PulteGroup 2022 ESG Report

OUR COMMITMENT TO ETHICS To always be moving toward our vision of being the most respected homebuilder in America, a company-wide commitment to ethics must serve as the foundation. Our Board of Directors and all company employees are subject to PulteGroup’s Code of Ethical Business Conduct. Every year, employees must certify that they have reviewed and understand our code. PulteGroup also maintains an ethics hotline that allows employees, customers and/or members of the public, named or anonymously, to alert the Board of possible issues or abuses in any areas of our operations. Concerns can be reported by phone (800-498-5629) text (904-782-6958) or through a link on PulteGroup’s website (speakup.pultegroup.com). All complaints are thoroughly investigated and properly reviewed. Senior leadership, working in partnership with our Board, routinely engages with PulteGroup’s institutional shareholders, on a proactive basis, to review our operating and financial results as well as our ESG policies and practices. “When it comes to how we build, how we treat

customers and employees, and generally how we want to act as people, our mantra is Do the Right Thing. I appreciate that sometimes doing the right thing can be hard, but we must hold ourselves and each other

We also work to provide timely responses to ESG-related shareholder inquiries and to provide greater transparency by participating in established ESG and broader environmental surveys. And we are ever conscious of the risks associated with some form of cyberattack significantly impacting our business. We maintain a data security and privacy program that protects company, employee, partner, customer and consumer data. We follow the National Institute of Standards and Technology (NIST) framework, and our Chief Information Officer reports to our Board on cybersecurity and privacy matters on a regular basis. Every employee participates in mandatory training on multiple policies related to data security and privacy, which includes a recurring cyber-phishing awareness campaign. We maintain meaningful share ownership guidelines for executive officers and directors, and have prohibitions against hedging and pledging Company securities by all employees and directors.

accountable.” RYAN MARSHALL President & CEO

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