1. THE
C E N T E X W AY
Your guide for decision making
on business conduct issues
S P E eA n te x Wa y P
KU
I t ’s T h Ce
1.877.313.4545
Look on page 36 for your Speak Up wallet card.

2. Our Mission. We are Centex.
One company. United around
one goal. One purpose.
One mission.
A unified commitment to
build the best.
Build the best home. Build the
best community. Build the
best Centex.
One company. One goal. One
purpose. One mission.
Build the Best.

3. START
5
Message from Tim Eller
6
What Comes With the Territory
Obligations We Share as Centex Employees
Special Obligations of Centex Leaders
8
How We Do Things at Centex
When In Doubt We Ask
Key Business Conduct Spotlight Areas
32
Conflicts of Interest 10
What To Do If Issues Arise
Dealing with Customers, Trade
Partners and Others 16
Government Affairs 20
Centex Property and Information/
Communication 24
The Workplace 28
How We Keep On
34
Track and Improve
The Speak Up
36
Hotline Wallet Card

4. Dear Colleague:
Excellence is a process, not just an outcome.
We have to demand high standards in the
work we do – building homes for families. Our
homes must be more than “good enough.” They
must be the best. And so must our approach,
the way we do business and deal with people.
The Centex Way embodies our company’s core
values – Build Trust, Build Respect, Build
Our Core Values. Relationships, Build Excellence, Build Value,
and Build Excitement – and supports our
“unified commitment to build the best.” Build
Build Trust. the best home. Build the best community.
Build the best career. Build the best Centex.
Build Respect.
A high caliber organization is a reflection
of its people. Part of your job is to help set,
Build Relationships. promote and enforce strong ethics. We have
to develop, nurture, embrace and celebrate a
Build Excellence. strong corporate conscience. The Centex Way
reinforces our fundamental cultural principles
and provides support in identifying cultural
Build Value. and ethical traps.
Build Excitement. I believe our core value of Build Trust says it
05
well: Do the right thing for our company, in all
situations. Have integrity. Do what you say.
We can’t win the struggle for high business
standards if we just talk a good game…we’ve
got to play a good game.
Let’s continue to build our great company by
following The Centex Way. It’s our path to
continued success.
Tim Eller
Chairman and CEO

5. What Comes With the Territory What Comes With the Territory
OBLIGATIONS WE SHARE SPECIAL OBLIGATIONS
AS CENTEX EMPLOYEES OF CENTEX LEADERS
When you join Centex you accept certain obligations Centex holds each leader accountable to:
and some of the most important of these relate to
_Lead through example, role-modeling and ethical
business conduct.
business conduct.
The Centex Way applies to all Centex directors,
_Monitor and ensure employees (and third parties
officers and employees. A waiver of these obligations
acting on our behalf) follow The Centex Way.
for executive officers or directors may be made only
by the board or a board committee, and must be
This includes:
promptly disclosed to Centex shareholders.
_Arranging for appropriate orientation and
training in the relevant laws, requirements
Centex expects each of us to: and processes.
_Read and understand The Centex Way (as well
as any business conduct policies specific to our _Being open and available to discuss concerns.
business units).
_Deal effectively with business conduct issues that
_Behave ethically and in compliance with all laws, arise in their work group, consistent with The
regulations and legal requirements. Centex Way.
_Participate in education to ensure we understand Centex will not tolerate any harassment
the laws, regulations and legal requirements relevant
or retaliation against any employee for
to our jobs.
reporting, supplying information or
assisting an investigation into a business
_Seek guidance in resolving business conduct and
conduct concern. Everybody makes
ethics issues by following the processes described in
07
this booklet. honest mistakes, but there’s no such
thing as an honest cover-up.
_Honestly answer all questions asked in compliance
certifications, and fully comply in internal
Consult the “What To Do If Issues
investigations, if asked.
Arise” section on page 32 for guidance
_Deal with departures from The Centex Way if you are concerned about whether
through the processes described in this booklet.
certain business conduct may violate
The Centex Way.
_Understand that there may be consequences
for departures from The Centex Way, and for
departures serious enough, consequences up to
and including dismissal.

6. How We Do Things at Centex
WHEN IN DOUBT WE ASK
MAP LEGEND
You should seek advice from your supervisor if you
are unable to answer “no” to any of these questions. The most common business
conduct issues are addressed from
three perspectives in this section.
1. Is this action inconsistent with The Centex
Way, our Company’s core values or business
unit policy?
2. Is the action likely to endanger anyone’s health
Guiding Principle
or safety?
3. Do I have any doubts about whether the action The Compass. For each
is legal? issue, the principle that
4. Even if it is legal, do I have any doubts about should guide our action
whether it also is the right thing to do? introduces the business
5. Would it be hard to defend this action with conduct topic. Principles
my supervisor, co-workers, customers, trade are useful because they can
partners or those in the community where we be used to guide actions in
do business? In other words, would I or could many situations and can
Centex be embarrassed if this action or situation reduce the need to have
were reported in the newspaper, on TV or posted rules for each situation.
on a Centex bulletin board?
6. Could I regret not having discussed this
situation with my supervisor or others within
Policies and Rules
Centex before taking the action?
Boundary Map. Rules are
also necessary and useful,
particularly where there are
laws or policies that we
must know about.
Decision Considerations
Navigation Aids. Since not
all ethical questions are
easily answered “yes” or
“no,” good judgment is
required. If there are special
considerations to support
your navigation through a
“maybe” area, they are
offered as the third element.

7. How We Do Things at Centex
CONFLICTS OF INTEREST
Guiding Principle
A conflict of interest is defined at
Conflicts of Interest. You know Centex as any activity, investment
or association that interferes or might appear
that a trade partner is quietly
to interfere with your judgment, objectivity
performing remodeling work on or ability in performing your job in the best
your supervisor’s home for free. interests of the Company and our shareholders.
Your supervisor manages the
We do not maintain relationships that could be
relationship with the trade partner, detrimental to Centex’s best interests or that could
create the appearance of divided loyalty.
and says that using this partner
saves the division a significant
Examples of Potential Conflict of
amount of money. He has told you Interest Situations
that any employee who reports
_An ownership interest in a Centex trade partner.
this information is untrustworthy
_A family member with an ownership interest in a
and will be let go. What should
Centex trade partner.
you do?
_Gifts of more than nominal value accepted from or
given to a current or prospective trade partner.
A. Investigate the situation yourself, then tell your
_Doing work for a Centex competitor.
supervisor that in the interest of fairness, the
trade partner should be willing to perform free
_Doing work for another employer during the
work for you, too.
work day, even if there is no direct relationship
B. Report the situation to your supervisor’s
between the other company and Centex.
supervisor or your division president. If you
are uncomfortable doing that, call Centex’s _Selling non-Centex products on Company
Speak Up Hotline. You may choose to remain property.
anonymous when you call the hotline.
_Supervising or making or influencing
C. Keep the information to yourself. Your
employment decisions about a family member or
supervisor is saving the company money. You
an employee with whom you have an intimate or
don’t have an obligation to report it, and you
other substantial relationship.
might lose your job if you do.
Answer
B. Employees should never accept a gift of goods
or services on their house from a Centex trade
partner. It’s every employee’s responsibility
to raise business conduct concerns. Centex
will not tolerate any harassment or retaliation
against any employee for honestly reporting,
supplying information or assisting an
investigation into a business conduct concern.
You shouldn’t conduct your own investigation
before reporting a misconduct concern.

8. How We Do Things at Centex
CONFLICTS OF INTEREST
Policies and Rules _Excepted are situations where family
members are distant relatives (more remote
Under No Circumstances than a first cousin).
_You must never, either directly or
_Always follow employment-related hiring
indirectly (nor should any member of
policies.
your family), accept cash, or accept gifts or
entertainment of greater than nominal value from
_Engaging in a business relationship between
any current or prospective trade partner, customer
Centex and a company in which you or your
or competitor.
family member has an ownership interest or holds
a position. This includes your participation (or a
_You must not make or influence decisions at
family member’s) in a company or other business
Centex, including contract terms, whenever a
association that agrees to sell land to Centex. If the
business or person with whom you have an intimate
transaction or relationship has already occurred,
or other substantial relationship is involved.
you must bring it to the attention of your direct
supervisor and the top executive promptly after you
_You should never accept a gift of goods or services
become aware of it.
on your house from a Centex trade partner.
_This could happen because of a recent
_You may not build a home in a manner that violates
marriage or because you learn about the actions
Centex’s policies with respect to the construction of
of a family member after they have occurred.
homes by employees.
With the Knowledge of Your Supervisor
With the Approval of Both Your
Supervisor and the Top Executive of Your _You must inform your supervisor before accepting
Business Unit any outside positions that involve substantial time
commitments, and in fulfilling those commitments
Permission must be granted before:
you must not use Centex time, personnel or
_Obtaining an ownership interest in, or position
property to carry out the work.
with, a Centex trade partner, customer or competitor.
_There is an exception where the interest in
the outside company is solely through the
ownership of publicly traded securities that
constitute less than 1% of the company’s
outstanding public securities, and the
investment is not a significant part of
your assets.
_Employing any family members where there is
either a direct or indirect reporting relationship or
a substantial amount of interaction between family
members on the job.

9. How We Do Things at Centex
CONFLICTS OF INTEREST
Decision Considerations _Is the gift personal, or is it something that can be
used on the job and shared with co-workers?
The decision about what constitutes
gifts and entertainment of more
_Is the reason I am accepting this gift merely because
than nominal value requires
“it always has been done this way?”
judgment. Is the gift or entertainment valuable
enough that it could affect decision making or _Will this action set a precedent?
even appear to do so? If the answer is “yes,”
the gift or entertainment is not nominal. And _Is the gift, service or entertainment something I
even something of small value that actually could not afford to buy or provide myself?
compromises good decision making is not
nominal regardless of amount. _Is any effort being made to conceal the gift or offer?
Frequency enters into the equation too. Occasional If your answer is “yes” or even “maybe” to any
meals where the giver is present are generally within of these questions, then you should seek your
the usual boundaries of good business conduct, supervisor’s advice.
whereas repeated meals may be perceived as
having greater than nominal value or may appear There also may be situations not specifically covered
compromising. here that could involve a conflict of interest. If
you believe you may have an outside interest that
Here are some of the questions that could conflict with those of Centex, you should
seek guidance from your supervisor. Your business
you might ask yourself if you are
unit may also have its own more narrowly defined
unsure whether accepting a gift or
policies on conflicts of interest. If so, you must
entertainment is appropriate:
comply with both the policy set out here and your
business unit policy.
_Is this gift being offered or given because my
position enables me to influence a Centex decision
in favor of the customer or trade partner?
_Will my accepting this gift influence or affect what
Centex pays or is paid for products and services?
_By accepting this gift, will I put myself, or appear
to put myself, in a compromised position with my
peers or the general public?
_Would providing the same gift in return be outside
the boundaries of what is acceptable at Centex?

10. How We Do Things at Centex
DEALING WITH
CUSTOMERS, TRADE
PARTNERS AND OTHERS
Dealing with Customers, Guiding Principle
Trade Partners and Others. All of Centex’s dealings with outside
parties must reflect our commitment
Susan believes her division’s
to “fair dealing. Fair dealing means that we:
”
purchasing manager gave
_Honor customer privacy with respect to the
preferential consideration to new
information customers provide to Centex, and not
trade partners selected for division use the information for purposes other than for
which it was intended.
projects. She told the director of
construction operations and he _Buy and sell products and services on the basis of
said he would investigate. Susan their value, and do so without creating perceptions
that bribes, personal incentives or kickbacks are
hasn’t heard anything in three involved, or that competitive bids are rigged.
months despite her requests for
_Make honest representations about Centex and its
updates. She’s afraid she might
products, without misrepresentation or distortion
lose her job if she further reports of facts.
the problem. What should she do?
_Do not use our position in the Company to obtain
a personal benefit from a current or prospective
trade partner.
A. She reported the problem to a supervisor. She
should now focus on her job and let others focus
Examples of Potentially Unfair or
on theirs.
B. Because purchasing managers have certain Unlawful Dealings
leeway when selecting partners, she should
assume there is no impropriety. _Selling or giving non-public personal
C. Because Susan believes her concern was not information about customers
properly investigated, she should continue to others.
to follow the steps in the “What To Do If
Issues Arise” section of The Centex Way: tell _Providing personal gifts or
the division president, call the Corporate making personal loans to
Compliance Office or call Centex’s Speak customers to get business.
Up Hotline.
_Discussing pricing
strategy with
Answer competitors.
C. Giving preferential treatment to prospective
trade partners violates The Centex Way fair
dealing principle. Every employee has the
responsibility to raise concerns and to surface
deviations from The Centex Way, and Centex
will not tolerate retaliation against those who do.

11. How We Do Things at Centex
DEALING WITH CUSTOMERS,
TRADE PARTNERS AND OTHERS
Policies and Rules With the Approval of Both Your
Supervisor and the Top Executive of
Under No Circumstances
Your Business Unit
You must never:
Permission must be granted before:
_Enter into discussions with competitors
_Discussing profits, costs, employee compensation,
to fix prices or terms of sale, divide up
market share, pricing or any other competitive
markets or customers, limit production or rig a
information with any competitor. (There may be
competitive bidding process.
narrow circumstances where such discussions could
be appropriate, but this is an area where General
_Discuss, agree to, or take any action to boycott a
Counsel should be consulted for confirmation.)
competitor, customer or trade partner.
_Serving as a director or an advisor to a competitor
_Give to or receive from a customer or any other
organization.
third party a gift, loan, cash or anything of value
that could be viewed as:
With the Knowledge of Your Supervisor
_All gifts and payments made to third parties on
_A bribe or kickback, or
behalf of Centex must be properly recorded.
_An attempt to improperly influence the
_Any entertainment receipts must be properly
relationship between Centex and the customer
submitted for reimbursement.
or other third party.
_Provide a gift that knowingly violates the policies
of the recipient’s employer.
_Use information we receive from companies or
individuals for purposes other than for which it
was intended, or violate any restrictions we agree to
by virtue of receiving the information.
_Demand or accept payment or personal favors
from current or prospective trade partners.

12. How We Do Things at Centex
GOVERNMENT AFFAIRS
Guiding Principle
Government officials and
Government Affairs. Your government agencies should be dealt
with using the same standards as other third
division is building a new home
parties; however, political contributions and
for a City Council member, and lobbying are special categories of governmental
it’s making an exception and dealings where specific laws apply.
customizing the home by making
We must always understand the laws before we make
one of the garages into an office. political contributions or engage in lobbying, and act
in accordance with these laws.
You’ve heard that the council
member won’t be charged for Examples of Potentially Unlawful Dealings
the customization. It’s very _Entertaining or making gifts to government officials
difficult for the division to get or their family members.
land entitlements without good _Providing resources (money or in-kind value) to
relationships with elected officials, political candidates, political parties or committees.
and you suspect that division
_Hosting political fund-raising events.
leadership has made this special
_Coercing employees or trade partners to support
concession to gain favor with the
candidates or engage in political activity.
council member for future votes.
_Seeking reimbursement from Centex for
What should you do?
political contributions.
A. Wait and see whether the council member
pays market value for the customization of
the home. If you find out that the council
member didn’t pay for the customization,
you can report it then.
B. Report your concern now following the
process in the “What To Do If Issues Arise”
section of The Centex Way. You don’t have to
provide evidence of misconduct when you
report your concerns.
C. Don’t report anything. You may not have all
the facts, and it won’t do any good anyway.
Answer
B. Report your concerns promptly so Centex
can investigate. Centex employees must
never make payments or offer anything
of value (even nominal value), directly or
indirectly to government officials to obtain a
particular result for the Company.

13. How We Do Things at Centex
GOVERNMENT AFFAIRS
Policies and Rules With the Approval of Both Your
Supervisor and the Top Executive of
Under No Circumstances
Your Business Unit
You must never:
_Funds or any other resources of the Company
_Make payments or offer anything of
(including “employee time”) may be used for
value (even of nominal value), directly
federal, state or local political campaign activity
or indirectly, (as an individual or as an employee
only with full confidence about the legality of
group) to:
the action.
_Government officials, domestic or foreign, to
Since laws in this area are complex and vary by
obtain a particular result for the Company.
jurisdiction, legality must be confirmed in advance
by submitting a request form in accordance with
_Any family member or friend of a
Centex’s political activity policies and procedures,
government official because of the official’s
which provide for a review for compliance with
status in order to obtain a particular result for
federal, state and local laws.
the Company.
_Communications with government officials
_Coerce, threaten, intimidate or otherwise
to promote Centex or influence legislative or
improperly induce any Centex employee to make
administrative action on behalf of Centex may be
or not make a political contribution or to engage or
done only with:
not engage in political activity.
_Proper registrations, if required, and
_Seek or accept reimbursement from Centex,
directly or indirectly, for making a political
_Full confidence about the legality of
contribution.
the action.

14. How We Do Things at Centex
CENTEX PROPERTY AND
INFORMATION/
COMMUNICATION
Centex Property and Guiding Principle
Information/Communication. Centex owns both tangible (physical)
At a meeting discussing a land property, such as computers and
offices, and intangible (intellectual) property,
deal, a new employee mentions such as trademarks and confidential information
that his former employer and materials. As part of our jobs, we must
properly use and protect Centex’s property.
considered purchasing this
same piece of land, and he has You are expected to:
a report he could share with the _Be an active steward in protecting and preserving
the value of Centex’s property.
team. John, a land manager,
recommends checking with Legal _Understand and abide by laws and Centex policies
concerning the communication of information, and
to determine if that’s appropriate.
its protection from unauthorized disclosure.
Several participants dismiss his
Examples of Misuse or Improper
comments, stating that because
Disclosure of Information
the other company is no longer
_Using material, non-public information as the
interested in the land, Centex basis for buying or selling Centex stock (or stock in
would not be using competitive another company).
trade secrets. In this situation, _“Tipping” or disclosing material, non-public
John should: information that another person might use as
a basis for buying or selling stock in Centex (or
another company).
A. Do nothing. The report probably consists of
information that is publicly available or is
_Falsifying vouchers, bills, payments or receipts.
generally known in the market.
B. Insist that Legal provide a recommendation
_Maintaining “off-the-books” accounts.
before reviewing the report. It’s better to
get clarification than risk using confidential
_Withholding pertinent information in internal or
information from another company.
external audits or investigations.
C. Call the other company to confirm they are not
interested in the land.
_Revealing trade secrets at a conference.
Answer _Acting as a spokesperson for Centex on financial
matters (other than those specially designated).
B. Centex employees should never use confidential
information obtained from other companies or
_Reviewing or discussing sensitive and proprietary
previous employers. If you’re not sure whether
or otherwise confidential information in public
information is confidential or proprietary,
places where others could see or overhear (e.g., on
you should ask a Company lawyer or call the
commercial airplane flights, elevators).
Corporate Compliance Office.
_Leaving portable computers unsecured.

15. How We Do Things at Centex
CENTEX PROPERTY AND
INFORMATION/COMMUNICATION
Decision Considerations
Policies and Rules
Property
Under No Circumstances
You must never: “Treating company property as if it
_Destroy or alter any records that may were our own” is an expression
relate to pending or anticipated litigation, sometimes used to describe how we should
audit or investigation or otherwise violate the preserve and protect Company property. Keep
records retention policy. in mind however, that Company property is
owned by Centex. As such, Centex reserves the
_Falsify or misstate, even in a minor way, vouchers, right to inspect or search any Company property
bills, payments or receipts or accounting records.
at any time, with or without your presence, to
ensure workplace safety and compliance with
_Disclose to third parties what might be considered
law and policy.
“insider information” (non-public information on
Centex operations, financial results or prospects).
There should be no presumption or expectation of
privacy related to any personal property that may
_Buy or sell securities of a company, including
be co-mingled with Company property, such as in
Centex securities, while in possession of material
office files, e-mails or voice mails.
non-public information.
Communication
_Disclose or improperly discard confidential
Our jobs often require us to discuss Company
customer or employee information in violation of
matters with third parties, such as when we
Centex policy or legal requirements.
are setting expectations with trade partners
or customers; when we are describing Centex
_Give Centex property to, or accept Centex property
27
culture to prospective employees; or when we are
from, another employee. There is an exception, of
responding to routine inquiries.
course, for an employee’s official Centex salary and
incentive compensation.
There are three questions that you should keep in
mind for which the answer always should be “yes”
Only With the Approval of the Top
before you share information about Centex:
Executive of Your Business Unit
_Disclose to third parties valuable internal
_Am I providing accurate and credible information?
information (including trade secrets, processes,
data, know-how, techniques and strategies).
_Is the information generally known to the public
or in the industry (e.g., not insider information or a
_Issue press releases referencing Centex. All press
trade secret)?
releases must be coordinated through Centex
Corporate Communications.
_Am I the right person to be providing the
information? (For example, only designated
_Produce and distribute external communications
employees are authorized to discuss Company
materials that refer to another Centex business unit.
financial matters with investors.)
_Establish or modify a Centex-related Internet site,
When in doubt about any of these, your business
home page or hyperlink.
unit communications leader and the VP of
Corporate Communications are good resources for
_Endorse any products or services using your job
advice, especially with respect to press inquiries.
role or title, or on behalf of Centex.

16. How We Do Things at Centex
THE WORKPLACE
Guiding Principle
Centex must be a place where
The Workplace. You have every employee can do his/her job
to the best of his/her abilities. This means each
recently seen a trade partner’s
employee has an obligation to do his/her part to
employee pay a lot of attention maintain a safe and secure work environment
to a new female employee in a free of discrimination, harassment and violence.
Centex sales office, saying things
Examples Counter to the Principle
that cross the line of proper
_Promotion decisions based on anything other than
businesslike behavior. The woman job qualifications, competence and merit.
seems annoyed, and you’re
_Display of offensive materials.
concerned that she may be afraid
_Inattention to resolving workplace safety hazards.
to confront the trade partner’s
employee because her supervisor _Fighting or threatening behavior.
has a good relationship with him.
_Being under the influence of alcohol or drugs
What should you do? at work.
_Remarks that are offensive or that could be viewed
A. Advise the woman to ignore the trade partner’s
as harassment.
employee. That’s all you can do because the
trade partner’s employee doesn’t have to
_Unwelcome physical contact.
comply with The Centex Way.
B. Confront the trade partner’s employee and tell
him to stop harassing the woman and to leave
her alone.
C. Report your concern. You have an obligation
to report concerns, but you’re not responsible
to handle misconduct yourself.
Answer
C. Centex does not allow our agents, customers or
trade partners to harass any Centex employee.
Harassment means verbal or physical abuse,
unwelcome contact, advances or propositions,
displays of offensive materials or other acts
that create a hostile work environment. You
should report your concern promptly so that
Centex can handle it.

17. How We Do Things at Centex
THE WORKPLACE
Decision Considerations
Policies and Rules
What may be offensive,
Under No Circumstances
threatening or intimidating to
You must never:
one person may not be to
_Discriminate on the basis of age, color,
another. The simple rule of
race, religion, disability, gender, sexual
thumb is “if any employee thinks my behavior
orientation or national origin.
is, then it is, and hence it should trigger
”
sincere re-examination.
_Use hiring tests that are not directly related to
job requirements or that have not been specifically
The questions that you should ask
validated for the job group.
yourself are:
_Harass or allow our customers or trade partners to _Is my behavior fully conducive to others doing
harass Centex employees. Harassment means verbal their best work?
or physical abuse, unwelcome contact, advances or
propositions, displays of offensive materials or other _Is my behavior relevant to meeting workplace
acts that create a hostile work environment. goals?
_Allow unsafe working conditions or environmental _Is there anything about my behavior that does
hazards to go unreported to your supervisor. not imply dignity and respect for the individual,
including respect for personal privacy?
_Make threats of violence, engage in acts of violence,
or otherwise intimidate other employees. If you cannot answer “yes” to all these questions,
then the behavior probably is inappropriate.
_Use, possess, distribute, manufacture or transport
on Centex property, or on company business, or
during working hours, any of the following:
_Illegal drugs, equipment or paraphernalia
related to illegal drugs, or prescription
drugs other than by those for whom they
were prescribed.
_Alcoholic beverages, except as specifically
authorized for company functions.
_Use or carry any lethal weapons or allow any
customers or trade partners to use or carry lethal
weapons on Centex property (unless they are police
officers, appropriately licensed security guards or
others with prior written consent from Centex, or
except to the extent applicable law may prevent
Centex from prohibiting the possession of firearms
for lawful self-defense).
Only With the Approval of the Top
Executive of Your Business Unit
_Allow family members or guests to visit non-public
Company facilities unaccompanied by an employee.

18. What To Do If Issues Arise
It is impossible to conduct business 5. If the process breaks down in any way or if you feel
without facing business conduct issues. a need to raise concerns anonymously, Centex has
established the Speak Up Hotline as an alternative
Most issues are fairly straightforward
avenue for raising concerns. The Speak Up Hotline
to resolve, but sometimes the issues
number is 877-313-4545.
are more complicated. The basic steps
for resolving any business conduct issue,
It is every employee’s responsibility to raise concerns
whether it is complicated or not, are the same.
and to surface deviations from The Centex Way,
including violations of law by Centex employees (or
When you confront an issue or have a
those who are acting on Centex’s behalf).
question, the following sequential steps
are advised:
_No Retaliation. Centex will not tolerate retaliation
1. First, consult the appropriate section of The against any employee who raises a business conduct
Centex Way or your business unit’s policies as key issue or reports a violation of the law or of Centex
reference guides. policy. You may not discharge, demote, suspend,
threaten, harass, discriminate or retaliate against
2. If you still have questions about what to do, seek a person who alleges misconduct or provides
your supervisor’s counsel and guidance. Your information in good faith in an investigation.
supervisor may also suggest other people to go
to for assistance, such as someone in the legal If you feel that you have experienced retaliation
department or in human resources. as a result of making a complaint or providing
information you should report it to your supervisor,
3. If your supervisor is unable to guide you or if you other management personnel, the legal department,
feel your supervisor’s advice is compromised in human resources, the Corporate Compliance Office
some way, you have two options. or the Speak Up Hotline.
33
_One is to approach your supervisor’s boss Centex will investigate allegations of retaliation,
with the matter (or even higher levels and violations will result in consequences up to
as required). and including termination of employment.
_The other is to call the Centex Corporate _False Claims. Employees who make claims
Compliance Office at 214-981-6822. This that they know to be false will be subject to
path also remains available if moving up the disciplinary action.
business channel proves unsatisfactory.
_Confidentiality. Centex will make every effort to
4. In the special case of questionable accounting or protect the confidentiality of individuals who report
auditing matters, you have two additional avenues violations of the law or Company policies, although
for resolving the issue or question. it may not be possible to do so in every case, such as
when disclosure is required by law.
_By calling the Centex VP of Internal Audit
at 214-981-6336.
_By calling 877-313-4545 and requesting
that your concern go to the Centex Board of
Directors Audit Committee Chairperson.

19. How We Keep On Track and Improve
The Centex Way is not just a code of _The business conduct issue themes and challenges
conduct. It is a process for ensuring most important to the business.
everyone in the Centex family “knows
_What is occurring in the business to ensure we
the way” and “follows the way” It is
.
keep on The Centex Way.
part of what distinguishes us as a
great organization that consistently
This enables Centex to:
operates at the highest standards of
_Ensure proper focus is maintained.
business conduct in everything we do.
_Communicate the importance placed on
Our process for keeping on track entails steps in
business conduct.
each of our work groups, steps as a company and
steps for us individually.
_Make good decisions about priority setting.
In Our Work Group
_Have a well-informed basis for reporting to the
Since each business unit faces distinct challenges, Centex Board of Directors on this key
we should expect the key business conduct issues in governance accountability.
each business unit to have a different emphasis.
Each of Us Individually
At least once each year Centex expects you will have
As a Centex employee, you are required to
the opportunity to:
promptly and honestly complete an annual
_Refresh (and deepen) your understanding about
questionnaire that asks important questions about
how The Centex Way applies specifically to your
your business conduct and the business conduct
work group.
you have observed at Centex over the past year.
One of these questions is whether you have had
_Surface business conduct topics most needing
an opportunity over the past year to discuss The
preventive attention and maintenance.
Centex Way in your work group. The answers to
this question are tabulated and status is provided
_Develop action plans appropriate to your business.
to business leaders.
_Assess progress made on those action plans.
The purpose of this step is to ensure the key
business conduct issues in The Centex Way are kept
Each business unit individually determines
top of mind for veteran employees and are properly
how these discussions occur and cascade in the
introduced during orientations for new employees.
organization, and how action planning and follow-
up occur. Commonly, The Centex Way is a staff
There is also a compliance benefit to this step
meeting agenda item, assisted by a Leaders Tool Kit.
that is in keeping with good governance best
practices, but the primary purposes at Centex are
As a Company
communication, process control, diagnosis
Each year at one of the quarterly reviews of business and improvement.
strategy execution, business unit executives share
with Centex corporate senior management:

20. Please carry your Speak Up Hotline
card in your wallet or purse.
1.877.313.4545 Ask yourself, does it:
SPEAK UP
It’s the Centex Way
Build Trust.
Build Respect.
Obligations We Share as Centex Employees
When you join Centex you accept certain obligations
Build Relationships.
and some of the most important of these relate to
business conduct.
1. Read and understand The Centex Way (as well
as any business conduct policies specific to your
Build Excellence.
business unit).
2. Behave ethically and in compliance with all laws,
regulations and legal requirements.
Build Value.
3. Participate in education to ensure you understand
the laws, regulations and legal requirements
relevant to your job.
Build Excitement.
4. Seek guidance in resolving business conduct and
ethics issues by following the processes described
in The Centex Way.
5. Honestly answer all questions in compliance
certifications or in internal investigations.
6. Deal with departures from The Centex Way
through the processes described in this booklet.
7. Understand that there may be consequences
for departures from The Centex Way and, for
departures serious enough, consequences up to
and including dismissal.

21. About Our Company
Dallas-based Centex, founded in
1950, is one of the nation’s leading
home building companies. Its
leading brands include Centex
Homes, Fox & Jacobs Homes and
CityHomes. In addition to its home
building operations, Centex also
offers mortgage, title and insurance
services. Centex has ranked among
the top three builders on FORTUNE
magazine’s list of “America’s Most
Admired Companies” for nine
straight years and is a leader in
quality and customer satisfaction.
The Centex Way articulates what
it means to be a Centex employee
with respect to exemplary business
conduct, a critical dimension of how
we measure success.
© 2003-2008 Centex Corporation
REV 07/08