THIRD PARTY CODE OF CONDUCT

Standard Purpose

Black Knight, Inc. (“Black Knight”) is a leading provider of integrated software, data and analytics solutions that facilitate and automate many of the business processes across the homeownership life cycle.  Black Knight is committed to being a premier business partner that our clients rely on to achieve their strategic goals, realize greater success and better serve their customers by delivering best-in-class software, services and insights with a relentless commitment to excellence, innovation, integrity and leadership.

Black Knight engages companies that have direct contractual relationships with Black Knight, to provide various goods and services (“Third Parties”). We expect Third Parties to demonstrate strong values and ethical practices and to operate in compliance with all applicable laws and regulations.

This Third Party Code of Conduct (“Code”) is subject to periodic updates and revisions reflecting Black Knight’ culture of continuous improvement.

Responsibilities

1.1.  Ethical Business Practices

Black Knight expects our Third Parties to aspire to the highest standards of integrity in their business dealings. This includes refraining from any and all forms of illegal or improper activity, including corruption, misrepresentation, extortion, embezzlement, or bribery. We also expect our Third Parties to engage in ethical employment practices, including the ethical treatment of their employees and third parties.

Third Parties are expected to report any actual or suspected violations of any applicable law, this Code, or to raise concerns about actual or suspected misconduct in connect with work performed for Black Knight to the Compliance and Ethics Hotline at www.blackknight.ethicspoint.com or 833-B-Knight (833-256-4448). Black Knight maintains a toll-free Compliance/Ethics Hotline that is operated by an independent third-party vendor and is available 24 hours a day, 7 days a week.

1.2 Disclosure of Conflicts of Interest

Black Knight expects its Third Parties to avoid any situation that creates or appears to create a conflict between personal interests and the interests of Black Knight. Third Parties are expected to disclose any situations of actual or potential conflicts of interest to Black Knight.

1.3 Employee Protection and Anonymous Complaints

Third Parties should provide an anonymous complaint mechanism for managers and employees to report workplace grievances and health and safety incidents. Third Parties should protect whistleblower confidentiality and prohibit retaliation, as well as maintain a system to investigate, track, and manage such reports.

1.4 Human Rights

The United States Government has adopted a policy prohibiting trafficking in persons, including trafficking-related activities, and Black Knight supports this policy. Our Third Parties and their agents shall not engage in forms of trafficking in persons.  Black Knight further seeks to support human rights by encouraging behaviors and practices that are consistent with the following:

• Freely Chosen Employment – Third Parties must not engage in or support human traficking, slavery, forced or involuntary labor.
• Prohibitionof Child Labor – Third Parties must not engage in the use of child labor and must only employ individuals who meet minimum legal age requirements in the country where the Third Party operates.
• Freedom of Association – Third Parties must allow its employees to lawfully form and join organizations and peacefully associate.
• Compensation and Working Hours – Third Parties must comply with applicable laws governing minimum wage, working and overtime hours, and legally mandated benefits.
• Health and Safety – Third Parties must comply with applicable laws that provide for the health, safety and welfare of its employees.
• Working Conditions – Third Parties must provide employees with reasonable access to clean toilet facilities and water.

1.5 Inside Information

Third Parties are strictly prohibited from buying or selling securities while in possession of material non-public information that the Third Party may acquire by virtue of its relationship with Black Knight. Further, a Third Parties communication of material non-public information to others is strictly prohibited whether the information is communicated expressly or by way of making a recommendation for the purchase or sale of such securities based upon the information.

1.6 Diversity and Inclusion

Third Parties are required to comply with all applicable laws concerning hiring and employment practices. Third Parties should actively demonstrate a commitment to equality, diversity and inclusion through all aspects of workplace management giving clear consideration to equality of opportunity in employment. Third Parties should promote a workplace free from discrimination, harassment, or any other form of inappropriate behavior or abuse on any grounds.

1.7 Environmental Stewardship

We encourage our Third Parties to implement systems designed to minimize its impact on the environment. Black Knight values business relationships with Third Parties who have developed and implemented internal programs fostering a culture of sustainability and increasing environmental stewardship in the local community.

Definitions

Terms	Term Definitions
Third Party	Refers to any company, its employees, subsidiary, affiliate or subcontractor that supplies or provides goods or services to Black Knight, or for use in or with Black Knight products.
Material nonpublic information	Information about the securities, activities, or financial condition of Black Knight. Information is material if it could have an impact on the market price of securities involved or if it is likely that a reasonable investor would consider the information important in deciding whether to purchase or sell the securities. Information is “nonpublic” unless it is clearly public.