(i) promote honest and ethical conduct, including the ethical handling of conflicts of interest;
(ii) promote full, fair, accurate, timely and understandable disclosure;
(iii) promote compliance with applicable laws and governmental rules and regulations;
(iv) ensure the protection of our legitimate business interests, including corporate opportunities, assets and confidential information; and
(v) deter wrongdoing.
Our codes of ethics were adopted to reinvigorate and renew our commitment to our longstanding standards for ethical business practices. Our reputation for integrity is one of our most important assets and each of our employees and directors is expected to contribute to the care and preservation of that asset. Under our codes of ethics, an amendment to or a waiver or modification of any ethics policy applicable to our directors or executive officers must be disclosed to the extent required under Securities and Exchange Commission and/or New York Stock Exchange rules. We intend to disclose any such amendment or waiver by posting it on the Investor Relations page of our website at www.fnf.com.
From the FNF Code of Business Conduct and Ethics
A Message from
William P. Foley, II, Chairman of the Board of Directors
Dear Fellow FNF Employees:
Fidelity National Financial, Inc. has developed six core values that represent the cornerstone of our management philosophy for operational success. I challenge each of you to use these precepts as a foundation for every decision you make in the workplace.
The six precepts are:
Autonomy and Entrepreneurship
Bias for Action
Customer-Oriented and Motivated
Highest Standard of Conduct
As indicated by our sixth precept, “Highest Standard of Conduct,” we are all expected to maintain the highest standard of business conduct and ethics. To achieve this objective, we are each responsible for behaving in a manner that reflects positively on both our personal reputation and the reputation of our company.
This Code of Business Conduct and Ethics is a resource for applying our values and ensuring a consistent understanding of what FNF expects of you and what our customers, business partners, and shareholders expect of us. It is intended to help resolve compliance and ethics issues by providing you with the information, tools and resources necessary to make good, ethical decisions. However, no code can provide answers for every situation that may arise. In the end, we rely on you to use sound judgment to make the right decision and to do the right thing.
It is important to read this Code to understand your role and responsibilities as an FNF employee.
Thank you for doing your part to ensure our ongoing success and our adherence to the Highest Standards of
William P. Foley, II
Chairman of the Board of Directors
and from p. 16 of that document
Do the Right Thing
• Deal fairly with customers, shareholders, regulators,
agents, business partners, service providers,
suppliers, competitors, and employees.
• Do not take unfair advantage of anyone
through manipulation, concealment, abuse of
privileged information or misrepresentation of