Ethics Reporting Guidelines

At CARS, we proactively communicate our ethics reporting policies to our employees through our Code of Conduct, which includes ethics reporting information aligned with this policy, and through new-hire and annual training. We require that all employees [and all members of our Board of Directors] annually review and attest to the Code of Conduct, acknowledging our ethics reporting policy and guidelines and processes.

Every Cars.com employee is responsible for ensuring that the company’s actions and associations maintain the highest professional standards. All employees are obliged to report any actual or suspected violation of company policy (including violations of accounting or auditing policy) or any suspected violation of the laws governing the Company’s business. Reports can be made any of the following ways (all of which are available 24/7):

Electronically at: www.lighthouse-services.com/cars.com

Or by phone at:

• English speaking USA and Canada: 833-222-1735
• Spanish speaking USA and Canada: 800-216-1288
• Spanish speaking Mexico: 01-800-681-5340
• French speaking Canada: 855-725-0002

There is no need to identify yourself. All reports will be confidential except as necessary to conduct investigations. Cars.com prohibits retaliation, or taking any action with the intent to retaliate, against anyone who in good faith raises questions or concerns about ethics and compliance, makes a report about a potential violation of any company policy or participates in any investigation. No one will be disciplined or suffer retribution for reporting violations. Retaliation or a threat of retaliation is a serious violation of the Cars.com Code of Conduct that will result in appropriate disciplinary action, including and up to termination of employment.

Handling Whistleblower and Ethics Reports

We take any report seriously and endeavor to resolve each concern swiftly. For that reason, we have structures in place to process these reports quickly and effectively.

When an ethics report is made, the Compliance Team reviews, document and report it more broadly based on the following guidelines:

• Actions prohibited by the Code of Conduct involving Directors or Executive Officers must be reported to any member of the Audit Committee or to the Chief Legal Officer, in which case the Chief Legal Officer shall advise the Chair of the Audit Committee of the report.
• Actions prohibited by the Code of Conduct involving anyone other than a Director or Executive Officer must be reported to Chief Legal Officer, HR, and to the reporting person's supervisor, in which the supervisor and HR shall advise the Chief Legal Officer.

After receiving a report of an alleged prohibited action, the Audit Committee, relevant supervisor, HR, a member of the Compliance Team and/or the Chief Legal Officer, as the case may be, must promptly take all appropriate actions necessary to investigate. Depending on the allegation, the corresponding actions may include developing an investigation plan, conduct fact-finding and interviews, engaging outside assistance, conducting background checks, and evaluating relationships and credibility.

Upon receipt of a determination that there has been a violation of the Code of Conduct  or Company policy, the Board of Directors, Chief Executive Officer and/or the Chief Legal Officer will take such preventative or disciplinary action as it or he deems appropriate, including a reprimand documented in the personnel file, loss of compensation, change of responsibilities to avoid repeat violations, demotion, termination, or other measures the Company deems appropriate, or, in the case of a Director, suspension or removal from the Board of Directors.