EXHIBIT A
CODE of CONDUCT

ENTERPRISE HOLDINGS
SINCE 1957, ENTERPRISE HOLDINGS’ EMPLOYEES HAVE 

EXCEEDED CUSTOMERS’ EXPECTATIONS BY BUILDING 

RELATIONSHIPS ONE HANDSHAKE AT A TIME AND ONE 

KEPT PROMISE AT A TIME.

Our organization is only as strong as the reputation that each of us maintains in the 

minds of customers, business partners, vendors, and employees. That is why we have 

made holding ourselves to the highest standards of business ethics and conduct the 

personal responsibility of every employee. It is one of our founding values.

The principles articulated in this Code of Conduct shine through in our culture, 

and they will not change. We communicate these timeless principles to employees 

each year because they remain fundamental to everything we say and do. We strive 

to demonstrate these principles every day. That may not always be easy, but you 

should understand that no financial objective outweighs our commitment to ethics, 

integrity, and compliance with applicable law. If you find yourself in a difficult situation 

where the right choice isn’t clear, ask your supervisor for guidance. You can also 

speak to another resource listed in this Code, or call the Ethics Hotline. You will 

never experience retaliation for asking a question or reporting a concern.

The commitment, integrity, and hard work of all employees have made Enterprise 

Holdings the No. 1 total transportation provider in the world. Our values of respect, 

dignity, and customer service have fueled our success—and those values provide 

the foundation we will build upon for years to come.

LETTER from our CHIEF EXECUTIVE OFFICER

Enterprise Holdings, Inc., owns a network of regional subsidiaries in the United States which operate the Enterprise Rent-A-Car, 

National Car Rental and Alamo Rent A Car brands, as well as Enterprise Car Sales, and Enterprise Car and Ride Sharing. In the 

rest of the world, Enterprise Holdings, Inc., owns international subsidiaries that similarly operate a portfolio of car rental brands 

through an integrated global network of regional subsidiaries and franchises. Additionally, Enterprise Holdings, Inc.’s affiliate, 

Enterprise Fleet Management, Inc., operates a fleet management and leasing business in the United States and its subsidiary 

similarly operates this business in Canada. This Code of Conduct (Code), and the policies and principles underlying it, have been 

adopted by Enterprise Holdings, Inc., Enterprise Fleet Management, Inc., and, individually, by management of each subsidiary 

company. The word ”Company,” where used in the Code, refers to Enterprise Holdings, Inc., Enterprise Fleet Management, Inc., 

and/or, in their individual capacities, each subsidiary company.

CHRISSY TAYLOR

PRESIDENT AND CHIEF EXECUTIVE OFFICER
our FOUNDING VALUES

THE VALUES THAT DEFINE US AND DRIVE US

OUR BRANDS are the most valuable thing we own.

PERSONAL HONESTY AND INTEGRITY

are the foundation of our success.

CUSTOMER SERVICE is our way of life.

Our company is a fun and friendly place where

TEAMWORK RULES.

We work hard... and WE REWARD HARD WORK.

GREAT THINGS HAPPEN WHEN WE LISTEN...

to our customers and to each other.

WE STRENGTHEN OUR COMMUNITIES,

one neighborhood at a time.

Our doors are OPEN.

1
Upholding our standards on integrity.

INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . 3

Why We Have a Code of Conduct. . . . . . 3

Who Should Follow The Code?. . . . . . . . 3

What Laws Must We 

Know and Follow?. . . . . . . . . . . . . . . . . . . 4

Obligations of Supervisors. . . . . . . . . . . . 4

What Are the Consequences 

of Code of Conduct Violations?. . . . . . . . 4

Great things happen when 

we listen to each other.

REPORTING VIOLATIONS. . . . . . . . . . . . . . 5

How to Report Concerns and 

Where to Go for Guidance. . . . . . . . . . . . 5

How We Investigate Reports. . . . . . . . . . . 5

Customer service is our way of life.

SERVICE. . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

We Provide Quality Products 

and Services. . . . . . . . . . . . . . . . . . . . . . . 6

We Deal Fairly with Customers 

and Suppliers. . . . . . . . . . . . . . . . . . . . . . 6

We Represent Our Company 

Fairly and Accurately. . . . . . . . . . . . . . . . . 7

We Protect Third-Party Information. . . . . 7

Our Procedures for Working 

with Government Customers. . . . . . . . . . 7

The foundation of our success.

HONESTY AND INTEGRITY. . . . . . . . . . . . 8

We Keep Honest and Accurate 

Books and Records. . . . . . . . . . . . . . . . . . 8

How We Respond to Inquiries 

from the Media. . . . . . . . . . . . . . . . . . . . . 8

We Avoid Conflicts of Interest. . . . . . . . . . 9

We Comply with Anti-Corruption Laws. . 11

Insider Trading. . . . . . . . . . . . . . . . . . . . . 12

We Comply with Competition Laws. . . . 12

We Protect Company Assets 

and Information. . . . . . . . . . . . . . . . . . . . 13

Our doors are always open.

TEAMWORK. . . . . . . . . . . . . . . . . . . . . . . . 14

We Uphold Respect in Our Workplace. . 14

We Value the Safety and 

Health of Employees. . . . . . . . . . . . . . . . 14

We Support Fair and 

Just Employment Practices. . . . . . . . . . 15

We Use Company 

Computer Systems Properly. . . . . . . . . . 15

We Respect Employee Privacy. . . . . . . . 15

Strengthening communities, 

one neighborhood at a time.

LOCAL ENGAGEMENT. . . . . . . . . . . . . . . 16

We Support Sustainability Practices. . . . 16

We Support Charitable Causes 

and the Political Process. . . . . . . . . . . . . 16

SUMMARY AND 

ACKNOWLEDGEMENT. . . . . . . . . . . . . . . 17

TABLE of CONTENTS

2 ENTERPRISE HOLDINGS CODE of CONDUCT
WHY WE HAVE A 

CODE OF CONDUCT

The Code of Conduct explains the standards of integrity 

we are all expected to uphold in our daily business 

interactions. We all make decisions every day that shape 

our work environment and the Company. In order to 

maintain a positive environment for each other, exceed 

our customers’ expectations, and ensure the Company’s 

continued success, we must understand and embrace 

the standards contained in the Code. Although not every 

situation we encounter can be covered in these pages, 

this document is intended as a guideline for achieving 

and maintaining the highest ethical business practices. 

Your own personal values and instincts should lead 

you to the proper decisions, but if you are ever unsure 

about the right course of action, it is best to ask your 

immediate supervisor for advice prior to making any 

decision. As you work your way through difficult issues, 

keep these questions in mind:

Is it legal?

Is it the right thing to do?

Can you justify it to... 

 your customers? 

 your fellow employees?

 your supervisor?

If the answer to any of these questions is “no,” or if you 

are not sure, seek appropriate advice before acting.

WHO SHOULD 

FOLLOW THE CODE?

The Code applies to all of us regardless of our position 

within the Company. All of us are expected to follow the 

principles outlined in the Code and Company policies, to 

act with integrity in all business transactions, and to treat 

each other with respect at all times. Doing what is right is 

a personal responsibility and must always be an integral 

part of the Company’s mission. Additionally, we expect 

that Company suppliers, business partners, consultants, 

and licensees and franchisees will follow similar principles. 

Our Supplier Code of Conduct and Franchisee Code of 

Conduct explain more about this expectation.

Upholding our standards on integrity. 

We make decisions 

every day that shape 

our work environment. 

3

INTRODUCTION
WHAT LAWS MUST WE 

KNOW AND FOLLOW?

It is imperative that we always follow the law—wherever 

we are located. Keep in mind that laws vary based 

upon location, so if you are ever unsure about whether 

something is allowed, you should seek guidance before 

taking action. Additionally, each of us is expected to 

know and follow all laws and regulations that specifically 

apply to our jobs. If you are ever in a situation where 

local law or custom is at odds with what is outlined in 

the Code, follow the more stringent standard or seek 

clarification from your supervisor, your Compliance and 

Ethics Committee, or the Corporate Compliance and 

Ethics Department. 

OBLIGATIONS OF SUPERVISORS

Employees in leadership positions are expected to 

do just that—lead by example and promote an opendoor policy where employees feel comfortable raising 

questions or concerns. When employees bring issues to 

their supervisors’ attention, those leaders are expected 

to address concerns and resolve them appropriately. It is 

also their obligation to monitor the business conduct of 

the employees who report to them to ensure compliance 

with the Code. Finally, supervisors are required to make 

sure the employees who report to them are trained on 

the Code and all relevant policies. 

It is especially important that supervisors promptly report 

any known or suspected violation of the Code or the law 

and never retaliate or ignore acts of retaliation against 

others. Supervisors who know—or should have known—

about a violation but fail to report it may be subject to 

discipline up to and including termination.

WHAT ARE THE 

CONSEQUENCES OF 

CODE OF CONDUCT 

VIOLATIONS?

Violations of the Code may result in disciplinary action 

up to and including termination. For violations of the 

Code that also break the law, the individuals involved 

may be subject to civil action or criminal prosecution. 

While certain sections of the Code point out the potential 

consequences of violations, be aware that the Company 

retains the right to apply disciplinary action for any 

act of misconduct. 

We always 

follow the law.

4 ENTERPRISE HOLDINGS CODE of CONDUCT

INTRODUCTION
HOW TO REPORT 

CONCERNS AND WHERE 

TO GO FOR GUIDANCE

One of our Founding Values is “Great things happen 

when we listen to each other.” This means that each of 

us should always feel comfortable coming forward and 

reporting concerns. If you have observed or suspect a 

violation of the Code or the law, you are encouraged 

to report it to your immediate supervisor. If you are 

uncomfortable going to your immediate supervisor for 

any reason, consider contacting any of the resources 

listed below for guidance:

 Your next-level supervisor 

 The Human Resources Department

 The Compliance and Ethics Committee

Additionally, you may report concerns through the ethics 

hotline. A link to the hotline for online reporting, as well as 

a toll-free number for telephonic reporting, are available 

on the intranet home page and HUB. Both services 

are monitored 24 hours a day, 365 days a year, by an 

independent third-party provider. Both the website and 

the toll-free number allow you to report anonymously, 

where allowed by law. 

Everyone is encouraged to report unethical or illegal 

behavior. The Company will not tolerate retaliatory acts 

toward anyone who makes a report. 

HOW WE INVESTIGATE REPORTS

All reports, however submitted, will be investigated 

promptly and thoroughly, and the Company will take 

corrective action when warranted. Reports will be 

handled confidentially within the limits of the law. 

Great things happen when 

we listen to each other.

Report to your Immediate 

Supervisor, Next-Level Supervisor, 

or Human Resources

Report to the Compliance 

and Ethics Committee

Report through 

the Ethics Hotline

Everyone is encouraged to report 

unethical or illegal behavior.

5

REPORTING VIOLATIONS
WE PROVIDE QUALITY 

PRODUCTS AND SERVICES

Our customers trust us to provide properly maintained, 

reliable vehicles and uncompromising service across all 

of the Company’s brands. Therefore, we must comply 

with applicable laws, regulations, and internal processes 

when it comes to maintaining our fleet of vehicles. If you 

have any concerns about the safety of our vehicles or the 

quality of our service, you should promptly report them. 

Additionally, we maintain customer trust by holding 

Company suppliers accountable for the quality and 

safety of the products and services they provide to 

us. If you believe that a supplier is not meeting our high 

standards of quality and safety, you are encouraged 

to report the situation. 

For more information, please refer to 

our Supplier Code of Conduct.

WE DEAL FAIRLY WITH 

CUSTOMERS AND SUPPLIERS

We build loyal, long-term relationships with our customers, 

business partners, and suppliers by treating them fairly 

at all times. These relationships, sustained by personal 

honesty and integrity, are the foundation of our success. 

Our dedication to fair dealing means that we provide 

only honest and accurate information to our customers 

and business partners. We do not misrepresent facts or 

engage in unethical or illegal conduct.

We maintain an uncompromising focus on customer 

service—whether it is Enterprise Rent-A-Car’s attentive, 

personalized service, the price and efficient service of 

Alamo, the speed and choice of offerings at National, or 

the “no-haggle” pricing of Car Sales. Customers seek 

out—and stay with—our brands and services because 

we truly believe in and deliver on complete customer 

satisfaction every day. Our goal is to exceed every 

customer’s expectations. 

We deliver our products and services to customers 

without favoritism or discrimination. We do not solicit 

tips, gratuities or other consideration for delivering 

products and services. Just as importantly, we honor our 

commitments and keep our promises. We communicate 

clearly and immediately clarify misunderstandings. We will 

always go the extra mile to ensure our customers’ loyalty.

We have learned that when we truly listen to our 

customers and understand their needs, they come 

back. This leads to opportunities—from little ways to 

serve them better, to new lines of business that open 

up exciting growth prospects for the Company.

Customer service is our way of life.

We honor our 

commitments 

and keep our 

promises.

6 ENTERPRISE HOLDINGS CODE of CONDUCT

SERVICE 
WE REPRESENT OUR COMPANY 

FAIRLY AND ACCURATELY

The Company believes in competing vigorously but 

fairly, which means that those of us involved in marketing, 

advertising, or sales must ensure that we only make 

accurate statements about our capabilities. We must 

remain accurate and truthful when representing the quality, 

features, or availability of any of our products or services.

WE PROTECT 

THIRD-PARTY INFORMATION

Our customers, suppliers, and other business partners 

frequently entrust us with confidential information that we 

agree to protect from disclosure or misuse. This means 

we diligently abide by all non-disclosure or confidentiality 

agreements that apply to us. Our obligation to protect 

this confidential information may continue even after our 

relationship with the third party or our employment ends. 

We also respect all third-party rights protected by 

copyright, trade secret, patent, or other intellectual 

property laws. This means, in part, that we may not 

install or distribute software products on Companyowned computers that are not appropriately licensed 

for such use. In addition, we may not make unauthorized 

copies of any copyrighted material. 

For more information, refer to the Personnel 

Policies Summary.

OUR PROCEDURES 

FOR WORKING WITH 

GOVERNMENT CUSTOMERS 

When working with government customers, we must 

follow certain laws and regulations that are often much 

stricter and more complex than those that govern our 

other business transactions. Be aware that violations of 

these rules can result in substantial fines, the loss of future 

government contracts, and even criminal prosecution for 

the individuals involved and the Company. 

Specific rules apply to doing business with the U.S. 

Government. If your work involves marketing or selling 

to, or contracting with or working on projects for, a U.S. 

Government agency, it is your responsibility to know and 

follow the particular rules that apply. This section does 

not provide all of the information and guidance we need 

to ensure that we are complying with the law. 

Please refer to the U.S. Federal Government 

Handbook for more information. 

Q A James tells customers that their regular car 

insurance won’t cover damages to the rental vehicle 

if they’re in an accident. He knows that it really 

depends on each customer’s insurance policy, 

and that many customers actually are covered for 

damage to a rental car. 

Still, this approach helps him sell more damage 

waiver protection, so he decides to keep giving 

customers this information. Is this ok?

No. James should not give customers 

information that he knows is potentially 

misleading, even if he thinks it is helping 

the bottom line. 

We have a responsibility to provide our 

customers with accurate information about 

the Company and its products. Doing so helps 

us maintain strong relationships and generate 

long-term business.

7
WE KEEP HONEST 

AND ACCURATE BOOKS 

AND RECORDS

Our customers, suppliers, business partners, lending 

sources, regulatory authorities, and fellow employees 

trust us to report transactions and events in a clear, 

concise, truthful, timely, and accurate manner. Every 

record and accounting entry must be accurate and may 

not hide or disguise the true nature of any transaction. 

Every one of us, regardless of our position within the 

Company, has an obligation to make sure that the 

information we record meets these standards. Our 

financial records must conform to both generally 

accepted accounting practices and our own system 

of internal controls. 

We each must do our part to make sure that the 

information we enter, such as that in time sheets, 

expense reports, and other reports, is accurate. In 

addition, we need to submit reports in a timely manner 

and always include full and appropriate documentation 

when submitting contracts for processing or payment. 

You are encouraged to report any questions or concerns 

about accurate books and records.

Properly maintaining Company 

books and records is as important 

as accurately creating them. 

We have established procedures for maintaining 

documents and files for required periods and destroying 

them when they are no longer needed. For more 

information regarding our data-retention guidelines, 

reach out to your supervisor or Business Manager.

From time to time, you may be notified about 

documents relevant to a pending, threatened, 

or anticipated litigation, investigation, or audit. 

We each have an obligation to cooperate with internal 

and external inquiries conducted by auditors, attorneys, 

investigators, or government agencies. Never destroy, 

alter, or hide a document in anticipation of or in response 

to such a request, and do not destroy any document 

potentially covered by a request without the express 

authorization of the Legal Group. If you receive a 

request for information from a government agency, 

as necessary or appropriate, notify the Legal Group 

before providing any information. 

HOW WE RESPOND TO 

INQUIRIES FROM THE MEDIA 

If you are contacted by a member of the media, you 

should refer them to Corporate Communications 

at reporterinquiries@ehi.com and notify your 

supervisor. Doing so allows for a complete and 

consistent message by the company.

The foundation of our success.

Q Stephanie’s branch is understaffed at 

the moment. Her manager promises 

that it won’t last for long, but in the 

meantime, everyone needs to work—

but not record—extra hours. He 

promises that he will make sure 

everyone gets some extra time off 

to make up for it.

Should Stephanie do as her 

manager asks?

A No, Stephanie should accurately 

record all the hours she works. 

Her manager should not have made 

this request. It is important for all the 

information we record for any purpose 

to be honest and accurate. Stephanie 

should report the request made by 

her manager to the Human 

Resources Department.

8 ENTERPRISE HOLDINGS CODE of CONDUCT

HONESTY AND INTEGRITY
WE AVOID CONFLICTS 

OF INTEREST

A conflict of interest occurs when one’s personal 

interests interfere with their ability to make unbiased 

decisions on behalf of the Company. When performing 

your job, you should base your actions on sound 

business judgment and not be motivated by personal 

gain. Any situation that creates or appears to create 

a conflict between your personal interests and those 

of the Company must be avoided. If you find yourself 

confronted with any of the situations described below, 

or if you are ever in doubt as to whether a business 

relationship is appropriate, you should bring the situation 

to your supervisor’s attention at once to determine the 

best course of action. Remember, having a conflict of 

interest is not always a violation of the Code, but failing 

to disclose the situation might be.

Gifts and Entertainment

The providing or exchanging of gifts and other things of 

value are common courtesies that can serve to enhance 

our business relationships with our customers, business 

partners, and suppliers. However, we never want any 

courtesy to compromise an individual’s ability to make 

objective and fair business decisions. 

Accepting or giving things of value is subject to 

restrictions relating to monetary value, how often you 

may give to or receive something from an individual, 

and other factors. The Anti-Corruption Policy provides 

detailed information on this topic. 

You should note that the rules surrounding gifts 

to or entertainment of government officials are much 

stricter than those relating to non-government entities. 

Please refer to the Anti-Corruption Policy and the “Our 

Procedures for Working on Government Contracts” and 

“We Comply with Anti-Corruption Laws” sections of the 

Code for more information. If you have any questions 

about acceptable gifts or entertainment, please 

contact your supervisor or the Legal Group 

before acting. 

Improper Personal Benefits

Unless otherwise made generally available to all of us, 

we are not allowed to accept special personal pricing for 

goods or services in our relationships with customers or 

suppliers because this would be considered a personal 

gift. Whenever special group pricing is available from 

a supplier, this arrangement should in no way obstruct 

our pricing arrangements or purchasing decisions. 

We should not offer special personal pricing to our 

customers or suppliers outside the requirements of 

certain contracts or our established discount programs. 

Q Shantelle works at an Enterprise Car Sales 

dealership. The dealership has a contract 

with a maintenance company that cleans the 

facilities on a regular basis. When she reviews 

an invoice from the maintenance company, 

Shantelle notices that they are billing the 

Company at a lower hourly rate than their 

contract specifies. 

Even though the lower rate would be saving 

the dealership money, she decides to reach 

out to the maintenance company to point 

out the error. Is she doing the right thing?

A Yes, she is. 

We need to follow the terms of all 

our contracts and make sure all invoices we 

receive and payments we make are correct.

9
Financial Investments 

A conflict of interest can also arise if you, your family 

member, or a close friend has a personal or material 

financial stake in a company that is our supplier, potential 

supplier, or competitor. If you find yourself in that 

situation, you must not use your position to influence 

the bidding process or negotiation in any way. If you 

are directly involved in supplier selection, notify your 

supervisor immediately and remove yourself from the 

decision-making process. If you have a family member 

or close friend who works for a competitor, you need 

to notify your supervisor.

Never use your position to 

influence a bidding process 

or negotiation in any way.

Outside Employment

Sometimes taking outside employment may create a 

potential conflict of interest. We may not take another 

job that interferes with our ability to do our work, such 

as conducting outside business during working hours 

or using Company property, equipment, or information 

for non-Company use. In addition, we must not take 

outside employment with a supplier or competitor of our 

Company. Because taking an outside job may create a 

conflict of interest, you must notify the Human Resources 

Department before you do so. Similarly, serving on 

the board of directors or a similar body for an outside 

company or government agency requires the advance 

approval of the Human Resources Department. 

Corporate Opportunities

Through your work or through contacts with customers 

or suppliers, you may become aware of an opportunity 

to make a purchase or investment in which the Company 

(whether subsidiary or holding company) might be 

interested. You must promptly notify your supervisor of the 

opportunity. You may not act on the opportunity privately 

before the Company has had a chance to evaluate it and 

has decided to pass on it. Any personal investments must 

be in accordance with Company policy.

Personal Relationships

It is also important to avoid supervising family or 

individuals with whom you have a personal (i.e. intimate, 

romantic) relationship, even indirectly. If a personal or 

family relationship between employees exists—especially 

if it is also a reporting relationship—it may seem that 

one employee could receive preferential treatment or 

favoritism. For this reason, you should never be placed 

in a position where you have direct decision-making 

authority over a family member or someone with whom 

you have a personal relationship, or vice versa. 

Remember, the important thing is to avoid even the 

appearance of bias. In the event a relationship is desired 

or anticipated to develop, you should disclose this to 

your supervisor so that it may be evaluated for any 

potential conflicts of interest. 

For further information, refer to the Personnel

Policies Summary.

Q A Robert works with a local body shop that repairs 

cars from Enterprise on a regular basis. Over the 

years, he’s become friendly with the owner of the 

business, Juan. He learns that Juan will celebrate 

his tenth anniversary of being in business. 

Can Robert send him a small gift basket to mark 

the occasion?

Probably—but Robert needs to check with 

his supervisor before sending the gift, to 

make sure it meets all of our guidelines. 

We may offer gifts only in specific situations, 

and only if they meet our requirements. Ask 

your supervisor if you have questions about 

whether a gift is appropriate.

10 ENTERPRISE HOLDINGS CODE of CONDUCT

HONESTY AND INTEGRITY
WE COMPLY WITH 

ANTI-CORRUPTION LAWS

Anti-corruption laws apply to our business activities 

throughout the world. These laws are complex and the 

consequences for violations are severe. We comply with 

the anti-corruption and anti-bribery laws of the countries 

in which we do business. 

A “bribe” is generally anything of value—including money, 

gifts, discounts, favors, and entertainment—that is given 

in an attempt to improperly influence the recipient’s 

actions or decisions. We cannot offer or accept a bribe, 

or “kickback,” as a reward for making or fostering 

business arrangements.

Commercial Bribery

We must be cautious to never engage in commercial 

bribery or give the appearance of doing so. “Commercial 

bribery” includes any situation where something of value 

is given—to us or by us—in the hopes of improperly 

influencing a business action or decision. This is not allowed 

whether done directly or indirectly through a third party.

Government Officials

Dealings with government officials require heightened 

care. You should never provide anything of value to 

a government official in return for an official action. 

There are specific laws that prohibit bribes or attempts 

to bribe government officials, employees of entities in 

which a government has a controlling or ownership 

interest (such as an Airport Authority), political party

officials, or candidates for public office. Many governments 

are taking steps to combat corruption and many countries 

have specific, stringent laws against it. 

If you interact with government officials, be sure 

to review all applicable policies. Raise any questions 

promptly with your supervisor or the Legal Group.

For more information, refer to the Anti-Corruption 

Policy. If your business is with the U.S. Government, 

you should also refer to the U.S. Federal 

Government Handbook.

Third Parties

We cannot hire third parties to do something we ourselves

are not allowed to do. Remember, our agents and 

consultants are held to the same rules that we are. For 

example, the Company may be liable for indirect payments

even if we do not know, but should know, that the payment 

is being made to influence a business action or decision. 

For more information about anti-corruption 

and bribery refer to the Anti-Corruption Policy

and the section of the Code above titled “Gifts 

and Entertainment.”

Q Layla, a Vehicle Repair Supervisor, 

is married to Jason, who manages an 

auto repair shop. The contract for car 

maintenance at a branch within Layla’s 

area is up for renewal, and she has not 

been satisfied with the current vendor. 

Layla would like to award the contract 

to her husband’s business instead. 

Since she has approval over this 

contract, can she award it to anyone 

who is qualified? Is this ethical?

A No, Layla has a conflict of interest 

in this situation because of her 

personal tie. 

She should hand this decision to her 

supervisor so that the vendor selection 

can be made impartially and with the 

Company’s best interests in mind. 

Even if Jason’s business is the best 

candidate, the selection would seem 

biased and unfair if the decision was 

made by Layla.

11
INSIDER TRADING

To do our jobs effectively, we may have access to “inside 

information” about the companies we do business with 

that is not available to people outside the Company. 

“Inside information” is material information that is not 

available to the public, or information that a reasonable 

investor would likely consider important in making a 

decision to buy or sell a security. Remember that even 

information about events or actions that are not certain to 

happen—such as the possible signing of a contract or sale 

of a subsidiary—can be considered inside information.

Buying or selling the securities of a company while you 

are aware of inside information about that company is 

considered “insider trading.” This practice is illegal, and 

so is “tipping,” or advising others to buy or sell securities 

based on inside information. 

If you have any questions, refer to the Insider Trading

Policy or consult the Legal Group. 

WE COMPLY WITH 

COMPETITION LAWS

We believe in vigorous competition, but we will always 

compete in an ethical manner. Information about 

market trends and about our competitors, customers, 

franchisees, and suppliers is a valuable asset to us. 

We must only gather this information in legal and 

ethical ways, never by theft or deception. 

Acceptable methods of gathering information include 

any source available to the general public, such as 

published articles or Internet research, surveys conducted 

by consultants, or information provided by customers 

or vendors as long as they are not violating an existing 

confidentiality agreement or offering the information to us 

in return for a preferential business deal. It is never all right 

to ask a colleague to reveal confidential information about 

a former employer or a business partner or customer 

to reveal competitive information that they are required 

to keep confidential.

If you inadvertently learn of information you suspect may 

be confidential, you must not share it or use it without 

first receiving advice from the Legal Group. You should 

not use information you have not acquired legally. 

Competition laws prohibit practices that restrain trade. 

In complying with competition laws, we must avoid 

discussing any of the following with competitors:

 Division or allocation of markets, customers, 

or territories

 Prices or price-related information, such as 

promotional spending, terms, costs, marketing, 

or bids for work or contracts

 Limitation of services provided 

Competition laws also generally prohibit entering into 

formal or informal agreements with suppliers or customers 

that may restrict competition. Such agreements include 

fixing resale prices, pricing below cost, boycotting 

particular customers or suppliers, and in some cases, 

providing exclusive or “most-favored” arrangements.

Q Nigel has been trying to close a deal 

with a local company. He has named his 

final price, which the other company has 

rejected. Before leaving the meeting, the 

representative of the other company says, 

“You know, we’re not that far apart, and 

it really is in both our companies’ interest 

to get this done. How about we just split 

the price difference? And to show our 

appreciation for being such a good partner, 

we could do something nice for you. Our 

company has four seats at midfield for this 

week’s playoff game. I’m sure you and your 

family would enjoy going to the game.” 

What should Nigel do?

A Nigel should not agree to this deal. The 

representative is trying to bribe him in order 

to secure better pricing. 

While he may have the latitude to split 

the price difference after naming his final 

price, if he were to do that in exchange 

for sporting event tickets he would be in 

violation of our Anti-Corruption policy and 

could also be in violation of laws that might 

subject him to fines and imprisonment. 

Instead, Nigel should refuse the deal and 

report the activity to his supervisor for 

follow-up. No deal is worth compromising 

the integrity of the Company. 

12 ENTERPRISE HOLDINGS CODE of CONDUCT

HONESTY AND INTEGRITY
Remember that even the appearance of collusion 

can pose serious problems for the Company, so if 

a competitor attempts to discuss any of these topics, 

you should stop the conversation immediately and 

report it to the Legal Group. Be especially mindful of 

your conversations at industry association meetings or 

other events where you are likely to interact with our 

competitors. 

Be mindful of 

your conversations.

Violations of competition laws can result in serious 

consequences—including criminal sanctions—for the 

Company as well as for the individuals involved. If you 

have marketing, sales, or purchasing responsibilities, 

you should be familiar with the competition laws that 

apply to your job.

If you need further guidance, refer to the 

Competition Policy or seek advice from the 

Legal Group.

WE PROTECT COMPANY 

ASSETS AND INFORMATION

Theft, carelessness, and waste have a direct impact on 

our brand, reputation, profitability, and ultimate success, 

so we must all take responsibility for the Company’s 

assets and expenditures. These assets are both tangible 

and intangible. Our physical assets include our supplies, 

equipment, facilities, vehicles, and documents. We are 

expected to use these assets in a professional and 

ethical manner, for business purposes only, maintain 

them in a good condition and secure them properly to 

protect them from compromise, damage, or theft. 

To protect our brand and maintain our competitive 

advantage in the marketplace, we also have a duty to 

protect the Company’s intangible assets: confidential 

information and intellectual property. This includes 

customer and employee personal information, trade 

secrets, financial information, computer files, vehicle 

telematics data, customer lists, and marketing plans. 

We protect this information, in part, by limiting access 

to those who have a business need to know it, securing 

the systems that transmit or store it, and ensuring 

our use of the information complies with privacy laws. 

This means, in part, that we properly collect and use 

personal information in accordance with our Privacy 

Principles, Global Privacy Policy, and Personnel 

Policies Summary. As a rule, we take every precaution 

necessary to avoid the improper release of proprietary 

or confidential information. For more information, refer 

to the Data Classification Policy. 

If you suspect or know of any misuse or compromise 

of the Company’s assets, or the making of improper 

expenditures, you are encouraged to report it. 

Q Cathy is the manager of an Enterprise rental 

branch at a large airport, and she is good 

friends with Sofia, who manages a branch of 

another car rental service at the same airport. 

Sofia comments that business has been a 

little bit slow lately, and she is having trouble 

meeting her financial targets. She says, “Why 

don’t you and I both raise our rates? We’d 

make more money.” 

What should Cathy do?

A Cathy should end the conversation 

immediately and tell her supervisor about it. 

What Sofia is suggesting is called “pricefixing,” and it is illegal. We make all pricing 

decisions independently, never by colluding 

with other companies. For advice about 

competition law, contact the Legal Group.

13
WE UPHOLD RESPECT 

IN OUR WORKPLACE

We believe that the success of our mission depends on 

the contribution of every member of our team. We are 

dedicated to providing each other with an atmosphere 

and culture that allow us to openly share ideas and 

feedback, resolve problems, and work effectively as 

team members to exceed our customers’ expectations 

by creating a pleasing business experience. 

More specifically, we are committed to the following:

 Respect for differences in the backgrounds, 

experiences, and perspectives of each other, 

our customers, suppliers, and business partners

 An environment free from discrimination against an 

employee or applicant for employment based on 

race, color, religion, sex, national origin, disability, 

age, sexual orientation, gender identity, veteran 

status, or any other status protected by law 

 An environment free from intimidation and 

harassment of any sort

While harassment may have different definitions in 

various locations, unlawful harassment is any unwelcome 

behavior toward another person relating to a person’s 

legally protected characteristics that have the purpose 

or effect of creating an intimidating, hostile, or offensive 

work environment. Such conduct may be physical, 

sexual, or psychological and may include:

 Unwanted sexual attention 

 Derogatory comments, slurs, or name calling

 Displays of offensive or derogatory posters, 

pictures, drawings, or gestures

 Assault, unwanted touching, bullying, 

or intimidation

If you feel that you or someone else is being harassed 

or discriminated against, contact any of the resources 

listed in the “How to Report Concerns and Where to 

Go for Guidance” section above. Your concerns will be 

investigated and appropriate disciplinary action will be 

taken, as necessary. Remember, the Company prohibits 

acts of retaliation against you for reports of harassment 

or discrimination. 

Please refer to the Personnel Policies Summary

for more information. 

WE VALUE THE SAFETY AND 

HEALTH OF EMPLOYEES

The Company values a safe and healthy workplace for 

us all. To reach that goal, we must always observe traffic 

laws and safe driving practices. This means we follow 

Our doors are always open.

Q A Aisha works in a rental location, and she 

sometimes works evening shifts with her 

coworker Ron. He often compliments her 

appearance or makes suggestive comments. 

He says he’s “just kidding,” but it’s starting 

to make Aisha uncomfortable. 

What should she do?

Aisha should advise Ron that she is uncomfortable 

with his comments and ask him to stop. She may 

also wish to speak to her supervisor or the Human 

Resources Department about Ron’s behavior 

as these unwelcome comments could qualify 

as harassment. 

We want to create a work environment where 

everyone feels valued and respected, and we 

never tolerate harassment. 

14 ENTERPRISE HOLDINGS CODE of CONDUCT

TEAMWORK
safe working procedures at all times and actively work 

to prevent accidents. We also observe all posted safetyrelated signs and use all prescribed safety and protective 

equipment. If you become aware of any threat to the 

safety of a fellow employee, customer, visitor, or facility, 

report it immediately to your supervisor. 

The use, sale, possession, manufacture, or distribution 

of any illegal drug or unauthorized controlled substance 

(including marijuana) by employees is prohibited. The 

consumption of alcohol is prohibited while working, 

whether on Company premises or offsite, and while 

driving Company vehicles. Reporting to work under 

the influence of alcohol or drugs is also prohibited. 

The Company will not tolerate threats, violent acts, or 

any other form of workplace violence. If there is a violent 

incident in the workplace, the aggressors will be subject 

to disciplinary action, up to and including termination, 

as well as criminal prosecution. Report any form of 

workplace violence to your supervisor. 

You may refer to the Personnel Policies Summary

for more information. 

WE SUPPORT FAIR AND JUST 

EMPLOYMENT PRACTICES

The Company will not tolerate child labor, forced labor, 

or any other unacceptable treatment of workers at 

any of our locations, and we will not knowingly partner 

with companies that do. Specifically, this means that 

we do not permit exploitation of children, physical 

punishment or abuse, or involuntary servitude. 

The Company follows all applicable wage and 

hour laws, including minimum wage, overtime, 

and maximum hour rules.

WE USE COMPANY COMPUTER 

SYSTEMS PROPERLY

Our business relies on computers, electronic information, 

and access to network systems to ensure successful 

performance. It is important that you use this technology 

for appropriate business purposes and in accordance with 

our policies. It is not appropriate to use the Company’s 

systems to transmit junk or chain email. 

Be sure to compose email, instant messages, and text 

messages with the same care you take in composing 

any other Company document. Electronic messages are 

lasting and recoverable written records and can easily be 

copied and forwarded without your knowledge or consent. 

You should not expect privacy when using companyowned or issued equipment or systems, including email or 

the Internet. The Company reserves the right to monitor 

email and Internet access on its computers or through its 

network to ensure they are used appropriately. Monitoring 

activities, when undertaken, will comply with any and all 

legal requirements. 

Exercise care whenever posting to blogs, social 

networking sites, or chat rooms, as your posts may be 

interpreted as the official views of the Company. Don’t: 

 Share proprietary data, trade secrets, internal 

reports, or customer information 

 Respond to online customer comments or 

complaints about the Company, its brands, or its 

industry—a dedicated team of customer service 

specialists monitors and addresses such issues

 Use another person’s or company’s property—

such as images, logos, or trademarks—unless you 

have specific permission

For more information, please refer to the Personnel

Policies Summary. 

WE RESPECT 

EMPLOYEE PRIVACY

The Company is committed to protecting the privacy 

of its employees’ private information, including their 

protected health information. We will act in compliance 

with all applicable laws regarding the accessing, 

receipt, use, or disclosure of employee health 

or medical information.

For more information, please refer to the 

Personnel Policies Summary. 

15
Strengthening communities, 

one neighborhood at a time.

WE SUPPORT CORPORATE 

SOCIAL RESPONSIBILITY

We are engaged in thousands of communities of all 

sizes, providing strategic transportation solutions while 

also promoting growth and prosperity. That means we 

take a long-term view and focus on how best to meet 

customer demand and local ground-transportation 

needs, today and tomorrow.

In addition, the Company is firmly committed to 

conducting business in compliance with all applicable 

environmental laws, regulations, and permits. 

For more information about our long-term, 

sustainable approach to business, refer to 

the Global CSR Policy.

WE SUPPORT 

CHARITABLE CAUSES AND 

THE POLITICAL PROCESS

The Company encourages us to be active in charitable 

and civic activities in our communities. 

The Company also respects and supports the right we 

each have to take an active interest in political activities 

during our personal time. We should not, however, use 

Company time, supplies, or facilities for such activities 

without prior approval. 

The Company believes in expressing its views on local 

and national issues that affect operations. Advocacy 

efforts on behalf of the Company’s interests are 

permissible as long as they are conducted in accordance 

with regulations governing such activities. The Company 

may support the political process financially but will do 

We are so only as permitted by applicable law. 

engaged in 

the communities 

we serve.

16 ENTERPRISE HOLDINGS CODE of CONDUCT

LOCAL ENGAGEMENT
BY SIGNING BELOW, I ACKNOWLEDGE THAT I HAVE READ, 

UNDERSTAND, AND AGREE TO FOLLOW THE PRACTICES 

AND POLICIES ADDRESSED IN THE CODE. 

I additionally acknowledge and agree that the Code is intended to 

provide a general overview of the Company’s policies, and does not 

necessarily represent all such policies and practices in effect at any 

particular time. I understand that I should make contact through one 

of the resources listed above if I have any questions concerning the 

Code or observe any violations of the Code. 

EMPLOYEE NAME (please print) DATE

EMPLOYEE SIGNATURE

We have a responsibility to act 

ethically and uphold the Company’s 

values in all our business dealings. 

Our success depends on our actions. You must never do anything that could 

appear to be illegal or unethical—even the appearance of an improper action 

can be damaging to the Company’s reputation and its bottom line.

When faced with a difficult situation, you should never hesitate to ask for help. 

You can speak to or refer to any of the resources listed in the Code of Conduct. 

Remember, the company will not tolerate retaliatory acts against employees 

that raise concerns.

With your help, we can uphold our proud tradition of doing the right thing. 

It’s the key to our success and the most important part of our culture.

17

SUMMARY AND ACKNOWLEDGEMENT