Rules of the Road
CODE OF BUSINESS ETHICS
2026
Code of Business Ethics
TABLE OF CONTENTS
Letter from the CEO 3
Our Vision, Mission and Values 4
Introduction and Overview 5
Maintaining our Commitment to
High Standards of Business Conduct 6
Our Business Ethics Program 6
To Whom Does the Code Apply? 6
Making Ethical Decisions 7
Seeking Guidance, Reporting Concerns
and Raising Ethical Issues 8
Accounting and Auditing Issues 9
The Alertline 9
We Do Not Retaliate for
Making Good Faith Reports 11
How We Enforce our
Standards of Conduct 11
Associate Responsibilities
Under the Code 11
A Word on Managers’ Additional Responsibilities Under the Code 12
Maintaining a Safe and
Ethical Workplace 13
Equal Employment Opportunity 14
Harassment 15
Wage and Hour Laws 15
Workplace Health and Safety 16
Protecting the Environment 16
Preventing Workplace Violence 17
Drugs and Alcohol 17
Ethical Practices in the Marketplace 18
Selling, Marketing and Advertising 19
Customer Financial Services 20
After-Sales 20
Information Belonging to Customers 21
Non-Discrimination 21
Competing Fairly 22
Properly Obtaining Competitive
Information 22
Anti-Money Laundering /
Economic Sanctions 23
Protecting the Property and
Information of Others 24
Protecting the Company’s Interests 25
Accurate Books and Records 26
Record Maintenance Requirements 28
Contact with the Media &
Members of the Financial Community 29
Social Media 30
Insider Trading 31
Conflicts of Interest and
Corporate Opportunities 32
Gifts and Entertainment 33
Procurement 34
Protection of Company Property
and Confidential Information 35
Protecting Information Technology 37
Ethical Matters Concerning
Government and the Community 38
Government Contracts 39
Dealing with Government
Officials and Employees 39
Investigations and Audits 40
Legally Protected Communications 41
Political Contributions and
Community Service 41
Conclusion 42
The Code Is Not Comprehensive 43
Administration of our Code 44
No Contract or Other Rights Created 45
Click heading to navigate directly to each topic.
Waivers of the Code 45
CODE OF BUSINESS ETHICS
Letter from the CEO
Thank you for making AutoNation America’s most admired automotive retailer. We take pride in operating our business with high standards of business conduct and in compliance with the law. These standards are critical to our continued success and our reputation for integrity when dealing with our fellow Associates, valued Customers, business partners and others.
AutoNation’s Code of Business Ethics and related policies support our commitment to lawful and ethical business conduct. The Code describes our standards of business conduct and helps us navigate legal and ethical dilemmas we may face. Our guiding principles are to be honest, fair, respectful and responsible in all workplace interactions and business dealings.
Every Associate is expected to read, understand, and follow our Code of Business Ethics and Business Ethics Policies.
In addition, each of us has a responsibility to report known or suspected violations of law or Company policy using the resources described in the Code. Remember, AutoNation has zero tolerance for retaliation, so we can have confidence when we raise issues or concerns.
Identifying and timely addressing potential issues prevents them from growing and is essential for us to maintain the high standard of ethical conduct to which we hold ourselves accountable. Please use the resources referenced in the Code to address any questions you may have about the law, ethics or Company policy.
I know each of us will do our part to ensure AutoNation maintains high standards of business conduct. Together we can protect the Company’s reputation, continue to deliver a wonderful Customer experience, and achieve even greater success.
Thank you for your contributions to AutoNation and your support of our Business Ethics Program. Sincerely,
Mike Manley
Chief Executive Officer
CODE OF BUSINESS ETHICS
OUR VISION, MISSION AND VALUES
AutoNation Vision
At AutoNation, our vision is to be “America’s best place to buy and service cars and trucks.” We strive to be the best in all facets of automotive retail through our shared ethical values and common
practices. Our vision is based on an uncompromising focus on the Customer. This vision shapes us as a Company that’s continuously improving and setting industry standards in all that we do.
AutoNation Mission
Our mission is simple. It is to deliver a “peerless Customer experience.” This means that our goal is to be the very best in the industry. We must provide a Customer experience better than everyone else.
Behaviors
D R I V E
Deliver Results
Respect Others
Ignite Performance
Value Accountability
Elevate the Business
Embrace and cherish competition
Deliver as a way of life
Drive to impress customers
Coach, empower, and develop others
Drive collaboration through respect and openness
Demonstrate humility
Be proactive
Have the courage to make tough calls
Develop plans and execute
Reach for discontinuity
Set incredibly high standards
Act with integrity and honesty
Hold yourself and others accountable
Benchmark the best and beat them
Know the marketplace
Make data-driven decisions
CODE OF BUSINESS ETHICS
Values
We are We are
driven to one
be great. AutoNation.
Every moment is an opportunity to make today better than yesterday
Leadership is Greatness earned every day. can be
We are a meritocracy.
measured.
Introduction and Overview
CODE OF BUSINESS ETHICS
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