Modern Slavery Statement

CarGurus is a multinational automotive platform helping consumers and dealers confidently buy and sell vehicles. CarGurus’ selection, trusted automotive insights and data-driven products and solutions support each shopper’s journey — from online research and shopping to in-dealership decisions — to empower them at every step. CarGurus provides dealers a personalized, predictive intelligence platform with software solutions that helps them run their businesses more efficiently and profitably at all stages of inventory acquisition and pricing, marketing and conversion to sale.

CarGurus operates online marketplaces in the U.S., U.K. and Canada. The company’s network of brands includes PistonHeads, an online motoring community in the U.K., and Autolist, a U.S.-based online marketplace. For more information about CarGurus, please visit our corporate website at www.cargurus.co.uk/Cars/aboutCargurus.html.

Our revenue is derived from three sources: (1) dealer subscription fees for marketing and data products (including dealer Listings subscription packages and digital product add-ons), conversion products, and inventory products; (2) advertising revenue from auto manufacturers and other brand advertisers; and (3) revenue from partnerships with financing services companies.

We engage with third-party service providers, including the following:

• Data center and networking hosts, information technology infrastructure suppliers, and data providers for our dealer inventory and vehicle information;
• Our payment processors, human resources information system providers, billing subscription software providers, customer relationship management software providers, financial planning and analysis software providers and general ledger providers;
• Search engine advertising services, and online, print, radio, social media and television media and advertising services;
• Marketing and public relations consultancy and market research services;
• Recruitment and talent search and training and development services; and
• Outside financial, audit and legal advisers.

At CarGurus, we are committed to operating in a fair, responsible and ethical manner with respect to fundamental human rights. While the countries, regions and industry sector within which our organization operates do not represent any particular risk associated with modern slavery, we recognize that slavery, servitude, forced and compulsory labor and human trafficking (referred to as “Modern Slavery”) are serious crimes and global human rights issues, and we take seriously our responsibility to comply with the Act and to assist in preventing and combating Modern Slavery.

This statement includes a description of our efforts over the past financial year to identify and mitigate the risk of Modern Slavery in our business and supply chain, and the policies and processes we have in place to report non-compliance.

It is paramount to our way of doing business at CarGurus to comply with applicable law and to act with the utmost integrity, honesty and transparency. CarGurus is committed to acting responsibly in all of our business dealings to ensure that we comply with applicable national and international legislation and industry standards, including laws and standards against Modern Slavery. Preserving an ethical workplace and supply chain that respects human rights is critical to our long-term success as a leading multinational automotive marketplace.

At CarGurus, we send a clear message to each CarGurus employee and supplier: We want to grow our business, but only if we can do it lawfully and ethically. At CarGurus, we obey applicable laws – including laws against Modern Slavery – and strive to hold ourselves to the highest ethical and legal standards; we expect the same of all of our suppliers.

As part of our initiative to identify and mitigate risk, we have a number of policies and processes that reflect our approach to ethics, human rights and Modern Slavery. As part of our initiative to identify and mitigate risk we have in place systems to:

• identify and assess potential risk areas in our supply chains;
• mitigate the risk of slavery and human trafficking occurring in our supply chains;
• monitor potential risks in our supply chains; and
• protect whistleblowers.

These policies and processes include:

• Our Code of Conduct (the “Code”)




The Code requires all directors, officers and employees of the Company to uphold high ethical and professional standards of conduct.

The Code requires such persons to report any violations confidentially, as applicable, to their manager, the Company’s People & Talent department or the Company’s Legal Department (or to the Company’s Audit Committee for suspected violations involving a director or executive officer).

• Our Whistleblower Policy




Through both the Code and our Whistleblower Policy, we prohibit any retaliation against those who make good-faith reports of concerns about the lawfulness of any of our business practices or breaches of the Code. In addition, our Whistleblower Policy sets forth a confidential process for reporting, investigating and resolving employee and third-party concerns related to accounting, auditing and similar matters. Individuals may confidentially provide information to the Company’s Audit Committee or to one or more of our individual directors by using the confidential and anonymous financial concern hotline that is operated by an independent, third-party service.

• Human Resource Policies and Procedures for Employees




In addition, to ensure that our employees are not subject to undue influence and are treated fairly and with respect, we have human resource policies and procedures, as well as onboarding processes and training, in place across all of our operations.

During new hire orientation and training, all recently hired employees receive a copy of the Code as well as certain human resource policies and procedures, including our Whistleblower Policy. Each year, we require our employees to complete an annual training on the Code.

In the 2026 financial year, we will maintain our practices and processes to help combat Modern Slavery.

This statement has been approved by the CarGurus Board of Directors.

/s/ Langley Steinert

Langley Steinert

Founder, Executive Chair and Chair of the Board