Supplier Code of Conduct - Zillow Group

ZILLOW GROUP, INC. SUPPLIER CODE OF CONDUCT

Zillow Group, Inc. (“Zillow”) is committed to doing the right thing and promoting the highest standards of social responsibility, ethical conduct, responsible business practices, and compliance with applicable laws, rules, and regulations. As part of this commitment, Zillow encourages its third-party suppliers (the “Suppliers”) to share the same values and has adopted this Supplier Code of Conduct (the “Code”) to set out the standards for Suppliers to adhere to when conducting business with or on behalf of Zillow.

At a minimum, Zillow expects its Suppliers to provide safe working conditions, treat workers with dignity and respect, act fairly and ethically, and use environmentally responsible practices in accordance with this Code. Zillow encourages Suppliers to promptly inform Zillow at Procurement@njsyxwj.cn when any situation develops that causes the Supplier to operate in violation of this Code. Compliance with this Code is important to Zillow and while Suppliers are expected to self-monitor and demonstrate their compliance with this Code, Zillow reserves the right to audit Suppliers’ compliance with the Code. Any violation of the Code may jeopardize the Supplier’s business relationship with Zillow. Thus, Zillow invites its Suppliers to do the right thing and practice compliance with the Code, in addition to any other required obligations specified in any agreement the Supplier may have with Zillow.

Labor and Human Rights

Zillow expects its Suppliers to share Zillow’s commitment to pursue fair employment practices, respect human rights, and promote equal opportunity in the workplace. All Zillow Suppliers will conduct their employment practices in full compliance with all applicable laws and regulations and will treat their workers with the utmost dignity and respect.

Anti-Discrimination

Supplier will evaluate individuals based on qualifications and not on personal characteristics or beliefs. Supplier will not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by applicable national or local law, in hiring and other employment practices. Where a Supplier’s activities require workers or applicants to take medical or drug tests, Supplier will comply with all applicable laws and shall not use the test results in a discriminatory manner.

Anti-Harassment and Abuse

Supplier will commit to a workplace free of harassment and abuse. Supplier will not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment.

Prevention of Involuntary Labor and Human Trafficking

Supplier will ensure that all work is voluntary. Supplier will not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.

Supplier will not withhold workers’ original government-issued identification and travel documents. Supplier will ensure that workers’ contracts clearly convey the conditions of employment in a manner that is understandable by the workers. Supplier will not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.

Workers will not be required to pay employers’ or their agents’ recruitment fees or other similar fees to obtain their employment. If such fees are found to have been paid by workers, such fees will be repaid to the worker.

Prevention of Underage Labor

Supplier will comply with all local and national minimum working age laws or regulations and not use child labor. Suppliers will not employ anyone under the age of 14, under the age for completing compulsory education, or under the legal minimum working age for employment— whichever is higher. Zillow only supports the development of legitimate workplace apprenticeship programs for the educational benefit of young people and will not do business with those who abuse such systems. Workers under the age of 18 cannot perform hazardous work and may be restricted from night work, with consideration given to educational needs.

Working Hours

Supplier will not require workers to work more than the maximum hours of daily labor set by local and national laws or regulations. Suppliers will ensure overtime is voluntary and paid in accordance with local and national laws or regulations.

Wages and Benefits

Supplier will pay at least the minimum wage and provide any benefits required by law and/or contract. Supplier will communicate pay structure and pay periods to all workers. Supplier will meet all legal requirements relating to wages and benefits, pay accurate wages in a timely manner, and wage deductions will not be used as a disciplinary measure. All use of temporary and outsourced labor will be within the limits of applicable law.

Health and Safety

Supplier will obtain, keep current, and comply with all required health and safety permits. Supplier will comply with the reporting and posting requirements of applicable permits and regulations.

Occupational Health and Safety Management

Supplier will educate workers on safety procedures and also control worker exposure to potential physical safety hazards by implementing physical guards, barriers, and/or engineering and administrative controls. Workers must be informed and receive appropriate education in advance if they will be working with (or otherwise exposed to) hazardous or dangerous conditions or materials. In addition, workers will be given appropriate personal protective equipment and educated and trained on the proper use of such equipment.

Emergency Preparedness and Response

Supplier will identify and assess potential emergency situations. For each situation, Supplier will develop and implement emergency plans and response procedures that will minimize harm to life, environment, and property.

Environment

Supplier will comply with all applicable environmental laws and regulations, including those related to hazardous materials, and will work to minimize the use of natural resources and any negative impact their operations have on the environment.

Environmental Permits and Reporting

Supplier will obtain, keep current, and comply with all required environmental permits. Supplier will comply with the reporting and posting requirements of applicable permits and regulations.

Effective Management and Disposal of Hazardous Substances -3-

Supplier will exercise due diligence to manage the safe handling, movement, storage, and disposal of chemicals and other harmful substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling and disposal of hazardous substances.

Resource Consumption Management

Supplier will use best efforts to manage and reduce consumption of fossil fuel, water, hazardous substances, and natural resources through conservation, re-use, recycling, substitution, or other measures.

Ethics

Zillow expects the highest standards of ethical conduct in all of our endeavors. Supplier will always be ethical in every aspect of its business, including relationships, practices, sourcing, and operations.

Responsible Sourcing of Materials

Supplier will exercise due diligence on relevant materials in their supply chains to identify potential risks and take appropriate steps to mitigate them. Specifically, Supplier will conduct and exercise due diligence to the material processing level in order to determine whether relevant materials originate from regions with high risks, which include areas associated with conflict, child labor, forced labor and human trafficking, gross human rights violations such as widespread sexual violence, or other reasonably objective high risk activities, including severe health and safety risks and negative environmental impacts.

Business Integrity

Supplier will exercise high standards of integrity in business interactions, and all of its business dealings will be accurately reflected in their books and records in accordance with applicable laws, rules, and regulations. Supplier will implement appropriate procedures designed to prevent bribery, corruption, kickbacks and embezzlement.

Disclosure of Information

Supplier will accurately record information regarding its business activities, labor, health and safety, and environmental practices and will disclose such information, without falsification or misrepresentation, to all appropriate parties and as required by law.

Protection of Confidential Information and Property -4-

Supplier will keep the confidentiality of confidential information, protect intellectual property rights, and safeguard customer information. Supplier will implement processes and/or systems to protect confidential information, intellectual property, and customer information from unized disclosure, security breach, or misuse.

Whistleblower Protection and Anonymous Complaints

Supplier will provide a safe mechanism for reporting and information to ensure all individuals understand how to report workplace concerns in a manner where they are protected from retaliation.

Supplier Equity and Belonging

Zillow believes that equity and belonging is a social and economic imperative and looks to Suppliers to share this commitment in their operations and within their supply chain. Suppliers are encouraged to take proactive steps to provide a full spectrum of businesses – based on the ownership structure (for example, women owned, minority owned, locally owned), scale (for example, small or medium enterprise) or nature of the enterprise (for example, social enterprise) – with the opportunity to compete on a fair and equal basis for business.