full-time employees hired between January 1st and June 30th receive 2 personal days upon
hire. Full-time employees hired between July 1 and December 31st receive 1 personal day upon
hire. Employees are granted 2 Personal days each January thereafter. Except as provided below
for California based employees, unused Personal Days are not carried over from one calendar
year to the next and accrued but unused personal leave balances are not paid out to employees
upon termination of employment.
California-based employees are eligible to carry over paid personal days from one calendar
year to the next but will not accrue any additional personal days after a balance of 32 hours has
been reached. Accrued but unused personal leave balances are paid out upon termination for
California-based employees only.
3.3 Sick Time
At the time of hire, full-time employees receive sick hours for their first calendar year of
employment based on their date of hire according to the chart below.
Hired
Jan - March
April - June
July - September
October - December
Sick Hours
Grant
40 hours
32 hours
24 hours
16 hours
Employees are granted an additional 40 sick hours each January 1st, up to a maximum balance
of 80 hours. To the extent any applicable state or local law requires accrual of additional sick
time, due to hours worked, beyond the sick hours grants set forth above, this policy will
incorporate those requirements such that in all cases, all employees will accrue at least 1 hour
of sick time for every 30 hours worked. For purposes of this policy, the calendar year is the
consecutive 12-month period beginning January 1st and ending on December 31st.
Sick hours are to be used for the following reasons:
1) Health reasons affecting the employee, the employees family member, or the employees
designated person (as defined under applicable law), such as:
Diagnosis, care, or treatment of a mental or physical illness, injury or other health
condition (including, but not limited to, pregnancy, childbirth, and post-partum
care);
Preventive medical care (such as a routine medical appointment);
Care for a family member when it has been determined by a lawful public health
authority or by a health care provider that the family members presence in the
community would jeopardize the health of others.
2) Absences such as the following, which are needed due to domestic or family violence,
sexual assault, harassment or stalking that affect the employee, the employees family
member, or the employees designated person (as defined under applicable law):
To obtain or attempt to obtain legal or law enforcement assistance or remedies
(such as a restraining order, or other injunctive relief, other civil or criminal
proceedings);
To help ensure the health, safety, or welfare;
To seek medical attention, care for, or recovery from related injuries;
To coordinate and obtain services and assistance from a shelter, program, rape crisis
center, or other similar organization;
To obtain appropriate psychological counseling; or
To relocate or take steps to secure an existing home to ensure the health and safety
from future domestic or family violence, sexual assault, harassment or stalking.
3) Closure of the employees place of business or exclusion of the employee from his or her
place of business, by order of a public official or pursuant to applicable law or rule, due to
public health reasons (e.g., to limit exposure to an infectious agent, biological toxin or
hazardous material), or when an employees childs school or place of care is closed by
order of a public official.
4) Bereavement for the death of a family member to the extent not covered by Bereavement
Leave in 3.8.
5) Any other reason provided for pursuant to applicable state or local law.
The smallest amount of sick time an employee can use is 30 minutes, and for uses beyond 30
minutes, employees can use sick time in 30 minute increments.
Employees will be notified of their available sick time on each itemized wage statement.
For purposes of this policy, family member includes a child (including biological, adopted, or
foster child, stepchild, legal ward, or a child to whom the employee stands in loco parentis, all
regardless of age or dependency status); spouse, registered domestic partner, or life partner
(all as defined by applicable state law); parent or parent-in-law (including biological, adoptive,
or foster parent; stepparent; legal guardian of an employee or the employees spouse or
registered domestic partner; or a person who stood in loco parentis when the employee was a
minor child); grandparent (including the spouse of a grandparent); grandchild; sibling
(including half siblings, step-siblings, foster siblings, and siblings related through adoption); or
any other individual who qualifies as a family member under applicable law.
Employees based in San Francisco, Oakland and Emeryville, CA who do not have a spouse or
registered domestic partner may designate, in writing and in advance, one person for whom
the employee may use sick time when providing aid or care for the person consistent with
policy as outlined above. Employees without a spouse or registered domestic partner have up
to 10 work days or 14 calendar days, whichever is greater, following the date on which their
first paid hour of sick time accrues to designate such person. Thereafter, employees will have
the opportunity to make such designation or change an existing designation on an annual basis,
commencing on January 1st each year and extending for a period of 10 work days or 14
calendar days, whichever is greater. HR will provide employees with a form for this purpose.
Employees out on sick time must give notice orally or in writing. If the need to use sick time is
foreseeable, employees must provide reasonable advance notification. In most cases,
reasonable generally means notifying your manager up to 1 week in advance of the
foreseeable absence. If the need to use sick time is unforeseeable, employees must provide
notice as soon as practicable. In most cases, as soon as practicable generally means notifying
your manager prior to the start of your work shift, if possible. In cases of accidents or sudden
illnesses, when employees may not able to provide such notice under the circumstances, notice
should be provided as soon as possible.
To the maximum extent permitted by applicable law, employees out on sick time for more than
three consecutive days may be asked to provide proof of their absence by a medical provider
or other documentation to verify their absence.
Sick time will be paid at the same rate as the employee earns from his or her employment at
the time the employee uses such time, but no less than the applicable minimum wage, unless
otherwise required by applicable law. Use of sick time is not considered hours worked for
purposes of calculating overtime.
Accrued sick time carries over from year to year, but is subject to the maximum balance of 80
hours. Once the maximum balance is reached, sick time will stop accruing until the next sick
time grant. Accrued but unused sick time is not paid out upon termination of employment.
To the extent any applicable paid sick time, leave or ordinance provides any greater rights
than set forth in this policy, such provisions are incorporated by reference for covered
employees.
3.4 Vacation
Full time employees are eligible for the following Vacation accrual schedule:
Completed
Years of
Service
0 - 2 years
2 years but
less than 5
years
5 years +
Vacation Accrual
12 days each year (96
hours), accrued at rate of
1.84 hours per week
15 days each year (120
hours), accrued at rate of
2.31 hours per week
20 days each year (160
hours), accrued at rate of
3.07 hours per week
Maximum Accrual
including rollover
hours from prior
year
144 hours
180 hours
240 hours
Part-time employees accrue vacation on a prorated basis based on the actual number of
regular hours worked.
Employees are able to accrue up to 5 days (40 hours) over the annual vacation accrual amount.
Once a maximum vacation accrual has been reached (see above chart, column 3), vacation will
be capped until the employee uses accrued vacation hours, allowing accruals to begin again.
Vacation requests should be submitted to and approved by the employee's manager through
Replicon in advance of the requested vacation dates so managers have enough time and
information to make appropriate decisions.
Vacation requests may be denied if the employee does not have the accrued time available or
due to workload, team coverage, department or business needs.
Full day vacation absences will always use 8 hours of vacation time for full-time employees and
the average hours worked per day from the previous month for part-time employees.
Any accrued but unused vacation time is paid upon termination of employment. Vacation time
is paid at the employees base rate of pay at the time of termination. It does not include
overtime or any special form of compensation such as incentives, commission or bonuses.
3.5 Wedding Leave
Full-time employees are eligible for three days paid leave when they get married, which may
be taken either within thirty days before or after the wedding. Renewal of vows and attending
someone elses wedding do not qualify for Wedding Leave.
3.6 Parental Leave
Full-time employees are eligible for ten days of paid parental leave. This leave can be taken
after the birth or adoption of a child and must be taken within sixty days of such birth or
adoption (or within ninety days if state disability benefits continue beyond the sixty day
period).
Parental leave runs concurrently with any Family and Medical Leave. Employees must request
the time off and seek approval from their manager and Human Resources.
3.7 Jury Duty
Full-time employees are eligible to receive regular salary or daily pay for jury duty. The
summons should be been given to the employees manager as soon as possible so that the
manager may accommodate the absence.
3.8 Bereavement Leave
Full-time employees are eligible for up to three days of paid leave in the unfortunate event of a
death in the family.
3.9 Voting
CoStar encourages employees to participate in their civic responsibilities. If an employees
schedule is such that they are unable to vote outside of their normal work hours, an employee
may be granted from one to four hours to vote, without a pay deduction.
Such absences should be unnecessary in most cases given the early opening and late closing
times for most voting stations.
3.10 Exempt employees & Leave Without Pay (LWOP)
If an exempt employee takes a full day off and does not have any accrued
Vacation/Sick/Personal hours to apply to the absence, then 8 hours of LWOP will be applied.
4.0 Responsibilities:
Employees are responsible for the following:
Using their paid time off for the appropriate reasons.
Managing their accrued time off balances.
We encourage employees to seek assistance before their substance abuse or alcohol misuse
interferes with the successful performance of their jobs, or jeopardizes the health and
safety of any CoStar employee, including them. Employees may seek assistance from the
Employee Assistance Program; the Company will also attempt to assist employees through
referrals to counseling, rehabilitation programs and other measures.
4.0 Consequences of Violating the Policy:
If a supervisor or manager has a reasonable suspicion that the employee is working in an
impaired condition or otherwise engaging in conduct that violates this Policy, the employee
will be asked about any observed behavior and offered an opportunity to give a reasonable
explanation. If the employee is unable to explain the behavior, he or she will be asked to leave
the workplace and may be tested. At least 2 members of management and the VP of Human
Resources shall substantiate and concur in the decision to test an employee who is reasonably
suspected of drug or alcohol use. Any employee who violates this policy will be subject to
corrective action, up to and including termination (the Corrective Action Policy).
Modified Operations: CoStars senior-most management for the local office may announce
modifications to operations and operating hours as a result of adverse conditions.
Employees will be responsible for their own transportation and getting to work when
Modified Operations are in effect.
Office Closures (partial/full day): If an office is closed for part of a work day due to
adverse conditions, the closure may be announced as Delayed Start or Early Close, or
both.
3.2 Timesheet Coding:
If Unscheduled Leave is in effect, and the employee does not report in to the office, they
should use either Vacation or Personal time off to account for the number of hours they did
not work (see the Paid Time Off Policy).
If the Office has a Delayed Start or Early Close or is Officially Closed for the full day,
then hourly employees will be paid but must code the time off using the Company Day
type in their Replicon timesheet with a comment describing the circumstance for applying
those hours.
Exempt employees do not need to code time off in their timesheets for official office
closures.
3.3 Notifying your Manager
If an employee does not report to work when the office is under an Unscheduled Leave
status, then the employee must notify his or her immediate manager via email, phone, text
or the way required by the manager no later than the employees regularly scheduled start
time and use paid leave (either Vacation or Personal) for the time they are unable to work
(see the Paid Time Off Policy).
3.4 Emergency Employees
Each employee who has been identified as an Emergency Employee should discuss his or
her responsibilities and make provisions to come to work even when the office is on
Unscheduled Leave or when there is an Office Closure (partial/full day) subject to personal
health, safety and department requirements.
Emergency employees may be authorized by senior department leadership to incur
reimbursable travel expenses as needed during Modified Operations.
Policy: Safety
Effective Date: 8/1/2015
1.0 Purpose:
CoStar has a long-standing philosophy of taking pride in its practices to ensure the safety, health
and well-being of all of its employees. This policy serves to outline the companys commitment to
this philosophy and to provide guidance to all employees on the safety standards the company
expects its employees to adhere to.
2.0 Eligibility:
All regular US employees, contractors, and temporaries of CoStar.
3.0 General Safety Rules:
CoStar employees perform a wide range of functions in various locations. Although some safety
rules apply only to specific positions, all employees are expected to comply with the rules in this
policy:
The facility where employees are assigned has emergency procedures and an evacuation
plan to follow in the event of fire or other disaster. Employees should follow emergency
procedures and evacuation plans per the guidelines in the building they occupy. Exits, fire
extinguishers, first aid kits and in some offices, defibrillators are located on each floor. All
employees are expected to familiarize themselves with the location of such equipment, as
well as the locations of building fire stairs.
3.2 On-the-Job Injuries and Illnesses
Any job-related injury or illness, regardless of severity, must be reported immediately to an
employees supervisor or HR for prompt and trained evaluation and medical attention as
necessary. The employees supervisor will complete an initial safety incident report and
forward it to HR.
3.3 Emergency Evacuation Plans and Re-Entry
In any emergency, employees should follow alarms or other alerts to evacuate the building
or area near the premises. Employees should always follow the basic evacuation
procedures and remember that personal safety is paramount and takes precedence.
Employees should do the following:
Check the work area for anything needing to be secured, and store it quickly.
Secure locks on all secured containers and cabinets.
Leave the work area, and report to the designated assembly area.
When possible, take your purse/wallet and building ID card with you.
The building property management or director of facilities will coordinate with fire, police
or other emergency preparedness personnel to determine when the building may be reentered. This information will then be passed through safety committee members.
4.0 Improper Health and Safety Practices:
All employees are expected to abide by safe work practices and adhere to general safety rules to
ensure their safety as well as the safety of co-workers.
Infractions of company health and safety practices will be dealt with in accordance with the
companys policies on corrective action and will be based on the following factors:
Some CoStar employees may spend a large amount of time driving for company business (either in
a privately owned vehicle or a company owned vehicle) and may also be subject to the Authorized
Driver Qualifications Policy. It is the drivers responsibility to operate the vehicle in a safe manner
and to drive defensively to prevent injuries and property damage. CoStar expects each driver to
drive in a safe and courteous manner pursuant to the following safety rules. The attitude you take
when behind the wheel is the single most important factor in driving safely.
All drivers and passengers operating or riding in a company vehicle must wear seat belts, even
if air bags are available.
Cell phone use should be kept to a minimum. Whenever possible, drivers should complete calls
while the vehicle is parked and/or use the phone in a hands free mode via a headset or
speaker. While driving, attention to the road and safety should always take precedence over
conducting business over the phone. Texting while driving is not acceptable.
Honor all posted traffic signs and obey all state and local laws.
Head lights should be used 2 hours before sunset and until 2 hours after sunrise, or during
inclement weather or at any time when a distance of 500 feet ahead of the vehicle cannot be
clearly seen.
Do not drive while under the influence of alcohol and/or drugs, which could impair driving
ability.
property, provided there is a reasonable basis or rational need for such search as
determined by CoStar. This includes lockers, vehicles, desks, cabinets, workstations,
packages, handbags, briefcases and other personal possessions or places of concealment, as
well as personal mail and email sent to CoStar, its employees or clients. Employees are
expected to cooperate in any search or inspection.
The fax, copier and telephone and mail systems, including email, are intended for business
use. As required for certain jobs and as approved by management, telephone conversations
may be monitored and voice mail messages may be retrieved in the process of monitoring
calls with customers and giving feedback to develop employees. Any private conversations
overheard during such monitoring, or private messages retrieved, that constitute threats
against other individuals can and will be used as the basis for termination for cause.
In some offices CoStar uses security cameras at various exits and entrances and in other
common areas on CoStar property for the safety of all employees. The Company may
monitor, record and store activity captured on the security cameras for a period of time
after the activity occurs.
The security of CoStars offices should be protected at all times. Visitors should be escorted
while in Company offices, should enter and leave through main doors, and should be given
access only to records and information they are authorized to receive.
3.4 Consequences of Violating this Policy
Appropriate corrective action (up to and including termination of employment) will be
taken against any individual found to have violated this policy. Any manager who receives a
complaint of or witnesses violence or a threat of violence against another employee and
fails to notify the Human Resources Department will also be subject to corrective action up
to and including termination.
3.5 Employee Responsibilities
CoStar specifically discourages individuals from engaging in any physical confrontation
with a violent or potentially violent individual. However, CoStar does encourage employees
to exercise reasonable judgment in identifying potentially dangerous situations and to
discuss concerns with their manager or Human Resources representative. Mental health
experts state that prior to engaging in acts of violence troubled individuals often exhibit
one (1) or more of the following behaviors or signs:
over-resentment, anger and hostility,
extreme agitation,
making ominous threats such as bad things will happen to a particular person, or a
catastrophic event will occur,
sudden and significant decline in work performance,
irresponsible, irrational, intimidating, aggressive or otherwise inappropriate
behavior,
reacting to questions with an antagonistic or overtly negative attitude,
discussing weapons and their use, and/or brandishing weapons in the workplace,
overreacting or reacting harshly to changes in Company policies and procedures,
personality conflicts with co-workers or a manager,
obsession or preoccupation with a co-worker or manager,
attempts to sabotage the work or equipment of a co-worker or a manager,
blaming others for mistakes and circumstances, or
demonstrating a propensity to behave and react irrationally.
Policy Statement
CoStar Group, Inc. (CoStar or the Company) complies with all applicable anti-corruption and antibribery laws in the jurisdictions in which it operates, including the Foreign Corrupt Practices Act in the U.S.
(FCPA), the Corruption of Foreign Public Officials Act and the Criminal Code in Canada, and the UK
Bribery Act (Anti-Corruption Laws). These laws prohibit corruption and bribery involving government
officials. The Company adheres to the following anti-corruption and anti-bribery policy (the Policy):
No Company employee or agent has authority to offer, agree, promise, make or facilitate the making of
payments or give anything of value to a government official in order to induce that official to make or
influence any government decision in a manner that will assist the Company in obtaining or retaining
business, directing business to any person or entity, or securing any improper advantage.
Every Company employee or agent is obligated to keep books, records, and accounts that accurately and fairly
reflect all transactions and disposition of Company assets.
All Company personnel are expected to conduct Company business legally and ethically. The use of Company
resources for any unlawful, improper, or unethical purpose is strictly prohibited.
The full CoStar UK Anti-Bribery Policy is available on CINDI. For business transacted in the UK, in the event
of any conflict, the UK Anti-Bribery Policy shall take precedence over this Policy.
Please review the Gifts and Favors section of the CoStar Employee Code of Business Conduct and Ethics for
guidance on giving and receiving gifts or favors in business dealings generally.
II.
Application
This Policy applies to all CoStar employees and agents. CoStar includes the parent company, CoStar Group,
Inc., and its affiliates and subsidiary companies. For the purposes of this Policy, CoStar employees and
agents include: (a) employees, officers and directors of CoStar; and (b) shareholders, contractors,
consultants or other third-parties when they are acting as CoStar agents or are working on behalf of CoStar.
Because the Anti-Corruption Laws do not always differentiate between the conduct of CoStar and that of a
third party acting on CoStars behalf, it is important that CoStar employees know their partners to ensure
that any third party, with or through whom CoStar does business, complies with the principles of this
Policy.
III.
Prohibited Payments
Under this Policy and the Anti-Corruption Laws, CoStars employees and agents are prohibited from
offering, promising, making, facilitating, or agreeing to the making of payments or offering or giving
anything of value to a government official in order to induce that person to make or influence any
government decision in a manner that will assist CoStar with obtaining or retaining business, directing
business to any person or entity, or securing any improper advantage.
For purposes of this policy:
a. A government official is an officer or employee of: (a) a government; (b) any department,
agency or instrumentality of a government; (c) a government-owned or governmentcontrolled state enterprise; (d) a public international organization, such as the United Nations,
World Bank, or International Monetary Fund; or (e) a political party, party official or candidate
for political office. Government officials include those in all levels and all ranks of government,
whether federal, state, provincial, municipal, or some other level. Some examples of
government officials include employees of non U.S. state-owned oil companies, members of the
non-U.S. military, employees of the World Bank or IMF, and employees of non-U.S. state-owned
universities. If you are in doubt whether or not a person is a government official, please contact
a member of the Legal Department for clarification.
b. Government means an agency, instrumentality, subdivision or other body of any national,
state or local government, including hospitals or other health facilities which are owned or
operated by a government, and including regulatory agencies or government-controlled
businesses, corporations, companies or societies.
c. A payment covers not just the payment of money, but also offering, promising, authorizing, or
agreeing with someone else to make such payment. Even if the improper payment is not
consummated, the mere fact that such payment was offered or agreed to violates this Policy.
d. Anything of value includes (but is not limited to) cash and cash equivalents, gifts,
entertainment, travel expenses, accommodations and anything else of tangible or intangible
value (see excluded permitted payments below).
e. Obtaining or retaining business or securing any improper advantage does not necessarily
mean obtaining the business of a government or government instrumentality. It could include,
for example, securing preferential treatment under local regulations.
IV. Limited Permissible Payments
Under some Anti-Corruption Laws, certain minor payments to low-level government officials for the
purpose of expediting or securing routine, non-discretionary government action, such as securing a
business permit, customs invoice or processing a visa, may be permitted. In Canada, it is expected that the
exemption allowing such payments will be removed in the near future. Under the UK Bribery Act and the
laws of most other countries, these payments are prohibited. Accordingly, these payments are prohibited
under this Policy.
There are, however, certain limited circumstances where payment or giving something of value to a
government official may be permitted, provided that, prior written approval is obtained, as set forth herein.
a. In exigent circumstances, such as where an employee is in imminent physical danger or
requires urgent medical attention, payment may be made. If such a circumstance arises, the
employee must immediately when practicable contact his or her supervisor and the General
Counsel and must contemporaneously document the occurrence.
b. Certain types of hospitality offered to government officials may be permitted if the expenditure
is directly related to Company business, reasonable in amount, offered in good faith only in
connection with the promotion, demonstration or explanation of Company products or services
or the execution or performance of a contract with a government or agency, and is lawful under
local law. No such expenditure shall be authorized without prior written approval from
Executive Vice President of Sales in consultation with the General Counsel. In the event the
Company is responsible for the airfare or lodging expenses of a government official, itineraries
and any other supporting documentation shall be maintained. No hospitality or entertainment
may be offered or provided in exchange for any favor or benefit to the Company.
V.
Recordkeeping Requirements
The Company is required to keep books, records, and accounts in reasonable detail that accurately and
fairly show all transactions and disposition of Company assets. The Company maintains a system of
internal accounting and operating controls sufficient to provide reasonable assurances that it: executes
transactions and permits access to Company assets only in accordance with proper authorizations;
records transactions as necessary to prepare financial statements and maintain accountability for
assets; and compares recorded accounting treatment for assets with the existing assets at reasonable
intervals and takes appropriate action with respect to any differences.
CoStar employees and agents must completely and accurately document all transactions and the
purpose of payments made on behalf of the Company. Examples of activities that are strictly prohibited
include:
a. establishing or maintaining accounts which do not appear in any of the books and records
that CoStar is required to keep in accordance with applicable accounting and auditing
standards;
b. making transactions that are not recorded in those books and records or that are
inadequately identified in them;
c. recording non-existent expenditures in those books and records;
d. entering liabilities with incorrect identification of their object in those books and records;
e. using false documents; or
f.
Additional special ethical obligations for CoStars employees in its Finance and Accounting Departments
pertaining to financial reporting are set forth in CoStars Employee Code of Business Conduct and Ethics.
VI.
If you believe that actions have taken place, may be taking place or may be about to take place that violate
or would violate this Policy, you must bring the matter to the attention of CoStar. Failure to report
knowledge of violation of this Policy may result in disciplinary action against those who fail to report.
You may report any suspected violation of this Policy to CoStars Human Resources department through
your HR Business Partner, or to CoStars General Counsel. Alternatively, you may report a suspected
violation through the Companys confidential compliance hotline in the U.S. or Canada at 1-800-750-4972
or in the U.K. by dialing the AT&T Direct Access Code (currently 0800-89-0011), followed by 800-7504972.
All reports under this Policy are guaranteed confidential treatment. While we would prefer you identify
yourself to facilitate our investigation of any report, you may choose to remain anonymous. We will use our
best efforts to protect the identity of any person who reports a suspected violation. We will also use
reasonable efforts to protect the identity of the person about or against whom an allegation is brought,
unless and until it is determined that a violation has occurred.
Any use of these reporting procedures in bad faith or in a false or frivolous manner will be considered a
violation of the Employee Code of Business Conduct and Ethics and may be subject to disciplinary action, up
to and including termination.
VII.
Retaliation in any form against an individual who reports a suspected violation in good faith, even if the
report is mistaken, or who assists in the investigation of a reported violation, is prohibited. In accordance
with the U.K. Public Interest Disclosure Act 1998 (PIDA) (the U.K. whistle blowing regime), employees in
the U.K. who report known or suspected illegal or unethical behavior will not be subjected to any form of
retaliation if the employee reasonably believes that the disclosure is in the public interest. Acts of
retaliation should be reported immediately. Any employee who engages in retaliation is subject to
discipline, up to and including termination, and in appropriate cases, civil and/or criminal liability.
Any questions concerning this Policy or the Anti-Corruption Laws may be addressed to the
General Counsel.
may not purchase or sell the Company's securities or securities of another entity (or options for
the Companys securities or securities of another company) if the employee is aware of
information about the Company or the other entity that has not been made public and that may be
considered material to an investor in making a decision about whether to buy or sell the
securities;
may not trade the Company's securities during any period in which the Compliance Officer has
announced that the trading window has closed (typically, the period beginning at the end of a
calendar quarter and ending on the second business day after the Company issues its earnings
press release for that quarter).
In addition, (i) all Company directors, (ii) all Company officers, (iii) all Company employees in the
Finance, Accounting, Legal and Investor Relations Departments, and (iv) from time to time certain other
employees of the Company must always obtain the approval of the Compliance Officer of the Company
prior to participating in any transaction relating to the Company's securities. All other Company
employees are encouraged to trade the Company's securities only during the ten-day trading period
beginning on the second business day after the Company issues its earnings press release or files its
annual or quarterly reports with the Securities & Exchange Commission (the "SEC").
If you have any questions about this policy statement or your responsibilities under it, seek
clarification before you act from Jonathan Coleman, the Company's Compliance Officer. Do not
try to resolve uncertainties on your own.
A.
"Inside" information is material information about the Company or its business plans, such as a plan to
invest in another company, that is not available to the public. Information generally becomes available
to the public after it has been disclosed by the Company or third parties in a press release or other public
statement, including any filing with the SEC. To allow for the orderly dissemination of information,
information is not considered generally available to the public for purposes of this policy statement until
the second business day after it has been first publicly released.
B.
Information generally is considered "material" if its disclosure to the public would be reasonably likely
to affect (i) investors' decisions to buy or sell the securities of the company in question or (ii) the market
price of the securities. Some examples of material information include the following: (a) a merger or
acquisition involving the Company; (b) information regarding the Company's revenues or earnings; (c)
pending regulatory action; (d) major litigation; (e) the public or private sale of additional securities of
the Company; (f) a tender offer by the Company for another company's securities or for the Company's
securities by a third party; (g) senior management changes; or (h) the gain or loss of a significant
customer to the Company's business. Obviously what is material information cannot be described with
precision, since there are many potentially gray areas and varying circumstances. Both good news and
bad news may be material. The determination of whether information was material is almost always
made after the fact when the effect on the market can be quantified. If you are unsure whether
information of which you are aware is material or nonpublic, you should consult with the
Company's Compliance Officer.
C.
All employees have a duty to keep confidential information they learn because of their employment.
The federal securities laws strictly prohibit any person who obtains material inside information and has a
duty not to disclose it and all Company employees have such a duty from using such information in
connection with the purchase and sale of securities. It does not matter how that information has been
obtained, whether in the course of employment, or from other employees or persons working for the
Company. Congress enacted this prohibition because the integrity of the securities markets would be
seriously undermined if the "deck were stacked" against investors not privy to such information. Your
failure to maintain the confidentiality of material nonpublic information about the Company could
greatly harm the Company's ability to conduct business. In addition, you could be exposed to significant
penalties and legal action, including criminal liability.
During your employment you may also learn information about other companies that is material and
non-public with regard to the securities of that other company. For example, you may learn that CoStar
is about to enter into a significant transaction with that other company. That information is also material
and non-public and you may not trade in the securities (or options) of that other company before the
information is released to the public.
D.
Unless and until the material information relating to the Company or its business is disseminated to the
general public, it must be kept in strict confidence. That means such information should be discussed
only with persons, generally within the Company or its lawyers, who have a "need to know" and should
be confined to as small a group as possible. When communicating such information to persons with a
"need to know," the recipients of the information should be clearly informed that the information is
confidential and should be given instructions about further dissemination of the information. The utmost
care and circumspection must be exercised at all times. Therefore, conversations in public places, such
as elevators, restaurants and airplanes, should be limited to matters that do not involve information of a
sensitive or confidential nature. You should keep in mind that calls made to or from cellular, digital
mobile, and cordless telephones can be intercepted. Thus, conversations regarding confidential matters
should be avoided in calls involving cellular, digital mobile, and cordless phones. You should also take
care to assure that others do not have access to data stored on your laptop, or other electronic media; that
those devices are secured; and that any e-mail communications containing confidential material
information are secure. You should take the same precautions with hard copy documents.
To assure that Company confidences are protected to the maximum extent possible, no individuals other
than those specifically authorized in accordance with the Companys Investor Communications Policy
may release material information to the public or respond to inquiries from the media, analysts,
shareholders or others outside the Company.
E.
In light of the Company's responsibilities under the federal securities laws, the Company has adopted the
following policies regarding your trading in securities:
1.
No director, officer or employee of the Company may buy or sell securities of the
Company or any other publicly traded company (or options for either of them) while in
possession of material nonpublic information regarding the Company or such other
company, except as set forth below. Neither you nor any person affiliated with you which
generally includes family members (as defined below) and business entities in which you are
a director, officer or large stockholder may buy or sell securities or engage in any other
action to take advantage of, or pass on to others, nonpublic material information. This
prohibition extends not only to transactions involving Company securities but also
transactions involving securities of other entities with which the Company has a relationship.
2.
No director or officer of the Company, nor any employee of the Company in the Finance,
Accounting, Legal and Investor Relations departments of the Company nor any other
employee designated by the Companys Compliance Officer may buy or sell securities of
the Company (or options for Company securities) without prior consultation with the
Company's Compliance Officer, except as set forth below. As a means of enforcing the
policies specified above, all directors and officers of the Company and employees of the
Company in the Finance, Accounting, Legal and Investor Relations departments, and all
other people designated by the Companys Compliance Officer are to refrain from buying or
selling Company securities (or options) without prior consultation with the Company's
Compliance Officer. The obligation to consult exists whether or not the director, officer or
employee thinks he or she is in possession of nonpublic material information. Because
enforcement authorities will assume that a director, officer or one of these employees was in
possession of any material inside information, and the difficulty of proving otherwise, these
persons should not trade whenever the Company is aware of material inside information,
except as set forth below. This prior consultation requirement applies to any person affiliated
with the director, officer or employee, which generally includes family members (as defined
below) and business entities in which such director, officer or employee is a director, officer
or large stockholder. This prohibition may also be imposed on other employees of the
Company while they are working on particularly sensitive matters.
3.
No director, officer, or employee may trade the Company's securities during any period in
which the Compliance Officer has announced that the trading window is closed, except as
set forth below. From time to time, the Compliance Officer will announce that the trading
window is closed and that no director, officer, or employee should engage in any transaction
involving the Company's securities, except as set forth below. Typically, the trading window
will close around the end of each calendar quarter and will remain closed until the second
business day after the Company issues the earnings press release. The Compliance Officer
may close the trading window under other circumstances as well. If the Compliance Officer
has announced that the trading window is closed, you should not trade the Company's
securities, except as set forth below, until the Compliance Officer announces the reopening of
the trading window.
4.
Employees are encouraged generally to plan to trade the Company's securities only during
the 10-day trading period beginning on the second business day following the release of
the quarterly earnings or the filing of the Company's annual or quarterly report with the
SEC. Employees of the Company other than directors, officers and employees in the
Finance, Accounting, Legal and Investor Relations departments are generally not subject to
any pre-clearance requirements (aside from the prohibition on trading when the trading
window is closed). However, it is recommended that employees limit their trading to the
period that begins the second business day after the release of quarterly earnings or after
quarterly or annual results are filed with the SEC (or other special filings are made) and
ending 10 trading days thereafter. During these periods, you can be reasonably sure that the
Company has announced all material information. However, there is no guarantee that all
information has been announced, as material developments often arise quite rapidly in our
business. Therefore, if you think that you are aware of material undisclosed information, you
should refrain from trading even during this period.
5.
No director, officer or employee of the Company may enroll in, make changes under,
withdraw from participation in or sell Company securities purchased under the Companys
Employee Stock Purchase Plan (Plan) when in possession of material nonpublic
information or during any period in which the Compliance Officer has announced that the
trading window is closed. In furtherance of the restrictions outlined in Section E.1. above, if
you are in possession of any material nonpublic information, at any time, you are prohibited
from enrolling in, making increases or decreases to your payroll deductions under,
withdrawing from participation in, or selling Company securities acquired under the Plan. In
addition, if the Compliance Officer has announced that the trading window is closed, you will
not be able to enroll in, make increases or decreases to your payroll deductions under,
withdraw from participation in, or sell Company securities acquired under the Plan until the
trading window has reopened. Notwithstanding the foregoing, participants shall remain
subject to automatic withdrawal from participation in the Plan in the event of the participants
death or other termination of employment in accordance with the terms of the Plan.
6.
Directors, officers and other employees of the Company may not communicate material
nonpublic information to other persons prior to its public disclosure and dissemination.
Persons at the Company who come into possession of material inside information must not
communicate that information to other persons prior to its public disclosure and
dissemination or recommend to anyone the purchase or sale of any Company securities when
aware of such information. There is, therefore, a need to exercise care when speaking with
other Company personnel who do not have a "need to know" and when communicating with
family, friends, and other persons not associated with the Company. To avoid even the
appearance of impropriety, it is wise to refrain from discussing the Company's business or
prospects or making recommendations about buying or selling the securities of the Company
or other entities with whom the Company has a relationship.
7.
Directors, officers, and other employees of the Company should not engage in speculative
or short-term financial activities involving the Company's securities or derivatives based
on the Company's securities without the Compliance Officers prior written consent. In
particular, persons at the Company should not trade options on the Company's securities or
make short sales on the Company's securities without the Companys Compliance Officers
prior written consent. (This prohibition does not, of course, prevent employees from
participating in the Company's Stock Incentive Plan, including exercising stock options
awarded under that Plan.)
For purposes of this policy statement, the term "family member" includes any child, stepchild,
grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law,
daughter-in-law, brother-in-law, or sister-in-law, including adoptive relationships. Directors, officers,
and employees are expected to be responsible for compliance with this policy by their family members.
Further, this policys trading restrictions generally do not apply to the exercise of a stock option. The
trading restrictions do apply, however, to any sale of the underlying stock or to a cashless exercise of the
option through a broker, which entails selling a portion of the underlying stock to cover the costs of
exercise.
F.
Officers and directors and other employees of the Company designated by the Compliance Offer are
permitted to establish trading plans pursuant to Rule 10b5-1 under the Securities Act. The trading plan
must be established at a time when such person has no material, nonpublic information regarding the
Company or its securities and at a time when the CoStar trading window is not closed. In addition, the
guidelines established by the Compliance Officer regarding such trading plan must be complied with. In
the event that a trading plan is established that meets the forgoing requirements, an order with respect to
the Companys securities under the trading plan may be executed, even at a time that the trading window
is closed and even without the prior consultation with the Companys Compliance Officer.
G.
The Company from time to time engages in transactions with lenders, investors and other companies
whose securities are publicly traded. Either the fact of such a transaction, or information regarding the
other company learned in the course of the transaction, may constitute material, nonpublic information
regarding the other company. The policy of the Company prohibits all Company employees from
engaging in transaction in the securities of other companies while in possession of material, nonpublic
information regarding the other company.
It is not always practical to disclose to all employees the other companies with whom the Company is
engaged in transactions that might result in some employees of the Company learning material,
nonpublic information regarding the other company. However, any employee who knows that the
Company is engaged in discussions regarding a transaction with another company should not trade in
securities of that company without checking with the Compliance Officer of the Company and must
refrain from trading if he or she indicates that the Company has material, nonpublic information
regarding the other company.
H.
Anyone who becomes aware of any improper use or disclosure of material inside information or any
other violation of this policy statement has a duty to immediately report the occurrence of the violation
and the surrounding facts to the Compliance Officer . Regardless of whether the violation was
intentional or inadvertent, it is important that the Compliance Officer be informed as soon as possible so
that the Company can, if appropriate, attempt to mitigate any potential harm.
Officers or directors may be held responsible for the improper use or disclosure of material inside
information or other violations of this policy statement by their subordinates, if the officer or director
knew or recklessly disregarded the fact that the subordinate was likely to engage in such actions and the
officer or director failed to take steps to prevent the abuse. Penalties can be even more severe than if the
officer or director engaged in the insider trading himself or herself. This means that officers and
directors must carefully supervise all subordinates who come into possession of inside information and
notify the Compliance Officer if the officer or director believes that a subordinate is violating this policy
statement.
I.
The penalties for violating insider trading prohibitions are severe and include:
(a)
(b)
termination of employment;
(c)
liability for up to three times the profit gained or loss avoided from insider trading
transactions by the person trading and for people who tip;
(d)
fines of up to $100,000 per violation by natural persons and from $50,000 to $500,000 by
others (and up to $1,000,000 for "controlling persons" who permit subordinates to violate
insider trading prohibitions);
(e)
(f)
the ban of individuals from serving as officers or directors of public companies for a
period of up to five years; and/or
(g)
private action by persons who trade contemporaneously with or on the other side of a
transaction from persons who trade on inside information.
Given the extremely serious nature of any violation of the insider trading provisions, the Company
wishes to make clear that any person found to have committed such a violation will be subject to
dismissal and to possible claims for any damages sustained by the Company including the cost of
dealing with any government investigation of an employees conduct -- as a result of the person's illegal
activities.
J.
Certification
You must sign, date and return the attached Certification stating that you received this Policy Statement
and that you agree to comply with it. Please note that you are bound by the Policy Statement whether or
not you sign the Certification.
CERTIFICATION
The undersigned hereby certifies that he or she:
a.
has read and understands the Policy Statement on Corporate Information including Inside
Information and Securities Insider Trading (the "Policy Statement"), a copy of which was distributed
with this Certification; and
b.
will comply with the policies and procedures set forth in the Policy Statement.
Signature:_____________________________
Name:________________________________
(Please Print)
Department or Title:_____________________
Date:_________________________________
Social Security Number:__________________
__________________________
Name and Title (Please Print)
__________________________
Department
Note: Explanations of any provision of the Policy and advice as to whether any specific set of circumstances
should be reported may be obtained from the Compliance Officer (General Counsel) or the Vice President of
Human Resources at CoStar Group, Inc., 1331 L Street, NW, Washington, DC 20005. The Compliance
Officer and the Vice President of Human Resources may also be reached by telephone at (202) 346-6500 or
Forms 10-K, 10-Q and 8-K, and by other means permitted by the SEC. The Companys legal
department should be consulted prior to any disclosure of material, non-public information.
3.
Non-Disclosure of Material, Non-Public Information. Material news, which has
not otherwise been disclosed through one of the means set forth in Section 2, should not be
disclosed by any officer, director or employee of CoStar unless a confidentiality agreement
exists. Specifically, material, non-public information should not be disclosed in industry or
investor forums to which access may be limited. These forums include, but are not limited to,
investor and industry conferences, trade shows and one-on-one meetings with third parties,
including investors. Such limited disclosure can create an unfair advantage for certain
stockholders. For purposes of these discussions, the key litmus test is that material information
must be disseminated broadly through one of the means set forth in Section 2 above before it is
discussed with individual investors, analysts, or at industry conferences.
In any circumstance in which any officer, director or employee is considering disclosing
potentially material, non-public information, the officer, director or employee must check with
CoStars General Counsel, the Chief Financial Officer or the Senior Director of Investor
Relations before such information is disclosed to determine whether the information has
already been publicly disclosed and whether the information is material.
In any circumstance in which potentially material information has been disclosed
other than through a means set forth in Section 2, the General Counsel must be notified
immediately. In the event of, for example, an inadvertent disclosure or an unauthorized
leak, the Company will assess promptly whether a public disclosure is required.
4.
Disclosure of Information to Customers. When disclosing information about the
Company to customers, material, non-public information should not be disclosed, unless a
confidentiality agreement exists with the customer. If you are unsure whether information has
been publicly disclosed or whether information is material, please contact one of the General
Counsel, the Chief Financial Officer or the Senior Director of Investor Relations. In addition, when
preparing information about the Company to disclose to customers, please contact the Companys
Marketing department to obtain the most up-to-date statistics regarding the Company.
5.
Quarterly Analyst Conference Calls. Analyst conference calls provide CoStar a
forum in which the Companys spokespersons can provide a perspective on the results of the
preceding quarter and the projections for future quarters. As a matter of practice, CoStar broadly
disseminates information to the public, including securities analysts and investors about
upcoming quarterly analyst calls. Information about upcoming analyst conference calls is
referenced on the Companys website and in the Companys quarterly earnings announcements.
All investors and financial reporters are welcome to monitor quarterly analyst conference calls. A
replay of the earnings conference call will typically be available for a period of time following the
call.
6.
Quiet Period. As a matter of policy, CoStar observes a quiet period from the end
of each quarter until the date of the earnings press release disclosing that quarters results or until
the date of another public disclosure by the Company relating to such earnings. Over this time
period, the Companys investor relations spokespersons will offer no comment on earnings or
projections for such fiscal quarter or future quarters in contacts with securities analysts and
investors. While communications between CoStar spokespersons and market participants may
continue over this time period, the purpose of the quiet period is to restrict contacts regarding
earnings at a particularly sensitive time.
7.
CoStar Investor Relations Web Site. CoStar utilizes its corporate web site as a
medium to communicate with all investors and other market participants. Any change in the
content of the investor relations component of CoStars web site must be authorized by the Senior
Director of Investor Relations or the General Counsel. The Companys web site may reference
information regarding analyst earnings expectations or the identities of analysts who cover the
Company. This information is provided for informational purposes only; CoStar does not endorse
any particular analyst or any analysts predictions.
8.
Social Media or Web-based Communications. Among other things, the Internet
affords people, including investors, the opportunity to discuss individual companies in various
social media formats, including social networking sites, micro-blogging sites, blogs and bulletin
boards or chat rooms that are transparent to other users. Some of these discussions may relate
to CoStar. No CoStar employee, officer or director may use these forums to communicate any
CoStar information without express, advance approval from a member of either the Investor
Communications team or the Media Communications team (depending on the content). If an
employee engages in social media, he/she must be aware of and comply with this Policy, CoStars
Employee Code of Conduct and the CoStar Social Media Policy.
9.
Marketplace Rumors. If CoStar is not the source of a marketplace rumor, it is the
Companys policy to respond to market rumors with a simple statement that the Company does
not comment on rumors or market activity in CoStar stock.
10.
Analyst Reports. It is the Company policy not to comment on drafts of reports by
the Companys analysts; provided, however, that a member of the Investor Communications team
may from time to time correct errors in historical factual information included in such reports
and/or comment on publicly disclosed information included in a report.
11.
Duty to Update. From time to time, the Company may make forward looking
statements regarding the Companys operations or financial expectations. These statements are
made as of the date of their release, and the Company disclaims a duty to update such statements.
12.
Safe Harbor. CoStar generally will take steps to avail itself of a statutory safe
harbor that shields a company from liability when financial results differ from predictions made
by the Company. Specifically, at the outset of analyst conference calls and investor conferences,
CoStars spokesperson will indicate that predictive statements will be made over the course of the
presentation and a description of risk factors that could cause actual results to differ can be found
in CoStars SEC filings. In addition, CoStar may include safe harbor language in its press releases,
its SEC filings and on its web site.
*
*
*
This policy statement serves only as a summary of the Companys current practices and
may be changed at any time in the Companys sole discretion. Please refer to the Legal
Department home page on CINDI for the most recent version of this policy statement. No summary
can address every situation that arises in the day-to-day exchanges with market participants. Any
questions regarding the application of this policy should be referred to CoStars General Counsel at
202-346-6500.
Revised April 2014
Google Drive, Mediafire, etc. Proprietary Information should not be transmitted to or from personal e-mail
accounts.
5. Storage of Company Proprietary Information. CoStar employees should not leave CoStar
Proprietary Information unattended on their desks or in unlocked file cabinets. Please remember to keep
such Proprietary Information in a safe, secure place.
6. Destruction of Documents Containing Proprietary Information. When discarding
Proprietary Information, please evaluate the nature of the document and whether it would be prudent to
place the information in a shredder, instead of a regular garbage can. If information is highly confidential, it
should always be shredded as opposed to left in a regular garbage can.
7. Visitors and Building Security. The security of CoStar's offices should be protected at all times.
Visitors should be escorted while passing through our offices; they should enter and leave through main
doors; and they should be given access only to records and information they are authorized to receive.
8. Use of Confidentiality Agreements. Whenever there is a need to share CoStar Proprietary
Information with non-employees, including contractors, suppliers, customers, and potential business
partners, CoStar's Legal Department should be contacted to determine whether an appropriate
Confidentiality Agreement is in place or whether one needs to be drafted with that non-employee.
9. Duty of Confidentiality. As an employee of CoStar, you have signed Terms and Conditions of
Employment with CoStar that set forth, among other things, your duty to keep CoStar Proprietary
Information secret and confidential and not to disclose, use or reproduce any of such information, except in
limited circumstances. Please remember that these confidentiality provisions remain in effect both during
and after your employment with CoStar. Upon the request of CoStar and, in any event, upon the
termination of your employment, you must return to CoStar all materials involving any CoStar Proprietary
Information as well as all other documents or media pertaining to the business of CoStar or your specific
duties for CoStar, including all copies of such materials.
Thank you for your assistance in following these guidelines.
CoStar understands that social media can be a fun and rewarding way to share your life and
opinions with family, friends and co-workers around the world. However, use of social media also
presents certain risks and carries with it certain responsibilities. This policy has been created to
assist you in making responsible and appropriate decisions about the use of your social media
accounts.
2.0 Eligibility:
The same principles and guidelines found in all CoStar policies apply to your activities online.
Ultimately, you are solely responsible for what you post online. Before creating online content,
consider some of the risks and rewards that are involved. Any online conduct or representation
that adversely affects your job performance, the performance of fellow associates, or otherwise
adversely affects members, customers, people who work on behalf of CoStar or CoStars legitimate
business interests may result in corrective action up to and including termination.
3.1 What Is Social Media - Social media includes all means of communicating or posting
information or content of any sort on the Internet, including to your own or someone
elses web log or blog, journal or diary, personal web site, social networking or affinity
web site, web bulletin board or a chat room, whether or not associated or affiliated with
CoStar, as well as any other form of electronic communication.
3.2 Know and Follow the Rules The content you post on any social media must be
consistent with the guidelines laid out in CoStars Employee Code of Business Conduct
and Ethics, Anti-Corruption Compliance, Non-Harassment, Corporate Information,
Including Inside Information and Securities Insider Trading (the Insider Trading
Policy), Communications, and the Company Equipment policies.
3.3 Be Respectful Always be fair and courteous to customers, fellow employees, and
others who work on behalf of CoStar. Avoid posting material that could be viewed as
malicious, obscene, threatening, or intimidating, that disparages customers, members,
or employees and/or material that might constitute harassment or bullying. Examples
of such conduct might include offensive posts meant to intentionally harm someones
reputation or posts that could contribute to a hostile work environment on the basis of
race, sex, disability, religion, or any other status protected by law or Company policy.
3.4 Be Honest and Accurate Ensure that you are always honest and accurate when
posting information or news, and if you make a mistake, correct it quickly. Remember
that the internet archives almost everything; therefore, even deleted postings can be
searched. Never post information or rumors that you know to be false about CoStar or
its subsidiaries or their products and services, fellow employees, customers, or people
working on behalf of CoStar, its subsidiaries or its competitors.
3.5 Post only Appropriate and Respectful Content
3.5.1 Maintain the confidentiality of CoStars trade secrets and private or
confidential information. Trade secrets may include information regarding
the development of systems, processes, products or services, know-how, and
technology. Do not post internal reports, policies, procedures or other
internal business-related confidential communications.
3.5.2 Respect financial disclosure laws. It is illegal to communicate or give a tip
on inside information to others so that they may buy or sell stocks or
securities. Such online conduct may also violate the Companys Insider
Trading Policy.
3.5.3 Do not create a link from your blog, website, or other social networking site
to a CoStar website without identifying yourself as a CoStar employee.
3.5.4 Express only your personal opinions. Never represent yourself as a
spokesperson for CoStar. If CoStar is a subject of the content you are creating,
be clear and open about the fact that you are an employee and make it clear
that your views do not represent those of CoStar or fellow employees. If you
do publish a blog or post online related to the work you do or subjects
associated with CoStar, make it clear that you are not speaking on behalf of
CoStar. It is best to include a disclaimer such as The postings on this site are
my own and do not necessarily reflect the views of CoStar.
3.6 Using Social Media at Work Use social media at work only if it is work-related and
authorized by your manager or consistent with the Company Equipment Policy.
Employee e-mail addresses should only be used for work purposes and should not be
utilized to register on social networks, blogs, or other online tools for personal use.
4.0 Media contacts
Only individuals designated to speak on behalf of CoStar may speak with the media in accordance
with the Companys Communications Policy. All media inquiries should be directed through
CoStars Marketing Department.
Electronic Resources are primarily for business use, employees may be required to inform
management of any private access codes or passwords, upon request.
3.3 Safeguarding of CoStar Electronic Resources
Employees must use Company-provided LAN hardware and software to access the Internet
for business purposes, in accordance with the settings preloaded on Company-provided
hardware. In order to eliminate concerns about virus protection and proprietary data
residing on non-CoStar property, only corporate assets may be connected to the CoStar
network. Personal computers and devices may be connected via the CoStar Guest wireless
network. Employees are prohibited from using third party dial-up connections or
broadband connections for computer assets located in CoStar offices, unless approved by
an IT Director or the Companys Chief Technology Officer.
Employees who are provided portable devices, such as laptops, mobile phones and tablets,
must keep these devices in their possession at all times, unless they have been deposited in
a secure location. When traveling by air with a CoStar-provided portable device containing
sensitive information, the device must be carried-on and cannot be checked with luggage.
3.4 Content
You may not use any CoStar Electronic Resource to send, display or store any material, in
graphic, audio or language format that violates any Company policy. You may not use any
CoStar Electronic Resource to send a chain letter or forward security-related messages not
formally originating from the Company. Content must not be offensive, obscene, derogatory
or disparaging based on an individuals sex, race, color, religion, age, national origin, marital
status, ancestry, sexual orientation, veteran status, disability, pregnancy or citizenship
status.
Users must apply the same standards with respect to the content, quality, and tone of
information sent or made available electronically that they apply to materials sent or made
available by any other means of communication. Additionally, while the Company cannot
insure against the receipt of inappropriate incoming messages or files through its
electronic and telephonic communications systems, users are expected to delete any such
messages or files and are prohibited from re-transmitting any inappropriate materials
received.
3.5 Internet Cafes for Personal Use
CoStar-provided Internet cafes are available at most CoStar research offices. These
computers are not connected to the CoStar network and can be used for accessing personal
e-mail accounts or personal web browsing on approved breaks and outside of work hours.
4.0 Violations:
4.1 Consequences of Violating this Policy
2.0 Scope:
All CoStar employees with eligible business related expenses or approved business travel.
3.0 Policy:
3.1 Authorization and responsibility
Staff travel must be authorized by employees supervisor. Travelers should verify that planned travel is
eligible for reimbursement before making travel arrangements. An individual may not approve their
own travel or reimbursement. Designated approval authorities will review expense reports and either
approve or deny reimbursement if there is reason to believe that expenses are inappropriate,
extravagant, or beyond designated dollar limit.
Expense reports submitted and approved with all necessary documentation by COB on Wednesdays of
the second week of a pay period will normally be reimbursed on the next pay date.
Refer to the Payroll Schedule with Expense Report deadlines. Reports submitted more than 90 days
after the expense is incurred are routed to higher level management approval.
3.4 Receipts
All line items in your expense report require a receipt (excluding tolls, tips, mileage). The receipt should
be scanned and saved electronically, so it can be submitted online. Credit card receipts only showing
amount, tip, and total charge will not be accepted as support.
Itemized restaurant receipts showing what food and drinks were purchased are required. CoStar only
reimburses meals for employees (with the exception of clients; see section 4.2). If 2 or more employees
are on the same receipt, then the employee who submits the receipt must identify the other CoStar
employees on their expense report and the highest level manager at the meal must pay for the meal and
submit the receipt.
Employees should use expense type Travel / Meals to account for their own personal
meals/beverages during business travel if not dining with clients.
For more information, contact the Accounting department.
No more than 3 clients can be entertained at a time. The daily meal allowance amount of $65 is the cap
that can be reimbursed per person. For example, if two CoStar employees and three clients are present,
then the total bill allowed for food and alcohol inclusive of tax and tip will be 5 x $65 = $325. Employees
who submit expense reports that include an average of more than $65 per attendee will have their
report flagged by Accounts Payable to justify the overage and be responsible for additional approval.
If 2 or more employees are at a meal together the highest level manager at the meal must pay for the
meal and submit the receipt. The employee who submits the receipt must identify the business
associates and Company worked for along with any other CoStar employees on their expense report.
Employees should use expense type Other: Meals-Client so Accounting will be able to identify that the
expense will count apart from the employees daily meal allowance under Travel / Meals.
Charges associated with upgrading to a preferred or extra leg room seat on flights longer than 3 hours,
are eligible for reimbursement or direct bill within our third party travel vendor. Booking more
expensive seats for flights of less than 3 hours is discouraged, unless flight is almost sold out or overbooked with limited seat availability. Business and First Class tickets must be pre-approved by the head
of department on a case by case basis.
CoStar encourages employees to use carry-on luggage when travelling for business purposes. However,
CoStar will reimburse the cost of checked-in baggage, if required.
Policy: Purchasing
Effective Date: 8/1/2015
1.0 Purpose:
To control costs of goods and services while providing CoStar with the best possible value
employees must adhere to the below purchasing policies.
2.0 Scope:
All regular U.S. employees of CoStar.
3.0 Policy:
In order to keep costs and purchases under control, all employees must adhere to the following
purchasing guidelines:
3.1 Vendor Selection
Managers authorized to make purchases for the Company are responsible for ensuring that the
vendor being utilized provides the best price and service. For purchases over $1,000, vendors
should generally be selected based upon a service and price comparison to include a minimum
of two vendors. No vendor shall be selected on the basis of an existing family or other personal
relationship between a key employee or decision-maker at the vendor and at the Company.
3.2 Purchase Orders
All non-travel purchases require a purchase order. CoStar utilizes an electronic purchase order
system. Authorized Managers have been provided with access to the purchase order system
with designated approval levels. The original approved purchase order number should then be
given to the Accounts Payable Department. Invoicing information should be directed to the
Accounts Payable Department, not to your Manager.
3.3 Signature Authority
As a result of CoStars status as a public company subject to certain internal control
requirements, please keep in mind that only CoStar officers that have been appointed by
CoStars Board of Directors are permitted to sign any contract, agreement or binding obligation
on behalf of CoStar. This includes any license agreement or any agreement obligating CoStar to
pay money or provide services.