REA : Code of Conduct

How We Do Things: Code of Conduct

Purpose 6

Scope

The Code of Conduct outlines REA Group's expectations for behaviour on a day-to-day basis, it is a guide for how we interact and work with each other, our customers, our shareholders, the business and our community. It is expected that everyone reads and acts in line with the Code of Conduct: we are all personally accountable for behaving in a way that is professional, lawful and in line with our values and policies.

Who does this policy apply to?

This policy applies to all REA Group directors, employees, contractors, consultants, and visitors working for the REA Group ('REA') in any of our business and in any of our offices around the world.

When does this policy apply?

This policy applies to everyone who works at REA Group whether:

in the workplace, including when working outside normal working hours

during work activities, including when working remotely, interstate or overseas

at work-related events, including conferences and social functions.

Code of Conduct | REA Group Ltd 3

Purpose6 Scope

What are the professional standards of behaviour we expect?

The Code of Conduct acts as a bridge between our values, and our policies and legal requirements.

Our values guide how we work, and ensure our competitive advantage through enabling each of our employees to bring their best creative and passionate selves to work:

Our policies ensure consistency in how we do business and guide us to act lawfully. In addition to reading this Code of Conduct, please ensure that you read and are familiar with REA's company policies, including those relevant to the Respect@Work legislation.

Our Code of Conduct guides how we behave, fostering cooperation, ethical and appropriate decision-making, and aligning our behaviour with expected professional norms. We expect that everyone will follow these minimum standards.

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We treat each other respectfully, courteously and with dignity

Everyone is entitled to be treated fairly and with respect as a person, regardless of role or individual differences.

We value our people and their personal commitment to delivering quality products and services.

We encourage cooperation, learning and growth in all who work with us.

We strive to understand and respond to the needs of our customers and other stakeholders.

We do not act in a manner that may cause offence to others.

We seek to foster a respectful and inclusive environment for everyone. This means that clothing and other accessories should avoid slogans, images or symbols that could be considered offensive, political or divisive.

We act against bullying, harassment, and victimisation caused by unlawful behaviour and uphold the principles of the Respect@Work legislation.

We are fair, upfront and honest in our dealings

We are fair and honest - we do not use coercive or misleading practices and we do not act in any way that could be considered fraudulent or corrupt. REA considers "fraud" to include (but is not limited to): forgery; misappropriating funds; falsifying financial records or documents; and/or any other dishonest or deceptive act intended to result in financial or personal gain.

We do not place ourselves in situations in which our private interests could conflict directly or indirectly with our obligations to REA.

We disclose to our People Leader any close personal relationship that we may have with another REA staff member or an actual or potential customer or supplier of REA where it may cause a conflict of interest. Examples may include but

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are not limited to direct reporting lines, conflicts in roles and responsibilities, ELT and another REA staff member/contractor/director, or a supplier/customer relationship where we have involvement around the contractual terms with that supplier. A close personal relationship would generally refer to a spouse, partner, dependent and any person living in the same dwelling as us.

We do not act in ways which may cause others to question our loyalty to REA.

We treat others in the workplace fairly and with respect, and do not harass, victimise or discriminate against team members, customers or others in work practices or the provision of services on the grounds of sex (including pregnancy), sexuality, transgender status, race, colour, ethnic or ethno-religious background, descent or national identity, disability, age, political conviction or religious belief, carers' responsibilities, irrelevant criminal or medical records or other grounds covered by relevant legislation, including the Respect@Work legislation.