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Code of Business Conduct and Ethics

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Title:

Code of Business Conduct and Ethics

Entities:

Lennar Corp.

Date:

2006

Size:

29KB total

Price:

$39

ID:

#2285848

► Legal ► Conduct & Ethics ► Codes ► Codes of Business Conduct & Ethics
► Construction

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CODE OF BUSINESS CONDUCT AND ETHICS

Purpose and Scope

Since its founding, Lennar Corporation (the Company) has required that all its associates maintain the highest level of integrity in their dealings on behalf of the Company and its subsidiaries, in their dealings with the Company, and in everything affecting the Company's relationships with its customers, banks, security holders and others with whom the Company does business. The Company believes the high level of integrity with which it conducts its affairs has been a major factor in the Company's success.

This Code of Business Conduct and Ethics (the "Code") is intended to document the principles of conduct and ethics to be followed by the Company's associates, officers, and directors, including its principal executive officer, its principal financial officer and its principal accounting officer, and is to be followed in both letter and spirit. Its purpose is to:

Promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

Promote avoidance of conflicts of interest, including disclosure to an appropriate person or committee of any material transaction or relationship that reasonably could be expected to give rise to such a conflict;

Promote full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with, or furnishes to, the Securities and Exchange Commission and in other public communications made by the Company;

Promote compliance with applicable governmental laws, rules and regulations;

Promote the prompt reporting to an appropriate person or committee of violations of this Code and provide mechanisms to do so;

Promote accountability for adherence to this Code;

Provide guidance to associates, officers, and directors to help them recognize and deal with ethical issues; and

Help foster the Company's longstanding culture of honesty and accountability.

The Company expects all its associates, officers, and directors to comply at all times with the principles in this Code. Violations of this Code by an associate, officer or director are grounds for disciplinary action, up to and including immediate termination of employment and forfeiture of any earned or unearned bonus and possible legal prosecution.

Fair Dealing

Each associate and officer will at all times deal fairly and in good faith with the Company and the Company's customers, subcontractors, suppliers, competitors and associates. While we expect our associates to try hard to advance the interests of the Company, we expect them to do so in a manner that is consistent with the highest standards of integrity and ethical dealing.

No associate or officer is to take unfair advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of material facts, fraudulent behavior or any other unfair-dealing practice.

Compliance with Laws, Rules and Regulations (Including Insider Trading Laws)

Associates, officers, and directors are expected to comply at all times with all applicable laws, rules and regulations, and with all other policies applicable to them that are adopted by the Company from time to time, whether or not addressed specifically in this Code. Please contact the Companys General Counsel if you have questions or need additional guidance.

Bribes and improper payments. The Company's policies prohibit bribery or kickbacks of any kind to and from anyone in the conduct of our business. Federal law and the laws of most states prohibit engaging in "commercial bribery." Commercial bribery involves conferring or agreeing to confer anything of value upon any employee, agent or fiduciary of a vendor, supplier, contractor, competitor or governmental agency (each, an "Employer") without the consent of the Employer that adversely influences the business, affairs or operations of the Employer. Commercial bribery also involves soliciting, demanding or agreeing to accept anything of value from anyone intending to adversely influence or be rewarded in connection with the business, affairs or operations of the Company.

In addition to the general prohibitions above, the Real Estate Settlement Procedures Act (RESPA) governs our relationship with mortgage companies, title agencies, and other settlement service providers, whether or not these companies are affiliated with the Company. Pursuant to RESPA, splitting the fee that a settlement service provider receives for its settlement services is prohibited unless appropriate services are performed justifying receipt of the fee.

Insider Trading and Tipping. Federal and state securities laws and the Companys policies prohibit:

Purchasing or selling securities of the Company while in possession of material, nonpublic information about the Company; and

Disclosing material, nonpublic information to others who then trade in the Companys securities.

Associates, officers, and directors are required to comply with the Company's policies regarding non-public information in sections 5.2 and 5.16 of the Associate Reference Guide. You should review and follow these policies carefully. Because of the complexity of inside information and insider trading issues, and the severity of the punishments involved, which can include criminal prosecution, please contact the Companys General Counsel if you have questions or need additional guidance on this topic.

Public Filings. Associates, officers, and directors must cooperate fully with the people responsible for preparing reports filed with or furnished to the Securities and Exchange Commission and all other materials that are made available to the investing public to make sure those people are aware in a timely manner of all information that might have to be disclosed in those reports or other materials or that might affect the way in which information is disclosed in them. The Company and the law require the preparation and maintenance of accurate and reliable business records. You must prepare all reports, books and records of the Company with care and honesty. The Company maintains a system of internal controls to ensure that transactions are carried out in accordance with managements authorization and properly recorded. This system includes policies, procedures and examination by a professional staff of internal auditors. The Company expects you to adhere to these policies and procedures. You should make all complaints regarding accounting, internal accounting controls, or auditing matters in the manner set forth in Reporting below.

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