One Charlotte Realty, Inc.

1. Introduction

This Policies, Procedures & Office Policy Manual establishes the operating standards, brokerage requirements, legal compliance obligations, and professional expectations for all affiliated brokers, provisional brokers, broker associates, assistants, independent contractors, and affiliated personnel of One Charlotte Realty, Inc.

Compliance with this Manual is a mandatory condition of affiliation with the Brokerage.

2. Brokerage Philosophy

One Charlotte Realty operates under a modern real estate brokerage model focused on agent independence, professional accountability, legal compliance, ethical conduct, strong broker supervision, and consumer-focused real estate services.

• 100% commission model for agent-generated business.
• 50% commission split to the agent on company-provided leads.
• Seller-focused low listing commission model.
• Professional standards.
• Strong legal compliance.
• Brokerage accountability.

3. Company Identification

4. Independent Contractor Relationship

All affiliated brokers are independent contractors unless otherwise stated in writing. Nothing in this Manual creates an employment relationship, salary obligation, benefits, workers compensation, payroll withholding obligation, partnership, or joint venture.

Agents are responsible for their own taxes, licensing fees, dues, continuing education, business expenses, marketing expenses, automobile expenses, equipment, technology, and professional costs.

Independent contractor status does not remove the Brokerage’s supervisory authority. The Broker-in-Charge may require compliance with office policies, file standards, advertising standards, agency disclosure rules, compensation policies, legal compliance requirements, and ethical obligations.

5. Licensing Requirements

All affiliated brokers must maintain an active real estate license in good standing and comply with all applicable real estate commission requirements.

Agents must immediately notify the Broker-in-Charge of any complaint, investigation, disciplinary action, lawsuit, criminal charge, regulatory issue, or matter that may affect real estate activity.

North Carolina

All North Carolina brokers must comply with North Carolina Real Estate Commission rules, North Carolina license law, Working With Real Estate Agents disclosure requirements, broker supervision requirements, continuing education requirements, advertising rules, trust money rules, and material fact disclosure obligations.

South Carolina

All South Carolina brokers must comply with South Carolina real estate license law, South Carolina Real Estate Commission rules, SCR forms where applicable, South Carolina agency disclosure requirements, trust account rules, advertising rules, broker supervision rules, written office policy requirements, and local MLS or REALTOR® association requirements.

6. Broker-in-Charge Authority

The Broker-in-Charge has final authority over compliance decisions, risk management, transaction review, listing approval, advertising approval, escrow procedures, disciplinary action, policy interpretation, and policy enforcement.

All affiliated personnel must comply immediately with Broker-in-Charge directives. Failure to comply may result in disciplinary action, suspension of brokerage privileges, withholding of commissions where permitted by law, termination of affiliation, or reporting to appropriate regulatory authorities.

7. Office Policies

Agents must maintain professionalism in appearance, communication, office conduct, transaction management, and representation of the Brokerage.

The Brokerage may operate virtually, remotely, physically, or through shared office resources. Agents are responsible for maintaining reliable communication, technology access, secure records, and professional client service.

8. Agency Policy

One Charlotte Realty, Inc. may practice seller agency, buyer agency, landlord agency, tenant agency, designated agency where permitted, dual agency where permitted and properly disclosed, and transaction brokerage or limited brokerage only where lawful and approved by company policy.

No broker may create an agency relationship without proper disclosure and written agreement when required by law or company policy.

In North Carolina, brokers must use the required Working With Real Estate Agents disclosure and must properly explain agency options before confidential information is shared.

In South Carolina, brokers must use appropriate South Carolina agency disclosure forms and comply with SCR and South Carolina Real Estate Commission requirements for agency relationships.

9. Buyer Representation Policy

Buyer representation requires proper agency disclosure, signed agency documentation where required, compensation disclosure, and full fiduciary duty compliance.

Before showing property, opening doors, arranging tours, submitting offers, or providing buyer representation, brokers must obtain a written buyer agency agreement or touring agreement when required by law, MLS rule, REALTOR® rule, settlement practice requirement, or Brokerage policy.

Agents must clearly explain agency relationships, compensation arrangements, and representation duties to clients and customers.

10. Listing Policy

All listings must use approved listing agreements, include required disclosures, comply with MLS rules, comply with state and federal law, and be approved by the Brokerage where required.

No listing may be marketed without a fully executed listing agreement and all required documentation.

Brokers must verify ownership, legal description, property address, tax records, HOA information, listing price, compensation terms, showing instructions, personal property exclusions, and known material facts.

11. Commission Structure

The standard Brokerage model provides 100% commission to agents on agent-generated business. The Brokerage charges only a $495 transaction fee per closed transaction and any delinquent Errors & Omissions insurance premiums owed by the agent, which shall be deducted from the agent’s commission at closing if unpaid.

Unless otherwise agreed in writing, company-provided leads shall be paid on a 50% commission split to the agent and a 50% commission split to the Brokerage, after deduction of the $495 transaction fee, applicable referral fees, delinquent E&O insurance premiums, third-party fees, and any other written obligations.

Commission is paid only after closing has occurred, the Brokerage has received funds, the compliance file is complete, and all required fees, transaction fees, referral fees, and E&O insurance obligations have been satisfied.

12. Transaction Fees

Each closed transaction requires payment of the applicable transaction fee, E&O contribution, and any outstanding Brokerage obligations.

Failure to satisfy required fees may result in commission withholding where permitted by law and Brokerage policy.

13. Errors & Omissions Insurance

Participation in Brokerage E&O insurance coverage is mandatory unless otherwise approved in writing.

Agents must immediately report potential claims, disputes, complaints, demand letters, threats of litigation, or circumstances that could create liability.

Failure to timely report a potential claim may create personal responsibility for uncovered losses.

14. Seller Compensation and Buyer Broker Compensation

One Charlotte Realty, Inc. allows sellers to decide whether to offer compensation to a buyer’s broker, subject to applicable law, MLS rules, and written agreement terms.

Brokers may explain market consequences of offering or not offering buyer broker compensation, but may not make false, misleading, anti-competitive, or coercive statements.

Brokers must not imply that commissions are fixed, standard, required, customary, or set by law.

15. Advertising & Marketing Policy

All advertising must comply with North Carolina Real Estate Commission rules, South Carolina Real Estate Commission rules where applicable, Fair Housing laws, MLS rules, federal advertising regulations, REALTOR® rules where applicable, and Brokerage branding standards.

Advertising may not be false, misleading, deceptive, unauthorized, discriminatory, or improperly licensed.

Advertising includes websites, landing pages, social media, flyers, yard signs, email campaigns, postcards, videos, reels, paid ads, property descriptions, MLS remarks, Google Business Profile posts, and online profiles.

16. Website, Social Media & Internet Policy

Agents may not create websites, landing pages, social media pages, paid advertising campaigns, online profiles, or online marketing using Brokerage branding without prior approval.

All online advertising must properly identify the Brokerage where required and comply with all legal, ethical, MLS, and Brokerage standards.

Brokers may not post confidential client information, inspection results, negotiations, private documents, settlement details, or transaction disputes without written permission.

17. Company-Provided Leads Policy

Company-provided leads are leads generated, purchased, captured, referred, assigned, or distributed by One Charlotte Realty, Inc. through Brokerage websites, advertising, online platforms, phone calls, walk-ins, referral relationships, social media, Google Business Profile, sign calls, internet lead providers, or any other Brokerage source.

Unless otherwise agreed in writing, any transaction resulting from a company-provided lead shall be paid on a 50% commission split to the agent and 50% commission split to the Brokerage, after deduction of applicable referral fees, transaction fees, E&O charges, third-party fees, or other written obligations.

The Brokerage has sole discretion to determine whether a client, customer, inquiry, referral, prospect, or transaction originated from a company-provided lead.

Failure to properly manage company-provided leads may result in reassignment, loss of lead privileges, commission adjustment, disciplinary action, or termination.

18. Lead Distribution Policy

Brokerage-generated leads remain the property of the Brokerage unless otherwise agreed in writing. Lead assignment does not create ownership rights in favor of the agent.

The Brokerage may assign, reassign, withdraw, or redistribute leads at its sole discretion.

19. NC Real Estate Commission Compliance

All agents handling North Carolina business must comply fully with North Carolina Real Estate Commission rules, North Carolina license law, federal law, local law, MLS requirements, association rules, and Broker-in-Charge directives.

Violations may result in internal discipline, financial liability, immediate termination, and reporting to appropriate authorities where required or appropriate.

20. South Carolina Real Estate Commission Compliance

All agents handling South Carolina business must comply fully with South Carolina Real Estate Commission rules, South Carolina license law, SCR forms and procedures where applicable, federal law, local law, MLS requirements, association rules, and Broker-in-Charge directives.

South Carolina-specific references, disclosures, forms, and office policy requirements are preserved for South Carolina transactions. Brokers must not assume North Carolina procedures apply to South Carolina property.

21. Trust Money & Escrow Handling

Agents may never personally hold escrow funds unless legally permitted and specifically authorized by the Broker-in-Charge.

Earnest money, due diligence fees, deposits, rental deposits, security deposits, and trust funds must be handled strictly according to the law of the state where the transaction is located, contract requirements, real estate commission rules, and Brokerage procedures.

North Carolina and South Carolina have different trust account and earnest money rules. Brokers must follow the law applicable to the transaction.

22. Agency Disclosure Requirements

Agency disclosure must be timely, accurate, documented, and compliant with applicable state requirements.

Failure to provide required agency disclosure is a serious compliance violation and may result in disciplinary action.

23. Contracts & Forms

Only approved and appropriate real estate forms may be used. Unauthorized drafting of legal documents is prohibited.

All contracts, addenda, disclosures, and transaction documents must comply with Brokerage review procedures.

Brokers may complete approved forms but may not practice law, draft complex legal language, interpret legal rights beyond license authority, or advise clients on legal consequences that require attorney advice.

24. Transaction Files

All transaction files must be complete, accurate, and submitted promptly. Required documents may include agency disclosures, listing agreements, buyer agency agreements, purchase agreements, addenda, amendments, disclosures, MLS sheets, correspondence, inspection repair agreements, closing statements, commission instructions, referral agreements, and any other documents required by law, MLS rule, or Brokerage policy.

No commission will be released until the transaction file is complete and approved by the Brokerage.

25. Offers and Negotiations

All offers and counteroffers must be presented promptly unless the client has provided lawful written instructions otherwise.

Brokers must not withhold offers, misrepresent terms, delay presentation, or discourage offers based on broker compensation.

Brokers must document material communications and keep copies of written negotiations in the transaction file.

26. Material Facts

Brokers must disclose material facts as required by law. Brokers may not conceal defects, misrepresent property condition, misstate square footage, hide adverse facts, or rely blindly on seller statements when facts appear inconsistent or suspicious.

Material facts may include property condition, title issues, zoning matters, flood concerns, HOA restrictions, special assessments, pending litigation, environmental concerns, structural issues, water intrusion, mold, permitted use, access issues, and other facts that may affect a party’s decision.

27. Fair Housing Policy

Strict compliance with federal, state, and local Fair Housing laws is mandatory.

Discrimination, steering, blockbusting, discriminatory advertising, unequal treatment, refusal of service, or any conduct that violates Fair Housing laws is prohibited.

The Brokerage maintains a zero-tolerance policy for discrimination.

28. Anti-Discrimination Policy

Discriminatory conduct by any affiliated person, agent, assistant, contractor, vendor, or staff member is grounds for immediate disciplinary action or termination.

29. Anti-Trust Policy

Brokers must not discuss, agree to, suggest, or imply fixed commissions, standard rates, uniform fees, market-wide compensation, boycotts, refusal to cooperate, or any practice that could violate anti-trust laws.

Commissions and fees are negotiable. Each brokerage and client independently determines compensation terms.

30. Confidentiality Policy

Client information must remain confidential during and after representation. Unauthorized disclosure of confidential client, transaction, financial, personal, or business information is prohibited.

Confidential information includes motivation, financial position, negotiating strategy, acceptable terms, personal circumstances, and any information the client has instructed the broker to keep confidential.

31. Professional Conduct Standards

Agents must maintain honesty, integrity, respectful communication, timely responses, professional conduct, legal compliance, and ethical behavior in all real estate activities.

Brokers must not harass clients, other brokers, vendors, staff, or members of the public. Brokers must not engage in fraud, misrepresentation, discrimination, intimidation, or conduct that damages the reputation of the Brokerage.

32. Ethics & REALTOR® Standards

Where applicable, agents must comply with REALTOR® ethical standards, MLS rules, association rules, and all professional conduct requirements.

33. Cooperation With Other Brokers

Professional cooperation with other brokers is required while protecting the best interests of the client and complying with all legal, ethical, contractual, and Brokerage obligations.

34. MLS Policy

Brokers must comply with all MLS rules, including timely listing entry, status updates, photo requirements, showing rules, compensation fields where applicable, clear cooperation rules, coming soon rules, withdrawn/cancelled procedures, and closing data requirements.

Brokers are responsible for MLS fines caused by their failure to follow MLS rules, unless otherwise determined by company management.

35. Showing Property Policy

Agents must verify showing authorization, follow showing instructions, protect property security, respect occupants, and secure all doors, windows, gates, garages, alarms, and lockboxes after showings.

Brokers must not provide lockbox codes to unauthorized persons.

36. Open House Policy

Open houses require seller authorization, professional supervision, safety awareness, compliance with Fair Housing laws, and Brokerage approval where required.

Agents must follow all property security and visitor safety procedures.

37. Safety & Security Policy

Agents must prioritize personal safety, client safety, property security, and professional judgment.

Business opportunities must never override safety concerns.

38. Property Management and Leasing

No broker may engage in property management, rent collection, lease drafting, security deposit handling, or tenant placement unless authorized by One Charlotte Realty, Inc. and properly licensed under applicable state law.

Property management and leasing laws differ between North Carolina and South Carolina. Brokers must obtain approval before performing leasing or management services.

39. Record Retention Policy

Transaction records, communications, contracts, disclosures, advertising materials, and supporting documents must be maintained in compliance with applicable law, real estate commission requirements, MLS rules, and Brokerage requirements.

Brokers must submit complete records to the Brokerage and may not withhold files, delete transaction documents, or rely only on personal devices.

40. Technology & Data Security Policy

Agents must protect client data, passwords, transaction files, email accounts, digital signatures, confidential documents, Brokerage systems, and all digital records from unauthorized access or disclosure.

Brokers must use reasonable security practices and must immediately report suspected data breaches, hacked email accounts, wire fraud attempts, or unauthorized access.

41. Confidential Information Protection

Sensitive transaction information must be securely stored, transmitted, and protected at all times.

Agents may not share confidential files, login credentials, client information, transaction data, or Brokerage information without authorization.

42. Wire Fraud Warning

Brokers must warn clients about wire fraud. Clients should independently verify wiring instructions directly with the closing attorney, title company, or settlement agent using a known verified phone number before sending funds.

Brokers must never alter wiring instructions, forward suspicious wiring instructions, or guarantee the authenticity of wiring information.

43. Copyright, Intellectual Property & Media Usage Policy

Agents are strictly prohibited from using, copying, uploading, distributing, modifying, publishing, advertising, reposting, or otherwise utilizing any third-party photographs, MLS photos, builder renderings, developer photography, drone photography, videos, floorplans, virtual staging, social media content, website content, listing descriptions, logos, graphics, marketing materials, or any other copyrighted or proprietary content without prior written authorization from the lawful owner or a valid written license granting such use.

“Found online,” MLS access, social media availability, prior agent use, seller possession of photos, builder-provided materials, or public visibility of content do not constitute ownership, permission, licensing rights, or authorization for use.

Only media that is fully owned by the agent, properly licensed, or specifically authorized in writing may be used in connection with any brokerage activity, MLS entry, website, social media, print advertising, email marketing, video marketing, paid advertising, or any other business purpose.

Each agent bears sole and absolute responsibility for independently verifying all usage rights, licenses, permissions, and ownership prior to publication or submission of any content.

The Brokerage does not review, verify, approve, or assume responsibility for copyright compliance of agent-submitted materials.

Agent shall be solely and personally liable for any copyright infringement, DMCA claims, cease-and-desist demands, settlements, judgments, licensing fees, statutory damages, actual damages, attorney fees, court costs, expert fees, defense costs, and any other expenses arising from unauthorized use of copyrighted materials.

Agent agrees to fully defend, indemnify, reimburse, and hold harmless One Charlotte Realty, Inc., its Broker, owners, officers, directors, employees, staff, and affiliates from and against any and all claims, demands, lawsuits, damages, penalties, losses, liabilities, and expenses arising from the agent’s use of unauthorized or infringing content.

Upon notice from Brokerage, MLS, copyright owner, attorney, platform provider, or any third party, Agent shall immediately remove the content and fully cooperate in resolving the matter at Agent’s sole expense.

Violation of this policy may result in immediate disciplinary action, mandatory reimbursement to Brokerage, commission withholding where permitted by law, termination of affiliation, reporting to the appropriate regulatory authorities, and any other legal remedies available to Brokerage.

These obligations shall survive termination of affiliation with the Brokerage.

44. Digital Millennium Copyright Act Policy

The Brokerage complies with the Digital Millennium Copyright Act, 17 U.S.C. § 512.

If a copyright owner claims that intellectual property has been used improperly, the Brokerage may immediately remove content, suspend marketing, disable access, investigate the violation, and require agent reimbursement.

Agents may not upload, publish, distribute, advertise, submit, or share content they do not legally own or have written permission to use.

45. Broker Approval for Third-Party Media

Prior written Broker approval is required before using builder renderings, developer photos, third-party professional photography, drone footage, virtual staging, social media reposts, promotional videos, AI-generated marketing materials, or marketing created by outside sources.

Broker approval does not relieve the agent from responsibility for confirming that all content is legally authorized for use.

46. AI-Generated Marketing Materials

Agents may use AI tools for drafts, marketing ideas, listing descriptions, blog posts, social media content, and client communications only when the final content is reviewed for accuracy, compliance, copyright, Fair Housing compliance, and advertising compliance.

AI-generated content may not be published if it contains false claims, inaccurate property information, misleading market data, discriminatory language, fabricated testimonials, fake reviews, fake credentials, unauthorized likenesses, or unsupported guarantees.

47. Immediate Removal, Discipline & Enforcement

The Brokerage may immediately remove any unauthorized content from MLS, Brokerage websites, social media, advertising platforms, print materials, email campaigns, and marketing materials.

Violations may result in withheld commissions where permitted by law, mandatory reimbursement, internal fines where permitted, suspension, termination of affiliation, reporting to licensing authorities, or legal action for damages.

48. Mandatory Agent Indemnification

Each affiliated agent agrees to fully indemnify, defend, and hold harmless One Charlotte Realty, Inc., its Broker-in-Charge, owners, officers, staff, managers, representatives, and affiliates from any and all claims, damages, losses, lawsuits, attorney fees, settlements, judgments, fines, MLS penalties, regulatory complaints, or legal expenses arising from the agent’s conduct.

This includes, but is not limited to, copyright infringement, unauthorized photo usage, advertising violations, Fair Housing violations, MLS violations, misrepresentation, contract disputes caused by the agent, client complaints caused by the agent, and compliance violations caused by the agent.

49. Independent Contractor Expenses

Agents are responsible for their own business expenses unless otherwise agreed in writing.

This includes advertising, marketing, signs, lockboxes, photography, transportation, licensing, continuing education, MLS dues, association dues, technology, supplies, and administrative costs.

50. Teams and Assistants

Teams, assistants, transaction coordinators, showing assistants, and administrative staff must comply with Brokerage policy and license law.

Unlicensed assistants may not perform licensed activities.

Team advertising must clearly comply with brokerage identification requirements and may not suggest the team is a separate brokerage.

51. Referrals

Referral agreements must be in writing and signed before closing. Brokers may only pay referral fees to properly licensed brokers or entities where permitted by law.

No broker may pay referral fees, kickbacks, rebates, or anything of value in violation of RESPA, state law, MLS rules, or Brokerage policy.

52. RESPA Policy

Brokers may not accept or pay illegal kickbacks, referral fees, marketing fees, or things of value in exchange for settlement service referrals.

This includes lenders, title companies, attorneys, inspectors, insurance agents, contractors, home warranty companies, and other settlement service providers.

Affiliated business arrangements must be disclosed where required.

53. Recruiting Policy

Agents may not recruit affiliated agents away from the Brokerage, interfere with Brokerage relationships, misuse Brokerage information for recruiting purposes, or solicit Brokerage agents for competing businesses while affiliated with the Brokerage.

54. Use of Attorneys

Brokers must advise clients to consult legal counsel when legal advice is needed.

This includes contract disputes, title issues, probate, estate matters, trusts, corporate ownership, boundary disputes, litigation, lease disputes, escrow disputes, and unusual addenda.

55. Complaints and Legal Claims

Brokers must immediately notify the Broker-in-Charge or company management of any complaint, demand letter, attorney communication, ethics complaint, commission dispute, license complaint, lawsuit, threat of litigation, subpoena, or claim.

Brokers must not respond to legal claims on behalf of the Brokerage without authorization.

56. Dispute Resolution Policy

Disputes must first be addressed internally with the Broker-in-Charge before outside escalation, unless otherwise required by law.

The Brokerage reserves all rights and remedies available under applicable law.

57. Broker Review & Compliance Audits

The Brokerage may audit files, advertising, communications, contracts, marketing materials, transaction records, lead activity, online content, and compliance documents at any time.

Agents must cooperate fully with all compliance reviews and audits.

58. Termination of Affiliation

The Brokerage may terminate affiliation at any time for compliance violations, legal risk, reputation risk, nonpayment of fees, failure to follow Broker directives, misconduct, misrepresentation, or conduct inconsistent with Brokerage standards.

Termination does not release the agent from confidentiality, indemnification, commission obligations, reimbursement obligations, or financial responsibilities that arose during affiliation.

Upon termination, all Brokerage property, files, signs, lockboxes, leads, passwords, and confidential materials must be returned or transferred as instructed.

59. Policy Changes & Broker Directives

This Manual may be updated, amended, revised, replaced, or supplemented at any time by the Brokerage.

Broker directives have immediate effect and are binding on all affiliated personnel. Continued affiliation constitutes acceptance of all updated policies, procedures, and Broker directives.

60. Final Acknowledgment

All independent contractors, licensed brokers, provisional brokers, broker associates, assistants, and affiliated personnel acknowledge and agree that affiliation with One Charlotte Realty, Inc. constitutes automatic acceptance of this Policies, Procedures & Office Policy Manual and all current and future Brokerage policies, procedures, rules, standards, compliance requirements, and Broker-in-Charge directives.

No separate signature shall be required for enforceability. Continued affiliation with the Brokerage, use of Brokerage services, participation in transactions, receipt of compensation, representation of the Brokerage, access to Brokerage systems, use of Brokerage branding, or performance of any real estate activities under One Charlotte Realty, Inc. shall constitute full legal acceptance of and agreement to comply with this Manual.

Each affiliated agent expressly agrees to remain bound by all confidentiality obligations, indemnification requirements, copyright protections, commission obligations, dispute resolution procedures, and financial responsibilities contained in this Manual both during affiliation and after termination of affiliation where applicable.

Failure to comply may result, in the sole discretion of the Brokerage, in disciplinary action, immediate suspension, withholding of commissions where permitted by law, termination of affiliation, personal financial responsibility for damages caused by the agent, reimbursement of legal fees and costs, indemnification obligations, reporting to regulatory authorities, and any other remedies available to the Brokerage under applicable law.

61. Optional Broker Signature Acknowledgment

I acknowledge that I have received access to the One Charlotte Realty, Inc. Policies, Procedures & Office Policy Manual. I understand that I am responsible for reading, understanding, and following Brokerage policies, applicable license law, MLS rules, agency requirements, Fair Housing laws, advertising rules, trust money rules, and all applicable North Carolina and South Carolina requirements.

Broker Name: __________________________________________

Broker Signature: _______________________________________

Date: _________________________________________________