Zillow Group, Inc. and its subsidiaries (collectively “Zillow”) are committed to doing the right thing and promoting high 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, as well as the Supplier’s employees, agents and subcontractors, to adhere to this Code and Zillow Group’s Code of Conduct, comply with applicable laws, 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 actively communicate and disseminate the principles of this Code with their own subcontractors and supply chain partners who perform work on Zillow’s behalf. We ask that Suppliers work collaboratively with these partners to uphold the same standards, and to help ensure ongoing awareness, understanding, and alignment with the Code’s expectations. Suppliers should promptly inform Zillow at vendormanagement@zillowgroup.com if any situation arises that may result in non-compliance with this Code. While Suppliers are expected to self-monitor and demonstrate compliance, Zillow may exercise its right to assess and verify Supplier conformance through audits, site visits, or other due diligence measures. 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.
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.
Suppliers will respect the rights of employees and comply with all laws concerning freedom of association and collective bargaining.
Suppliers will evaluate individuals based on skills and qualifications and not on personal characteristics or beliefs. Suppliers will not discriminate against any worker based on age (other than to protect minors), 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 Suppliers’ activities require workers or applicants to take medical or drug tests, Suppliers will comply with all applicable laws and shall not use the test results in a discriminatory manner.
Suppliers will commit to a workplace free of harassment and abuse. Suppliers 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, or sexual harassment.
Suppliers will ensure that all work is voluntary. Suppliers 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.
Suppliers will not withhold workers’ original government-issued identification and travel documents. Suppliers will ensure that workers’ contracts clearly convey the conditions of employment in a manner that is understandable by the workers. Suppliers 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.
If applicable, Suppliers will take reasonable measures to provide workers with acceptable living conditions.
Suppliers 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 and professional benefit of participants 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.
Suppliers 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 accurately paid in accordance with local and national laws or regulations.
Suppliers will pay at least the minimum wage required in any jurisdiction and provide any benefits required by law and/or contract. Suppliers will meet all legal requirements relating to wages and benefits, pay accurate wages in a timely manner, and use temporary and outsourced labor within the limits of applicable law.
Zillow also encourages Suppliers to work toward providing a living wage — defined as income sufficient to afford a basic but decent standard of living for workers and their families, including access to food, housing, healthcare, education, and discretionary income.
Suppliers will obtain, keep current, and comply with all required health and safety permits. Suppliers will comply with the reporting and posting requirements of applicable permits and regulations.
Suppliers 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.
Suppliers will identify and assess potential emergency situations. For each situation, Suppliers will develop and implement emergency plans and response procedures that will minimize harm to life, environment, and property.
Suppliers must comply with all applicable environmental laws and regulations, including those related to hazardous materials. Zillow also encourages suppliers to reduce their greenhouse gas emissions and to minimize the use of natural resources and any negative impact their operations have on the environment.
Suppliers will obtain, keep current, and comply with all required environmental permits. Suppliers will comply with the reporting and posting requirements of applicable permits and regulations.
Zillow’s science-based targets (SBTs) were validated by the Science Based Targets initiative (SBTi). Zillow’s SBTs include a Scope 3 target that 75% of Zillow’s suppliers will have science-based targets by 2028.
As part of Zillow’s work to meet this target, Zillow encourages its suppliers to set a SBT in alignment with SBTi guidance, which aims to limit global warming to 1.5°C or less by December 31, 2028. For more information, visit: https://sciencebasedtargets.org/.
Suppliers 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.
Suppliers 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.
Suppliers will always be ethical in every aspect of its business, including relationships, practices, sourcing, and operations.
Suppliers will exercise due diligence on relevant materials in their supply chains to identify potential risks and take appropriate steps to mitigate them. Specifically, Suppliers 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.
Suppliers 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. Suppliers will implement appropriate procedures designed to prevent bribery, corruption, kickbacks and embezzlement.
Suppliers 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.
Suppliers will keep the confidentiality of confidential information, protect intellectual property rights, and safeguard customer information. Suppliers processing personal data shall meet CCPA and any local equivalents, and notify Zillow security within 24 hours of a confirmed breach. Suppliers will implement processes and/or systems to protect confidential information, intellectual property, and customer information from unauthorized disclosure, security breach, or misuse.
Suppliers 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.
Zillow endeavors to deal honestly, ethically, and fairly with its consumers, customers, suppliers, competitors and employees. We expect Suppliers to uphold these values in their own operations and decision-making. This means that statements regarding products and services must not be false, misleading, deceptive or fraudulent. Suppliers may not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice.
Suppliers must comply with all applicable federal, state and local laws and regulations related to gifts. Gifts, hospitality, and trips that lack transparency or a legitimate business purpose may be construed to indicate an intent to improperly influence the business relationship with Zillow and may create the appearance of a conflict of interest, or may be perceived as an attempt to improperly influence decision making. De minimis gifts or the exchange of normal social amenities are permitted, unless prohibited under applicable law; provided, Suppliers are prohibited from giving gifts of any value to any member of certain Zillow organizations, including Strategic Sourcing or its representatives. Furthermore, Suppliers should not offer anything of value to obtain or retain a benefit, and should not offer anything that might appear to influence, compromise judgment, or obligate the Zillow employee.
Under certain jurisdictions and laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and similar anti-bribery and anti-corruption laws worldwide, giving anything of value to a government official of any country to obtain or retain business or secure favorable treatment may be prohibited. Violations of such laws can be criminal offenses subject to prosecution and conviction. Suppliers must comply with anti-bribery and anti-corruption laws in every jurisdiction in which they operate.
Suppliers must comply with all applicable sanctions, trade embargoes, import and export control laws, and related regulations in every jurisdiction in which they operate. This includes, without limitation, compliance with the regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and comparable authorities in other countries and regions.
Suppliers must not engage, directly or indirectly, in any transaction or dealing with individuals, entities, countries, or regions subject to sanctions, embargoes, or other trade restrictions. Suppliers must also refrain from any action that could reasonably be expected to cause Zillow to violate applicable sanctions, embargoes, or trade laws, or expose it to penalties.
Suppliers are expected to establish and maintain a compliance program, including applicable written policies, procedures, and internal controls designed to ensure compliance with sanctions, import, and export control laws. Such programs should include initial and ongoing screening of all relevant customers, suppliers, subcontractors, and other third parties against applicable restricted-party lists, as well as checks for beneficial ownership by sanctioned parties.
Suppliers should implement measures to identify and address potential “red flags,” including but not limited to:
Suppliers must promptly report any suspected or actual violations of sanctions, import, or export control laws to the appropriate authorities and to Zillow, as permitted by law.
Suppliers must cooperate fully with Zillow’s Third-Party Risk Management (TPRM) requirements, which may include the completion of due diligence questionnaires, submission of documentation (such as information security, privacy, business continuity, and compliance policies), and participation in periodic inspections and reassessments.
Suppliers are expected to:
Failure to participate in required due diligence activities or to remediate identified risk gaps may impact a Supplier’s ability to enter into or continue a business relationship with Zillow.
