eXp World Holdings, Inc._December 31, 2025

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K

(Mark One)

☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2025

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from ________ to _________

Commission File Number: 001-38493

eXp World Holdings, Inc.

(Exact name of registrant as specified in its charter)


Delaware		98-0681092
(State or other jurisdiction		(I.R.S. Employer
of incorporation or organization)		Identification No.)



2219 Rimland Drive, Suite 301 Bellingham, WA		98226 (Zip Code)
(Address of principal executive offices)

Registrant’s telephone number, including area code: (360) 685-4206

Securities registered pursuant to section 12(b) of the Act:


Title of each class	Trading Symbol(s)	Name of each exchange on which registered
Common Stock, par value $0.00001 per share	EXPI	The Nasdaq Stock Market

Securities registered pursuant to section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

Yes ☒ No ☐

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.

Yes ☐ No ☒

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.

Yes ☒ No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Yes ☒ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer”, “accelerated filer”, “smaller reporting company”, and “emerging growth company” in Rule 12b-2 of the Exchange Act.



Large accelerated filer	☒	Accelerated filer	☐
Non-accelerated filer	☐	Smaller reporting company	☐
Emerging growth company	☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. ☒

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).

Yes ☐ No ☒

Based on the registrant’s closing price of $9.10 as quoted on the Nasdaq Stock Market on June 30, 2025 the last business day of the Registrant’s most recently completed second fiscal quarter, the aggregate market value of the voting and nonvoting common equity held by non-affiliates of eXp World Holdings, Inc. was approximately $795.7 million. The number of shares of the registrant’s common stock outstanding as of December 31, 2025 was 161,049,979.

DOCUMENTS INCORPORATED BY REFERENCE The registrant intends to file a definitive proxy statement pursuant to Regulation 14A within 120 days after the end of the fiscal year ended December 31, 2025. Portions of such proxy statement are incorporated by reference into Part III of this annual report on Form 10-K.

Table of Contents

TABLE OF CONTENTS

		Page
FORWARD LOOKING STATEMENTS		1
NOTE REGARDING INDUSTRY AND MARKET DATA

PART 1		2
Item 1.	Business	2
Item 1A.	Risk Factors	5
Item 1B.	Unresolved Staff Comments	18
Item 1C.	Cybersecurity	18
Item 2.	Properties	19
Item 3.	Legal Proceedings	19
Item 4.	Mine Safety Disclosures	19

PART II		20
Item 5.	Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities	20
Item 6.	[Reserved]	21
Item 7.	Management’s Discussion and Analysis of Financial Condition and Results of Operations	21
Item 7A.	Quantitative and Qualitative Disclosures About Market Risk	29
Item 8.	Financial Statements and Supplementary Data	30
Item 9.	Changes in and Disagreements with Accountants on Accounting and Financial Disclosure	54
Item 9A.	Controls and Procedures	54
Item 9B.	Other Information	56
Item 9C.	Disclosure Regarding Foreign Jurisdictions that Prevent Inspections	56

PART III		56
Item 10.	Directors, Executive Officers and Corporate Governance	56
Item 11.	Executive Compensation	56
Item 12.	Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters	56
Item 13.	Certain Relationships and Related Transactions, and Director Independence	56
Item 14.	Principal Accountant Fees and Services	56

PART IV		57
Item 15.	Exhibits and Financial Statement Schedules	57
Item 16.	Form 10-K Summary	58

SIGNATURES		59

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FORWARD-LOOKING STATEMENTS

Each of the terms the “Company”, “eXp”, “we”, “us”, and “our” as used herein refers collectively to eXp World Holdings, Inc. and its wholly owned subsidiaries, unless otherwise stated.

This Annual Report on Form 10-K (the “Annual Report”) contains forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties. Many of the forward-looking statements are located in Part I, Item 1 of this Annual Report under the heading “Business” and Part II, Item 7 of this Annual Report under the heading “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. For example, statements in this Annual Report regarding the potential future impact of macroeconomic conditions on the Company’s business and results of operations and expectations of growth, including as a result of investment in technology and entering into new markets, are forward-looking statements. Forward-looking statements can also be identified by words such as “future,” “anticipates,” “believes,” “estimates,” “expects,” “intends,” “plans,” “predicts,” “will,” “would,” “could,” “can,” “may,” and similar terms. Forward-looking statements are not guarantees of future performance and the Company’s actual results may differ significantly from the results discussed in the forward-looking statements. Factors that might cause such differences include, but are not limited to:

●

the impact of macroeconomic conditions on the strength of the residential real estate market;

●

the impact of monetary policies of the U.S. federal government and its agencies on the Company’s operations;

●

the impact of changes in consumer attitudes on home sale transaction volume;

●

the impact of excessive or insufficient home inventory supply on home sale transaction value;

●

the Company’s ability to attract and retain additional qualified personnel;

●

changes in tax laws and regulations that may have a material adverse effect on the Company’s business;

●

the Company’s ability to protect its intellectual property rights;

●

the impact of security breaches, interruptions, delays and failures in the Company’s systems and operations on the Company’s business;

●

the Company’s financial condition and reputation;

●

the Company’s ability to predict the demand or growth of its new products and services;

●

the Company’s ability to maintain its agent growth rate;

●

the impact of adverse outcomes in litigation and regulatory actions against the Company and other companies and agents in its industry on the Company’s business, including the outcome of any settlements related to those actions; and

●

the effects of inflation and continuing high interest rates on real estate transaction values and the Company’s operating results, profits and cash flows;

as well as those risks discussed in Part I, Item 1A, “Risk Factors”, Item 3, “Legal Proceedings,” Item 7, “Management’s Discussion and Analysis of Financial Condition and Results of Operations”, and elsewhere in this Annual Report. The Company assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law.

NOTE REGARDING INDUSTRY AND MARKET DATA

This Annual Report contains information based on industry publications or reports generated by third-party providers, or other publicly available information, as well as other information based on the Company’s internal sources. As noted in this Annual Report, the National Association of Realtors (“NAR”), and various Multiple Listing Service (“MLS”) systems are the primary source for third-party industry data and those systems generally state that the information contained therein has been obtained from sources believed to be reliable. We have not independently verified any of the data from third-party sources nor have we validated the underlying economic assumptions relied on therein.

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PART I

Item 1.

BUSINESS

General

The Company owns and oversees a diversified portfolio of service-oriented businesses. These businesses are integrated through the Company’s advanced enabling technology platform which enables collaboration and operational leverage across its ecosystem.

The Company’s strategic focus is the continued expansion of its real estate brokerage operations by delivering a differentiated value proposition to agents—centered on industry-leading economics, ownership opportunities, and access to tools and services that support long-term professional growth. Through disciplined investment in technology, education, and affiliated services, the Company seeks to provide a scalable platform where real estate professionals can grow their businesses and adapt to an evolving real estate marketplace. A core element of the Company’s value proposition is its commitment to cooperation, transparency, and consumer-centric practices, which the Company views as essential to a healthy, open real estate marketplace and a key differentiator in attracting and retaining professional agents.

Throughout 2025, the Company also introduced new programs and specialized divisions designed to support agents in growing and expanding their businesses across a range of property types. In the second quarter of 2025, the Company launched its Land and Ranch Division, to support agents specializing in rural, recreational, and agricultural properties. During the fourth quarter of 2025, the Company launched its Sports and Entertainment Division, aimed at supporting agents serving clients in the sports and entertainment sectors. In addition, during the second quarter of 2025, the Company introduced its Co-Sponsor Program, allowing agents to designate both a primary sponsor and a co-sponsor, as well as a U.S. open-sourced Seller Advisory: Risks of Limited Market Exposure form, in line with the Company’s commitment to transparency and education.

The Company also continued to invest in its technology platform and agent-facing tools. In the third quarter of 2025, the Company launched its CRM of Choice initiative, which allows agents to select from three leading customer relationship management platforms based on their individual business needs, and released LYVVE^TM, its global property search platform designed to consolidate listings and related data from multiple countries into a single, border-agnostic search interface for agents and consumers.

During 2025, the Company made several key leadership appointments to support its continued growth and operational focus. In the third quarter of 2025, Jesse Hill was appointed Chief Financial Officer of eXp World Holdings, Inc. In the fourth quarter of 2025, Carrie Lysenko was appointed Chief Technology Officer of eXp Realty ®, and Holly Mabery was appointed Chief Brokerage Officer of eXp Realty.

Business Segments

The Company operates its business through three reportable segments: North American Realty, International Realty, and Other Affiliated Services. North American Realty includes residential and commercial brokerage, lead generation, and related support services in the United States and Canada and, beginning with the first quarter of 2025, FrameVR.io, the Company’s proprietary, web-accessible 3D immersive technology platform that provides a virtual environment for agent collaboration, training, and community engagement. International Realty includes brokerage operations and support services across 27 countries throughout the Americas, Europe, the Middle East, Asia-Pacific, and South Africa. Both segments generate revenue primarily from commissions on residential real estate transactions, supported by the Company’s cloud-based brokerage model.

Other Affiliated Services includes SUCCESS^® magazine and related media properties. Prior to the first quarter of 2025, Other Affiliated Services also included FrameVR.io. In 2024, the Company wound down the Virbela business, and its remaining operations no longer met the criteria for a reportable segment; therefore, any operating results related to Virbela, prior to the completion of its disposition in the fourth quarter of 2024, are included in discontinued operations. As a result, all prior period segment disclosures have been reclassified to conform to the current reporting structure.

North American Realty and International Realty

Both the North American Realty segment and the International Realty segment generate revenue primarily by serving as a licensed broker for the purpose of processing residential and commercial real estate transactions, from which the Company earns commissions. The Company in turn pays a portion of the commissions earned to its real estate agents and brokers. eXp offers an innovative cloud-based brokerage model, which reduces costs to the Company’s agents and brokers. The model features low entry fees, stock ownership opportunities for agents and brokers and a revenue-sharing plan through which agents and brokers can earn commission from transactions conducted by agents and brokers they have attracted to eXp.

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Other Affiliated Services

The Company’s Other Affiliated Services segment includes SUCCESS^®magazine and its related media properties, which provide training, classes, resources, and tools to empower our agents, brokers, staff, and general customers to excel and empower their professional development.

Markets and Customers

The Company’s clients are primarily residential homeowners and homebuyers served through its network of independent agents and brokers. The North American Realty segment includes operations across all 50 U.S. states and all Canadian provinces and represented 96.9% of total consolidated revenues in 2025. The International Realty segment includes operations in 27 countries throughout the Americas, Europe, the Middle East, Asia-Pacific, and South Africa and represented 3.1% of total consolidated revenues in 2025. Other Affiliated Services includes SUCCESS® media properties, which provide affiliated services and professional development tools that support its agents, brokers, and customers.

Competition

The Company’s real estate brokerage business competes with local, regional, national and international residential real estate brokerages with respect to the sale of homes and to attract and retain agents, teams of agents, brokers and consumers — both home sellers and buyers. The Company competes primarily on the basis of its service, culture, collaboration, and utilization of cloud-based systems and technologies that reduce costs, while providing relevant and substantial professional development and opportunities for its agents and brokers to generate more business and participate in the growth of the Company.

Residential real estate brokerage companies typically realize revenues in the form of a commission based on a percentage of the price of each home purchased or sold, which varies based on geographical location and specific customer-agent negotiations, among other factors. Therefore, variability in the commissions earned in the real estate industry exists based on general economic and market factors, as well as the price and volume of homes sold. The Company is positioned to earn commissions on either — or both — of the buy side or sell side of residential real estate transactions, as well as the ability to receive other fees for complementary services provided during the closing process.

The Company believes that it is the only global cloud-based real estate brokerage with massive scale. This innovative operational structure coupled with the Company’s distribution model allows the Company to effectively enter new markets with speed and flexibility and without much of the investment and cost associated with establishing a traditional brokerage. The Company also believes its compensation and incentive programs to attract and retain highly productive agents are some of the most compelling in the industry. As such, the Company believes that it is well positioned in the competitive landscape.

Software Development

The Company continues to increase its investment in the development of its own cloud-based technology and transaction processing platforms and further expand its technological products and service offerings. The Company continues to create process efficiencies and provide its agents and brokers with technologies designed to facilitate transactions in an efficient and consumer-friendly way. The Company’s operational model and growth strategies necessitate the proprietary technologies used to support its operations now and in the future, as well as requiring the Company to, at times, consider existing and emerging technology companies for acquisition, partnerships and other collaborative relationships.

Intellectual Property

The Company’s cloud-based real estate brokerage is highly dependent on the proprietary technology that the Company employs and the intellectual property that the Company creates. “eXp Realty” is one of the Company’s registered trademarks in the United States, among other registered and nonregistered trademarks. The Company also owns the rights to key domain names used by its domestic and international brokerages: including, for example, https://exprealty.com and https://exprealty.ca. Additionally, the Company owns registered trademarks and the rights to domain names which are leveraged in its other business segments and in connection with services that complement its real estate brokerage, such as the “SUCCESS^®” registered trademark and https://success.com. The Company has also engaged various third parties to extend enterprise licenses for critical transaction management, client relationship management and other proprietary software. Information contained on the websites associated with such domain names is not incorporated by reference into this Annual Report.

While there can be no assurance that registered trademarks and other intellectual property rights will protect the Company’s proprietary information, it intends to assert its intellectual property rights against any infringement. Although any assertion of the Company’s rights could result in a substantial cost and diversion of management effort, the Company believes the protection and defense against infringement of its intellectual property rights are essential to its business.

Seasonality of Business

Seasons and weather traditionally impact the real estate industry in the markets in which the Company operates. Spring and summer seasons historically reflect greater sales periods and, in turn, higher revenues and operating results in comparison to fall

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and winter seasons. The Company has historically experienced higher revenue during the second and third quarters of its fiscal year due in part to seasonal industry patterns. By contrast, the Company’s Other Affiliated Services segment experiences generally consistent revenue during the year, with some increased adoption around the Company’s eXpcon events held throughout the year.

Government Regulation

Legal and Regulatory Environment

The Company operates in highly regulated industries and is subject to changes in laws, regulations, and government policies, as well as their interpretation and enforcement by regulatory bodies and other authorities.

Residential Real Estate

The Company operates in the residential real estate industry, which is subject to extensive federal, state, local, and international regulation, as well as oversight by industry associations. Our participation in multiple listing services and industry organizations also exposes us to evolving rules and policies that may be influenced by regulatory developments, litigation, or government action. The industry is also subject to scrutiny in areas such as antitrust, competition, settlement procedures, consumer protection, and worker classification.

RESPA

The Real Estate Settlement Procedures Act (“RESPA”) and similar laws govern payments and referrals in connection with residential real estate transactions, including mortgages, title, and insurance. Compliance can be complex due to differing interpretations by courts and regulators, and violations may result in loss of brokerage licensure, significant fines, legal costs, and private litigation. State laws restricting inducements and gifts to consumers also affect our lead-generation efforts.

Antitrust

The Company is subject to U.S. and international antitrust and competition laws, including the Sherman Act, the Federal Trade Commission Act, the Clayton Act, and comparable statutes in other jurisdictions. These laws prohibit anti-competitive conduct such as price-fixing and apply broadly to our industry.

Regulatory scrutiny of broker compensation and MLS practices has intensified in recent years. In March 2024, the NAR reached a settlement requiring significant changes to its policies, including increased transparency in agent compensation and MLS rules, which have impacted industry practices. The long-term effects of these changes remain uncertain but could increase costs or alter competitive dynamics.

As disclosed in Note 13 – Commitments and Contingencies to the consolidated financial statements, the Company is a defendant in certain antitrust class actions in the U.S. and Canada. In December 2024, the Company agreed to a settlement requiring changes to business practices and a payment of $34.0 million, subject to final court approval. These proceedings, and related settlements across the industry, may continue to require changes to our or our brokers’ business models, including compensation practices.

Worker Classification

Most of the Company’s real estate professionals are retained as independent contractors, except where local laws require otherwise. Their classification is subject to rules of the Internal Revenue Service (“IRS”), foreign regulations, and applicable state and provincial laws, all of which are subject to interpretation and change. The Company monitors ongoing federal, state, and international developments in this area.

Cybersecurity and Data Privacy Regulations

The Company is subject to domestic and international laws governing data privacy and cybersecurity, including U.S. statutes such as the Gramm-Leach-Bliley Act and the California Consumer Privacy Act, and international frameworks such as the European Union’s General Data Protection Regulation. These laws impose obligations related to safeguarding personal data and carry significant penalties for non-compliance. Global data privacy requirements continue to evolve, and we monitor developments across jurisdictions. For additional discussion of related risks, see Item “1A - Risk Factors” in this Annual Report.

TCPA

The Telephone Consumer Protection Act (“TCPA”) regulates telemarketing practices, including restrictions on autodialing, prerecorded messages, and communications to numbers on national or state Do-Not-Call registries. The TCPA requires written consent for certain mobile communications, and some states have adopted or may adopt their own versions of these rules. The Company may be subject to class action claims alleging responsibility for contacts made by its real estate professionals.

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Environmental Regulation

Although the Company operates with a limited physical footprint, we are subject to environmental regulations, particularly those addressing emissions from data centers and cloud operations. In the U.S., states such as California have expanded climate reporting and accountability laws. Internationally, the European Union’s Corporate Sustainability Due Diligence Directive and the International Sustainability Standards Board’s sustainability disclosure standards may increase expectations for emissions reporting and transparency. While the direct impact on our business is limited by our cloud-based model, evolving global requirements and stakeholder demands could increase compliance obligations.

Human Capital

The Company’s employees, brokers, and independent contractor real estate agents represent the human capital investments imperative to its operations. As of December 31, 2025, the Company had approximately 1,834 full-time equivalent employees and over 83,000 real estate agents. The Company also utilizes part-time and temporary employees and consultants when necessary; in a limited number of the Company’s foreign markets, the Company relies on the use of indirect employment structures where personnel providing certain services to the foreign entities are employed by a contractor of the Company and are not employed by the Company. The Company’s employees are not members of any labor union.

The Company’s operations are overseen directly by management. Management oversees all responsibilities in the areas of corporate administration, business development and technological research and development. The Company continues to enhance its current management to retain skilled employees with experience relevant to the Company’s business.

The Company’s human capital objectives focus on attracting, developing, and retaining employees and agents. The Company also offers competitive compensation programs, including equity award opportunities for its agents and employees.

Most of the Company’s real estate professionals are retained as independent contractors, except where local laws require otherwise. Their classification is subject to IRS rules, foreign regulations, and applicable state and provincial laws, all of which are subject to interpretation and change. The Company monitors ongoing federal, state, and international developments in this area.

Available Information

Our website is https://expworldholdings.com. The Company’s Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934 as amended (the “Exchange Act”), are filed with the Securities and Exchange Commission (the “SEC”). Such reports and information are made available free of charge through our Investor Relations website, www.expworldholdings.com/investors/sec-filings/, as soon as reasonably practicable after we electronically file that material with, or furnish it to, the SEC. The public can obtain any documents that we file with the SEC at www.sec.gov.

Item 1A.

RISK FACTORS

In addition to the other information set forth in this Annual Report, you should carefully consider the following factors, which could materially affect the Company’s business, financial condition or results of operations in future periods. The risks described below are not the only risks facing the Company. Additional risks not currently known to the Company or that it currently deems to be immaterial may materially adversely affect its business, financial condition or results of operations in future periods. You should carefully consider the risk factors described below, together with all of the other information in this Annual Report, including the Company’s consolidated financial statements and notes thereto and the “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in Part II, Item 7 of this Annual Report. Certain statements in this Annual Report are forward-looking statements. See the section of this Annual Report titled “Forward-Looking Statements.”

Risks Related to the Company’s Business and Industries

The Company’s business results are materially influenced by the strength of the U.S. residential real estate sector and overall economic conditions.

The Company’s business results are closely related to the strength of the U.S. residential real estate market, which is cyclical in nature, and general economic conditions, which are beyond its control. Any of the risks identified below could reduce residential real estate transaction volumes, depress home prices, or otherwise negatively influence the industry and the Company’s results of operations:

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economic slowdown or recession in the U.S., Canada, or other markets within which the Company operates;

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increased unemployment or declines in wage and salary levels;

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increased energy costs;

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higher interest rates, such as the high interest rates during 2024 and 2025, and continuing inflationary pressures;

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increased costs of obtaining mortgages, reduced availability of mortgage financing, or increased down payment requirements;

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an increase in foreclosure activity;

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general changes in consumer attitudes and behaviors, such as declining marriage and birth rates;

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disruptions in capital markets, significant volatility in U.S. and international equity markets, deterioration in global financial conditions, or declines in the stock market;

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changes to tax laws that eliminate, reduce, or limit deductions for mortgage interest or property taxes;

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changes in laws or regulations or actions taken by international, federal, and state governments, agencies and government-sponsored entities;

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lower consumer confidence in the national and global economy and/or real estate market;

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declining affordability of homes;

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slowdown in buyer demand for real estate and changing social attitudes toward home ownership;

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excessive or insufficient housing inventory;

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evolving federal policy under the current administration, including “Buy American” and protectionist trade or immigration measures, which could affect global supply chains, the cost of goods and labor, or foreign investment in real estate, each of which may influence housing demand or affordability;

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war, terrorist attacks or other geopolitical and security issues, including the ongoing conflict in Eastern Europe, rising tensions in the Middle East (including with Iran), and heightened strategic competition in the Asia-Pacific region (including between China and Taiwan), any of which could disrupt global economic conditions, supply chains, or the Company’s international operations;

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changes in trade policy including the imposition of new tariffs, and responses to such tariffs, that may indirectly affect the cost of homebuilding materials, consumer goods, or broader economic sentiment; and

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natural disasters or adverse weather events, or the public perception that any of these events may occur.

Monetary policies of the U.S. federal government and its agencies, particularly those impacting mortgage interest rates and buyer affordability, may have a material adverse impact on the Company’s operations.

The Company generates a significant portion of its revenue from the U.S. real estate market, which is heavily influenced by the Federal Reserve Board. By regulating the supply of money and credit these policies directly impact mortgage interest rates – a primary driver of the U.S. real estate market The Company’s business and profitability are negatively impacted by any rising interest rate environment, as higher mortgage rates typically lead to a decrease in the number of home sale transactions.

Elevated mortgage rates, combined with an increased overall cost of living and broader economic pressures, create significant affordability challenges that reduce the ability and willingness of prospective buyers to purchase a home. Specifically:

Higher interest rates reduce purchasing power. In addition, rising costs associated with student loan obligations, healthcare, insurance, and other essential living expenses have further constrained affordability for households considering homeownership.

These affordability pressures have contributed to longer decision timelines and, in some cases, delayed or deferred home purchases, particularly among first-time buyers. As a result, the average age of first-time homebuyers has increased, which may reduce transaction activity earlier in the buyer lifecycle and negatively impact overall housing demand.

The mortgage market continues to rely heavily on government-sponsored enterprises such as Fannie Mae, Freddie Mac, and Ginnie Mae to provide liquidity. While these programs remain in place, changes to their underwriting standards, loan programs, or pricing, as well as sustained higher interest rates, could further affect affordability and buyer demand.

In addition, the availability and cost of homeowners’ insurance particularly in regions subject to increased climate-related risks - can materially affect the cost of homeownership and a buyer’s ability to obtain financing. If insurance coverage becomes more limited or more expensive, housing demand and transaction activity may decline.

If elevated interest rates, affordability challenges, or other economic pressures persist or worsen, the number of real estate transactions facilitated through the Company’s platform could continue to decline, which would adversely affect the Company’s revenues, operating results, and financial condition.

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Fluctuations in housing inventory levels can negatively impact the Company’s business, which depends on the ability of its brokers and agents to facilitate home sales. In certain markets, limited supply in recent years has reduced transaction activity.

Factors outside the Company’s control such as the pace of new housing construction, macroeconomic conditions, rising mortgage costs that discourage potential sellers from moving, and increased purchases of residential properties by institutional investors for long-term rental or corporate use have contributed to lower inventory and fewer completed transactions in recent years. Conversely, periods of elevated inventory can also dampen demand and slow sales activity. Sustained imbalances in housing supply, whether too low or too high, could materially and adversely affect the Company’s business, financial condition, and results of operations.

Material decreases in the average brokerage commission rate, due to conditions beyond the Company’s control, could materially adversely affect its financial results.

There are many factors that contribute to average broker commission rates that are beyond the Company’s control. Factors that can contribute to a material decrease in brokerage commissions include changes in regulation, litigation (including pending litigation and industry practice changes described elsewhere in this Annual Report), the rise of certain competitive brokerage or non-traditional competitor models, an increase in the popularity of discount brokers and agents, increased adoption of flat fees, commission models with more competitive rates, rebates or lower commission rates on transactions, as well as other competitive factors. For example, the Company competes with other brokerages that may have reduced operating margins and access to capital resources permitting them to prioritize market share over profits, as well as the growing popularity of non-traditional platforms such as listing aggregators, which may put additional pressure on the Company’s commissions and related costs. The average broker commission rate for a real estate transaction is a key determinant of the Company’s profitability, and a material decrease in brokerage commission rates could have a material adverse effect on the Company’s business and profitability.

The introduction and integration of emerging technologies, including artificial intelligence, presents various operational, compliance, and reputational risks and could impact the Company’s competitive position and financial performance.

Emerging technologies, including artificial intelligence (“AI”) and machine learning, are reshaping the real estate brokerage industry and offer opportunities to enhance efficiency, productivity, and client experience; however, the Company’s adoption of these tools—including agent support chatbots, document processing systems, employee digital twins, and agent-facing custom Generative Pre-trained Transfer, or GPTs—also creates risks related to reliability, accuracy, data privacy, bias, and regulatory compliance. Failures or limitations in these technologies could disrupt operations, expose the Company to legal or reputational harm, and negatively affect agent productivity and its competitive position.

Additionally, AI algorithms and other emerging technologies may be flawed and datasets underlying such technologies may be insufficient or contain biased information. If the new technologies integrated into the Company’s operations produce analyses or recommendations that are or are alleged to be deficient, inaccurate, or biased, the Company’s reputation, business, financial condition, and results of operations may be adversely affected.

The Company expects that there will continue to be new laws or regulations governing the use of AI technology, which might be burdensome for the Company to comply with and may limit the Company’s ability to offer or enhance its existing tools and features or new offerings using, incorporating, or relying on AI technology. Further, the use of AI technology requires specialized expertise. The Company may not be able to attract and retain top talent to support the Company’s AI technology initiatives. If any of the operational, compliance or reputational risks were to materialize, the Company’s business and results of operations may be adversely affected.

The Company’s operating results are subject to seasonality and vary significantly among quarters during each calendar year, making meaningful comparisons of successive quarters difficult.

Home sales in successive quarters can fluctuate significantly due to a wide variety of factors, including, but not limited to, holidays, national or international emergencies, the school year calendar’s impact on timing of family relocations, interest rate changes or speculation of pending interest rate changes, natural disasters, including hurricanes, flooding and wildfires, and the overall macroeconomic market.

Additionally, seasons and weather traditionally impact the real estate industry. The Company has historically experienced lower revenues during the fall and winter seasons in comparison to spring and summer seasons, as well as during periods of unseasonable weather, which reduces the Company’s operating income, net income, operating margins and cash flow. Past performance in similar seasons or during similar weather events can provide no assurance of future or current performance and macroeconomic shifts in the markets the Company serves can conceal the impact of poor weather or seasonality.

The Company’s revenue and operating margins each quarter will remain subject to seasonal fluctuations, poor weather and natural disasters and macroeconomic market changes that may make it difficult to compare or analyze the Company’s financial performance effectively across successive quarters.

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Climate-related physical impacts, regulatory changes, and disclosure obligations could increase costs, reduce transaction activity, and expose the Company to liability or reputational harm.

Chronic and acute physical impacts of climate change, such as rising home insurance costs, home insurance unavailability, flooding, wildfires, hurricanes, and other severe weather events, may reduce property values, disrupt housing supply, and limit affordability for buyers. These events can slow transaction volumes, shift population growth away from high-risk regions, negatively affect the geographic mix of the Company’s revenues, and pose direct risks to the safety of the Company’s agents, brokers, clients, and employees in affected markets. Transition risks, including new building codes, retrofitting mandates, energy-efficiency standards, and climate-related taxes or insurance market interventions, may increase the cost of property ownership, alter buyer demand, and extend transaction timelines. Liability risks may arise if the Company’s brokers or agents fail to comply with new climate-related disclosure requirements or misstate property-related risks, and the Company could also face regulatory penalties, litigation, or reputational harm if the Company fails to comply with evolving climate-related laws and regulations applicable to the Company’s operations. Any or all of these risks could materially and adversely impact the Company’s business, revenue, results of operations, and financial condition.

The Company may be unable to attract, retain, and incentivize qualified real estate professionals.

The Company’s success depends significantly on its ability to attract, retain, and engage qualified real estate agents and brokers, who are the foundation of the Company’s revenue-generating activities. Competition for skilled agents and brokers is intense, as the Company faces pressure from other brokerages offering alternative compensation models, technology tools, or support services, as well as from technology companies seeking experienced professionals in software development and cloud-based solutions. If the Company fails to recruit and retain a strong network of agents and brokers, the Company’s competitive position, market share, and overall business performance could be adversely affected.

Industry and regulatory changes, including recent revisions to National Association of Realtors (“NAR”) policies and standards, buyer-broker compensation practices, and the recent settlement resolving nationwide antitrust litigation against NAR and major brokerages, may increase compliance burdens for agents, raise operating costs, and impact the perceived value of the profession. These developments could lead to higher attrition rates across the industry and at the Company, particularly among part-time agents or those with lower transaction volumes. Broader shifts in compensation structures, licensing requirements, or competitive dynamics could further complicate the Company’s ability to recruit and retain agents, and if a significant number of agents leave the profession or fail to maintain active licenses, the Company’s agent base and market presence could be materially diminished.

Further, the Company’s value proposition for agents and brokers, which includes allowing them to participate in the revenue of the Company, is not typical in the real estate industry. If agents and brokers do not understand or appreciate this unique model, including the Company’s revenue share program, equity incentives, and cloud-based platform, the Company may not be able to attract, retain, and incentivize agents effectively. In addition, volatility in the value of the Company’s stock or changes to the perceived value of its programs could negatively impact recruitment and retention.

If the Company is unable to attract, retain qualified agents and brokers, or to maintain their engagement with its model and programs, the Company’s business, financial condition, results of operations, and growth prospects could be materially and adversely affected.

Loss of the Company’s current executive officers or other key management could significantly harm its business.

The Company depends on the industry experience and talent of its current executives. The Company believes that its future results will depend in part upon its ability to retain and attract highly skilled and qualified management. The loss of the Company’s executive officers could have a material adverse effect on its operations because other officers may not have the experience and expertise to readily replace these individuals. To the extent that one or more of the Company’s top executives or other key management personnel depart from the Company, its operations and business prospects may be adversely affected. In addition, changes in executives and key personnel could be disruptive to the Company’s business.

The Company’s business, financial condition and reputation may be substantially harmed by security breaches, interruptions, delays and failures in its systems and operations.

The performance and reliability of the Company’s systems and operations are critical to its reputation and ability to attract agents, teams of agents and brokers into the Company as well as its ability to service homebuyers and sellers. The Company’s systems and operations are vulnerable to security breaches, interruption or malfunction due to events beyond its control, including natural disasters, such as earthquakes, fires and floods, power loss, telecommunication failures, break-ins, sabotage, computer viruses, intentional acts of vandalism and similar events. In addition, the Company relies on third-party vendors to provide key components of the Company’s cloud office platform and to provide additional systems and related support. If the Company cannot continue to retain these services on acceptable terms, its access to these systems and services could be interrupted. Any security breach, interruption, delay or failure in the Company’s systems and operations could substantially reduce the transaction volume that can be processed with its systems, impair quality of service, increase costs, prompt litigation and other consumer claims and damage the Company’s reputation, any of which could substantially harm the Company’s results of operations and financial condition.

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Cybersecurity incidents could disrupt the Company’s business operations, result in the loss of critical and confidential information, adversely impact the Company’s reputation and harm its business.

Cybersecurity threats and incidents directed at the Company could range from uncoordinated individual attempts to gain unauthorized access to information technology systems to sophisticated and targeted measures aimed at disrupting business or gathering personal data of clients, agents, or customers. Additionally, bad actors are increasingly using AI technology to launch more automated, targeted, and coordinated attacks, including deep-fake impersonations and other techniques that could facilitate wire fraud or other fraudulent activities. In the ordinary course of the Company’s business, the Company and its agents and brokers collect and store sensitive data, including proprietary business information and personal information about its clients.

The Company’s business, and particularly its cloud-based platform, is reliant on the uninterrupted functioning of its information technology systems. The secure processing, maintenance and transmission of information are critical to the Company’s operations, especially the processing and closing of real estate transactions, which are increasingly targeted by wire fraud schemes. Although the Company employs measures designed to prevent, detect, address and mitigate these threats (including access controls, data encryption, vulnerability assessments and maintenance of backup and protective systems), cybersecurity incidents, depending on their nature and scope, could potentially result in the misappropriation, destruction, corruption, or unavailability of critical data and confidential or proprietary information (the Company’s own or that of third parties, including potentially sensitive personal information of the Company’s clients, agents, and customers) and the disruption of business operations.

Any such compromises to the Company’s security could cause harm to its reputation, which could cause clients, agents and customers to lose trust and confidence in the Company or could cause agents and brokers to unaffiliate with us. In addition, the Company may incur significant costs for remediation that may include liability for stolen assets or information, repair of system damage and compensation to clients, agents, customers and business partners. The Company may also be subject to legal claims, government investigations and additional state and federal statutory requirements.

The potential consequences of a material cybersecurity incident include regulatory violations of applicable U.S. and foreign privacy and other laws, reputational damage, loss of market value, litigation with third parties (which could result in the Company’s exposure to material civil or criminal liability), diminution in the value of the services the Company provides to its customers, and increased cybersecurity protection and remediation costs (that may include liability for stolen assets or information), which in turn could have a material adverse effect on the Company’s competitiveness and results of operations.

The Company may not be able to utilize a portion of its net operating loss or research tax credit carryforwards, which may adversely affect the Company’s profitability.

As of December 31, 2025, the Company had federal, state and foreign net operating losses carryforwards due to prior years’ losses. Certain pre-fiscal 2018 state net operating losses will carry forward for a limited number of years. Federal, as well as some state and foreign net operating losses generated in and after fiscal 2018 do not expire and can be carried forward indefinitely. The Company also has recorded federal research tax credits for the years 2019 to 2025 which will carry forward for 20 years and are expected to be fully utilized before expiration. A nominal portion of the Company’s net operating loss may expire, increasing future income tax liabilities which may adversely affect its profitability.

In addition, under Section 382 of the Internal Revenue Code of 1986, as amended, the Company’s ability to utilize net operating loss carryforwards or other tax attributes, in any taxable year, may be limited if the Company experiences an "ownership change.” A Section 382 “ownership change” generally occurs if one or more stockholders or groups of stockholders who own at least 5% of the Company’s stock increase their ownership by more than 50 percentage points over their lowest ownership percentage within a rolling three-year period. Similar rules may apply under state tax laws. It is possible that an ownership change, or any future ownership change, could have a material effect on the use of the Company’s net operating loss carryforwards or other tax attributes, which could adversely affect its profitability.

The Company could be subject to changes in tax laws and regulations that may have a material adverse effect in its business.

The Company operates and is subject to taxes in the United States and numerous other jurisdictions throughout the world. Changes to federal, state, local, or international tax laws on income, sales, use, indirect, or other tax laws, statutes, rules or regulations may adversely affect the Company’s effective tax rate, operating results or cash flows.

The Company’s effective tax rate could increase due to several factors, including: changes in the relative amounts of income before taxes in the various jurisdictions in which the Company operates that have differing statutory tax rates; changes to the Company’s assessment about its ability to realize the Company’s deferred tax assets that are based on estimates of its future results, the prudence and feasibility of possible tax planning strategies, and the economic and political environments in which the Company does business; the outcome of current and future tax audits, examinations or administrative appeals; and limitations or adverse findings regarding the Company’s ability to do business in some jurisdictions.

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In particular, new income, sales and use or other tax laws or regulations could be enacted at any time, which could adversely affect the Company’s business operations and financial performance. Further, existing tax laws and regulations could be interpreted, modified or applied adversely to us. For example, the One Big Beautiful Bill Act (“OBBBA”) enacted many significant changes to the U.S. tax laws. Future guidance from the IRS and other tax authorities with respect to the OBBBA may affect us, and certain aspects of the OBBBA could be repealed or modified in future legislation. In addition, it is uncertain if, and to what extent, various states will conform to the OBBBA or any newly enacted federal tax legislation. Changes in corporate tax rates, the realization of net operating losses, and other deferred tax assets relating to the Company’s operations, the taxation of foreign earnings, and the deductibility of expenses under the OBBBA or future reform legislation could have a material impact on the value of the Company’s deferred tax assets and could increase its future U.S. tax expense.

Tax incentives tied to homeownership, such as the deductibility of mortgage interest and property taxes, influence the affordability and attractiveness of buying a home. These benefits are subject to provincial, federal, and state limitations and could be eliminated, restricted, or otherwise reduced through changes in tax law. Any reduction in these incentives would increase the after-tax cost of homeownership, which could decrease buyer demand, slow residential real estate activity, and, in turn, adversely affect the Company’s business, financial condition, and results of operations.

The Company may be unable to effectively and efficiently manage growth in its business.

The Company may struggle to manage growth in its business efficiently. Failing to scale the Company’s operations to meet the increasing demands of its real estate professionals could negatively impact the Company’s performance. As the Company onboards more real estate professionals, the need to enhance the Company’s systems, integrate third-party systems, and maintain infrastructure becomes vital. Any delay in these upgrades can lead to system issues and reduced satisfaction among the Company’s real estate professionals. This could deter existing and potential professionals from associating with the Company. Expanding the Company’s systems efficiently may be challenging and also poses inherent risks, and the Company cannot guarantee timely and effective implementation. Such efforts might lead to decreased revenues and margins, impacting the Company’s financial results.

The Company may not successfully complete or integrate acquisitions or joint ventures.

The Company regularly evaluates potential acquisitions, joint ventures, and other strategic opportunities as part of its growth strategy. These activities involve risks, including the Company’s ability to identify and complete transactions on favorable terms, successfully integrate acquired businesses or joint ventures into its operations, and realize anticipated synergies or efficiencies within expected timeframes. Such transactions may also divert management’s attention, increase costs, cause shareholder dilution, or expose the Company to unforeseen liabilities. If the Company is unable to complete or effectively integrate acquisitions or joint ventures, the Company’s business, financial condition, and results of operations could be materially and adversely affected.

The Company’s international operations are subject to risks not generally experienced by its U.S. operations.

The Company has operations throughout the Americas, Europe, the Middle East, Asia-Pacific, and South Africa. The Company’s international operations are subject to risks not generally experienced by its U.S. operations. The risks involved in the Company’s international operations and relationships that could result in losses against which it is not insured and, therefore, affect the Company’s profitability include:

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fluctuations in foreign currency exchange rates, foreign exchange controls, and limitations on the repatriation of funds;

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exposure to local economic conditions and local laws and regulations;

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exposure to political, economic, legal, regulatory and social conditions, or instability, and economic and political tensions between governments;

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employment laws that are significantly different than U.S. employment laws;

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diminished ability to legally enforce the Company’s contractual rights and use of the Company’s trademarks in foreign countries;

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difficulties in registering, protecting or preserving trade names and trademarks in foreign countries;

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restrictions on the ability to obtain or retain licenses required for operations;

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withholding and other taxes on third-party cross-border transactions as well as remittances and other payments by subsidiaries;

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onerous requirements, subject to broad interpretation, for indirect taxes and income taxes that can result in audits with potentially significant financial outcomes;

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changes in foreign taxation structures;

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compliance with the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, or similar laws of other countries; and

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regional and country specific data protection and privacy laws including the European Union’s General Data Protection Regulation (“GDPR”).

In addition, activities of agents and brokers outside of the U.S. are more difficult and more expensive to monitor and improper activities or mismanagement may be more difficult to detect. Negligent or improper activities involving the Company’s agents and brokers may result in reputational damage to the Company and may lead to direct claims against the Company based on theories of vicarious liability, negligence, joint operations and joint employer liability which, if determined adversely, could increase costs and subject the Company to incremental liability for their actions.

The Company is actively developing, and intends to continue to develop, new products and services complementary to its brokerage business and the Company’s failure to accurately predict their demand or growth could have an adverse effect on its business.

The Company is actively investing and intends to continue to invest resources in developing new technology, services, products and other offerings complementary to the Company’s brokerage business. New business initiatives are inherently risky and may involve unproven business strategies and markets with which the Company has limited or no prior development or operating experience. Risks from these new initiatives include those associated with potential defects in the design, ongoing development and maintenance of technologies, reliance on data or user inputs that may prove inadequate or unavailable, failure to design products and services in a way that is more effective or affordable than competing third-party products and services and failure to scale businesses as they grow, among others. As a result of these risks, the Company could experience increased legal claims, reputational damage, financial loss or other adverse effects, which could be material. The Company can provide no assurance that it will be able to efficiently or effectively develop, commercialize and achieve market acceptance of new products and services. Additionally, the human and financial capital committed to develop new products and services may either be insufficient or result in expenses that exceed the revenue actually originated from these new products and services. In addition, the Company’s efforts to develop new products and services could distract management from current operations and could divert capital and other resources from the Company’s existing business, including its brokerage business. Failure to achieve the expected benefits of the Company’s investments may occur and could harm its business.

The real estate market may be severely impacted by industry changes as the result of certain class action lawsuits, settlements, or government investigations and the recent industry changes and/or any additional meaningful changes could have a materially adverse effect on the Company’s business, operations, financial condition and results of operations.

The real estate industry faces significant pressure from private lawsuits and investigations by the U.S. Department of Justice (the “DOJ”) into antitrust issues.

In April 2019, the NAR and certain brokerages and franchisors (including Realogy Holdings Corp., HomeServices of America, Inc. RE/MAX, and Keller Williams Realty, Inc.) were named as defendants in a class action complaint alleging a conspiracy to violate federal antitrust laws by, among other things, requiring residential property sellers in Missouri to pay inflated commission fees to buyer brokers (the “NAR Class Action”). On October 31, 2023, a jury found NAR and various of its co-defendants liable and awarded plaintiffs nearly $1.8 billion in damages (all defendants have since settled, which remain subject to ongoing appeals processes). Class action suits raising similar claims are already pending in this and other jurisdictions and the outcome of the NAR Class Action may result in additional such actions being filed. The Company was named as one of several defendants in similar class action suits. See Note 13 – Commitments and Contingencies to the consolidated financial statements.

On December 9, 2024, the Company and certain of its subsidiaries entered into a Settlement Agreement (the “Settlement”) with plaintiffs in the U.S. antitrust lawsuit 1925 Hooper LLC, et al. v. The National Association of Realtors et. al., Case No. 1:23-cv-05392- SEG (United States District Court for the Northern District of Georgia, Atlanta Division), which was filed on November 22, 2023 against the Company and other U.S. brokerage defendants (the “Hooper Action”). The Settlement resolves all claims set forth in the Hooper Action, as well as all similar claims on a nationwide basis against the Company (collectively, the “Claims”) and releases the Company, its subsidiaries and affiliates, and their independent contractor real estate agents in the United States from the Claims. By the terms of the Settlement, the Company agreed to make certain changes to its business practices and to pay a total settlement amount of $34.0 million. The Settlement received preliminary approval on May 23, 2025, but remains subject to final court approval and will become effective following an appeals process, if applicable.

Defending against class action litigation is costly, may divert time and money away from the Company’s operations, and imposes a significant burden on management and employees. Also, the results of any such litigation or investigation cannot be predicted with certainty, and any negative outcome could result in payments of substantial monetary damages or fines, and/or undesirable

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changes to the Company’s operations or business practices, and accordingly, its business, financial condition, or results of operations could be materially and adversely affected.

On March 15, 2024, NAR entered a settlement agreement to resolve on a class wide basis the claims against NAR in the NAR Class Action. In addition to a monetary payment of $418 million, NAR agreed to change certain business practices, including changes to cooperative compensation and buyer agreements. The NAR settlement agreement: (1) prohibits NAR and REALTOR® MLSs from requiring that listing brokers or sellers make offers of compensation to buyer brokers or other buyer representatives; (2) prohibits NAR, REALTOR® MLSs and MLS participants from making an offer of compensation on the MLS; and (3) requires all REALTOR® MLS participants to enter into a written buyer agreement specifying compensation before taking a buyer on tour. The NAR settlement received preliminary court approval on April 23, 2024.

These revised NAR rules and practices have caused and may require additional changes to the Company’s business model, including changes to agent and broker compensation and how they meet home buyers. For example, the Company may see the introduction of hourly or a la carte services. Or, if buyers increasingly compensate brokers, they may be more likely to contact listing agents directly, which could reduce overall brokerage participation in buyer representation. If sellers increasingly do not offer compensation to buyer agents, and because existing mortgage lending rules and market practices generally do not permit buyers to finance buyer-agent compensation as part of a home loan, some buyers may have limited ability to pay such fees at the time of purchase. The amended rules and regulations also require the Company and its agents to get a buyer agreement signed before taking a home buyer on a first tour. This requirement may dissuade buyers from hiring the Company, thereby reducing the fees the Company receives from its agents. These and other shifts in the model for agent and broker compensation could significantly change the brokerage landscape overall and may adversely affect the Company’s financial condition and results of operations.

In addition to the NAR Class Action and various similar private actions already pending, beginning in 2018, the DOJ began investigating NAR for violations of the federal antitrust laws. The DOJ and NAR appeared to reach a resolution in November 2020, resulting in the filing of a Complaint and Proposed Consent Judgment pursuant to which NAR agreed to adopt certain rule changes, such as increased disclosure of commission offers. The DOJ has since sought to continue its investigation of NAR, and on April 5, 2024, a federal appeals court decided that the DOJ could reopen its investigation. It is uncertain what effect, if any, the resumption of the DOJ’s investigation could have on the larger real estate industry, including any further settlement that may result therefrom.

More recently, litigation between other real estate industry participants has highlighted the risk of private litigation under the auspices of antitrust laws. For example, in July 2025, Compass, Inc. filed a lawsuit against Zillow Group, Inc. claiming that Zillow had engaged in anti-competitive conduct. The lawsuit included allegations that other industry participants, including the Company, had conspired with such anti-competitive conduct. Although the Company is not named as a defendant in that action, these types of lawsuits reflect the risk of both private litigation and regulatory action to challenge business practices in the residential real estate sector. Even when not directly targeted, the Company may face reputational, operational, or financial consequences as a result of broader industry litigation. The Company may be required to further adjust its business practices, increase legal spend, or defend against claims, any of which could materially and adversely affect the Company’s business, financial condition, or results of operations.

Negligence or willful misconduct of independent real estate professionals affiliated with the Company owned brokerages could materially and adversely affect the Company’s reputation and subject it to liability.

The Company’s operations rely on the performance of real estate brokers and agents. If the Company brokers and agents were to provide lower quality services to its customers or engage in negligent or intentional misconduct, the Company’s image and reputation could be materially adversely affected. In addition, the Company has previously been subject to and could continue to be subject to public scrutiny as well as litigation and regulatory claims arising out of the Company’s brokers’ and agents’ performance of brokerage services or other conduct, which if adversely determined, could result in substantial financial or legal penalties.

If the Company fails to grow in the various local markets that it serves or are unsuccessful in identifying and pursuing new business opportunities, the Company’s long-term prospects and profitability will be harmed.

To capture and retain market share in the various local markets that the Company serves, it must compete successfully against other brokerages for agents and brokers and for the consumer relationships that they bring. The Company’s competitors could lower the fees that they charge to agents and brokers or could raise the compensation structure for those agents. The Company’s competitors may have access to greater financial resources than us, allowing them to undertake expensive local advertising or marketing efforts. In addition, the Company’s competitors may be able to leverage local relationships, referral sources and strong local brand and name recognition that the Company has not established. The Company’s competitors could, as a result, have

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greater leverage in attracting new and established agents in the market and in generating business among local consumers. The Company’s ability to grow in the local markets that it serves will depend on its ability to compete with these local brokerages.

The Company may implement changes to its business model and operations to improve revenue that cause a disproportionate increase in the Company’s expenses or reduce profit margins. For example, the Company may allocate resources to acquiring lower margin brokerage models and has invested in the development of a mortgage servicing division, a commercial real estate division, title and escrow companies, a mortgage lending company, and a personal and continuing education company. Expanding the Company’s service offerings could involve significant up-front costs that may only be recovered after lengthy periods of time. The barrier to entering in new real estate markets is low given the Company’s cloud-based operating model; however, attempts to pursue new business opportunities could result in a disproportionate increase in the Company’s expenses and in reduced profit margins. In addition, expansion into new markets and business lines, including internationally, could expose the Company to additional compliance obligations and regulatory risks. If the Company fails to continue to grow in the local markets it serves or if it fails to successfully identify and pursue new business opportunities, the Company’s long-term prospects, financial condition and results of operations may be harmed, and its stock price may decline.

The Company’s growth depends in part on the success of its strategic relationships with third parties.

To support and expand the Company’s business, the Company relies on strategic relationships with a variety of third parties, including settlement service providers, mortgage lenders, title companies, referral sources, and other third parties that support the Company’s operations. Building, negotiating, and maintaining these relationships requires significant time and resources, and there is no guarantee they will continue on favorable terms. The Company also depends on access to MLSs in the Company’s markets, which serve as critical sources of property data and listing distribution. Competitors may have similar or superior access to MLS data, and any changes to the Company’s rights of use, disruptions in access, or termination of agreements could impair its ability to provide accurate pricing, market listings efficiently, or support the Company’s agents’ businesses. If the Company is unable to maintain or expand key third-party relationships, its competitive position, growth prospects, and financial performance could be materially and adversely affected.

Risks Related to Legal and Regulatory Matters

The Company is subject to certain risks related to legal proceedings filed by or against it and adverse results may harm its business and financial condition.

The Company is subject to risk of and are from time to time involved in, or may in the future be subject to or involved in, claims, suits, government investigations and proceedings arising from the Company’s business, including, but not limited to, actions with respect to securities, intellectual property, privacy, information security, data protection or law enforcement matters, tax matters, labor and employment, including claims challenging the classification of the Company’s agents and brokers as independent contractors and compliance with wage and hour regulations, and claims alleging violations of Real Estate Settlement Procedures Act (“RESPA”) (and similar state statutes) compliance or state consumer fraud statutes and commercial arrangements. The Company is also subject to risk related to stockholder derivative actions, standard brokerage disputes, vicarious liability based upon conduct of individuals or entities outside of its control, including the Company’s agents, brokers, third-party service or product providers and purported class action lawsuits. Such litigation and other proceedings may include, but are not limited to, the currently pending antitrust and derivative litigation as disclosed in Note 13 – Commitments and Contingencies to the consolidated financial statements included elsewhere within this Annual Report. A substantial unsatisfied judgment against the Company or one of its subsidiaries could result in bankruptcy, which would materially and adversely affect its business and operating results.

The Company cannot predict with certainty the cost of defense, the cost of prosecution, insurance coverage or the ultimate outcome of litigation and other proceedings filed by or against us, including remedies or damage awards and/or undesirable changes to the Company’s operations or business practices. Adverse results in such litigation and other proceedings may harm the Company’s business and financial condition. Class action lawsuits can often be particularly burdensome given the breadth of claims, large potential damages and significant costs of defense. In the case of intellectual property litigation and proceedings, although the Company has taken measures to protect its intellectual property rights, including existing and future trademarks, trade secrets, patents and copyrights, adverse outcomes could include the cancellation, invalidation or other loss of material intellectual property rights used in the Company’s business or injunctions prohibiting its use of business processes or technology that is subject to third-party patents or other third-party intellectual property rights. In addition, the Company may be required to enter into licensing agreements (if available on acceptable terms) and be required to pay royalties. In the case of securities litigation and proceedings, adverse outcomes could include the cancellation, invalidation, or modification of the Company’s existing equity incentive program.

From time to time, the Company may become involved in lawsuits and legal proceedings which arise in the ordinary course of business. Except as set forth in Note 13 – Commitments and Contingencies to the consolidated financial statements included elsewhere within this Annual Report, the Company is not involved in any material pending legal proceedings and there are no known proceedings in which any of the Company’s directors, officers or affiliates is an adverse party or has a material interest adverse to its interest.

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Adverse outcomes in litigation and regulatory actions against other companies and agents in the Company’s industry could adversely impact its financial results.

Adverse outcomes in legal and regulatory actions against other companies, brokers, and agents in the residential and commercial real estate industry may adversely impact the financial condition of the Company and its real estate brokers and agents when those matters relate to business practices shared by the Company, its real estate brokers and agents, or its industry at large. Such matters may include, without limitation, RESPA, Telephone Consumer Protection Act of 1991 and state consumer protection law, antitrust and anticompetition, and worker classification claims. Additionally, if plaintiffs or regulatory bodies are successful in such actions, this may increase the likelihood that similar claims are made against the Company and/or its real estate brokers and agents which claims could result in significant liability and be adverse to its financial results if the Company or its brokers and agents are unable to distinguish or defend their business practices.

The Company faces significant risk to its brand and revenue if it fails to maintain compliance with the law and regulations of federal, state, county and foreign governmental authorities, or private associations and governing boards.

The Company operates in a heavily regulated industry subject to complex, federal, state, provincial and local laws and regulations within the markets in which the Company operates and third-party organizations’ regulations, policies and bylaws governing the real estate business.

In general, the laws, rules and regulations that apply to the Company’s business practices include, without limitation, RESPA, the federal Fair Housing Act of 1968, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”), the Exchange Act and federal advertising and other laws, as well as comparable state statutes; rules of trade organizations such as NAR, local MLSs and state and local Association of Realtors; licensing requirements and related obligations that could arise from the Company’s business practices relating to the provision of services other than real estate brokerage services, including without limitation, its mortgage lending services; privacy regulations relating to the Company’s use of personal information collected from the registered users of its websites; laws relating to the use and publication of information through the internet; and state real estate brokerage and mortgage lending licensing requirements, as well as statutory due diligence, disclosure, record keeping and standard-of-care obligations relating to these licenses. Recent regulatory scrutiny regarding the classification of real estate agents as independent contractors, particularly at the state level, could lead to increased compliance costs, potential reclassification, or penalties, which could materially impact the Company’s owned brokerage operations.

Additionally, the Dodd-Frank Act contains the Mortgage Reform and Anti-Predatory Lending Act (“Mortgage Act”), which imposes a number of additional requirements on lenders and servicers of residential mortgage loans, by amending certain existing provisions and adding new sections to RESPA and other federal laws. It also broadly prohibits unfair, deceptive or abusive acts or practices and knowingly or recklessly providing substantial assistance to a covered person in violation of that prohibition. The penalties for noncompliance with these laws are also significantly increased by the Mortgage Act, which could lead to an increase in lawsuits against mortgage lenders and servicers.

As the Company expands its business in international markets, including new and existing international markets, the Company is subject to additional foreign governmental regulation. Ensuring compliance with these newly applicable laws could substantially increase its operating expenses. In addition, entry into these new markets exposes the Company to increased risk and liability. A violation of any of these applicable laws could have a material adverse effect on the Company’s business.

Maintaining legal compliance is challenging and increases the Company’s costs due to resources required to continually monitor business practices for compliance with applicable laws, rules and regulations and to monitor changes in the applicable laws themselves. For example, the potential reclassification of agents under wage and hour laws could result in additional liabilities for minimum wage, overtime pay, and penalties for prior periods, creating significant operational disruptions.

The Company may not become aware of all the laws, rules and regulations that govern its business, or be able to comply with all of them, given the rate of regulatory changes, ambiguities in regulations, contradictions in regulations between jurisdictions and the difficulties in achieving both company-wide and region-specific knowledge and compliance.

If the Company fails, or is alleged to have failed, to comply with any existing or future applicable laws, rules and regulations, it could be subject to lawsuits and administrative complaints and proceedings, as well as criminal proceedings. The Company’s noncompliance could result in significant defense costs, settlement costs, damages and penalties.

The Company’s business licenses could be suspended or revoked, its business practices enjoined, or the Company could be required to modify its business practices, which could materially impair, or even prevent, the Company’s ability to conduct all or any portion of its business. Any such events could also damage the Company’s reputation and impair its ability to attract and service homebuyers, home sellers, agents, clients and customers as well as its ability to attract brokerages, brokers, teams of agents and agents to the Company, without increasing costs.

Further, if the Company loses its ability to obtain and maintain all of the regulatory approvals and licenses necessary to conduct business as it currently operates, the Company’s ability to conduct business may be harmed. Lastly, any lobbying or related

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activities the Company undertakes in response to mitigate liability of current or new regulations could substantially increase operating expenses.

The Company offers independent agents the opportunity to earn additional commissions through its revenue sharing plan, which pays under a multi-tiered compensation structure similar in some respects to network marketing. Network marketing is subject to intense government scrutiny and regulation and changes in the law, or the interpretation and enforcement of the law, might adversely affect the Company’s business.

Various laws and regulations in the United States and other countries regulate network marketing. These laws and regulations exist at many levels of government in many different forms, including statutes, rules, regulations, judicial decisions and administrative orders. Network marketing regulations are inherently fact-based and often do not include "bright line" rules. Additionally, the Company is subject to the risk that the regulations, or a regulator's interpretation and enforcement of the regulations, could change. From time to time, the Company has received requests to supply information regarding its revenue sharing plan to regulatory agencies. The Company could potentially in the future be required to modify its revenue sharing plan in certain jurisdictions in order to comply with the interpretation of the regulations by local authorities.

In the United States, the Federal Trade Commission (“FTC”) has entered into several highly publicized settlements with network marketing companies that required those companies to modify their compensation plans and business models. Those settlements resulted from actions brought by the FTC involving a variety of alleged violations of consumer protection laws, including misleading earnings representations by the companies' independent distributors, as well as the legal validity of the companies' business model and distributor compensation plans. FTC determinations such as these have created an ambiguity regarding the proper interpretation of the law and regulations applicable to network marketing companies in the U.S. Although a consent decree between the FTC and a specific company does not represent judicial precedent, FTC officials have indicated that the network marketing industry should look to these consent decrees and the principles contained therein, for guidance. Additionally, following the issuance of these consent decrees, the FTC issued non-binding guidance to the network marketing industry, suggesting it intended to reinforce the principles contained in the consent decrees and provide other operational guidance to the network marketing industry.

While the Company strives to ensure that its overall business model and revenue-sharing plan are compliant with applicable regulations in each of its markets, the Company cannot assure you that a regulator, if it were to review the Company’s business, would agree with the Company’s assessment and would not require the Company to change one or more aspects of its operations. Any action against the Company in the future by the FTC or another regulator could materially and adversely affect the Company’s operations.

The Company cannot predict the nature of any future law, regulation, or guidance, nor can it predict what effect additional governmental regulations, judicial decisions, or administrative orders, when and if promulgated, would have on the Company’s business. Failure by the Company, or its independent agents, to comply with these laws, could adversely affect its business.

The Company may suffer significant financial harm and loss of reputation if it does not comply, cannot comply, or is alleged to have not complied with applicable laws, rules and regulations concerning its classification and compensation practices for the agents in the Company’s brokerage operations.

Except for the Company’s employed state brokers, commission-only employees, and where otherwise dictated by local law, all real estate agent professionals in the Company’s brokerage operations have been retained as independent contractors, either directly or indirectly through third-party entities formed by these independent contractors for their business purposes. With respect to these independent contractors, like most brokerage firms, the Company is subject to the taxing authorities’ regulations and applicable laws regarding independent contractor classification. These regulations and guidelines are subject to judicial and agency interpretation, and it might be determined that the independent contractor classification is inapplicable to any of the Company’s affiliated real estate professionals. Further, if legal standards for classification of real estate professionals as independent contractors change or appear to be changing, it may be necessary to modify the Company’s compensation and benefits structure for its affiliated real estate professionals in some or all of its markets, including by paying additional compensation or reimbursing expenses.

In the future, the Company could incur substantial costs, penalties and damages, including back pay, unpaid benefits, taxes, expense reimbursement and attorneys’ fees, in defending future challenges by the Company’s affiliated real estate professionals to the Company’s employment classification or compensation practices.

The Company is, and may in the future be, blocked from or limited in providing its agent compensation plans in certain jurisdictions and may be required to modify its business model in those jurisdictions as a result.

The Company’s agent compensation plans represent a key lever in its strategy to attract and retain independent agents and brokers and are subject to various international, federal, state, territorial and local laws, rules and regulations which differ in each of the Company’s existing and future markets. As a result, the Company is, and may in the future be, blocked from or limited in providing each of its agent compensation plans in certain markets. In addition, these laws, rules and regulations are subject to

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judicial and agency interpretation, and it might be determined that the Company’s agent compensation plans are not permitted to be offered to independent contractors. In response to such limitations, the Company has, and may in the future be, required to modify its agent compensation practices in such markets. Failure to comply with applicable law, rules and regulations or failure to subsequently modify the Company’s business model in certain jurisdictions to effectively attract and retain agents and brokers could negatively affect the Company’s business, results of operations or financial condition. The costs attributable to developing compliant agent compensation plans can be significant and could adversely affect the Company’s financial condition.

If the Company fails to protect the privacy and personal information of its customers, agents or employees, it may be subject to legal claims, government action and damage to its reputation.

Hundreds of thousands of consumers, independent contractors and employees have shared personal information with the Company during the normal course of its business processing real estate transactions. This includes, but is not limited to, Social Security numbers, annual income amounts and sources, consumer names, addresses, telephone and cell phone numbers and email addresses. To run the Company’s business, it is essential for the Company to store and transmit this sensitive information in its systems and networks. At the same time, the Company is subject to numerous laws, regulations and other requirements that require businesses like the Company’s to protect the security of personal information, notify customers and other individuals about its privacy practices and limit the use, disclosure, or transfer of personal data across country borders. Regulators in the U.S. and abroad continue to enact comprehensive new laws or legislative reforms imposing significant privacy and cybersecurity restrictions. The result is that the Company is subject to increased regulatory scrutiny, additional contractual requirements from corporate customers and heightened compliance costs. These ongoing changes to privacy and cybersecurity laws also may make it more difficult for the Company to operate its business and may have a material adverse effect on its operations. For example, the European Union’s GDPR conferred new and significant privacy rights on individuals (including employees and independent agents) and materially increased penalties for violations. In the U.S., California enacted the California Consumer Privacy Act, which imposes comprehensive requirements on organizations that collect and disclose personal information about California residents.

Any significant violations of privacy, including as a result of cybersecurity breaches, could result in the loss of new or existing business, litigation, regulatory investigations, the payment of fines, damages and penalties and damage to the Company’s reputation, which could have a material adverse effect on its business, financial condition and results of operations.

The Company could also be adversely affected if legislation or regulations are expanded to require changes in the Company’s business practices or if governing jurisdictions interpret or implement their legislation or regulations in ways that negatively affect its business, results of operations or financial condition. For example, the Company has and may continue to incorporate new technologies such as machine learning and AI—defined broadly as the use of computer systems to simulate human intelligence, including decision-making, pattern recognition, and predictive analysis—into the Company’s processes and systems, which are under increased regulatory scrutiny. The Company may be required to change its platforms and services due to new laws and/or decisions related to emerging technologies which may decrease the Company’s operational efficiency and/or hinder its ability to improve its services.

In addition, while the Company discloses information collection and dissemination practices in the published privacy statements on its various websites, which it may modify from time to time, the Company may be subject to legal claims, government action and damage to its reputation if it acts or is perceived to be acting inconsistently with the terms of the Company’s privacy statement, customer expectations or state, national and international regulations. The Company’s policies and safeguards could be deemed insufficient if third parties with whom the Company has shared personal information fail to protect the privacy of that information.

The occurrence of a significant claim in excess of the Company’s insurance coverage or which is not covered by its insurance in any given period could have a material adverse effect on the Company’s financial condition and results of operations during the period. In the event the Company or the vendors with which it contracts to provide services on behalf of its customers were to suffer a breach of personal information, its customers and independent agents could terminate their business with the Company. Further, the Company may be subject to claims to the extent individual employees or independent contractors breach or fail to adhere to Company policies and practices and such actions jeopardize any personal information. The Company’s legal liability could include significant defense costs, settlement costs, damages and penalties, plus damage to the Company’s reputation with consumers, which could significantly damage its ability to attract customers. Any or all of these consequences would result in a meaningful unfavorable impact on the Company’s brand, business model, revenue, expenses, income and margins.

In addition, concern among potential homebuyers or sellers about the Company’s privacy practices could result in regulatory investigations, especially in the European Union as related to the GDPR. Additionally, concern among potential homebuyers or sellers could keep them from using the Company’s services or require it to incur significant expense to alter its business practices or educate them about how the Company uses personal information.

Entering into new business arrangements, joint ventures, or business lines may expose the Company to additional regulatory and compliance risks that could materially and adversely affect the Company’s business and financial condition.

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The Company’s strategy includes pursuing new business initiatives, entering into joint ventures, and expanding into complementary business lines. These efforts often require the Company to navigate complex and evolving regulatory environments that may differ significantly from those governing the Company’s core operations. If the Company is unable to timely and effectively address these regulatory and compliance requirements, or if risks arise beyond the Company’s reasonable ability to mitigate, its business and financial condition may be materially and adversely affected.

For example, SUCCESS^® Lending, the Company’s joint venture mortgage business launched in 2021, operates in the highly regulated mortgage lending industry, which involves stringent licensing requirements, state and federal oversight, and compliance with consumer protection laws. The mortgage lending business faces inherent risks, including but not limited to, operational challenges, legal and regulatory scrutiny, and unforeseen compliance costs.

These new business lines also require significant investments in infrastructure, personnel, and systems to ensure compliance. Failure to meet these obligations could result in legal or regulatory penalties, reputational damage, or the inability to scale these operations as planned. Moreover, the financial success of these ventures is uncertain given their limited operating histories, making it difficult to predict their long-term contribution to the Company’s overall financial performance.

While the Company aims to mitigate these risks through robust compliance frameworks and strategic partnerships, no mitigation effort can fully eliminate all risk. Unanticipated challenges in these or other future ventures could materially and adversely affect the Company’s operations, reputation, and financial condition.

Risks Related to the Company’s Common Stock

Glenn Sanford, the Company’s Chairman and Chief Executive Officer, together with Penny L Sanford TTEE Gratitude 2022 Trust, own a significant percentage of the Company’s common stock. As a result, the trading price for the Company’s shares of common stock may be depressed and they can significantly influence actions that may be adverse to the interests of the Company’s other stockholders.

As of January 31, 2026, Glenn Sanford beneficially owns approximately 25.7% and the Penny L Sanford TTEE Gratitude 2022 Trust owns approximately 16.5% of the Company’s outstanding common stock. While Mr. Sanford and the Penny L Sanford TTEE Gratitude 2022 Trust do not have voting group, this significant concentration of share ownership may adversely affect the trading price of the Company’s common stock because investors may perceive disadvantages in owning stock in a company with two stockholders holding a significant number of the Company’s shares. Each of Mr. Sanford and Penny L Sanford TTEE Gratitude 2022 Trust can significantly influence all matters requiring approval by the Company’s stockholders, including the election and removal of directors and any proposed merger, consolidation or sale of all or substantially all of the Company’s assets. In addition, due to his significant ownership stake and his service as the Company’s Chief Executive Officer and Chairman of the Company’s Board of Directors (“Board”), Mr. Sanford significantly influences the management of the Company’s business and affairs. This concentration of ownership and influence could have the effect of delaying, deferring, or preventing a change in control, or impeding a merger or consolidation, takeover or other business combination that could be favorable to the Company’s other stockholders.

Because the Company can issue additional shares of common stock and because it issues stock under an equity incentive plan, its stockholders may experience dilution in the future.

The Company is authorized to issue up to 900,000,000 shares of common stock, of which 207,785,762 shares were issued and 161,049,979 shares were outstanding as of December 31, 2025. Additionally, the Company maintains an active 2024 Equity Incentive Plan from which employees, agents, brokers and certain service providers of the Company and its affiliates can receive awards of the Company’s common stock. Previously, the Company maintained a 2015 Equity Incentive Plan. The Company ceased issuing shares under the 2015 Equity Incentive Plan when it began issuing shares under the 2024 Equity Incentive Plan in September 2024. The Board has the authority to cause the Company to issue additional shares of common stock without consent of any of its stockholders, subject to applicable Nasdaq listing rules. Consequently, current stockholders may experience more dilution in their ownership of the Company’s common stock in the future.

The price of the Company’s common stock is subject to volatility.

The Company’s common stock has experienced substantial price volatility in the past and may continue to do so in the future. Additionally, the Company, the real estate brokerage industry and technology industry and the stock market as a whole have, from time to time, experienced extreme stock price and volume fluctuations that have affected stock prices in ways that may have been unrelated to these companies’ operating performance which may occur again in the future. Additionally, future dividends are subject to declaration by the Board, and the Company’s share repurchase program does not obligate it to acquire any specific number of shares. If the Company fails to meet expectations related to future growth, profitability, dividends, share repurchases or other market expectations, the price of the Company’s common stock may decline significantly, which could have a material adverse impact on investor confidence and employee retention.

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Delaware law and the Company’s organizational documents may impede or discourage a takeover, which could deprive the Company’s investors of the opportunity to receive a premium for their shares.

The Company is a Delaware corporation, and the anti-takeover provisions of Delaware law impose various impediments to the ability of a third party to acquire control of the Company, even if a change of control would be beneficial to its existing stockholders. In addition, provisions of the Company’s restated certificate of incorporation and restated bylaws may make it more difficult for, or prevent a third party from, acquiring control of the Company without the approval of its Board of Directors. Among other things, these provisions:

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do not permit cumulative voting in the election of directors, which would otherwise allow less than a majority of stockholders to elect director candidates;

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delegate the sole power to a majority of the Board of Directors to fix the number of directors;

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provide the power to the Board to fill any vacancy on the Board, whether such vacancy occurs as a result of an increase in the number of directors or otherwise;

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eliminate the ability of stockholders to call special meetings of stockholders; and

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establish advance notice requirements for nominations for election to the Board or for proposing matters that can be acted on by stockholders at stockholder meetings.

The foregoing factors could impede a merger, takeover or other business combination or discourage a potential investor from making a tender offer for the Company’s common stock which, under certain circumstances, could reduce the market value of the Company’s common stock and its investors’ ability to realize any potential change-in-control premium.

Item 1B.

UNRESOLVED STAFF COMMENTS

None.

Item 1C.

CYBERSECURITY

The Company maintains a cybersecurity program designed to identify, assess, and manage material risks from cybersecurity threats across all business segments. Our cybersecurity program considers cybersecurity risks alongside other company risks as part of our overall enterprise risk assessment process, and shares common methodologies, reporting channels and governance processes that apply to other risks impacting the company, such as regulatory, financial and operational risks. Each reporting segment is responsible for monitoring and responding to risks within its operations, supported by annual training, standardized controls, and companywide policies.

The Company engages third-party consultants and technology providers to test and evaluate its security posture, provide independent assessments, and support remediation efforts. The Company also assesses cybersecurity risks presented by key suppliers and service providers, document their security posture through internal tools, and in certain cases requires third party audit reports or contractual notification of security incidents.

Daily monitoring and incident response activities are carried out by IT staff, with escalation protocols to the Company’s Chief Technology Officer (“CTO”) and Chief Executive Officer (CEO) as appropriate. FrameVR.io maintains its own cybersecurity program in consultation with the CTO. The Company has processes in place to log, track, and remediate incidents, and to coordinate responses across reporting segments. To date, the Company has not identified any cybersecurity threats or incidents that have had, or are reasonably likely to have, a material effect on the Company’s business strategy, financial condition, or results of operations.

Oversight of risks from cybersecurity threats is provided by the Board through the Board’s Nominating and Corporate Governance Committee, which receives quarterly reports from the CTO on emerging threats, program initiatives, regulatory compliance, and any incident activity. The CTO, in coordination with IT team members and legal team support segment leaders, ensures that significant developments are escalated to the Board, and the CEO retains ultimate responsibility for the Company’s cybersecurity risk management. The CEO has over 25 years of technology leadership experience. The CEO also holds a degree in Economics and Computer Science from the University of Oklahoma, which supports his ability to align technology initiatives with strategic business goals. The CTO has over 20 years of experience leading digital product and technology teams with a focus on delivering innovative software solutions that have served millions of consumers globally and internal enterprise groups. She drives business transformation through secure, scalable platforms focused on software reliability, user experience, data integrity, and system architecture. She has extensive experience in dealing with system security implementations, data architectures, risk mitigation and system protections. She holds a Master of Business Administration, with a specialty in Executive Leadership, from Royal Roads University and undergraduate degrees from Queen's University and the University of British Columbia.

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Item 2.

PROPERTIES

The Company leases its principal corporate office in Bellingham, Washington. As of December 31, 2025, the Company also leased small offices in various jurisdictions to meet regulatory and licensing requirements and, in certain cases, to provide space for managing brokers or drop-in use by agents. The Company does not own any real property. The Company believes its leased facilities are adequate for current operations and that additional space would be available to meet future needs.

Item 3.

LEGAL PROCEEDINGS

The information set forth under “Contingencies” under Note 13 – Commitments and Contingencies to the consolidated financial statements included in Part II, Item 8, Financial Statements and Supplementary Data, of this Annual Report is incorporated herein by reference.

Item 4.

MINE SAFETY DISCLOSURES

Not applicable.

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PART II

Item 5.

MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES

The common stock of eXp is traded on the Nasdaq Global Market under the trading symbol “EXPI”.

Holders

As of February 17, 2026, the Company had approximately 103,034 stockholders of record.

Dividends

During 2025, cash dividends paid totaled $30,773. The Board currently intends to continue paying quarterly dividends. However, payment of cash dividends is at the discretion of the Board in accordance with applicable law after taking into account various factors, including our financial condition, operating results, current and anticipated cash needs and plans for growth. Under Delaware law, we can only pay dividends either out of surplus or out of the current or the immediately preceding year’s earnings. Therefore, no assurance is given that we will pay any future dividends to our common stockholders, or as to the amount of any such dividends.

Purchases of Equity Securities by the Issuer and Affiliated Purchasers

Share repurchase activity during the three months ended December 31, 2025 was as follows:


Period	Total number of shares purchased	Average price paid per share	Total number of shares purchased as part of publicly announced plans or programs⁽¹⁾	Approximate dollar value of shares that may yet be purchased under the plans or programs
10/1/2025-10/31/2025	-	$ -	-	$ 243,105,741
11/1/2025-11/30/2025	928,827	10.77	928,827	233,105,769
12/1/2025-12/31/2025	-	-	-	233,105,769
Total	928,827	$ 10.77	928,827

(1)

In December 2018, the Company’s Board of Directors approved a stock repurchase program authorizing the Company to purchase its common stock, which has been amended from time to time. Most recently, in June 2023, the Board approved an increase to the total amount of its buyback program from $500.0 million to $1.0 billion. The Company may repurchase shares of our common stock from time to time at prevailing market prices, depending on market conditions, through open market, privately negotiated transactions, or through a 10b5-1 plan. No date has been established for the completion of the share repurchase program and the Company is not obligated to repurchase any shares. Subject to applicable corporate securities laws, repurchases may be made at such times and in such amounts as management deems appropriate or in accordance with the terms of the 10b5-1 plan. Repurchases under the program can be discontinued at any time the Board feels additional repurchases are not warranted. Any shares repurchased under the program are returned to the status of authorized but unissued shares of common stock until retired. The stock repurchase program is more fully disclosed in Note 9 – Stockholders’ Equity to the consolidated financial statements included elsewhere in this Annual Report.

Company Stock Performance

The following graph compares the performance of the Company’s common stock to the Standard & Poor’s (“S&P”) 500 Index and the S&P Homebuilders Select Industry Index. The graph assumes $100 was invested in each investment option as of December 31, 2020 and that dividends, if any, were reinvested. Past stock price performance is not necessarily indicative of future stock price performance.

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Year	2020	2021	2022	2023	2024	2025
EXPI	$ 100.00	$ 107.00	$ 36.00	$ 50.00	$ 38.00	$ 30.00
S&P 500 Index	100.00	127.00	102.00	127.00	157.00	182.00
S&P Homebuilders Index (XHB)	100.00	150.00	106.00	171.00	189.00	188.00

Item 6.

[RESERVED]

Item 7.

MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

The following discussion should be read in conjunction with the consolidated financial statements and accompanying notes included in Part II, Item 8 of this Annual Report. This Item generally discusses 2025 and 2024 items and year-to-year comparisons between 2025 and 2024. Discussions of 2023 items and year-to-year comparisons between 2024 and 2023 are not included, and can be found in “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in Part II, Item 7 of the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024. All dollar amounts presented below are in USD thousands except share amounts and per share data and as otherwise noted.

2025 Business Developments

The Company announces new agent offerings, markets, and business updates at various times during the year. Significant announcements during the year ended December 31, 2025 included the following:

First Quarter 2025:

●

Announced expansion into Peru.

Second Quarter 2025:

●

Announced expansion into Ecuador and Türkiye.

●

Launched Land and Ranch Division, empowering agents serving rural, recreational, and agricultural properties.

●

Launched the Co-Sponsor Program, allowing agents to name both a Primary Sponsor and a Co-Sponsor.

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●

Launched U.S. open-sourced Seller Advisory: Risks of Limited Market Exposure form.

Third Quarter 2025:

●

Announced expansion into Japan.

●

Appointed Jesse Hill as Chief Financial Officer of eXp World Holdings, Inc.

●

Launched CRM of Choice, allowing agents to choose from three leading customer relationship management platforms.

Fourth Quarter 2025:

●

Announced expansion into Romania and the Netherlands.

●

Launched Sports and Entertainment Division, empowering agents serving clients in the sports and entertainment industries.

●

Appointed Carrie Lysenko as Chief Technology Officer of eXp Realty and Holly Mabery as Chief Brokerage Officer of eXp Realty.

●

Launched LYVVE^TM, the Company’s global property search platform aggregating listings and related data across multiple countries.

Market Conditions and Industry Trends

Our performance is closely tied to housing market activity, which is influenced by economic conditions such as employment, consumer confidence, mortgage availability, interest rates, and the balance of supply and demand. Periods of economic growth and lower interest rates generally support higher home sales activity, while rising rates, affordability constraints, or broader economic slowdowns may reduce transaction volumes and pricing. Regulatory developments, geopolitical events, and shifts in consumer sentiment can also affect housing demand.

In 2025, U.S. home sales were relatively flat compared to 2024, and home sales prices increased 1.7%, according to the NAR. Inventory levels remain constrained, and new housing construction activity decreased during the year. These conditions may continue to limit transaction volumes in the near term.

Despite these challenges, we believe the Company is positioned for growth with a strong base of agents, an efficient cloud-based operating model, and low fixed costs. This structure allows us to adapt quickly to market changes while supporting long-term productivity and retention.

Key Business Metrics

The following table outlines the key business metrics that we periodically review to track the Company’s performance:


	Year Ended December 31,
	2025	2024	2023

Performance:
Agent NPS	75	76	73
Agent count	83,060	82,980	87,515
Real estate sales transactions	440,163	434,165	422,772
Real estate sales volume⁽²⁾	$ 194,038,232	$ 185,170,695	$ 169,202,948
Other real estate transactions	80,468	84,524	71,636
Real estate per transaction cost	$ 624	$ 559	$ 573
Revenues⁽²⁾	$ 4,772,311	$ 4,567,672	$ 4,273,821
Gross profit⁽²⁾	$ 333,578	$ 342,395	$ 319,924
Operating income (loss)⁽²⁾	($ 21,466)	($ 18,994)	$ 522
Consolidated adjusted EBITDA⁽¹⁾⁽²⁾	$ 33,172	$ 75,483	$ 65,328

(1)

Consolidated adjusted EBITDA is not a measurement of our financial performance under U.S. GAAP and should not be considered as an alternative to net income, operating income, or any other measures derived in accordance with U.S. GAAP. For a definition of consolidated adjusted EBITDA and a reconciliation of consolidated adjusted EBITDA to net income (loss), and a discussion of why we believe consolidated adjusted EBITDA is useful to investors, see “Non-U.S. GAAP Financial Measures”.

(2)	Dollar amounts are presented in thousands

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Agent Net Promoter Score (“aNPS”)

aNPS is a scale-based measure of customer satisfaction and an aNPS above 50 is considered excellent. aNPS plays a crucial role in attracting and retaining agents and teams. Despite the challenging market conditions, aNPS was relatively flat, when compared to the prior year, and the Company continues to provide enhancements to agent programs and offerings, including the Co-Sponsor Program, CRM of Choice, and the launch of new specialized divisions.

Agent Count

The number of agents was relatively flat in 2025 compared to 2024. The Company continues to attract and retain productive agents through the execution of its growth strategies and the end-to-end suite of services the Company offers its agents.

Real Estate Sales Transactions and Sales Volume

Real estate sales transactions are based on the side (buyer or seller) of each real estate transaction and are recorded when our agents and brokers represent buyers or sellers in the purchase or sale, respectively, of a home, from which the Company earns brokerage commissions and related fees. Transaction volume represents the total sales value for all transactions.

Real estate sales transactions increased 1% during 2025 compared to 2024, primarily driven by increased sales transactions in Canada and in our international markets. Real estate sales volume increased 5% in 2025 compared to 2024 driven by increased sales prices in North America and in our international markets, and to a lesser extent, increased transactions.

Other real estate transactions

Other real estate transactions are recorded for leases, rentals and referrals that are undertaken by the Company’s agents and brokers.

Other real estate transactions decreased during 2025 compared to 2024. The decrease in other real estate transactions was primarily driven by changes in the rental market, and shift in mix toward real estate sales.

Real estate per transaction cost

Real estate per transaction cost is measured as selling, general and administrative, sales and marketing and technology and development expenses in North American Realty and International Realty segments, divided by total transactions (real estate sales transactions and other real estate transactions).

Real estate per transaction cost increased during 2025 compared to 2024, primarily due to employee-related, technology and legal expenses.

Revenues

Revenues represent the commission revenue earned by the Company for closed brokerage real estate transactions.

Revenues increased during 2025 compared to 2024, primarily driven by increased home sale prices in the U.S., and increased sales transactions in Canada and international markets.

Gross Profit

Gross profit decreased in 2025 when compared to 2024, reflecting revenue growth, offset by increased agent capping and lower agent fees.

Operating Income (Loss)

Operating income (loss) increased in 2025, when compared to 2024, due to increased legal expenses and accruals, employee-related and other operating expenses, including expenses to support our continued technology improvements. Operating income (loss) in 2024 includes $34.0 million related to litigation contingency accrual and $4.9 million of impairment expense.

Consolidated Adjusted EBITDA

Management reviews consolidated adjusted EBITDA, which is a non-U.S. GAAP financial measure, to understand and evaluate our core operating performance. Consolidated adjusted EBITDA decreased by $42.3 million in 2025, compared to 2024. The decrease in consolidated adjusted EBITDA reflects a decrease in operating results related to increased agent capping and lower agent fees, as well as increased employee-related, technology and legal expenses, which more than offset increased revenues.

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Consolidated Operating Performance


	Year Ended December 31, 2025	Year Ended December 31, 2024	Change 2025 vs. 2024
Statement of Operations Data:
Revenues	$ 4,772,311	$ 4,567,672	4%
Commissions and other agent-related costs	4,438,733	4,225,277	5%
Gross profit	333,578	342,395	(3)%
Operating expenses
General and administrative expenses	274,871	252,369	9%
Technology and development expenses	69,618	58,182	20%
Sales and marketing expenses	10,555	11,908	(11)%
Impairment expense	-	4,930	(100)%
Litigation contingency	-	34,000	(100)%
Total operating expenses	355,044	361,389	(2)%
Operating income (loss)	(21,466)	(18,994)	(13)%
Other (income) expense
Other (income) expense, net	(1,513)	(4,445)	66%
Equity in (income) losses of unconsolidated affiliates	281	1,168	(76)%
Total other (income) expense, net	(1,232)	(3,277)	62%
Income (loss) before income tax expense	(20,234)	(15,717)	(29)%
Income tax (benefit) expense	2,480	1,071	132%
Net income (loss) from continuing operations	(22,714)	(16,788)	(35)%
Net income (loss) from discontinued operations	-	(4,479)	100%
Net income (loss)	(22,714)	(21,267)	(7)%

Commissions and Other Agent-Related Costs

Commissions and other agent-related costs increased 5% primarily because of the increase in real estate transactions and increased home sales prices, as well as increased agent capping. Commissions and other agent-related costs include sales commissions, revenue share and stock-based compensation paid to the Company’s agents.

General and Administrative Expenses

General and administrative expenses increased 9% due to increased employee-related expenses, including severance and increased legal expenses and accruals, and increased costs in agent-related seminars and conferences. General and administrative expenses include costs related to wages, employee stock compensation, and other general overhead expenses.

Technology and Development Expenses

Technology and development expenses increased 20%, primarily due to increased technology expenses related to continued improvements in our technology offerings to our agents. These expenses include employee-related costs and other expenses related to the maintenance and development of the technology used by both the Company’s agents and employees.

Sales and Marketing Expenses

Sales and marketing expenses decreased (11)% in 2025 compared to 2024 due to decreased lead capture and advertising expenses in the residential real estate market.

Other (Income) Expense, Net

Other (income) expense, net increased 62% primarily due to lower interest income and increased other expenses. Other (income) expense, net includes interest income earned on cash and cash equivalents, and (earnings) losses related to equity investments.

Income Tax (Benefit) Expense

The increase in income tax (benefit) expense was primarily attributable to the decrease in research and development (“R&D”) credit generation in the current year.

Refer to Critical Accounting Policies and Estimates within the MD&A and Note 12 - Income Taxes to the consolidated financial statements included elsewhere in this Annual Report for further information.

Segment Operating Performance

The Company has three operating and reportable segments as follows: North American Realty, International Realty and Other Affiliated Services. We report corporate expenses, as further detailed below, as “Corporate expenses and other.” All segments

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follow the same basis of presentation and accounting policies. See Note 2 - Summary of Significant Accounting Policies to the consolidated financial statements included elsewhere in this Annual Report for additional information about the Company’s significant accounting policies.

See Note 10 – Segment Information to the consolidated financial statements included elsewhere in this Annual Report for additional information regarding the Company’s business segments. The following table reflects the results of each of the Company’s reportable segments for 2025 and 2024:


	December 31, 2025	December 31, 2024	Change 2025 vs. 2024

Statement of Operations Data:
Revenues
North American Realty	$ 4,624,913	$ 4,478,293	3%
International Realty	146,930	88,146	67%
Other Affiliated Services	2,873	6,105	(53)%
Corporate expenses and other	(2,405)	(4,872)	51%
Total Consolidated Revenues	$ 4,772,311	$ 4,567,672	4%

Segment Adjusted EBITDA⁽¹⁾
North American Realty	$ 59,753	$ 99,253	(40)%
International Realty	(9,933)	(9,481)	(5)%
Other Affiliated Services	(5,804)	(4,876)	(19)%
Corporate expenses and other	(10,844)	(9,413)	(15)%
Total Segment Adjusted EBITDA⁽¹⁾	$ 33,172	$ 75,483	(56)%

Operating Income (Loss)
North American Realty	$ 9,322	$ 16,468	(43)%
International Realty	(11,674)	(10,492)	(11)%
Other Affiliated Services	(6,153)	(11,615)	47%
Corporate expenses and other	(12,961)	(13,355)	3%
Total Consolidated Operating Income (Loss)	($ 21,466)	($ 18,994)	(13)%

(1)

Segment adjusted EBITDA is not a measurement of our financial performance under U.S. GAAP and should not be considered as an alternative to net income, operating income, or any other measures derived in accordance with U.S. GAAP. For a definition of segment adjusted EBITDA and a reconciliation of segment adjusted EBITDA to net income, and a discussion of why we believe segment adjusted EBITDA is useful to investors, see “Non-U.S. GAAP Financial Measures”. Management evaluates the operating results of each of its reportable segments based upon revenue, Segment adjusted EBITDA and operating income (loss). Segment adjusted EBITDA is defined by us as net income before depreciation and amortization, interest expense, income taxes, stock compensation expense, stock option expense, and other items that are not core to the operating activities of the Company. The Company’s presentation of segment adjusted EBITDA may not be comparable to similar measures used by other companies.

North American Realty revenue increased 3% during 2025 compared to 2024 primarily due to an increase in home sale prices in the U.S. and in overall real estate transactions in Canada, and improved agent productivity, partially offset by reductions in the Company’s agent base. North American Realty adjusted EBITDA as well as operating income (loss) decreased during 2025 compared to 2024 due to increased commissions and other agent-related costs as a result of increased capping and lower agent fees, as well as increased operating costs, including employee-related, technology and legal expenses.

International Realty revenue increased 67% during 2025 compared to 2024 primarily due to increased real estate transactions driven by increased productivity in previously launched markets, as well as the strategic launch of several new markets during the year. International Realty adjusted EBITDA and operating income (loss) reflect the higher costs of entering new countries.

Other Affiliated Services revenue decreased (53)% during 2025 compared to 2024 due to lower SUCCESS® Magazine revenues. Other Affiliated Services adjusted EBITDA decreased due to lower revenues and increased costs, including severance costs. Operating income (loss) in 2024 includes $4.9 million of impairment expenses.

Corporate expenses and other contain the costs incurred to operate the corporate parent of eXp Realty.

Liquidity and Capital Resources

The Company believes that its existing balances of cash and cash equivalents and cash flows expected to be generated from its operations will be sufficient to satisfy its normal operating requirements for at least the next 12 months and beyond. As of December 31, 2025, the Company’s cash and cash equivalents totaled $124.2 million. Cash equivalents are comprised of financial

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instruments with an original maturity of 90 days or less from the date of purchase, primarily money market funds. The Company currently does not hold any other marketable securities. We currently do not hold any bank debt, nor have we issued any debt instruments through public offerings or private placements.

Operations

Currently, the Company’s primary use of cash on hand is to sustain and grow its business operations, including, but not limited to, commission and revenue share payments to agents and brokers and cash outflows for operating expenses. During 2025, the Company utilized its cash on hand to support our agent productivity, growth initiatives and investment in technology, the first payment of the litigation contingency in the antitrust lawsuits settlement and to a lesser extent, for repurchases of its common stock and quarterly cash dividends. See Note 13 – Commitments and Contingencies to the consolidated financial statements included elsewhere in this Annual Report for further information related to the Company’s litigation.

Share Repurchase Program

The Company has an authorized share repurchase program which is currently approved by the Board up to $1.0 billion in aggregate. The program does not obligate the Company to acquire a minimum amount of shares. Additionally, during 2023, 2024, and 2025, the Company has paid quarterly cash dividends. As of December 31, 2025, the Company’s quarterly cash dividend was $0.05 per share. During 2025, the Company repurchased $56.2 million of its common stock and paid cash dividends of $30.8 million. There can be no assurance that future cash dividends will be declared by the Board or that the stock repurchase program will be sustained or proceed at historical levels.

Legal Proceedings

For information regarding the Company’s expected cash requirement related to settlement costs, see “Contingencies” under Note 13 – Commitments and Contingencies to the consolidated financial statements included elsewhere in this Annual Report.

The Company’s future capital requirements will depend on many factors, including the outcome of pending antitrust litigation settlement, its level of investment in technology, its rate of growth into new markets and cash used to pay quarterly cash dividends and repurchase shares of the Company’s common stock. The Company’s capital requirements may be affected by factors which it cannot control such as the changes in the residential real estate market, interest rates and other monetary and fiscal policy changes to the manner in which it currently operates. In order to support and achieve the Company’s future growth plans, it may need or seek advantageously to obtain additional funding through equity or debt financing.

Net Working Capital

Net working capital is calculated as the Company’s total current assets less its total current liabilities. The following table presents the Company’s net working capital for the periods presented:


	December 31, 2025	December 31, 2024
Current assets	$ 304,868	$ 267,972
Current liabilities	(199,701)	(185,853)
Net working capital	$ 105,167	$ 82,119

As of December 31, 2025, net working capital increased by $23.0 million, or 28%, compared to the prior year, primarily due to an increase in accounts receivable, due to the timing of revenue in December, partially offset by an increase in accrued expenses.

Cash Flows

The following table presents our cash flows for the periods presented:


	Year Ended December 31,
	2025	2024
Net cash provided by operating activities	$ 118,611	$ 191,514
Net cash used in investing activities	(23,472)	(19,470)
Net cash used in financing activities	(86,538)	(170,377)
Effect of changes in exchange rates on cash, cash equivalents and restricted cash	4,274	(2,972)
Net change in cash, cash equivalents and restricted cash	$ 12,875	($ 1,305)

For the year ended December 31, 2025, cash provided by operating activities decreased (38)% compared to the same period in 2024, primarily due to lower agent equity program participation, increased accounts receivable, net, due to the timing of revenue in December, as well as the first payment of $17 million related to the antitrust litigation accrual, partially offset by an increase in accrued expenses.

For the year ended December 31, 2025, cash used in our investing activities increased 21% compared to the same period in 2024, primarily due to an increase in investments in unconsolidated subsidiaries.

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For the year ended December 31, 2025, cash used in financing activities decreased by (49)%, compared to the same period in 2024, primarily related to lower repurchases of our common stock of ($84.9) million.

Critical Accounting Policies and Estimates

The preparation of financial statements in accordance with U.S. GAAP and the Company’s discussion and analysis of its financial condition and operating results require the Company’s management to make certain judgments and assumptions and estimates that affect the amounts reported. The Company’s significant accounting policies are described in Note 2 – Summary of Significant Accounting Policies to the consolidated financial statements included elsewhere in this Annual Report.

Management bases its estimates on historical experience and on various other assumptions it believes to be reasonable under the circumstances, the results of which form the basis for making judgments about the carrying values of assets and liabilities.

Stock-based compensation

The Company’s stock-based compensation is comprised of stock option awards and restricted stock unit grants to service providers, including, but not limited to, agents, employees, and directors. The Company accounts for stock-based compensation using a fair value method. Stock-based compensation awards are measured at the grant date fair value and the stock-based compensation cost is recognized over the requisite service period of the awards, usually the vesting period, on a straight-line basis, net of forfeitures. The Company reduces recorded stock-based compensation for forfeitures when they occur.

Recognition of compensation cost for an award with a performance condition is based on the probable outcome of that performance condition being met. The Company estimates the share-based liability based on estimated performance probabilities using the Company’s most recent estimates on probable achievement of the performance measures. Also, the requisite service period at the grant date of performance awards is estimated based on the probable amount of time it will take to meet the performance metric. The value of the stock award is amortized over this period and recognized as stock-based compensation expense starting on the grant date.

If factors change causing different assumptions to be made in future periods, estimated compensation expense may differ significantly from that recorded in the current period. See Note 9 – Stockholders’ Equity to the consolidated financial statements included elsewhere in this Annual Report, for more information regarding the assumptions used in estimating the fair value of the Company’s awards.

Revenue recognition

The Company generates a substantial portion of its revenue from its North American Realty and International Realty segments and generates a de minimis portion of its revenues from its Other Affiliated Services segment.

North American Realty and International Realty

The Company serves as a licensed broker in the areas in which it operates for the purpose of processing real estate transactions. The Company is contractually obligated to provide services for the fulfillment of transfers of real estate between buyers and sellers. The Company provides these services itself and controls the services necessary to legally represent the transfer of real estate. Correspondingly, the Company is defined as the principal. The Company, as principal, satisfies its obligation upon the closing of a real estate transaction. As principal and upon satisfaction of the Company’s obligation, the Company recognizes revenue in the gross amount of consideration to which the Company expects to be entitled.

Revenue is derived from assisting homebuyers and sellers in listing, marketing, selling and finding real estate. Commissions earned on real estate transactions are recognized at the completion of a real estate transaction once the Company has satisfied its performance obligation. Agent-related fees are currently recorded as a reduction to commissions and other agent-related costs.

At each reporting period, the Company estimates and accrues revenue for closed transactions for which it is entitled to, but have not yet received, a commission due to those transactions settling after the reporting period. The accrual for this estimated revenue was immaterial for the years ended December 31, 2025 and 2024.

Business combinations

Our growth strategy is primarily driven by organic initiatives; however, we regularly evaluate strategic acquisitions, partnerships, and other transactions that may accelerate our objectives, expand our capabilities, or create long-term shareholder value

Fair value determinations require significant judgment and are sensitive to assumptions about revenue and income growth, terminal values, discount rates, industry indices, and market transactions. The Company uses cost, income, and market approaches in assigning values.

Identifiable net assets, including contingent liabilities, are recognized at fair value at the acquisition date and may be adjusted within a one-year measurement period based on new information about conditions at that time.

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Goodwill and intangibles recorded at acquisition-date fair values are subject to impairment risk if expected growth rates are not achieved or if market or macroeconomic conditions deteriorate.

Income taxes

We recognize deferred tax assets and liabilities based on the differences between the financial statement carrying amounts and the tax basis of assets and liabilities. A valuation allowance against deferred tax assets would be established if, based on the weight of available evidence, it is more likely than not (a likelihood of more than 50%) that some or all of the deferred tax assets are not expected to be realized. Our assumptions, judgments, and estimates relative to the value of our deferred tax assets take into account predictions of the amount and category of future taxable income. As of December 31, 2025, based on our assessment of the realizability of the net deferred tax assets, we reached the conclusion that some of our net deferred tax assets will most likely not be fully realized and therefore a total valuation allowance of $0.5 million was recorded.

Although management believes that the judgment and estimates involved are reasonable and that the necessary provisions related to income taxes have been recorded, changes in circumstances or unexpected events could adversely affect our financial position, results of operations, and cash flows.

See Note 12 – Income Taxes to the consolidated financial statements included elsewhere in this Annual Report for further information related to our income tax positions.

Litigation

The Company is subject to various legal proceedings and claims that arise in the ordinary course of business, the outcomes of which are inherently uncertain. The Company records a liability when it is probable that a loss has been incurred and the amount is reasonably estimable, the determination of which requires significant judgment. Resolution of legal matters in a manner inconsistent with management’s expectations could have a material impact on the Company’s financial condition and operating results. See Note 13 – Commitments and Contingencies to the consolidated financial statements included elsewhere in this Annual Report for further information related to the Company’s litigation.

Non-U.S. GAAP Financial Measures

To supplement our consolidated financial statements, which are prepared and presented in accordance with U.S. GAAP, we use consolidated adjusted EBITDA and segment adjusted EBITDA, non-U.S. GAAP financial measures, to understand and evaluate our core operating performance. These non-GAAP financial measures, which may be different than similarly titled measures used by other companies, are presented to enhance investors’ overall understanding of our financial performance and should not be considered a substitute for, or superior to, the financial information prepared and presented in accordance with U.S. GAAP.

We define the non-U.S. GAAP financial measure of consolidated adjusted EBITDA to mean net income, excluding other income (expense), income tax benefit (expense), depreciation, amortization, impairment charges, stock-based compensation expense and stock option expense and other items that are not core to the operating activities of the Company. Segment adjusted EBITDA is defined as net income before depreciation and amortization, interest expense, income taxes, stock compensation expense, stock option expense, and other items that are not core to the operating activities of the Company. We believe that consolidated adjusted EBITDA and segment adjusted EBITDA provides useful information about our financial performance, enhances the overall understanding of our past performance and future prospects and allows for greater transparency with respect to a key metric used by our management for financial and operational decision-making. We believe that segment adjusted EBITDA helps identify underlying trends in our business that otherwise could be masked by the effect of the expenses that we exclude in segment adjusted EBITDA. In particular, we believe the exclusion of stock and stock option expenses provides a useful supplemental measure in evaluating the performance of our underlying operations and provides better transparency into our results of operations.

We are presenting the non-U.S. GAAP measures of consolidated adjusted EBITDA and segment adjusted EBITDA to assist investors in seeing our financial performance through the eyes of management and because we believe these measures provide additional tools for investors to use in comparing our core financial performance over multiple periods with other companies in our industry.

Consolidated adjusted EBITDA should not be considered in isolation from, or as a substitute for, financial information prepared in accordance with U.S. GAAP. There are several limitations related to the use of consolidated adjusted EBITDA and segment adjusted EBITDA compared to net income, the closest comparable U.S. GAAP measure. Some of these limitations are:

●

Consolidated adjusted EBITDA and segment adjusted EBITDA exclude stock-based compensation expense related to our agent growth incentive program and stock option expense, which have been and will continue to be for the foreseeable future, significant recurring expenses in our business and an important part of our compensation strategy; and

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●

Consolidated adjusted EBITDA and segment adjusted EBITDA exclude certain recurring, non-cash charges such as depreciation of fixed assets, amortization of intangible assets and impairment charges related to these long-lived assets and, although these are non-cash charges, the assets being depreciated, amortized, or impaired may have to be replaced in the future.

The following table presents a reconciliation of consolidated adjusted EBITDA to the most comparable U.S. GAAP financial measure, for each of the periods presented:


	Year Ended December 31,
	2025	2024	2023
Net income (loss) from continuing operations	($ 22,714)	($ 16,788)	$ 3,533
Total other (income) expense, net	(1,232)	(3,277)	(2,995)
Income tax (benefit) expense	2,480	1,071	(16)
Depreciation and amortization	9,562	10,289	10,892
Impairment expense	-	4,930	-
Litigation contingency	-	34,000	-
Stock-based compensation expense ⁽¹⁾	38,610	37,285	43,178
Stock option expense	6,466	7,973	10,736
Consolidated adjusted EBITDA	$ 33,172	$ 75,483	$ 65,328

(1)

This includes agent growth incentive stock compensation expense and stock compensation expense related to business acquisitions.

The primary driver for the decrease in consolidated adjusted EBITDA was a decrease in gross profit, primarily driven by increased agent capping as well as increased operating costs including employee-related, technology and legal expenses, partially offset by increased revenues.

Item 7A.

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

The Company is exposed to market risk from foreign currency and exchange rate fluctuation and interest rate changes.

The majority of the Company’s net sales, expenses and capital purchases were transacted in U.S. dollars. However, exposure with respect to foreign exchange rate fluctuation existed due to the Company’s operations throughout the Americas, Europe, the Middle East, Asia-Pacific, and South Africa. Based on fiscal 2025 performance, a hypothetical appreciation or decline in the value of the Canadian dollar in relation to the U.S. dollar of 10% would have an immaterial impact on operating income. The individual impacts to the operating income of hypothetical currency fluctuations in the Canadian dollar have been calculated in isolation from any potential responses to address such exchange rate changes in the Company’s other foreign markets. The Company’s exposures to foreign currency risk related to its other operations in international locations were immaterial and have been excluded from this analysis.

The Company’s investments in the net assets of the Company’s international operations were also subject to foreign exchange rate risk. As of December 31, 2025, the impacts of translations of foreign-denominated net assets of the Company’s international operations were immaterial to the Company’s consolidated financial statements. The translation impacts related to the net assets of the Company’s international operations are recorded within accumulated other comprehensive income. Historically, the Company has not hedged this exposure, although it may elect to do so in future periods.

The Company is also exposed to market risk for changes in interest rates on its financial instruments, which relate to the Company’s cash equivalents primarily invested in money market funds. The Company does not use derivative financial instruments in its investing activities. The Company places cash and cash equivalents with various major financial institutions. The Company protects its invested principal funds by limiting default risk, market risk and reinvestment risk. The Company mitigates against such risks by utilizing investment vehicles restricted to short-term U.S. government and agency obligations, thereby prioritizing capital preservation and immediate liquidity.

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Item 8.

FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

Index to Consolidated Financial Statements

	Page
Report of Independent Registered Public Accounting Firm (PCAOB ID No. 34)	31
Consolidated Balance Sheets	33
Consolidated Statements of Comprehensive Income (Loss)	34
Consolidated Statements of Stockholders’ Equity	35
Consolidated Statements of Cash Flows	36
Notes to Consolidated Financial Statements	37

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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the stockholders and the Board of Directors of eXp World Holdings, Inc.

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of eXp World Holdings, Inc. and subsidiaries (the “Company”) as of December 31, 2025 and 2024, the related consolidated statements of comprehensive income (loss), stockholders' equity, and cash flows, for each of the three years in the period ended December 31, 2025, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2025 and 2024, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2025, in conformity with accounting principles generally accepted in the United States of America.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the Company's internal control over financial reporting as of December 31, 2025, based on criteria established in Internal Control — Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated February 24, 2026, expressed an unqualified opinion on the Company's internal control over financial reporting.

Basis for Opinion

These financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

Critical Audit Matter

The critical audit matter communicated below is a matter arising from the current-period audit of the financial statements that was communicated or required to be communicated to the audit committee and that (1) relates to accounts or disclosures that are material to the financial statements and (2) involved our especially challenging, subjective, or complex judgments. The communication of critical audit matters does not alter in any way our opinion on the financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing a separate opinion on the critical audit matter or on the accounts or disclosures to which it relates.

Commissions and Other Agent-Related Costs – Sustainable Revenue Share Plan expenses – Refer to Note 2 to the financial statements

The Company maintains a revenue share program which allows agents and brokers to earn additional income from real estate transactions closed by agents they have attracted to the Company. Agents are eligible for revenue share based on defined qualification requirements. These additional commissions are funded from the Company’s portion of transaction commissions and are included within commissions and other agent-related costs.

We identified the revenue share program as a critical audit matter because the plan has a complex multi-tiered compensation structure involving highly automated system calculations to determine the commissions paid to agents and brokers. This required an increased extent of audit effort to audit and evaluate the accuracy of commissions paid under the revenue share program.

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How the Critical Audit Matter Was Addressed in the Audit

Our audit procedures related to the testing of the accuracy and completeness of expenses under the revenue share program included the following, among others:

●

We tested the effectiveness of controls over the revenue share expenses, including management’s controls over the calculation of commission under the revenue share program.

●

With the assistance of our IT specialists, we:

o

Identified the significant system used to process revenue share transactions and tested the general IT controls over the system, including testing of user access controls, change management controls, and IT operations controls.

o

Performed testing of automated controls for the system calculation of revenue share and the system determination of number of agents attracted to the Company.

●

We tested the amount of revenue share expense by developing an expectation of the amount based on a percentage of the Company’s portion of transaction commissions and comparing our expectation to the amount recorded by management.

●

We selected samples of commissions paid to agents and brokers under the revenue share program and recalculated the commissions amount based on the terms of the respective independent contractor agreements.

●

For the samples selected:

o

We tested the mathematical accuracy of the recorded commission by recalculating the revenue share allocation in accordance with the independent contractor agreements and traced the underlying transactions to third party documents.

o

We tested the accuracy and completeness of agent attributes attracted to the Company by reviewing independent contractor agreements and obtaining evidence that agents achieved the required sales transaction volume.

/s/ Deloitte & Touche LLP

San Francisco, California

February 24, 2026

We have served as the Company's auditor since 2019.

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EXP WORLD HOLDINGS, INC.
CONSOLIDATED BALANCE SHEETS

(In thousands, except share amounts)


	December 31, 2025	December 31, 2024
ASSETS
CURRENT ASSETS
Cash and cash equivalents	$ 124,245	$ 113,607
Restricted cash	57,218	54,981
Accounts receivable, net of allowance for credit losses of $2,690 and $1,589, respectively	108,838	87,692
Prepaids and other assets	14,567	11,692
TOTAL CURRENT ASSETS	304,868	267,972
Property and equipment, net	14,314	11,615
Other noncurrent assets	23,495	11,679
Intangible assets, net	4,421	6,456
Deferred tax assets, net	77,510	75,774
Goodwill	17,872	17,226
TOTAL ASSETS	$ 442,480	$ 390,722

LIABILITIES AND EQUITY
CURRENT LIABILITIES
Accounts payable	$ 14,613	$ 10,478
Customer deposits	57,204	55,660
Accrued expenses	108,208	85,661
Litigation contingency	17,000	34,000
Other current liabilities	2,676	54
TOTAL CURRENT LIABILITIES	199,701	185,853
TOTAL LIABILITIES	199,701	185,853

EQUITY
Common Stock, $0.00001 par value 900,000,000 shares authorized; 207,785,762 issued and 161,049,979 outstanding at December 31, 2025; 195,028,207 issued and 154,133,385 outstanding at December 31, 2024	2	2
Additional paid-in capital	1,105,434	962,758
Treasury stock, at cost: 46,735,783 and 40,894,822 shares held December 31, 2025 and December 31, 2024, respectively	(742,879)	(686,680)
Accumulated earnings (deficit)	(121,622)	(68,135)
Accumulated other comprehensive income (loss)	1,844	(3,076)
TOTAL EQUITY	242,779	204,869
TOTAL LIABILITIES AND EQUITY	$ 442,480	$ 390,722

The accompanying notes are an integral part of these consolidated financial statements.

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EXP WORLD HOLDINGS, INC.
CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (LOSS)

(In thousands, except share amounts and per share data)


	Year Ended December 31,
	2025	2024	2023
Revenues	$ 4,772,311	$ 4,567,672	$ 4,273,821
Commissions and other agent-related costs	4,438,733	4,225,277	3,953,897
Gross profit	333,578	342,395	319,924
Operating expenses
General and administrative expenses	274,871	252,369	247,799
Technology and development expenses	69,618	58,182	59,547
Sales and marketing expenses	10,555	11,908	12,056
Impairment expense	-	4,930	-
Litigation contingency	-	34,000	-
Total operating expenses	355,044	361,389	319,402
Operating income (loss)	(21,466)	(18,994)	522
Other (income) expense
Other (income) expense, net	(1,513)	(4,445)	(4,383)
Equity in (income) losses of unconsolidated affiliates	281	1,168	1,388
Other (income) expense, net	(1,232)	(3,277)	(2,995)
Income (loss) before income tax expense	(20,234)	(15,717)	3,517
Income tax (benefit) expense	2,480	1,071	(16)
Net income (loss) from continuing operations	(22,714)	(16,788)	3,533
Net income (loss) from discontinued operations	-	(4,479)	(12,506)
Net income (loss)	($ 22,714)	($ 21,267)	($ 8,973)
Earnings (loss) per share
Basic, net income (loss) from continuing operations	($ 0.14)	($ 0.11)	$ 0.02
Basic, net income (loss) from discontinued operations	$ -	($ 0.03)	($ 0.08)
Basic, net income (loss)	($ 0.14)	($ 0.14)	($ 0.06)
Diluted, net income (loss) from continuing operations	($ 0.14)	($ 0.11)	$ 0.02
Diluted, net income (loss) from discontinued operations	$ -	($ 0.03)	($ 0.08)
Diluted, net income (loss)	($ 0.14)	($ 0.14)	($ 0.06)
Weighted average shares outstanding
Basic	156,879,412	153,684,907	153,232,129
Diluted	156,879,412	153,684,907	156,773,528
Comprehensive income (loss):
Net income (loss)	($ 22,714)	($ 21,267)	($ 8,973)
Other comprehensive income (loss):
Foreign currency translation gain (loss), net of tax	4,920	(3,408)	96
Comprehensive income (loss)	($ 17,794)	($ 24,675)	($ 8,877)

The accompanying notes are an integral part of these consolidated financial statements.

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EXP WORLD HOLDINGS, INC.
CONSOLIDATED STATEMENTS OF STOCKHOLDERS’ EQUITY

(In thousands)


	Year Ended December 31,
	2025	2024	2023
Common stock:
Balance, beginning of period	$ 2	$ 2	$ 2
Balance, end of period	2	2	2
Treasury stock:
Balance, beginning of period	(686,680)	(545,559)	(385,010)
Repurchases of common stock	(56,199)	(141,121)	(160,549)
Balance, end of period	(742,879)	(686,680)	(545,559)
Additional paid-in capital:
Balance, beginning of period	962,758	804,833	611,872
Shares issued for stock options exercised	434	2,012	4,980
Agent growth incentive stock-based compensation	37,627	36,675	41,995
Agent equity stock-based compensation	98,149	111,278	135,226
Stock option compensation	6,466	7,960	10,760
Balance, end of period	1,105,434	962,758	804,833
Accumulated earnings (deficit):
Balance, beginning of period	(68,135)	(16,769)	20,723
Net income (loss)	(22,714)	(21,267)	(8,973)
Dividends declared and paid ($0.05 per share of common stock)	(30,773)	(30,099)	(28,519)
Balance, end of period	(121,622)	(68,135)	(16,769)
Accumulated other comprehensive income (loss):
Balance, beginning of period	(3,076)	332	236
Foreign currency translation gain (loss)	4,920	(3,408)	96
Balance, end of period	1,844	(3,076)	332
Noncontrolling interest:
Balance, beginning of period	-	1,169	1,169
Transactions with noncontrolling interests	-	(1,169)	-
Balance, end of period	-	-	1,169
Total equity	$ 242,779	$ 204,869	$ 244,008

The accompanying notes are an integral part of these consolidated financial statements.

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EXP WORLD HOLDINGS, INC.
CONSOLIDATED STATEMENTS OF CASH FLOWS

(In thousands)


	Year Ended December 31,
	2025	2024	2023
OPERATING ACTIVITIES
Net income (loss)	($ 22,714)	($ 21,267)	($ 8,973)
Reconciliation of net income (loss) to net cash provided by operating activities:
Depreciation expense	6,870	7,835	8,352
Amortization expense - intangible assets	2,692	2,454	2,540
Impairment expense	-	4,930	9,203
Loss on disposition of business	-	266	472
Allowance for credit losses on receivables/bad debt on receivables	1,101	(615)	(1,711)
Equity in loss of unconsolidated affiliates	281	1,168	1,388
Agent growth incentive stock-based compensation expense	38,364	37,265	43,178
Stock option compensation	6,466	7,975	10,736
Agent equity stock-based compensation expense	98,149	111,278	135,226
Deferred income taxes, net	(1,736)	(6,521)	(2,666)
Changes in operating assets and liabilities:
Accounts receivable	(21,098)	(1,704)	3,474
Prepaids and other assets	(2,875)	3,041	(1,263)
Customer deposits	1,544	11,110	6,761
Accounts payable	4,135	1,690	(1,491)
Accrued expenses	21,810	(1,445)	8,424
Long term payable	-	-	(4,677)
Litigation contingency	(17,000)	34,000	-
Other operating activities	2,622	54	158
NET CASH PROVIDED BY OPERATING ACTIVITIES	118,611	191,514	209,131
INVESTING ACTIVITIES
Purchases of property and equipment	(9,569)	(6,483)	(5,363)
Purchase of business	-	(6,150)	-
Proceeds from sale of business	-	-	330
Investments in unconsolidated affiliates	(13,246)	(5,447)	(5,876)
Capitalized software development costs in intangible assets	(657)	(1,390)	(2,594)
NET CASH USED IN INVESTING ACTIVITIES	(23,472)	(19,470)	(13,503)
FINANCING ACTIVITIES
Repurchase of common stock	(56,199)	(141,121)	(160,550)
Proceeds from exercise of options	434	2,012	4,980
Transactions with noncontrolling interests	-	(1,169)	-
Dividends declared and paid	(30,773)	(30,099)	(28,519)
NET CASH USED IN FINANCING ACTIVITIES	(86,538)	(170,377)	(184,089)
Effect of changes in exchange rates on cash, cash equivalents and restricted cash	4,274	(2,972)	(38)
Net change in cash, cash equivalents and restricted cash	12,875	(1,305)	11,501
Cash, cash equivalents and restricted cash, beginning balance	168,588	169,893	159,383
CASH, CASH EQUIVALENTS AND RESTRICTED CASH, ENDING BALANCE	$ 181,463	$ 168,588	$ 170,884
SUPPLEMENTAL DISCLOSURE OF CASH FLOWS INFORMATION:
Cash paid for income taxes	4,597	2,694	2,731
SUPPLEMENTAL DISCLOSURE OF NON-CASH INVESTING AND FINANCING ACTIVITIES:
Termination of lease obligation - operating lease	-	-	859
Contingent consideration for disposition of business	-	-	1,209
Property, plant and equipment increase due to transfer of right-of-use lease asset	-	-	1,100
Property and equipment purchases in accounts payable	-	-	63

The accompanying notes are an integral part of these consolidated financial statements.

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eXp World Holdings, Inc.
Notes to Consolidated Financial Statements
(Amounts in thousands, except share and per share amounts, unless otherwise noted)

1.	DESCRIPTION OF BUSINESS AND BASIS OF PRESENTATION

eXp World Holdings, Inc. (the “Company” or “eXp”) was incorporated in Delaware on July 30, 2008. The Company operates a cloud-based real estate brokerage and related services supporting agents, brokers, and entrepreneurs across North America and international markets.

The accompanying consolidated financial statements are prepared in accordance with U.S. generally accepted accounting principles (“U.S. GAAP”), expressed in U.S. dollars, and the Company’s fiscal year ends on December 31. The preparation of these consolidated financial statements and accompanying notes in conformity with U.S. GAAP requires the use of management estimates.

The Company reports results through three segments: North American Realty, International Realty, and Other Affiliated Services (see Note 10 – Segment Information to the consolidated financial statements included elsewhere in this Annual Report).

2.	SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Principles of consolidation

The consolidated financial statements include the accounts of eXp World Holdings, Inc., its wholly-owned subsidiaries, and entities in which the Company has a variable interest of which the Company is the primary beneficiary. If the Company has a variable interest in an entity but it is not the primary beneficiary of the entity or does not exercise control over the operations and has less than 50% ownership, it will use the equity or cost method of accounting for investments. We hold investments in certain equity securities that do not have readily determinable fair values and for which we do not exercise significant influence. These investments qualify for and are accounted for using the measurement alternative under Financial Accounting Standards Board Accounting Standards Codification (“ASC”) Topic 321, Investments – Equity Securities (“ASC 321”).

Joint ventures

A joint venture is a contractual arrangement whereby the Company and other parties undertake an economic activity through a jointly controlled entity. Joint control exists when strategic, financial and operating policy decisions relating to the activities require the unanimous consent of the parties sharing control. Joint ventures are accounted for using the equity method and are recognized initially at cost. Joint ventures are typically included in the Other Affiliated Services unless the joint venture specifically supports one of the other reportable segments.

Investments in Equity Securities

We hold investments in certain equity securities that do not have readily determinable fair values and for which we do not exercise significant influence. These investments qualify for and are accounted for using the measurement alternative under ASC 321.

Use of estimates

Preparing financial statements under U.S. GAAP requires management to make estimates and assumptions that affect reported amounts and disclosures. Key areas requiring estimates include credit losses, legal contingencies, income taxes, revenue recognition, stock-based compensation, goodwill, and deferred tax assets.

Management bases these estimates on current facts, historical experience, and other reasonable factors. Actual results may differ materially and adversely from these estimates, which could affect future results of operations.

Reclassifications

When necessary, the Company will reclassify certain amounts in prior period financial statements to conform to the current period’s presentation. The Company maintains a consistent presentation across all periods presented.

Cash and cash equivalents

Cash and cash equivalents include cash on hand, money market instruments and all other highly liquid investments purchased with an original or remaining maturity of three months or less at the date of acquisition.

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Restricted cash

Restricted cash represents amounts held in escrow by the Company’s brokers and agents on behalf of real estate buyers. These amounts are recorded as customer deposit liabilities until released, at which time the liability is reduced. A reconciliation of cash, cash equivalents, and restricted cash to the amounts presented in the statement of cash flows is provided in the following table.


	December 31, 2025	December 31, 2024
Cash and cash equivalents	$ 124,245	$ 113,607
Restricted cash	57,218	54,981
Total cash, cash equivalents, and restricted cash	$ 181,463	$ 168,588

Accounts receivable and allowance for expected credit losses

The Company evaluates expected credit losses using an aging schedule and records an allowance when amounts are determined to be uncollectible.

As of December 31, 2025 and 2024, the Company recognized expected credit losses of $82 and $34, respectively.

Foreign currency translation

The Company’s functional reporting currency is the U.S. dollar. The functional currency of each foreign subsidiary is its local currency, with monetary assets and liabilities translated at period-end exchange rates and non-monetary items at historical rates. Revenues and expenses are translated at average monthly rates. Translation gains and losses are included in other comprehensive income (loss). The Company does not use hedging instruments to manage foreign currency risk.

Fixed assets

Fixed assets are recorded at cost and depreciated on a straight-line basis over estimated useful lives, generally three to five years for computer hardware and software and five to seven years for furniture, fixtures, and equipment. Maintenance and repairs are expensed as incurred, while expenditures that extend useful life or improve functionality are capitalized. The Company also capitalizes eligible costs related to the development of internal-use software, including upgrades and enhancements.

Software development costs

The Company capitalizes software development costs related to products to be sold, leased, or marketed to external users and internal-use software.

Impairment of long-lived assets

The Company reviews long-lived assets for impairment when events or changes in circumstances indicate that carrying amounts may not be recoverable. If the expected undiscounted cash flows are less than the carrying value, the asset is written down to fair value.

Stock-based compensation

Stock-based compensation is measured at grant date fair value and recognized on a straight-line basis over the requisite service period, net of forfeitures. Awards with performance conditions are recognized based on the probable outcome of those conditions.

Revenue recognition

The Company generates a substantial portion of its revenue from North American Realty and International Realty segments and generates a de minimis portion of its revenues from its Other Affiliated Services segment. The Company does not have contracts with customers that provide variable consideration.

North American Realty and International Realty

The Company serves as a licensed broker in the areas in which it operates for the purpose of processing residential real estate transactions. The Company is contractually obligated to provide services for the fulfillment of transfers of residential real estate between buyers and sellers. The Company provides these services itself and controls the services necessary to legally transfer residential real estate. Correspondingly, the Company is defined as the principal. The Company, as principal, satisfies its obligation upon the closing of a residential real estate transaction. As principal and upon satisfaction of the performance obligation, the Company recognizes revenue in the gross amount of consideration to which the Company expects to be entitled. The Company estimates and accrues revenue to which it is entitled to for closed transactions but has yet to receive all the necessary closing documents.

Revenue is derived from assisting homebuyers and sellers in listing, marketing, selling and finding residential real estate. Commissions earned on real estate transactions are recognized at the completion of a residential real estate transaction

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once the Company has satisfied the performance obligation. Agent-related fees charged by the Company are recorded as a reduction to commissions and other agent-related costs.

Software Subscription and Professional Services

Subscription revenue is derived from fees from customers to access the Company’s virtual reality software platform. The terms of subscriptions do not provide customers the right to take possession of the software. Subscription revenue is generally recognized ratably over the contract term.

Professional services revenue is derived from implementation and consulting services. Professional services revenue is typically recognized over time as the services are rendered, using an efforts-expended (labor hours) input method.

Disaggregated revenue

The Company primarily operates as a real estate brokerage firm and discloses disaggregated revenue from services to customers across its three reportable segments to provide additional insight into the future recognition of revenue and cash flows. The vast majority of the Company’s revenue is derived from providing real estate brokerage services to purchasers and sellers of homes in the U.S., Canada and internationally. See Note 10 – Segment Information for details regarding segment and geographic information.

Management provides disaggregation of revenue from its services to customers to provide additional insight into the future recognition of revenue and cash flows.

Sustainable Revenue Share Plan expenses

The Company maintains a revenue share program that allows agents and brokers to earn additional income from real estate transactions closed by agents they have attracted to the Company, subject to defined qualification requirements. Payments under the plan are funded from the Company’s portion of transaction commissions and are recorded as commissions and other agent-related costs in the consolidated statements of comprehensive income (loss).

Advertising and marketing costs

Advertising and marketing costs are generally expensed in the period incurred. Advertising and marketing expenses are included in the sales and marketing expense line item on the accompanying consolidated statements of comprehensive income (loss). For the years ended December 31, 2025, 2024 and 2023, the Company incurred advertising and marketing expenses of $10,555, $11,908 and $12,056, respectively.

Income taxes

The Company accounts for income taxes using the asset and liability method. Deferred tax assets and liabilities are recognized for temporary differences between financial reporting and tax basis of assets and liabilities, measured using enacted tax rates expected to apply when the differences reverse. Deferred tax assets are recorded when realization is considered more likely than not, and a valuation allowance is established when necessary. Uncertain tax positions are recognized when it is more likely than not that the position will be sustained, measured as the largest amount of benefit more than 50% likely to be realized upon settlement.

Comprehensive income (loss)

The Company’s only components of comprehensive income (loss) are net income (loss) and foreign currency translation adjustments.

Accounting pronouncements

The Company has adopted all new accounting standards currently in effect and does not believe that any recently issued standards will have a material impact on its financial statements.

In July 2025, the Financial Accounting Standards Board (“FASB”) issued ASU 2025-05, which simplifies the application of the Current Expected Credit Loss (“CECL”) model for short-term assets. The update provides a practical expedient allowing entities to assume that current economic conditions at the balance sheet date will remain constant over the remaining short life of accounts receivable and contract assets, rather than requiring complex macroeconomic forecasting. This standard is effective for the Company beginning January 1, 2026, with early adoption permitted. The adoption of this standard is expected to streamline the financial reporting process and eliminate the need for complex macroeconomic modeling on its short-term commission-related receivables.

In September 2025, the FASB issued ASU 2025-06 to modernize software cost accounting. The amendments remove the traditional project stages to better align with agile and iterative development cycles. Capitalization now begins when management authorizes the project and it is "probable to complete." The standard is effective for the Company for fiscal years beginning after

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December 15, 2027, with early adoption permitted. The Company anticipates that the adoption of this standard will better align its accounting for internal-use software with its agile development environment and while it is still evaluating the full impact, the update is expected to increase the level of judgment required in determining the commencement of capitalization and may result in a greater portion of development costs being expensed in the earlier stages of its technology projects.

In December 2025, the FASB issued ASU 2025-11 to improve the navigability of interim financial statement disclosures. The update provides a centralized list of required interim disclosures and introduces disclosure principles requiring entities to report significant events occurring since the previous year end that have a material impact. While the ASU clarifies what must be disclosed, it is not intended to significantly change existing reporting volume for SEC filers. The standard is effective for the Company’s interim periods beginning January 1, 2028, and early adoption is permitted. As a result, the Company expects the adoption this standard to enhance the consistency and navigability of its quarterly filings through the application of the new centralized disclosure framework, though it does not anticipate that the adoption of this update will have a material impact on its consolidated financial position or results of operations.

In December 2025, the FASB issued ASU 2025-12 as part of its ongoing project to clarify and correct various sections of the Accounting Standards Codification. Key improvements in this update include clarifications on the calculation of diluted earnings per share (“EPS”) during loss periods and the accounting for treasury stock retirements. The amendments are effective for the Company beginning January 1, 2027, and may be applied either prospectively or retrospectively depending on the specific issue within the update. The Company is currently evaluating the impact of these clarifications on its reporting processes but expects that the adoption of this standard will primarily result in refined calculations of diluted EPS during periods of net loss and provide a more standardized approach to its treasury stock accounting without significantly altering its overall financial position.

3.	DISCONTINUED OPERATIONS

In 2023, In accordance with ASC 205-20, the Company determined that Virbela was no longer continuing operations, and the results of the Virbela business have been presented as discontinued operations in the consolidated statements of comprehensive income (loss) and, as such, have been excluded from continuing operations. In the fourth quarter of 2024, the Company completed the disposition of Virbela. The following table presents the information for Virbela’s operations for the years ended December 31, 2024 and 2023 (in thousands).


INCOME STATEMENT OF DISCONTINUED OPERATIONS

	Year Ended December 31,
	2025	2024	2023
Revenues	$ -	$ 652	$ 7,284
Operating expenses
Cost of revenue	-	3,083	3,156
General and administrative expenses	-	3,139	10,804
Technology and development expenses	-	322	1,003
Sales and marketing expenses	-	(2)	100
Impairment expense	-	-	9,203
Total operating expenses	-	6,542	24,266
Operating income (loss)	-	(5,890)	(16,982)
Other (income) expense
Other (income) expense, net	-	(278)	(31)
Total other (income) expense, net	-	(278)	(31)
Income (loss) before income tax expense	-	(5,612)	(16,951)
Income tax benefit (expense)	-	1,133	4,445
Net income (loss) from discontinued operations	$ -	($ 4,479)	($ 12,506)

4.	FAIR VALUE MEASUREMENT

The Company holds funds in a money market account, which are considered Level 1 assets. The Company values its money market funds at fair value on a recurring basis.

As of December 31, 2025 and 2024, the fair value of the Company’s money market funds was $12,397 and $38,344, respectively.

The Company holds investments in equity securities without readily determinable fair values, accounted for under the measurement alternative in accordance with ASC 321. As of December 31, 2025, the carrying value of these investments was $12,235, reflecting an initial acquisition of $11,000 in the first quarter of 2025 and a subsequent capital contribution during the third and fourth quarter of 2025. There were no transfers between levels of the fair value hierarchy, and the Company held no Level 2 financial instruments during the periods presented.

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5.	PREPAIDS AND OTHER ASSETS

Prepaids and other assets consisted of the following:


	December 31, 2025	December 31, 2024
Prepaid expenses	$ 6,612	$ 7,817
Prepaid insurance	4,723	2,686
Other assets (includes inventory)	3,232	1,189
Total prepaid expenses	$ 14,567	$ 11,692

6.	PROPERTY AND EQUIPMENT, NET

Property and equipment, net consisted of the following:


	December 31, 2025	December 31, 2024
Computer hardware and software	$ 53,849	$ 44,079
Furniture, fixture, and equipment	2,206	2,205
Total depreciable property and equipment	56,055	46,284
Less: accumulated depreciation	(42,184)	(35,262)
Depreciable property and equipment, net	13,871	11,022
Assets under development	443	593
Property and equipment, net	$ 14,314	$ 11,615

For the years ended December 31, 2025, 2024 and 2023, depreciation expense was $6,870, $7,835 and $8,352, respectively.

7.	GOODWILL AND INTANGIBLE ASSETS

Changes in the carrying amount of goodwill were:


	December 31, 2025	December 31, 2024
Goodwill	$ 17,226	$ 16,982
Acquisitions	-	3,737
Impairments	-	(2,386)
Currency translation impact	646	(1,107)
Total goodwill	$ 17,872	$ 17,226

The Company performed its annual goodwill impairment testing in the fourth quarter of 2025 and 2024. In 2024, the Company determined that the goodwill associated with SUCCESS^® was impaired. The Company recognized goodwill impairment charge of $2,386 for the year ended December 31, 2024.

The Company has a risk of future impairment to the extent that individual reporting unit performance does not meet projections. Additionally, if current assumptions and estimates, including projected revenues and income growth rates, terminal growth rates, competitive and consumer trends, market-based discount rates and other market factors, are not met, or if valuation factors outside of the Company’s control change unfavorably, the estimated fair value of goodwill could be adversely affected, leading to a potential impairment in the future.

Definite-lived intangible assets were as follows:


	December 31, 2025
	Gross	Accumulated		Net Carrying
	Amount	Amortization	Impairment	Amount
Trade name	$ 2,068	($ 1,262)	$ -	$ 806
Existing technology	5,996	(4,871)	-	1,125
Non-competition agreements	476	(368)	-	108
Customer relationships	2,011	(1,051)	-	960
Licensing agreement	210	(210)	-	-
Intellectual property	1,453	(31)	-	1,422
Total intangible assets	$ 12,214	($ 7,793)	$ -	$ 4,421

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	December 31, 2024
	Gross	Accumulated		Net Carrying
	Amount	Amortization	Impairment	Amount
Trade name	$ 2,042	($ 943)	$ -	$ 1,099
Existing technology	5,349	(2,564)	-	2,785
Non-competition agreements	461	(272)	-	189
Customer relationships	2,560	(503)	(549)	1,508
Licensing agreement	210	(210)	-	-
Intellectual property	3,448	(578)	(1,995)	875
Total intangible assets	$ 14,070	($ 5,070)	($ 2,544)	$ 6,456

For the years ended December 31, 2025, 2024 and 2023, amortization expense for definite-lived intangible assets was $2,692, $2,454, and $2,540, respectively.

As part of the Company’s annual assessment, the Company also reviews the useful lives of its amortizable intangible assets and determines if there should be any change to the amortization period. In 2024, for amortizable intangible assets related to SUCCESS^®, the Company recognized an impairment loss related to the net book value of the customer lists of $549 and content of $1,995.

In 2025, there was no impairment of goodwill or intangible assets, and there was no change to the useful lives of amortizable intangible assets.

8.	ACCRUED EXPENSES

Accrued expenses consisted of the following:


	December 31, 2025	December 31, 2024
Commissions payable	$ 73,474	$ 58,984
Payroll payable	7,635	7,619
Taxes payable	3,791	3,999
Stock liability awards	5,782	5,045
Other accrued expenses	17,526	10,014
	$ 108,208	$ 85,661

9.	STOCKHOLDERS’ EQUITY

The following table represents a reconciliation of the Company’s issued common stock shares for the periods presented:


	Year Ended December 31,
	2025	2024	2023
Common stock:
Balance, beginning of period	195,028,207	183,606,708	171,656,030
Shares issued for stock options exercised	82,936	380,919	832,993
Agent growth incentive stock-based compensation	2,802,114	1,787,280	2,219,881
Agent equity stock-based compensation	9,872,505	9,253,300	8,897,804
Balance, end of period	207,785,762	195,028,207	183,606,708

Dividends

The Company declared and paid dividends of $0.05 quarterly in 2025 and 2024. The Company declared and paid dividends of $0.045 in each of the first and second quarters of 2023, $0.05 in each of the third and fourth quarters of 2023. Dividends are declared at the discretion of the Board and are based on various factors, including the Company’s financial condition, results of operations, capital requirements, and market conditions. The total cash dividends paid during each of these years were funded from available cash and were recorded as reductions to accumulated earnings (deficit).

2024 Equity Incentive Plan

The eXp World Holdings, Inc. 2024 Equity Incentive Plan (the “2024 Plan”) is a stockholder-approved plan that provides for broad-based equity grants to service providers, including employees, directors, agents, and consultants, and permits the granting of restricted stock units (“RSUs”), stock grants, performance-based awards, stock options and stock appreciation rights. RSUs granted under the 2024 Plan generally vest over four years, based on continued services, and are settled upon vesting in shares of the Company’s common stock on a one-for-one basis. All RSUs granted under the 2024 Plan have dividend equivalent rights, which entitle holders of RSUs to the same dividend value per share as holders of common stock. A maximum of approximately 150 million shares were authorized for issuance pursuant to 2024 Plan awards at the time the plan was approved on May 13, 2024.

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The Company’s stockholder approved equity programs described below are administered under the 2024 Plan, beginning in September 2024. Prior to that time, the equity programs were administered under the eXp World Holdings, Inc. 2015 Equity Incentive Plan which has since terminated. The purpose of the 2024 Plan is to retain the services of valued employees, directors, officers, agents and consultants and to incentivize such persons to make contributions to the Company and motivate excellent performance.

2015 Equity Incentive Plan

The eXp World Holdings, Inc. 2015 Equity Incentive Plan, as amended and restated (the “2015 Plan”), is a stockholder-approved plan that provided for broad-based equity grants to service providers, including employees, directors, agents, and consultants. The 2015 Plan permitted the granting of the same types of equity awards with substantially the same terms as the 2024 Plan. In the third quarter of 2024, the Company terminated the authority to grant new awards under the 2015 Plan.

Agent Equity Program (“AEP”)

The Company provides agents and brokers the opportunity to elect to receive 5% of commissions earned from each completed residential real estate transaction in the form of common stock of the Company at a discount recognized by the Company. If agents and brokers elect to receive portions of their commissions in common stock, they are entitled to receive the equivalent number of shares of common stock based on the fixed monetary value of the commission payable.

For the years ended December 31, 2025, 2024 and 2023, the Company issued 9,872,505, 9,253,300 and 8,897,804 shares of common stock, respectively, to agents and brokers for $98,149, $111,278 and $135,226, respectively, net of discount, attributable to the AEP.

Agent Growth Incentive Program (“AGIP”)

The Company administers AGIP whereby agents and brokers become eligible to receive awards of the Company’s common stock through agent attraction and performance benchmarks. The incentive program encourages greater performance and awards agents with common stock based on achievement of performance milestones. Awards typically vest after performance benchmarks are reached and three years of subsequent service is provided to the Company. Share-based performance awards are based on a fixed-dollar amount of shares once performance metrics are achieved. As such, the awards are classified as liabilities until the number of share awards becomes fixed once the performance metric is achieved.

For the years ended December 31, 2025, 2024 and 2023, the Company’s stock compensation attributable to the AGIP was $37,222, $36,998 and $43,178, respectively. The amount of stock compensation attributable to liability classified awards was $2,736, $2,251 and $3,832 for the years ended December 31, 2025, 2024 and 2023, respectively.

As of December 31, 2025, the total unrecognized compensation costs associated with these awards, where the performance metric has been achieved and the number of shares awarded are fixed, was $59,896, which is expected to be recognized over a weighted-average period of approximately 2.02 years.

The following table illustrates changes in the Company’s stock compensation liability, included in accrued liabilities for the periods presented:


		Amount
Balance, December 31, 2023		$ 5,000
Stock grant liability increase year to date		2,251
Stock grants reclassified from liability to equity year to date		(2,206)
Balance, December 31, 2024		$ 5,045
Stock grant liability increase year to date		2,736
Stock grants reclassified from liability to equity year to date		(1,999)
Balance, December 31, 2025		$ 5,782

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The following table illustrates the Company’s stock activity for the AGIP for stock awards where the performance metric has been achieved for the following periods:


			Weighted Average
			Grant Date
	Shares		Fair Value
Balance, December 31, 2023	6,875,289		$ 17.80
Granted	4,472,988		12.22
Vested and issued	(1,773,129)		22.99
Forfeited	(1,720,193)		15.93
Balance, December 31, 2024	7,854,955		$ 13.80
Granted	5,490,988		10.06
Vested and issued	(2,715,482)		13.65
Forfeited	(1,355,254)		12.66
Balance, December 31, 2025	9,275,207		$11.74

Activity related to Other Restricted Stock Units (“RSUs”), which was previously included in the AGIP stock activity table for prior years, is now presented independently in the Other Restricted Stock Units section below.

Other Restricted Stock Units

RSUs may be granted to directors, officers, certain employees and consultants. Each RSU represents the right to receive one share of the Company’s common stock upon vesting, subject to time-based and/or performance-based restrictions. RSUs typically vest over a three-year period with equal and periodically graded vesting or cliff vesting, as applicable. The fair value of RSUs granted is determined based on the closing market price of the Company's common stock on the grant date. The total fair value of RSUs is recognized as stock-based compensation expense over the vesting period, with adjustments for estimated forfeitures.

For the years ended December 31, 2025, 2024 and 2023, the Company's stock compensation attributable to these RSUs was $1,142, $267 and $0, respectively.

As of December 31, 2025, the total unrecognized compensation costs associated with these RSUs was $2,877, which is expected to be recognized over a weighted-average period of approximately 2.21 years.

The following table illustrates the Company’s RSU activity for the following periods:


			Weighted Average
			Grant Date
	Shares		Fair Value
Balance, December 31, 2023	-		$ -
Granted	115,574		12.89
Vested and issued	(14,151)		12.06
Forfeited	-		-
Balance, December 31, 2024	101,423		$ 13.00
Granted	300,410		10.13
Vested and issued	(86,632)		11.02
Forfeited	(20,508)		12.34
Balance, December 31, 2025	294,693		$10.71

Stock Option Awards

Stock options are granted to directors, officers, certain employees and consultants with an exercise price equal to the fair market value of common stock on the grant date and the stock options expire 10 years from the date of grant. These options generally have time-based restrictions with equal and periodically graded vesting over a three-year period.

The fair value of the options issued is calculated using a Black-Scholes-Merton option-pricing model with the following assumptions:


	2025	2024	2023
Expected term	5 years	5 years	5 - 6 years
Expected volatility	68.69% - 74.72%	73.51% - 74.29%	73.64% - 76.78%
Risk-free interest rate	3.54% - 4.41%	3.48% - 4.61%	3.28% - 4.86%
Dividend yield	1.76% - 2.24%	1.39% - 1.99%	0.72% - 1.64%

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The following table illustrates the Company’s stock option activity for the following periods:


								Weighted
								Average
				Weighted				Remaining
				Average				Contractual Term
		Options		Exercise Price		Intrinsic Value		(Years)
Balance at December 31, 2023		6,198,544		$ 14.23		$ 3.62		7.29
Granted		1,012,111		11.74		-		9.19
Exercised		(380,919)		5.29		5.79		—
Forfeited		(959,539)		18.84		0.05		—
Expired		(300,052)		23.60		0.04		—
Balance at December 31, 2024		5,570,145		$ 13.09		$ 1.17		6.97
Granted		557,664		10.15		-		8.95
Exercised		(82,936)		5.22		5.34		—
Forfeited		(763,475)		14.39		0.08		—
Expired		(118,165)		14.23		0.02		—
Balance at December 31, 2025		5,163,233		$ 12.72		$ 0.36		6.14
Exercisable at December 31, 2025		3,798,468		$ 12.93		$ 0.50		5.27
Vested at December 31, 2025		3,798,468		$ 12.93		$ 0.50		5.27

				Weighted
				Average
		Options		Exercise Price
Range of stock option exercise prices at December 31, 2025:
$0.01 - $10.00 (average remaining life - 4.52 years)		2,261,770		$ 8.91
$10.01 - $30.00 (average remaining life - 7.5 years)		2,678,741		$ 13.91
$30.01 - $60.00 (average remaining life - 5.4 years)		222,722		$ 38.14

The grant date fair value of options to purchase common stock is recorded as stock-based compensation over the vesting period. As of December 31, 2025, unrecognized compensation cost associated with the Company’s outstanding stock options was $7,811, which is expected to be recognized over a weighted-average period of approximately 0.75 years.

Stock Repurchase Program

During 2025, the Company repurchased 5,840,961 shares of its common stock for $56.2 million. The Company’s share repurchase program does not obligate the Company to acquire a minimum amount of shares and it limits the Company’s aggregate repurchases to $1.0 billion. Under the programs, shares may be repurchased in privately negotiated or open market transactions, including under plans complying with Rule 10b5-1 under the Securities Exchange Act of 1934, as amended. For accounting purposes, common stock repurchased under the stock repurchase programs is recorded based upon the trade date of the applicable trade. Such repurchased shares are held in treasury and are presented using the cost method. These shares are considered issued but not outstanding. The following table shows the changes in treasury stock shares for the periods presented:


	Year Ended December 31,
	2025	2024	2023
Treasury stock:
Balance, beginning of period	40,894,822	28,937,671	18,816,791
Repurchases of common stock	5,840,961	11,957,151	10,110,152
Forfeiture to treasury stock for acquisition	-	-	10,728
Balance, end of period	46,735,783	40,894,822	28,937,671

10.	SEGMENT INFORMATION

Segment information aligns with how the Chief Operating Decision Maker (“CODM”), Glenn Sanford, Chief Executive Officer of eXp World Holdings, Inc., manages the business and allocates resources as three operating segments. The Company determines an operating segment if a component (i) engages in business activities from which it earns revenues and incurs expenses, (ii) has discrete financial information, and is (iii) regularly reviewed by the CODM. Once operating segments are identified, the Company performs a quantitative analysis of the current and historic revenues and profitability for each operating segment, together with a qualitative assessment to determine if operating segments have similar operating characteristics. The Company has three operating segments and three reportable segments.

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The CODM uses revenues, segment adjusted EBITDA, and operating income (loss) as key metrics to evaluate the operating and financial performance of a segment, identify trends affecting the segments, develop projections and make strategic business decisions. The CODM also regularly reviews commissions and other agent-related costs to assess segment performance. Commissions and other agent-related costs include sales commissions, revenue share and stock-based compensation paid to the Company’s agents. segment adjusted EBITDA for the reportable segments is defined as net income before depreciation and amortization, interest expense, income taxes, stock compensation expense, stock option expense, and other items that are not core to the operating activities of the Company. The Company’s three reportable segments are as follows:

●

North American Realty: includes real estate brokerage operations in the United States and Canada, as well as lead-generation and other real estate support services provided in North America.

●

International Realty: includes real estate brokerage operations in all other international locations.

●

Other Affiliated Services: includes SUCCESS^® Magazine and other ancillary ventures.

The Company also reports corporate expenses, as further detailed below, as “Corporate expenses and other” which include expenses incurred in connection with business development support provided to the agents as well as resources, including administrative, brokerage operations and legal functions.

All segments follow the same basis of presentation and accounting policies as those described in Note 2 – Summary of Significant Accounting Policies. The following table provides information about the Company’s reportable segments and a reconciliation of the total segment Revenues to consolidated Revenues. Financial information for the comparable prior periods presented have been revised to conform with the current year presentation.


	Revenues
	Year Ended December 31,
	2025	2024	2023
North American Realty	$ 4,624,913	$ 4,478,293	$ 4,220,063
International Realty	146,930	88,146	53,931
Other Affiliated Services	2,873	6,105	4,802
Commissions reconciliation:
Segment eliminations	(2,405)	(4,872)	(4,975)
Consolidated revenues	$ 4,772,311	$ 4,567,672	$ 4,273,821


	Commissions and other agent-related costs
	Year Ended December 31,
	2025	2024	2023
North American Realty	$ 4,315,316	$ 4,153,113	$ 3,910,851
International Realty	122,061	71,657	43,103
Other Affiliated Services	1,356	2,742	2,448
Commissions reconciliation:
Segment eliminations	-	(2,235)	(2,505)
Consolidated commissions and other agent-related costs	$ 4,438,733	$ 4,225,277	$ 3,953,897

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	Adjusted EBITDA
	Year Ended December 31,
	2025	2024	2023
North American Realty	$ 59,753	$ 99,253	$ 91,101
International Realty	(9,933)	(9,481)	(13,657)
Other Affiliated Services	(5,804)	(4,876)	(3,795)
Corporate expenses and other	(10,844)	(9,413)	(8,321)
Consolidated adjusted EBITDA	$ 33,172	$ 75,483	$ 65,328

Income (loss) before income tax expense reconciliation:
Depreciation and amortization expense	9,562	10,289	10,892
Impairment expense	-	4,930	-
Litigation contingency	-	34,000	-
Stock-based compensation expense	38,610	37,285	43,178
Stock option expense	6,466	7,973	10,736
Other (income) expense, net	(1,232)	(3,277)	(2,995)
Consolidated income (loss) before income tax expense	($ 20,234)	($ 15,717)	$ 3,517


	Operating Income (Loss)
	Year Ended December 31,
	2025	2024	2023
North American Realty	$ 9,322	$ 16,468	$ 33,388
International Realty	(11,674)	(10,492)	(14,248)
Other Affiliated Services	(6,153)	(11,615)	(4,590)
Segment Operating Income (Loss)	(8,505)	(5,639)	14,550
Corporate expenses and other	(12,961)	(13,355)	(14,028)
Consolidated Operating Income (Loss)	(21,466)	(18,994)	522


	Goodwill
	December 31, 2025	December 31, 2024
North American Realty	$ 17,872	$ 17,226
International Realty	-	-
Other Affiliated Services	-	-
Segment and consolidated total	17,872	17,226

Geographical information

For the years ended December 31, 2025, 2024 and 2023 approximately 13%, 11% and 9%, respectively, of the Company’s total revenue was generated outside of the U.S. Long-lived assets held outside of the U.S. were 10% and 17% as of December 31, 2025 and 2024, respectively.

The Company’s CODM does not use segment assets to allocate resources or to assess the performance of the segments and therefore, total segment assets have not been disclosed.

11.	EARNINGS PER SHARE

Basic earnings (loss) per share is computed by dividing the net income (loss) by the weighted average number of shares of common stock outstanding during the year. Dilutive earnings per share is computed consistently with the basic computation while giving effect to all dilutive potential common shares and common share equivalents that were outstanding during the period. The Company uses the treasury stock method to reflect the potential dilutive effect of unvested stock awards and unexercised options.

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The following table sets forth the calculation of basic and diluted earnings per share attributable to common stock during the years presented:


	Year Ended December 31,
	2025	2024	2023
Numerator:
Net income (loss) from continuing operations	($ 22,714)	($ 16,788)	$ 3,533
Net income (loss) from discontinued operations	$ -	($ 4,479)	($ 12,506)
Net income (loss)	($ 22,714)	($ 21,267)	($ 8,973)
Denominator:
Weighted average shares - basic	156,879,412	153,684,907	153,232,129
Dilutive effect of common stock equivalents	-	-	3,541,399
Weighted average shares - diluted	156,879,412	153,684,907	156,773,528
Earnings per share:
Net income (loss) from continuing operations per share - basic	($ 0.14)	($ 0.11)	$ 0.02
Net income (loss) from discontinued operations per share - basic	$ -	($ 0.03)	($ 0.08)
Net income (loss) per share - basic	($ 0.14)	($ 0.14)	($ 0.06)
Net income (loss) from continuing operations per share - diluted	($ 0.14)	($ 0.11)	$ 0.02
Net income (loss) from discontinued operations per share - diluted	$ -	($ 0.03)	($ 0.08)
Net income (loss) per share - diluted	($ 0.14)	($ 0.14)	($ 0.06)

For the years ended December 31, 2025, 2024 and 2023, total outstanding shares of common stock excluded from the computation of diluted earnings per share because their effect would have been anti-dilutive were 3,419,590, 3,698,061 and 820,376, respectively.

12.	INCOME TAXES

Provision for Income Taxes and Effective Tax Rate

The following table provides the components of income (loss) before provision for income taxes from continuing operations by domestic and foreign subsidiaries:


	Year Ended December 31,
	2025	2024	2023
Domestic	($ 31,404)	($ 24,479)	$ 431
Foreign	11,170	8,762	3,086
Total	($ 20,234)	($ 15,717)	$ 3,517

The components of the income tax (benefit) expense from continuing operations are as follows:


	Year Ended December 31,
	2025	2024	2023
Current:
Federal	($ 59)	$ 408	$ 301
State	374	1,211	795
Foreign	3,576	3,060	1,789
Total current income tax provision	3,891	4,679	2,885
Deferred
Federal	(1,709)	(2,277)	(1,137)
State	(458)	(573)	(903)
Foreign	756	(758)	(861)
Total deferred income tax benefit	(1,411)	(3,608)	(2,901)
Total income tax (benefit) expense from continuing operations	$ 2,480	$ 1,071	($ 16)

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The reconciliation of the provision for income tax (benefit) expense from continuing operations at the United States federal statutory rate compared to the Company's income tax (benefit) expense as reported is as follows, with reconciling items for all periods presented disaggregated by nature and jurisdiction in accordance with the retrospective adoption of ASU 2023-09, Improvements to Income Tax Disclosures, effective January 1, 2025:


	Year Ended December 31,
	2025		2024		2023
	Amount	Percent	Amount	Percent	Amount	Percent
U.S. Federal Statutory Tax Rate	($ 4,249)	21.00%	($ 3,302)	21.00%	$ 739	21.00%

State and Local Income Taxes, Net of Federal Effect^(a)	137	(0.68)%	815	(5.18)%	558	15.87%

Foreign Tax Effects	1,861	(9.20)%	951	(6.05)%	(409)	(11.66)%
Canada
Foreign Rate Differential	512	(2.53)%	327	(2.08)%	668	18.98%
Stock Based Compensation	81	(0.40)%	149	(0.95)%	(446)	(12.68)%
Adjustment to Deferred Tax Assets	875	(4.33)%	(17)	0.11%	157	4.46%
Other	-	0.00%	-	0.00%	1	0.01%
Other Foreign Jurisdictions	393	(1.94)%	492	(3.13)%	(789)	(22.44)%

Effect of Changes in Tax Laws or Rates	-	0.00%	-	0.00%	-	0.00%

Effect of Cross-Border Tax	-	0.00%	-	0.00%	-	0.00%

Tax Credits	431	(2.13)%	(2,576)	16.38%	(1,903)	(54.10)%
Research and Development Tax Credit	431	(2.13)%	(2,576)	16.38%	(1,903)	(54.10)%

Change of Valuation Allowance	-	0.00%	-	0.00%	-	0.00%

Nontaxable or Nondeductible Items	4,077	(20.15)%	4,617	(29.37)%	(373)	(10.61)%
Fines/Penalties	345	(1.70)%	-	0.00%	-	0.00%
Non-deductible Legal Settlement	630	(3.11)%	-	0.00%	-	0.00%
Stock Compensation	3,305	(16.34)%	4,675	(29.74)%	(375)	(10.66)%
Other	(203)	1.00%	(58)	0.37%	2	0.05%

Changes in Unrecognized Tax Benefits	217	(1.07)%	652	(4.14)%	475	13.53%

Other	6	(0.03)%	(86)	0.55%	897	25.50%
Effective Tax Rate	2,480	(12.26)%	1,071	(6.81)%	(16)	(0.47)%

(a)

^{State taxes in}^{Texas and California}^{made up the majority (greater than 50 percent) of the tax effect in this category}

The following table provides the income taxes paid, net of refunds received, disaggregated by federal, state, and foreign jurisdictions in accordance with ASU 2023-09:


	Year Ended December 31,
	2025	2024	2023
Federal	$ 166	$ 608	$ -
State	947	401	831
Foreign	3,484	1,685	1,900
Total	$ 4,597	$ 2,694	$ 2,731

Income taxes paid (net of refunds) exceeded 5% of total income taxes paid (net of refunds) in the following jurisdictions:


	Year Ended December 31,
	2025	2024	2023
State
Texas	$ 322	$ 230	$ 390

Foreign
Canada	$ 2,990	$ 1,612	$ 1,887

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The Company has adjusted prior year amounts to remove amounts from discontinued operations.

Deferred tax assets and liabilities from continuing operations consist of the following for the periods presented:


	December 31, 2025	December 31, 2024
Deferred tax assets:
Net operating loss carryforward	$ 30,238	$ 26,110
Accruals and Reserves	8,392	11,252
Goodwill and Intangibles	984	1,887
Research and Experimental Costs	22,138	19,331
Research and Development Credit	4,605	4,973
Share-based compensation	14,814	14,685
Total gross deferred tax assets	81,171	78,238
Less: Valuation allowance	(542)	(158)
Deferred tax assets, net of valuation allowance	80,629	78,080
Deferred tax liabilities:
Property and equipment	(3,476)	(2,659)
Other	357	353
Total gross deferred tax liabilities	(3,119)	(2,306)
Net deferred tax assets	$ 77,510	$ 75,774

The Company accounts for deferred taxes under ASC Topic 740 – Income Taxes (“ASC 740”), which requires a reduction of the carrying amount of deferred tax assets by a valuation allowance if, based on available evidence, it is more likely than not that such assets will not be realized. Accordingly, the need to establish valuation allowances for deferred tax assets is assessed periodically based on the ASC 740 more-likely-than-not realization threshold criterion. This assessment considers matters such as future reversals of existing taxable temporary differences, projected future taxable income, tax-planning strategies, and results of recent operations. The evaluation of the recoverability of the deferred tax assets requires that the Company weigh all positive and negative evidence to reach a conclusion that it is more likely than not that all or some portion of the deferred tax assets will not be realized. The weight given to the evidence is commensurate with the extent to which it can be objectively verified. As of December 31, 2025, based on its assessment of the realizability of its net deferred tax assets, the Company concluded that its U.S. federal, and the majority of its foreign net deferred tax assets will more-likely-than-not be fully realized, however certain U.S. State and foreign deferred tax assets will likely not be fully realized.

As of December 31, 2025, the Company had federal, state and foreign net operating losses of approximately $110.9, $84.8 and $11.3, respectively. The full amount of $110.9 of federal net operating loss can be carried forward indefinitely and can offset 80% of future taxable income. Certain state net operating losses will carry forward for a limited number of years and, if not utilized, may begin to expire in 2031. As of December 31, 2025, the Company determined that $14.5 of state net operating loss (“NOL”) will likely expire and recorded $0.3 of valuation allowance. Certain foreign net operating losses will carry forward for a limited number of years and, if not utilized, will begin to expire in 2029. As of December 31, 2025, the Company determined that $1.0 of foreign NOL will likely expire and recorded $0.2 million of valuation allowance. The Company conducted an IRC Section 382 analysis with respect to its net operating loss carryforward and determined there was an immaterial limitation.

Undistributed earnings of the Company’s foreign subsidiaries are considered to be indefinitely reinvested and accordingly, no provision for applicable income taxes has been provided thereon. Upon distribution of those earnings, the Company would be subject to withholding taxes payable to various foreign countries. As of December 31, 2025 the undistributed earnings of the Company's foreign subsidiaries could result in withholding taxes of approximately $1.2, if repatriated.

As of December 31, 2025, the Company had federal and California Research and Development credit carryforwards of approximately $6.3 and $0.8, respectively. The federal credit can be carried forward 20 years and will begin to expire in 2039. The California credit can be carried forward indefinitely.

Uncertain Tax Positions

The Company maintains liabilities for uncertain tax positions. These liabilities involve considerable judgment and estimation and are continuously monitored by management based on the best information available, including changes in tax regulations, the outcome of relevant court cases, and other information. A reconciliation of the beginning and ending amount of gross unrecognized benefits is as follows:

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	Year Ended December 31,
	2025	2024	2023
Unrecognized tax benefits - beginning of year	$ 2,573	$ 1,904	$ 1,309
Gross increase for tax positions of prior years	(450)	(39)	63
Gross increase for tax positions of current year	278	708	532
Unrecognized tax benefits - end of year	$ 2,401	$ 2,573	$ 1,904

The unrecognized tax benefits relate to federal and California R&D credits are generated from 2019 through 2025. The total amount of unrecognized tax benefits that would affect the Company's effective tax rate, if recognized, is $2,401 and $2,573 at December 31, 2025 and 2024, respectively. The Company's policy is to recognize interest and penalties related to income tax matters in income tax expense. As of December 31, 2025 and 2024, the Company did not accrue interest or penalties related to uncertain tax positions. The company does not expect any of the uncertain tax positions to reverse during the next 12 months.

There are no federal or state tax examinations in progress. Because the Company has net operating loss carryforwards, there are open statutes of limitations in which federal taxing authorities may examine the Company's tax returns for all years from December 31, 2012 through the current period. U.S. State taxing authorities may examine the Company's tax returns for all years from December 31, 2015 through the current period and foreign tax authorities may examine the Company's tax return for all years from December 31, 2020 through the current period.

The Company is subject to a wide variety of tax laws and regulations across the jurisdictions where it operates. Regulatory developments from the U.S. or international tax reform legislation could result in an impact to the Company's effective tax rate. On July 4, 2025, the One Big Beautiful Bill Act (“OBBBA”) was enacted into U.S. law. In accordance with ASC 740, the Company evaluated the impact of the legislation on its financial statements, including potential changes to deferred tax assets and liabilities, and the effective tax rate. The Company determined that OBBBA did not have a material impact on its consolidated financial statements. The Company continues to monitor the Base Erosion and Profit Shifting (BEPS) Integrated Framework provided by the Organization for Economic Co-operation and Development (OECD) including the legislative adoption of Pillar I and II by countries, and all other tax regulatory changes, to evaluate the potential impact on future periods. The adoption of Pillar Two rules did not have a significant impact on the Company's consolidated financial statements in 2025.

13.	COMMITMENTS AND CONTINGENCIES

Contingencies

The Company is subject to various legal proceedings and claims that have arisen in the ordinary course of business and that have not been fully resolved. The outcome of litigation is inherently uncertain. In the opinion of management, and except as set forth below, there was not at least a reasonable possibility the Company may have incurred a material loss, or a material loss greater than a recorded accrual, concerning loss contingencies for asserted legal and other claims.

Litigation and other legal matters are inherently unpredictable and subject to substantial uncertainties and adverse resolutions could occur. In addition, litigation and other legal matters, including class-action lawsuits, government investigations and regulatory proceedings can be costly to defend and, depending on the class size and claims, could be costly to settle. The Company believes that its defenses and assertions in pending legal proceedings have merit and the Company believes that it has adequately and appropriately accrued for legal matters that are estimable. However, substantial unanticipated judgments, penalties, sanctions, and fines do occur. As a result, the Company could from time to time incur judgments, enter into settlements, or revise its expectations regarding the outcome of certain matters, and such developments could have a material adverse effect on its results of operations in the period in which the amounts are accrued and/or its cash flows in the period in which the amounts are paid.

Antitrust Litigation

The Company and its affiliated brokerage entities were among several defendants in eight U.S. and one Canadian putative class action lawsuits alleging that the Company participated in a system that resulted in sellers of residential property paying inflated buyer broker commissions in violation of U.S. federal and state antitrust laws and federal Canadian antitrust laws, as applicable, and one U.S. putative class action lawsuit alleging that the Company participated in a system that resulted in buyers of residential property paying inflated home prices as a result of sellers paying inflated buyer broker commissions in violation of federal and Illinois antitrust laws (collectively, the “antitrust litigation”). On December 9, 2024, the Company and certain of its subsidiaries entered into a Settlement Agreement (the “Settlement”) with plaintiffs in the U.S. antitrust lawsuit 1925 Hooper LLC, et al. v. The National Association of Realtors et al., Case No. 1:23-cv-05392- SEG (United States District Court for the Northern District of Georgia, Atlanta Division), which was filed on November 22, 2023 against the Company and other U.S. brokerage defendants (the “Hooper Action”). The Settlement resolves all claims set forth in the Hooper Action and similar claims on a nationwide basis against the Company (collectively, the “Claims”) and releases the Company, its subsidiaries and affiliates, and their independent contractor real estate agents in the U.S. from the Claims. By the terms of the Settlement, the Company agreed to make certain changes to

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its business practices and to pay a total settlement amount of $34.0 million (not in thousands) (the “Settlement Amount”) into a qualified settlement escrow fund (the “Settlement Fund”). The Settlement Amount is expected to be deposited into the Settlement Fund in installments, of which 50% of the settlement (or $17.0 million (not in thousands)) is to be deposited into the Settlement Fund within 30 business days after preliminary court approval of the Settlement and the final 50% (or $17.0 million (not in thousands)) is to be deposited on or before the one-year anniversary of the initial settlement payment. On May 23, 2025, the United States District Court for the Northern District of Georgia granted preliminary approval of the Settlement. In accordance with the Settlement terms, the Company funded the first $17.0 million (not in thousands) installment into the Settlement Fund during the fiscal quarter ended June 30, 2025. The Company intends to use available cash to pay the remaining Settlement Amount. While management has determined that loss in excess of the Settlement Amount is reasonably possible, it is currently unable to reasonably estimate the possible additional loss or range of possible additional loss because, among other reasons, (i) the settlement is subject to court approval and appeals processes, (ii) further developments in the legal proceedings, including but not limited to motions or rulings, could impact the Company’s exposure; and/or (iii) potential changes in law or precedent could affect the final determination of liability.

The Settlement remains subject to final court approval and will become effective following any appeals process, if applicable. The Settlement and any actions taken to carry out the Settlement are not an admission or concession of liability, or of the validity of any claim, defense, or point of fact or law on the part of any party. The Company continues to deny the material allegations of the complaints in the antitrust litigation. The Company entered into the Settlement after considering the risks and costs of continuing the litigation.

The Company continues to vigorously defend against the claims in the Canadian putative class action antitrust lawsuit Kevin McFall v. Canadian Real Estate Association, et al., Case No. T-119-24-ID 1 (Federal Court of Canada), filed on January 18, 2024. Management is currently unable to reasonably estimate the possible loss or range of possible loss for the Canadian antitrust litigation because, among other reasons, (i) the proceeding is in preliminary stages, (ii) specific damage amounts have not been sought, (iii) damages sought are, in our opinion, unsupported and/or exaggerated, (iv) there are significant factual issues to be resolved; and/or (v) there are novel legal issues or unsettled legal theories presented. For the Canadian antitrust litigation, we have not recorded any accruals as of December 31, 2025. While the Company does not expect such litigation to have a material adverse effect on our business, results of operations, cash flows or financial condition, due to the complexities inherent in such litigation, including the uncertainty of legal processes and potential developments in the cases, the ultimate liability may differ from current expectations.

Derivative Litigation

Certain current and former directors and officers of the Company were named as defendants, and the Company was named as a nominal defendant, in a derivative lawsuit in the Court of Chancery of the State of Delaware, first filed on September 25, 2024, entitled Los Angeles City Employees’ Retirement System, on behalf of eXp World Holdings, Inc. v. Glenn Sanford, et al. (C.A. No. 2024-0998-KSJM). The lawsuit alleges that certain current and former directors and officers breached fiduciary duties related to the Company’s response to reports of alleged sexual misconduct involving independent contractor real estate agents affiliated with the Company’s subsidiaries and that certain defendants had improper compensation arrangements allowing them to profit from the Company’s revenue share program in connection therewith. The complaint seeks a court declaration of fiduciary duty breaches, disgorgement of profits, damages with interest, injunctive relief for improved oversight of sexual misconduct allegations, and reimbursement of plaintiffs’ costs, including expert and attorney fees. Although the Company does not anticipate that the outcome of such litigation will have a material adverse effect on its business, results of operations, cash flows, or financial condition, the inherent complexities and uncertainties of legal proceedings may result in a liability that differs from current expectations. Management is currently unable to reasonably estimate the possible loss or range of possible loss for this matter because, among other reasons, (i) the proceeding is progressing through preliminary stages, (ii) specific damage amounts have not been sought, (iii) there are significant factual issues to be resolved; and/or (iv) there are novel legal issues or unsettled legal theories presented.

Capital Maintenance Agreements

An indirect subsidiary and unconsolidated joint venture of the Company, SUCCESS^® Lending, is a party to Mortgage Warehouse Agreements and related ancillary agreements (the “Credit Agreements”) with JPMorgan Chase Bank and Texas Capital Bank, which each provide SUCCESS^® Lending with a revolving warehouse credit line of up to $25 million. It is customary for mortgage businesses like SUCCESS^® Lending to obtain warehouse credit lines in order to enable them to close and fund residential mortgage loans for subsequent sale to investors. SUCCESS^® Lending will use the borrowing capacity under the Credit Agreements exclusively for such purposes and borrowings will generally be repaid with the proceeds received from the sale of mortgage loans.

In connection with the Credit Agreements, the Company has entered into Capital Maintenance Agreements with each of JPMorgan Chase Bank and Texas Capital Bank whereby the Company agrees to provide certain funds necessary to ensure that SUCCESS^®Lending is at all times in compliance with its financial covenants under the Credit Agreements. The Company’s capital commitment

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liability under the Capital Maintenance Agreement with JPMorgan Chase Bank is limited to $2.0 million. The Company’s capital commitment liability under the Capital Maintenance Agreement with Texas Capital Bank is limited to $1.25 million. The Credit Agreements represent off-balance sheet arrangements for the Company.

14.	DEFINED CONTRIBUTION SAVINGS PLAN

The Company offers a defined contribution savings plan to provide eligible employees with a retirement benefit that permits eligible employees the opportunity to actively participate in the process of building a personal retirement fund. The Company sponsors the defined contribution savings plan. The Company matches a portion of contributions made by participating employees. For the years ended December 31, 2025, 2024 and 2023, the Company's costs for contributions to this plan were $4,536, $4,569, and $4,763, respectively.

15.	SUBSEQUENT EVENTS

Quarterly Cash Dividend

On February 10, 2026, the Board approved a cash dividend of $0.05 per common share expected to be paid on March 27, 2026 to stockholders of record on March 9, 2026.The ex-dividend date is expected to be on or around March 6, 2026. The dividend will be paid in cash.

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Item 9.

CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE

None.

Item 9A.

CONTROLS AND PROCEDURES

Evaluation of Disclosure Controls and Procedures

The Company’s management, with the participation of the Company’s Chief Executive Officer and Principal Financial Officer, has evaluated the effectiveness of the Company’s disclosure controls and procedures pursuant to Rule 13a-15 under the Exchange Act as of December 31, 2025. The term “disclosure controls and procedures” means controls and other procedures of a company that are designed to ensure that information required to be disclosed by a company in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the SEC’s rules and forms. Disclosure controls and procedures include, without limitation, controls and procedures designed to ensure that information required to be disclosed by a company in the reports that it files or submits under the Exchange Act is accumulated and communicated to the Company’s management, including its principal executive and principal financial officers, as appropriate to allow timely decisions regarding required disclosure.

Based on the evaluation, the Company’s management has concluded that the Company’s disclosure controls and procedures are effective as of December 31, 2025 to provide reasonable assurance regarding the reliability of the Company’s financial reporting and the preparation of its financial statements for external reporting purposes in accordance with U.S. generally accepted accounting principles.

Management’s Annual Report on Internal Control Over Financial Reporting

The Company’s management is responsible for establishing and maintaining adequate internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act). The Company’s management, including its Chief Executive Officer and Principal Financial Officer, conducted an evaluation of the effectiveness of the Company’s internal control over financial reporting as of December 31, 2025. In making its evaluation, management used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control – Integrated Framework (2013). Based on this evaluation, management concluded that the Company’s internal control over financial reporting was effective as of December 31, 2025. Deloitte and Touche LLP, the Company’s independent registered public accounting firm, has issued an attestation report on the effectiveness of its internal control over financial reporting, which is included below.

Changes in Internal Control Over Financial Reporting

There were no material changes in the Company’s internal control over financial reporting that occurred during the year ended December 31, 2025 that have materially affected, or are reasonably believed to be likely to materially affect, the Company’s internal control over financial reporting.

Inherent Limitations on Effectiveness of Controls

The Company’s management, including the Principal Executive Officer, the Principal Financial Officer and the Principal Accounting Officer, does not expect that the Company’s disclosure controls and procedures or its internal control over financial reporting will prevent or detect all errors and fraud. A control system, no matter how well designed and operated, can provide only reasonable, not absolute, assurance that the control system’s objectives will be met. The design of a control system must reflect the fact that there are resource constraints, and the benefits of controls must be considered relative to their costs. Further, because of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that misstatements due to error or fraud will not occur or that all control issues and instances of fraud, if any, within the Company have been detected. These inherent limitations include the realities that judgments in decision-making can be faulty and that breakdowns can occur because of simple error or mistake. Controls can also be circumvented by the individual acts of some persons, by collusion of two or more people, or by management override of the controls. The design of any system of controls is based in part on certain assumptions about the likelihood of future events and there can be no assurance that any design will succeed in achieving its stated goals under all potential future conditions. Projections of any evaluation of controls effectiveness to future periods are subject to risks. Over time, controls may become inadequate because of changes in conditions or deterioration in the degree of compliance with policies or procedures.

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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the stockholders and the Board of Directors of eXp World Holdings, Inc.

Opinion on Internal Control over Financial Reporting

We have audited the internal control over financial reporting of eXp World Holdings, Inc. and subsidiaries (the “Company”) as of December 31, 2025, based on criteria established in Internal Control — Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). In our opinion, the Company maintained, in all material respects, effective internal control over financial reporting as of December 31, 2025, based on criteria established in Internal Control — Integrated Framework (2013) issued by COSO.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the consolidated financial statements as of and for the year ended December 31, 2025, of the Company and our report dated February 24, 2026, expressed an unqualified opinion on those financial statements.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over financial reporting, included in the accompanying Management’s Annual Report on Internal Control Over Financial Reporting. Our responsibility is to express an opinion on the Company's internal control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company's assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

/s/ Deloitte & Touche LLP

San Francisco, California

February 24, 2026

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Item 9B.

OTHER INFORMATION

Insider Trading Arrangements

During the quarter ended December 31, 2025, no directors or officers (as defined in Rule 16a-1(f) of the Exchange Act) adopted or terminated a Rule 10b5-1 trading arrangement or non-Rule 10b5-1 trading arrangement, as each term is defined in Item 408 of Regulation S-K.

Item 9C.

DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS

Not applicable.

PART III

Item 10.

DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

The Company has an insider trading policy governing the purchase, sale and other dispositions of the Company’s securities that applies to all Company personnel, including directors, officers, employees, agents, brokers, and other covered persons. The Company also follows procedures for the repurchase of its securities. The Company believes that its insider trading policy and repurchase procedures are reasonably designed to promote compliance with insider trading laws, rules and regulations, and listing standards applicable to the Company. A copy of the Company’s insider trading policy is filed as Exhibit 19.1 to this Annual Report.

The other information required by this Item will be included in the Company’s definitive proxy statement to be filed with the SEC within 120 days after December 31, 2025, in connection with the solicitation of proxies for the Company’s 2026 annual meeting of stockholders (the “2026 Proxy Statement”) and is incorporated herein by reference.

Item 11.

EXECUTIVE COMPENSATION

The information required by this Item will be included in the 2026 Proxy Statement and is incorporated herein by reference.

Item 12.

SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS

The information required by this Item will be included in the 2026 Proxy Statement and is incorporated herein by reference.

Item 13.

CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

The information required by this Item will be included in the 2026 Proxy Statement and is incorporated herein by reference.

Item 14.

PRINCIPAL ACCOUNTANT FEES AND SERVICES

The information required by this Item will be included in the 2026 Proxy Statement and is incorporated herein by reference.

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PART IV

Item 15.

EXHIBITS AND FINANCIAL STATEMENT SCHEDULES

(a)(1) Financial Statements. See Consolidated Financial Statements in Part II, Item 8 of this Annual Report.

(a)(2) Financial Statements Schedule. All other schedules have been omitted because they are inapplicable, not required or because the information is presented in the Consolidated Financial Statements or notes thereto.

(a)(3) Exhibits. The exhibits listed in the Exhibit Index immediately below are filed as part of this Annual Report or are incorporated herein by reference.

EXHIBITS

		Incorporated by Reference
Exhibit Number	Exhibit Description	Form	Exhibit	Filing Date
3.1	Restated Certificate of Incorporation, effective February 21, 2023	10-K	3.1	2/28/2023
3.2	Restated Bylaws, effective January 13, 2022	10-K	3.2	2/28/2023
4.1	Description of Securities	10-K	4.1	2/20/2025
10.13*	U.S. Form of eXp Realty, LLC Independent Contractor Agreement	NA	NA	NA
10.14*	U.S. Form of eXp Realty, LLC Policies & Procedures	NA	NA	NA
10.15*	U.S. Form of 2024 Agent Equity Program Participation Election Form	NA	NA	NA
10.16†	Offer Letter, dated as of March 12, 2019, by and between eXp Realty, LLC and James (Jim) Bramble	10-K	10.15	2/20/2025
10.17†	Offer Letter, dated as of May 21, 2022, by and between eXp Realty, LLC and Leonardo (Leo) Pareja	10-K	10.17	2/20/2025
10.18†	Description of Compensation Terms with Chief Financial Officer, effective as of June 30, 2025, by and between eXp World Holdings, Inc. and Jesse Hill	10-Q	10.1	7/31/2025
10.19†	Offer Letter, dated as of March 6, 2020, by and between eXp Realty, LLC and Jian (Kent) Cheng	10-K	10.16	2/20/2025
10.20†	Offer Letter amendment, by and between Kent Cheng and eXp World Holdings, dated as of March 5, 2025	8-K	10.1	3/7/2025
10.21†	U.S. Form of Notice of Restricted Stock Unit Grant (2015 Equity Incentive Plan)	10-Q	10.10	5/6/2025
10.22†	2024 Equity Incentive Plan of eXp World Holdings, Inc.	DEF14C	NA	3/10/2025
10.23†	U.S. Form of Notice of Stock Option Grant (2024 Equity Incentive Plan)	10-Q	10.12	5/6/2025
10.24†	U.S. Form of Notice of Restricted Stock Unit Grant (2024 Equity Incentive Plan)	10-Q	10.13	5/6/2025
10.25	Settlement Agreement, dated December 9, 2024, by and among eXp World Holdings, Inc. and its subsidiaries, eXp Realty, LLC, eXp Realty of California, Inc., eXp Realty of Southern California, Inc., eXp Realty of Greater Los Angeles, Inc., and eXp Realty of Northern California, Inc. and Plaintiffs 1925 Hooper LLC, Robert J. Arko and Andrew M. Moore	8-K	10.1	1/8/2025
14.1*	Code of Business Conduct and Ethics	NA	NA	NA
19.1	Insider Trading Policy	10-K	19.1	2/20/2025
21.1*	Subsidiaries of the Registrant	NA	NA	NA
23.1*	Consent of Deloitte & Touche LLP, Independent Registered Public Accounting Firm	NA	NA	NA
24.1*	Power of Attorney (included on signature page hereto)	NA	NA	NA
31.1*	Certification of the Chief Executive pursuant to Rule 13a‑14(a) under the Securities Exchange Act of 1934, as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002	NA	NA	NA

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		Incorporated by Reference
Exhibit Number	Exhibit Description	Form	Exhibit	Filing Date
31.2*	Certification of the Chief Financial Officer (Principal Financial Officer) pursuant to Rule 13a‑14(a) under the Securities Exchange Act of 1934, as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002	NA	NA	NA
32.1**	Certification of the Chief Executive Officer pursuant to 18 U.S.C. 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002	NA	NA	NA
32.2**	Certification of the Chief Financial Officer (Principal Financial Officer) pursuant to 18 U.S.C. 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002	NA	NA	NA
97	Policy Relating to Recovery of Erroneously Awarded Compensation	10-K	97	2/22/2024
101.INS*	Inline XBRL Instance Document	NA	NA	NA
101.SCH*	Inline XBRL Taxonomy Extension Schema Document	NA	NA	NA
101.CAL*	Inline XBRL Taxonomy Extension Calculation Linkbase Document	NA	NA	NA
101.DEF*	Inline XBRL Taxonomy Extension Definition Linkbase Document	NA	NA	NA
101.LAB*	Inline XBRL Taxonomy Extension Label Linkbase Document	NA	NA	NA
101.PRE*	Inline XBRL Taxonomy Extension Presentation Linkbase Document	NA	NA	NA
104*	Cover Page Interactive Data File (embedded within the inline XBRL document)	NA	NA	NA

*Filed herewith

**Furnished herewith and not “filed” for purposes of Section 18 of the Securities Exchange Act of 1934, as amended.

† Management contract or compensatory plan or arrangement

Item 16.

Form 10-K Summary

None.

Table of Contents

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

	eXp World Holdings, Inc.
	(Registrant)

Date: February 24, 2026	/s/ Glenn Sanford
	Glenn Sanford
	Chief Executive Officer (Principal Executive Officer)


Date: February 24, 2026	/s/ Jesse Hill
	Jesse Hill
	Chief Financial Officer (Principal Financial Officer)

POWER OF ATTORNEY

KNOW ALL PERSONS BY THESE PRESENTS, that each person whose signature appears below constitutes and appoints each of Glenn Sanford and Jesse Hill, severally, his or her attorneys-in-fact, each with the power of substitution, for him or her in any and all capacities, to sign any amendments to this Annual Report on Form 10-K, and to file the same, with exhibits thereto and other documents in connection therewith, with the Securities and Exchange Commission, hereby ratifying and confirming all that each of said attorneys-in-fact, or his substitute or substitutes, may do or cause to be done by virtue hereof.

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

Name		Title		Date

/s/ GLENN SANFORD		Chief Executive Officer and Chairman of the Board		February 24, 2026
Glenn Sanford		(Principal Executive Officer)

/s/ JESSE HILL		Chief Financial Officer		February 24, 2026
Jesse Hill		(Principal Financial Officer)

/s/ JAMES BRAMBLE		Chief Legal Counsel and Corporate Secretary		February 24, 2026
James Bramble

/s/ RANDALL MILES		Director		February 24, 2026
Randall Miles

/s/ DAN CAHIR		Director		February 24, 2026
Dan Cahir

/s/ MONICA WEAKLEY		Director		February 24, 2026
Monica Weakley

/s/ PEGGIE PELOSI		Director		February 24, 2026
Peggie Pelosi

/s/ FRED REICHHELD		Director		February 24, 2026
Fred Reichheld

Exhibit 10.14

eXp Realty (USA) Policies and Procedures Page 1 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES eXp Realty (hereafter, “eXp,” “we,” “our,” and such analogous terminology) reserves the right to make updates to the policies and procedures set forth within these eXp Realty (USA) Policies and Procedures (“eXp P&Ps” or “eXp’s P&Ps”). When and if updates are made, they will be communicated through Slack, eXp News weekly newsletter, and/or the weekly company meeting. By signing an Independent Contractor Agreement (“ICA”) with eXp, each independent contractor real estate licensee with eXp (singularly an “Agent”; and collectively, “Agents”) is agreeing to adhere to and abide by these eXp P&Ps, with such eXp P&Ps being incorporated by reference into Agent’s ICA verbatim and at length, and constituting a part of Agent’s ICA as though fully set forth therein. A glossary of terms defined in these eXp P&Ps is located at the back of these eXp P&Ps; defined terms that are used but not otherwise defined in these eXp P&Ps shall be as defined in the ICA. TABLE OF CONTENTS: I. CORE VALUES...................................................................................................................................... 6 II. POLICY................................................................................................................................................. 6 III. PROCEDURES ...................................................................................................................................... 7 IV. STATE POLICIES AND PROCEDURES ................................................................................................ 7 V. CODE OF CONDUCT ............................................................................................................................ 7 VI. DUTIES AS AN AGENT ........................................................................................................................ 8 A. Fiduciary .......................................................................................................................................... 8 B. Cooperation and Compensation .................................................................................................... 9 C. Good Standing................................................................................................................................. 9 D. Agreements, Compliance Forms, Insurance Forms.................................................................... 10 E. License Renewal and State Department of Licensing Rules ...................................................... 10 F. Non-Disclosure Of Trade Secrets................................................................................................. 10 G. Real Estate Transactions.............................................................................................................. 10 H.Transaction Files........................................................................................................................... 11 1. Forms ........................................................................................................................................ 11 2. Executed Real Estate Documents............................................................................................ 11 3. Earnest Money .......................................................................................................................... 12 4. Late or Incomplete Paperwork Submissions .......................................................................... 12 I. Agent-Owned Real Properties........................................................................................................ 13 1. Generally.................................................................................................................................... 13 2. Personal Transactions ............................................................................................................. 14 J. Commercial Property.................................................................................................................... 15 K. Unauthorized Activities................................................................................................................. 15 1. Generally.................................................................................................................................... 15 2. Competitor Affiliation is Prohibited ......................................................................................... 17 3. Limited Representation is Prohibited ...................................................................................... 18 VII. ANCILLARY AND AFFILIATED SERVICES ........................................................................................ 18 A. Property Preservation Services.................................................................................................... 18 B. Mortgage Loan Origination........................................................................................................... 19 1. Generally.................................................................................................................................... 19 2. Dual Capacity ............................................................................................................................ 19

eXp Realty (USA) Policies and Procedures Page 2 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 3. Familial Relationship - Conditionally Acceptable.................................................................... 19 C. Title And Escrow Companies ....................................................................................................... 19 D. Home Warranty Companies ......................................................................................................... 21 1. Free to Contract with Home Warranty Company .................................................................... 21 2. No Review of Contract.............................................................................................................. 21 3. No Referral Fees ....................................................................................................................... 21 4. Free to Receive Payment for Compensable Services............................................................. 22 5. No Amendment to ABA Disclosure Form................................................................................ 22 VIII. AGENT FEES...................................................................................................................................... 22 A. Standard Fees ............................................................................................................................... 22 B. Minimum Company Dollar Rule.................................................................................................... 24 1. Exemptions from the Minimum Company Dollar Rule:........................................................... 25 C. Late Fees ....................................................................................................................................... 25 D. eXp Right to Payment ................................................................................................................... 26 E. Agent Fees Non-Refundable......................................................................................................... 26 IX. ACCOUNTING AND COMPENSATION.............................................................................................. 26 A. I.R.S. Form 1099............................................................................................................................ 26 B. Compensation; Other Fees From Clients..................................................................................... 27 C. Compensation Advances.............................................................................................................. 28 D. Actions for Unpaid Compensation or Procuring Cause Claims ................................................. 29 E. Referral Payments and Relocation Companies........................................................................... 29 F. Perceived Compensation Discrepancies..................................................................................... 29 X. MARKETING AND ADVERTISING ..................................................................................................... 30 A. Compliance with Laws, Guidelines, and Regulations.................................................................. 30 B. eXp Brand Guidelines.................................................................................................................... 31 C. Intellectual Property Rights .......................................................................................................... 31 1. Permission to Use eXp Trademarks ........................................................................................ 32 2. eXp Trademark Usage .............................................................................................................. 32 3. Unlicensed Content and Trademarks ...................................................................................... 33 D. Review and Approval .................................................................................................................... 33 E. Review and Approval Process...................................................................................................... 33 F. Property-Related Advertising........................................................................................................ 33 G. MLS Advertising ............................................................................................................................ 34 H.General Advertising....................................................................................................................... 34 1. In Any Medium .......................................................................................................................... 34 2. Business Cards ......................................................................................................................... 34 3. Social Media.............................................................................................................................. 35 4. Websites.................................................................................................................................... 36 I. Promotional Discount Advertisements ......................................................................................... 36 J. Co-Marketing and Co-Listing Arrangements ............................................................................... 37 K. Employment Ads and Job Postings............................................................................................. 37 L. Media Relations ............................................................................................................................ 38 M. ........................................................................... Content License And Model Release Provided By An Agent ....................................................................................................................................................... 38 XI. REALTOR® ASSOCIATION AND MULTIPLE LISTING SERVICE BOARDS OF DIRECTORS.............. 39 A. Associations of REALTORS® ........................................................................................................ 39

eXp Realty (USA) Policies and Procedures Page 3 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES B. Multiple Listing Services............................................................................................................... 39 XII. EXP’S REVENUE SHARE PLAN ......................................................................................................... 40 A. Overview ........................................................................................................................................ 40 B. Revenue Share Explained ............................................................................................................. 41 C. Qualifications To Receive Revenue Share ................................................................................... 41 D. Manipulating Revenue Share Plan Prohibited ............................................................................. 42 E. Revenue Share Vesting Policy...................................................................................................... 42 1. Achieving Vested Status .......................................................................................................... 42 2. Maintaining Vested Status ....................................................................................................... 42 3. Losing Vested Status................................................................................................................ 43 4. Discretionary Regaining of Vested Status upon Reaffiliation ................................................ 43 F. Agent Succession Policy .............................................................................................................. 43 G. Modifications to the Revenue Share Plan.................................................................................... 45 XIII. AGENT ATTRACTION........................................................................................................................ 46 A. Sponsorship Interference Prohibited ........................................................................................... 46 B. Income and Lifestyle Claims ........................................................................................................ 46 C. Recruiting....................................................................................................................................... 47 D. Sponsorship .................................................................................................................................. 48 1. Definition and Responsibilities................................................................................................. 48 2. Change Requests...................................................................................................................... 49 3. Co-Sponsor................................................................................................................................ 50 E. Agent Prospects, Contacts, and Leads........................................................................................ 50 F. Attraction Marketing and Communication .................................................................................. 51 G. Reporting Agent Attraction Violations ......................................................................................... 52 H.Stock Solicitations Prohibited ...................................................................................................... 52 I. Event Sponsorship Requests from Vendors ................................................................................. 53 XIV. COMPANY TOOLS AND INFORMATION .......................................................................................... 53 A. eXp Communication and Training Platforms.............................................................................. 53 B. Slack .............................................................................................................................................. 54 1. Agent Conduct Guidelines........................................................................................................ 54 2. Channel and Creation Guidelines............................................................................................. 54 3. Reporting & Oversight............................................................................................................... 55 C. eXp World ...................................................................................................................................... 55 D. eXp Email for Agents .................................................................................................................... 55 XV. ICON AGENT AWARD........................................................................................................................ 56 XVI. EXP MENTOR PROGRAM.................................................................................................................. 56 XVII. EXPRESSOFFERS INVESTOR REFERRAL FEE.................................................................................. 56 XVIII.MULTI-GLOBAL LICENSE PROGRAM .............................................................................................. 56 A. Background ................................................................................................................................... 56 B. Multi-Country Affiliation (Generally)............................................................................................. 57 C. Agents’ Additional Affiliation........................................................................................................ 57 D. Agents’ Independent Obligations ................................................................................................. 57 E. “Capped Status” Matters .............................................................................................................. 57 F. ICON Agent Awards ...................................................................................................................... 58 G. Sponsor; FLQA; Initial FLQA Period.............................................................................................. 58 XIX. LEGAL, INSURANCE, and COMPLIANCE WITH THE LAW............................................................... 58

eXp Realty (USA) Policies and Procedures Page 4 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES A. Antitrust......................................................................................................................................... 58 B. Conflicts of Interest ...................................................................................................................... 59 C. Data Security and Client Privacy .................................................................................................. 59 D. Do Not Call Rules .......................................................................................................................... 59 E. Drones............................................................................................................................................ 60 F. Drug and Alcohol Use ................................................................................................................... 60 G. Harassment................................................................................................................................... 60 H.Prohibition on Changes to Compensation Splits and Referral Fees During Legal Action; No Split Checks................................................................................................................................... 61 I. Products and Services ................................................................................................................... 61 1. Selling, Offering To Sell, Or Promoting Any Competing Products Or Services...................... 61 J. Reporting Problems ...................................................................................................................... 61 K. Legal Action Between eXp Agents............................................................................................... 62 L. Legal Action Against eXp Prohibited ........................................................................................... 63 M.Claims Reimbursement ................................................................................................................ 63 N.Claims That Are Not Covered By Real Estate E&O Insurance .................................................... 63 XX. OFFICE POLICIES .............................................................................................................................. 64 A. Agent Business Expenses ............................................................................................................ 64 B. Agent Assistants - Generally ........................................................................................................ 65 C. Agent Assistants - Unlicensed ..................................................................................................... 65 D. Agent Assistants - Licensed......................................................................................................... 66 E. Administrative Transaction Fees ................................................................................................. 66 F. Associations and Board Memberships........................................................................................ 67 G. Contact Information...................................................................................................................... 67 H.Contacting the State Broker(s)..................................................................................................... 68 I. Open Houses ................................................................................................................................. 68 J. Out of Town or Unavailable .......................................................................................................... 68 K. Physical Office Space ................................................................................................................... 68 L. Data Privacy & Artificial Intelligence (AI) Use Policy................................................................... 69 1. Purpose. ........................................................................................................................................ 69 2. Definitions. .................................................................................................................................... 69 3. Agent Responsibilities. ................................................................................................................. 69 4. Permissible Use of AI with Client and Customer Data................................................................ 70 5. Prohibited AI Use Involving Client and Customer Data............................................................... 70 6. Approved Company Tools & Security Practices.......................................................................... 71 7. AI & Disclosure Requirements...................................................................................................... 71 8. Broker Oversight & Enforcement.................................................................................................. 71 XXI. TEAMS AT EXP REALTY ................................................................................................................... 71 A. Generally........................................................................................................................................ 71 B. Team Names................................................................................................................................. 71 C. Team Composition ....................................................................................................................... 72 D. Team Agreements ........................................................................................................................ 72 E. Team Disputes .............................................................................................................................. 72 F. Team Fee Distribution................................................................................................................... 73 G. Non-Solicitation of Other eXp Team Members ........................................................................... 73 H.Application of Non-Solicitation and Non-Disparagement Policy To Teams.............................. 73

eXp Realty (USA) Policies and Procedures Page 5 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES XXII. OMISSIONS FROM POLICY AND PROCEDURES.............................................................................. 73 XXIII.UPON TERMINATION OF ICA........................................................................................................... 73 A. eXp’s Transfer of Pending Transactions ..................................................................................... 74 B. eXp’s Retention of Pending Transactions ................................................................................... 74 C. Leads Upon Departure .................................................................................................................. 75 D. Rejoining eXp................................................................................................................................. 75 XXIV.EXP’S COMPLIANCE COMMITTEE .................................................................................................. 76 A. Appeal of Determination made by eXp’s Compliance Committee............................................. 76 XXV. INTERPRETATION............................................................................................................................ 77 XXVI. CONFLICTS ..................................................................................................................................... 77 XXVII. REVISIONS TO THESE EXP P&PS ................................................................................................. 77 XXVIII. GLOSSARY OF DEFINED TERMS................................................................................................... 77 XXIX. INSIDER TRADING POLICY OF EXP WORLD HOLDINGS, INC....................................................... 85 [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

eXp Realty (USA) Policies and Procedures Page 6 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES I. CORE VALUES At eXp, our core values are more than just motivational posters on virtual walls; they support our vision and shape our culture. Our global community is powered by agents, partners, and staff who work collaboratively to transform the real estate experience. These eXp P&Ps, our Code of Conduct, and the way we carry out our daily operations, including the enforcement of these policies, are based on these nine core values. II.POLICY It is the policy of eXp to participate in a real estate activity only when it is legal, honest, fair and beneficial to us and others. In pursuit of compensation for ourselves, we will never ignore the benefit of our community. Therefore, we will conduct our business in a manner to follow all the laws and rules of our profession. We pledge to exercise the highest standard of ethics, honesty, fairness and professionalism in all our real estate activities. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

eXp Realty (USA) Policies and Procedures Page 7 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES III. PROCEDURES Every Agent is expected to adhere to and abide by these eXp P&Ps. Failure to adhere to the eXp P&Ps could result in legal and regulatory liability for the Agent and eXp. Therefore, the Agent agrees that if they depart from the eXp P&Ps, they will defend, indemnify and hold eXp, and its principals and affiliates harmless against any and all claims, complaints or actions that may arise from such a departure. In addition, failure to comply with this Policy is grounds for the immediate release of an Agent’s license and removal from eXp. These eXp P&Ps provide detailed guidelines for eXp’s brokerage policies and procedures; however, there may be some circumstances or issues that are not addressed. In those instances, decisions and actions taken will reflect our core values. As provided above, these eXp P&Ps are incorporated into the ICA that each Agent entered into as part of the process of associating with eXp. Failure to comply with these eXp P&Ps may be grounds for immediate termination and dismissal from eXp. Additionally, an Agent’s right to be compensated for their work, activities on behalf of eXp, revenue share and stock may be adversely affected by any failure on Agent’s part to carry out, adhere to, and otherwise support and fulfill the provisions of these eXp P&Ps. IV. STATE POLICIES AND PROCEDURES These eXp P&Ps are designed to address nationwide brokerage policies and procedures applicable to all Agents in all states in which eXp does business. It is impractical to address the peculiarities of state and local requirements in the body of these eXp P&Ps, particularly the responsibilities of Agents to principals and the public. While it is each Agent’s obligation to be fully familiar with and fully comply with state and local law pertaining to the provision of real estate brokerage services, eXp offers additional state policies and procedures where necessary, to address many, but not all, state and local requirements. Any State P&Ps, if applicable, will be a critical part of these eXp P&Ps and, to the extent it is inconsistent with these eXp P&Ps, the applicable State P&Ps supersedes these eXp P&Ps. V. CODE OF CONDUCT All Agents shall conduct their business in alignment with eXp’s core values, the National Association of REALTORS® Code of Ethics, and in accordance with applicable federal and state laws. Agents should conduct themselves in an appropriate business-like manner in all activities and relations with fellow Agents, clients, potential customers and eXp staff. All Agents shall strive at all times to perform in a manner that will increase the goodwill, reputation and business of eXp, and Agents shall do nothing which would serve to disturb, discredit or devalue eXp or eXp’s goodwill, reputation and/or business. Any Agent whose conduct, actions or performance violates or conflicts with eXp’s P&Ps, eXp’s core values, or any other eXp policy, may be released from eXp immediately and without warning.

eXp Realty (USA) Policies and Procedures Page 8 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES It is the commitment of eXp to ensure the brokerage is free from negative, aggressive and inappropriate behaviors, and that the environment is aimed at providing an atmosphere upholding our core values. All Agents and employees of eXp have the right to be treated with dignity and respect. All complaints of negative and inappropriate behaviors will be taken seriously and followed through to resolution. Agents or employees of eXp who file complaints will not be victimized for “whistle-blowing” or reporting others for their inappropriate behavior. Agents may file complaints by emailing [email protected]. Agents who are members of the National Association of REALTORS® are required to maintain their mandatory ethics training. Failure to complete the course will result in suspension or termination of Realtor® membership and removal from eXp. Agents are expected to become familiar with and adhere to the National Association of REALTORS® Pathways to Professionalism found on their website at https://www.nar.realtor/code-of-ethics-and-arbitration-manual/pathways-to-professionalism. Agents shall not disparage the conduct, reputation, or character of another Agent, of any eXp employee or member of management, or of eXp itself (including eXp’s products, services, and business model). Agents shall not disparage competing brokerages or their agents. Agents shall not solicit, recruit, employ, induce, or entice (either for themselves or another), directly or indirectly through a third party, any eXp partners, affiliates, salespersons, real estate agents, and/or employees to leave eXp during the Term of an Agent’s ICA, and for a period of two (2) years following termination of an Agent’s ICA. This paragraph shall be referred to as eXp’s Non-Solicitation and Non-Disparagement Policy. Agents shall not take any action that creates, or has the possibility of creating, any civil and/or criminal liability for eXp and/or other eXp Agents. Violations of this Code of Conduct are grounds for immediate termination of Agent’s ICA. VI. DUTIES AS AN AGENT A. Fiduciary 1. The Agent and all licensed assistants shall abide by their fiduciary responsibilities when acting as an Agent for a client. The Agent owes the client the fiduciary duties of obedience, loyalty, disclosure, confidentiality, accounting, reasonable skill and care. Agents shall also deal fairly with all parties to a transaction. 2. The agency relationship with any party with whom an Agent is working on behalf of eXp or an Agent must have their license affiliated with eXp and have established in writing on a form acceptable to the state Designated Managing Broker or applicable Managing Broker(s) (individually, and collectively, hereinafter referred to as “State Broker”) before an offer on a property is written, or a listing is taken. The failure to establish and disclose the type of relationship one has by the time of contract is unacceptable. The contract is to serve only as confirmation of an election made by the buyer/lessee or seller/lessor in a separate written agreement before the contract is written.

eXp Realty (USA) Policies and Procedures Page 9 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES B. Cooperation and Compensation 1. As a matter of policy, eXp does not offer cooperation or compensation to sub-agents. 2. eXp does not share listing compensation with a buyer’s broker. eXp will assist any seller-directed compensation for a buyer’s broker at a seller’s written direction. 3. eXp does not require sellers to offer compensation to a buyer’s broker. If a seller chooses to offer compensation, the compensation offered by a seller to a buyer’s broker is not required to be a, “blanket or unilateral offer of compensation”. The seller may determine when the offer of compensation is made, at time of listing, at time of showing, or negotiated in the purchase contract. 4. An Agent exclusively representing a buyer shall not, under any circumstances, contact a seller directly without first obtaining the express consent by the listing broker and State Broker. The exception to this policy being for sale by owner properties. 5. eXp Agents representing a buyer in a Transaction shall have a Buyer-Broker Agreement. Compensation to buyer’s broker shall be established via this agreement. 6. eXp Agents shall not advertise or otherwise represent their services as being “free” unless they will not receive any compensation from any source for those services. 7. eXp Agents may not filter or restrict listings to a buyer based on the existence or amount of any offer of compensation offered to a buyer’s broker. eXp Agents shall make available properties as requested by a buyer and not refuse to show based on offers of compensation to a buyer’s broker. 8. eXp Agents shall disclose to a buyer any offer of compensation made to a buyer’s broker. C. Good Standing Each Agent has a duty to remain in Good Standing at eXp. To be considered in “Good Standing,” an Agent must: 1. be current on all financial obligations and not have any unpaid fees, charges, repayments, or any other amounts owed by the Agent to eXp; 2. have and maintain an active and current status for: a) all required licenses; b) local, state, and national REALTOR® Association/Board memberships, where applicable; and c) any other subscriptions that are required to conduct real estate business in the Agent’s state(s); and 3. not be deemed in breach of any term, covenant, condition, obligation (including monies owed) or duty set forth in the ICA and these eXp P&Ps, as determined by eXp in its reasonable discretion. eXp reserves the right to withhold earnings from, and assign another Agent to close out, any pending transactions concerning any Agent that is not in Good Standing. In order to remain eligible to collect revenue share under eXp’s Revenue Share Plan, an Agent must be and remain in Good Standing; any failure to remain in Good Standing may result in a loss of pending revenue share earnings. See section titled, “Qualifications to Receive Revenue Share,” for more information.

eXp Realty (USA) Policies and Procedures Page 10 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES D. Agreements, Compliance Forms, Insurance Forms Each Agent will submit all documents necessary for eXp to keep themselves in compliance with all applicable local, state, and federal laws, as well as with eXp’s P&Ps. eXp will share all materials with an Agent that eXp maintains in its records relating to that Agent’s agency and independent contractor relationship with eXp. eXp reserves the right to assess penalties (financial and otherwise) against an Agent, in accordance with each Agent’s ICA and eXp’s P&Ps, if that Agent fails or refuses to provide completed documentation as required by eXp or by any applicable local, state, or federal law, in order to achieve and maintain compliance with such laws. E. License Renewal and State Department of Licensing Rules Agents shall maintain an active real estate license with the applicable state department or agency that is charged with administering the issuance of any real estate licenses in that state (“State Department of Licensing”). It is the Agent’s sole responsibility to fulfill all continuing education requirements and file their renewal promptly and be aware of their licensing status with the State Department of Licensing. eXp may, at its sole option, sever the Agent’s license with eXp if the Agent’s license is not renewed on time. Failure to renew can have severe financial impacts on the Agent. Compensation is subject to forfeiture for any unlicensed real estate activities after expiration/revocation of an Agent’s license. Agents shall adhere to all state and federal licensing rules and regulations. It shall be the Agent’s responsibility to be knowledgeable about the rules set forth by their State Department of Licensing. Should a complaint be filed against an Agent, the Agent must immediately notify eXp via their State Broker for assistance in responding promptly to the complaint and cooperate fully with the State Department of Licensing. F. Non-Disclosure Of Trade Secrets Each Agent recognizes and acknowledges that much of the information that will be furnished to him/her concerning eXp’s clients, customers, listings, holdings, investments, transactions, eXp-generated leads, and other confidential matters constitutes valuable, special, and unique assets and are trade secrets of eXp. Accordingly, Agents shall not, during or after their affiliation with eXp, disclose any such information or any part thereof, to any person, firm, corporation, association, or other entity for any reason or purpose whatsoever without the express written consent of eXp. G. Real Estate Transactions All real estate transactions must be taken in eXp’s name (and not in an Agent’s name or in the name of any other real estate brokerage company), and processed and closed through eXp. This means that any listings (whether sale or rental) must be listed, advertised, processed, and closed through eXp; and any buyer/tenant-representation services must be performed through eXp. Each Agent shall ensure that all fees or other compensation earned by the Agent, and for which the Agent must be an active licensed real estate professional in order to receive such compensation in

eXp Realty (USA) Policies and Procedures Page 11 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES connection with the sale, lease, or rental of real estate, and any interest therein or service in relation thereto, are made payable to eXp. In order to receive compensation, Agents acting on behalf of buyers shall have a written agreement prior to touring a home (e.g., a “touring agreement” or Buyer-Broker Agreement). Where state law is more restrictive, refer to State P&Ps. H. Transaction Files 1. Forms Agents shall use the most current forms provided by eXp Realty or that are customary to the MLS or REALTOR® Board where the Agent is a member. eXp does not condone or endorse the unauthorized use of any copyright-protected forms developed by any MLS or REALTOR® Board. Under no circumstance may Agents use any copyright-protected forms developed by any MLS or REALTOR® Board unless such Agents belong to the MLS or REALTOR® Board that created the copyright-protected forms. Agents, and not eXp, will be solely responsible for all costs and expenses arising from their unauthorized use of any copyright-protected forms. Agents must use any applicable regulatory documents required by federal and state agencies. Agents may not create, use AI to create, and/or use their own transaction forms (e.g., purchase and sale agreements, addenda, etc...), or engagement forms (e.g., listing agreements, buyer representation agreements, etc...) unless the forms intended to be used are first approved, in writing, by both their State Broker and Regional Director. However, nothing in these eXp P&Ps shall prevent Agents from using transaction forms provided by a client and/or a client’s lawyer, provided that such forms are presented to Agent’s State Broker and Regional Director prior to their execution. Many eXp forms will be found within the transaction management system currently used. Agents are aware and understand that all dual agency transactions must contain a fully executed consent for dual/limited representation form, completed prior to purchase/sale contract execution, in order to preserve the right to errors and omissions insurance coverage on the file. Agents are aware that if they fail to obtain such written consent, the file may be excluded from coverage and such Agent shall be responsible for the full amount of the damages, attorneys’ fees, and costs incurred by and/or recovered against eXp. 2. Executed Real Estate Documents The State Broker has a supervisory responsibility by law and must comply with the State Licensing Department’s rules. All purchase and sale agreements, listings, buyer-broker agreements, referrals and any other transactional documents must be uploaded into the transaction management system within two business days of execution to allow time for review and approval by the applicable State Broker team. Please refer to the transaction checklists provided in each state. Transaction files should include all documents related to the transaction and any and all correspondence, notes, email communications, text messages, etc., regardless of whether the Transaction closed or not. Agents are encouraged to make copies of their files. eXp reserves the right to maintain digital files in storage for the statutory period as required by the state licensing

eXp Realty (USA) Policies and Procedures Page 12 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES departments. Unauthorized removal of any file from the transaction management system may lead to termination. Once a customer or client has signed a document, they are entitled to and shall, therefore, receive a copy of the document upon its execution. Agents are required to either provide an electronic copy, via email, or deliver a physical copy of the document(s) to them. Agents shall transact ALL real estate brokerage business through one of the eXp World Holdings, Inc. family of real estate brokerage companies. Transactions that are processed outside of the foregoing may be grounds for immediate termination. 3. Earnest Money Earnest money shall be handled as described in State P&Ps. The Agent will be subject to immediate termination if it has been determined that there has been any improper handling of earnest money. All files must contain an accounting for disbursement of funds including earnest money and final settlement statements. 4. Late or Incomplete Paperwork Submissions Signed documents of any variety, listing files, and files pertaining to completed transactions must each be uploaded within eXp’s transaction management system within the sooner of the following: (a) forty-eight (48) hours after their execution or in the case of a completed transaction, the respective closing date (as applicable), or (b) the maximum time period permitted by the Agent’s applicable state’s real estate licensing laws. Listing files and files pertaining to completed transactions must include all required paperwork pertaining to the listing or transaction, as applicable; missing paperwork is not acceptable. Failure to adhere to these requirements is a violation of eXp policy and may subject the Agent to escalating repercussions, all as determined by the State Broker and/or Brokerage Operations leadership, in their sole discretion. Such repercussions include, without limitation, any of the following or combination thereof: a) Loss of split check (if allowed in the Agent’s state) for stated times; b) If the Agent fails to adhere to these requirements three (3) or more times within a rolling, consecutive 6-month period, the Agent will be required to use an eXp-approved Transaction Coordinator (“TC”) to assist Agent with organizing and uploading the Agent’s next three (3) Agent listing files and/or files pertaining to completed transactions, all at the Agent’s sole cost and expense. Thereafter, the Agent is free to continue or discontinue using the same or different eXp-approved TC, as the Agent determines; if use is continued, such use will be at the Agent’s sole cost and expense. c) Required training on eXp’s transaction management system, and policies and procedures pertaining to state contracts; and d) Offboarding the Agent from eXp. Any fines assessed to the State Broker, or to eXp, pertaining to an Agent’s failure to follow these document and file submission policies shall be reimbursed by that Agent. The costs of

eXp Realty (USA) Policies and Procedures Page 13 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES undertaking any investigation by the State Broker for an Agent’s non-compliance with these document and file submission policies may be passed on to that Agent, all at eXp’s sole discretion. I. Agent-Owned Real Properties 1. Generally One of the great benefits of having a real estate license is the advantage of building personal wealth through the sale and purchase of real estate. However, these transactions place both eXp as well as the Agent-Owner (defined below) at a greater risk of litigation due to the nature of rehabbed and flipped property transactions. In addition, the mere fact that a seller or buyer is a licensed real estate professional and REALTOR® means they are held to a higher standard and subject to higher incidences of legal claims and litigation. Therefore, these policies are intended to protect both the Agent-Owner, eXp, and all of our Agents and shareholders. a) “Agent-Owned” means ownership is held or controlled by an Agent, whether through an Agent’s own name, a spouse’s name, a business entity, a trust, or that is otherwise owned and/or controlled by Agent and/or Agent’s spouse (also referred to as an “Agent-Owner”) b) Unless prior written approval is granted by Brokerage Operations leadership, Agents shall not enter into a contract to sell or flip a property until the Agent holds legal title (as opposed to mere equitable title) to the subject property. c) A single Agent may not represent both sides of a sales transaction if the Agent or a family member of the Agent is a principal or party to the transaction. d) Under NO circumstances can an Agent represent the buyer in a Personal Transaction (as defined below); additionally, an Agent cannot act as an intermediary in a Personal Transaction. e) Agents shall never act as a principal in a transaction without the full written consent of all parties. f) The buyer must sign an agency representation disclosure. g) Both the buyer and Agent shall execute the Disclosure of Personal Interest of eXp Realty Agent Addendum to Residential Purchase Contract with each Agent-Owned property. h) The parties must use standard forms and sales contracts and all forms must be state approved with full and accurate signatures & dates. i) Agent’s name, Agent and/or Agent’s spouse’s business entity or trust name, or Agent’s spouse’s name must be on the title or lease agreement (as applicable) for the Transaction to be considered. j) All seller disclosures must be made regarding any property defects or material information, must be completed on a seller’s disclosure notice, and must have all necessary signatures, dates & initials. k) For all transactions where the property is Agent-Owned, eXp strongly encourages that the Agent-Owner ensures a home inspection is delivered to the buyer. (1) The buyer must have a home inspection done by a licensed property inspector (if licensing is a requirement in the state in which the property is located) or submit a written waiver of such. (2) If buyer waives the right to a property inspection, the buyer must provide written notice of that waiver by completing and signing the Buyer Acknowledgement and Waiver of Inspections.

eXp Realty (USA) Policies and Procedures Page 14 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES (3) A copy of the property inspection, along with all addenda and/or amendments must be included in the file. l) For all transactions where the property is Agent-Owned, the Agent-Owner is strongly encouraged to ensure the property is covered by a standard home warranty from a company of the buyer’s choice. (1) The buyer must be made aware that they may purchase a residential service contract (home warranty) for the property via the Disclosure of Personal Interest of eXp Agent Addendum to Residential Purchase Contract. m) Ownership must be disclosed in all marketing materials, MLS, advertising, and stated in the special provisions, or its equivalent, section of the contract regardless of what percentage of ownership interest in the property is held by the Agent. n) Agents are required to turn in a copy of the full closing disclosure and copies of any/all compensation checks received for the transaction. o) Any work completed on the property that requires a permit or is a major repair (i.e., repairs that are not of a casual nature, or otherwise require permits) shall be done by a licensed, bonded, and insured contractor. In jurisdictions where a contractor license is not required, the individual performing the repair(s) must be an experienced and qualified tradesperson. 2. Personal Transactions A “Personal Transaction” is any Transaction concerning a property that is owned or leased by an Agent (whether in an Agent’s own name, a spouse’s name, a business entity, a trust, or that is otherwise controlled by Agent and/or Agent’s spouse), regardless of whether Agent chooses to represent themselves or have another eXp Agent represent them. Agents may exempt from the Minimum Company Dollar Rule three (3) Personal Transactions per Anniversary Year, whether involving the Agent’s ownership interests or leasehold interests. (Please communicate with your State Broker should you have questions.) Personal Transactions will carry a Personal Transaction Fee (“Personal Transaction Fee”) taken as a charge against the Contractor Dollar, as follows: a) Personal Transactions involving a purchase or sale will carry a $250 Personal Transaction Fee, in addition to the Transaction Review Fee and Risk Management Fee. For Agents who have reached a Capped Status and who are paying a reduced Capped Status Transaction Fee, the Personal Transaction Fee shall be collected at the reduced rate of $75 per Personal Transaction for the remainder of that Agent’s Capping Period. b) Personal Transactions involving a lease will carry a $75 Personal Transaction Fee, and either, (i) no Transaction Review Fee or Risk Management Fee (if the Gross Compensation Income is $1,000 or less), or (ii) a Transaction Review Fee and Risk Management Fee (if the Gross Compensation Income is greater than $1,000). **Personal Transactions involving a lease do not count towards the three (3) exempt Personal Transactions per Anniversary Year.

eXp Realty (USA) Policies and Procedures Page 15 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Personal Transaction compensation is not included in revenue share calculations where no Company Dollar is generated from the completion of the Personal Transactions. When an Agent in the eXp Mentor Program is purchasing a personal property, a Buyer-Broker Agreement is required for the amount of compensation being collected. Minimum compensation must be minimum Company Dollar for a Personal Transaction. For eXp Agents in the eXp Mentor Program, please see the relevant eXp Mentor Program Addendum to Independent Contractor Agreement for rules and fees involved in a Personal Transaction. J. Commercial Property Prior to transacting in or contemplating a commercial transaction, Agents must have authorization from their State Broker. Agents may not act outside their area of expertise. Agents must be aware that eXp’s errors & omissions insurance policy limits are generally not sufficient to conduct many commercial real estate activities. For purposes of these eXp P&Ps, “Residential Property” shall be defined as any real property that is zoned to accommodate a residential dwelling having not less than one (1) and not greater than four (4) dwelling units, whether such real property is vacant land or improved real property; and “Commercial Property” shall be defined as any real property that is not Residential Property. K. Unauthorized Activities 1. Generally a) No business will be conducted in eXp’s name that does not pertain directly to the duties of a real estate licensee as directed by federal, state and local laws/regulations as well as eXp’s Policies, referenced herein. b) Agents shall not open any brick-and-mortar offices in eXp’s name or bind eXp to any agreements without the written consent of their State Broker. c) Except as otherwise provided in the last sentence to this paragraph, Agents shall not conduct property management services through eXp. The term “property management services” means engaging in any activities concerning an actual or prospective tenant on behalf of a client, whether or not such activities are coupled with any property preservation services (as that term is defined herein) (e.g., collecting rents, performing inspections, setting up repairs and maintenance, running a background check, making or assisting with tenant selection, etc.). However, Agents may list rental properties on behalf of landlord-clients, and Agents may assist tenant-clients in locating suitable properties in which to rent. d) Agents shall not operate limited function referral offices through eXp. The term “limited function referral offices” means those offices that are solely engaged in referring clients or customers to non-eXp real estate brokerage companies. Agents desiring to perform limited function referral offices should both (i) refer to their State P&Ps, and (ii) contact their State Broker for more information.

eXp Realty (USA) Policies and Procedures Page 16 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES e) Agents shall not sell or list to sell business opportunities or engage in business brokerage activities. For avoidance of doubt, this prohibition does not apply to brokering interests of cooperative corporations (co-ops). f) Agents shall not conduct a final walk-through inspection on behalf of a client. g) Agents shall not perform work or do repairs on properties where the Agent is representing a buyer or seller. h) A single Agent shall not represent both sides of a sales transaction if the Agent or a family member of the Agent is a principal or party to the transaction. Failure to follow this policy can result in loss of errors and omissions coverage and each Agent shall be responsible for any legal costs and may be subject to removal from eXp, as provided in their ICA. i) Agents shall not represent both sides of a transaction without full written consent from all parties executed prior to contract. Failure to follow this policy can result in loss of errors and omissions coverage. Agents shall be responsible for all legal costs and may be subject to removal from eXp, as more fully provided in Agent’s ICA. j) Agents shall not engage in the act of wholesaling properties, in which they, or a family member, have a financial interest without first obtaining written approval from both the State Broker and Brokerage Operations leadership. No real estate compensation arising from a wholesaling transaction in which either the Agent and/or the Agent’s family member is a principal, shall be credited, reduced, or otherwise waived unless the transaction file is complete; and if the file is complete, any such crediting, reduction, or waiver must be approved in writing, and in advance, by Agent’s State Broker. In this instance, real estate wholesaling occurs when the Agent contracts with a home seller to purchase their property, markets the home to potential buyers and then sells and assigns the purchase contract to another buyer before the purchase transaction closes. The Agent makes a profit, which is the difference between the contracted price with the seller and the amount paid by the buyer. For avoidance of doubt, real estate wholesaling does not occur (for purposes of this paragraph) when there is a deed transfer as between the original seller and first buyer, on the one hand, and a second deed transfer as between the first buyer and subsequent buyer, on the other hand, even if the two deed transfers occur on the same day, whether or not through simultaneous closings. Agents should consult with their State Broker team or Regional Director (formerly known as their, “Centers of Excellence Director” or “COE Director”) for more information. k) Agents may only work with an unrepresented party with proper disclosure, and the Agent must represent a party in the transaction (i.e., helping a buyer client purchase from a for sale by owner, helping an unrepresented buyer purchase their listing where they represent the seller). MLS-only listings are not allowed. l) Agents shall not act outside of their area of expertise, either in knowledge base or geographic area. At the option of the State Broker, another Agent may be assigned to work with the Agent or to personally assist the Agent in such a transaction. If compensation to the Agent is affected, the State Broker shall negotiate a reasonable compensation agreement on that transaction. m) As a general rule, Agents shall not contract for any services or bind eXp in any way without written consent of eXp. However, Agents may enter into client-specific or transaction-specific agreements (on eXp’s behalf), (1) that affect only themselves (as opposed to any other eXp Agents), and (2) which a reasonably prudent real estate licensee would customarily enter into in the normal and regular course of rendering those real estate

eXp Realty (USA) Policies and Procedures Page 17 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES brokerage services offered by eXp (including, without limitation, listing agreements, client-specific or transaction-specific referral agreements, and buyer-broker agreements). n) For avoidance of doubt, Agents do not have authority and are not permitted to enter into any agreements (on eXp’s behalf) that may affect any Agents other than themselves or eXp, including by way of example only, and without limitation, master referral agreements, lead generation agreements, master service agreements, office lease agreements, non-disclosure or confidentiality agreements, or any other type of business-to-business vendor agreement. If Agents are unsure whether they have the authority to enter into an agreement on eXp’s behalf, they should refrain from entering into that agreement and confer with their State Broker. o) Agents shall not render legal, appraisal or tax advice to any person on behalf of the Agent, the State Broker or eXp. Under no circumstances is an Agent to deny, or in any way discourage, a client from seeking the advice of an attorney of client’s choice. Rather, such activity should be encouraged. p) An Agent shall not act, or agree to act, as an “attorney in fact” (whether under a power of attorney, a representation agreement, or a transaction-related document), as follows: 1) on behalf of a client or customer of eXp; or 2) on behalf of a party that is on the opposite side of a Transaction from either an eXp client or customer, or from Agent (when acting as a principal in a Transaction). NOTE: An Agent may act as an “attorney in fact” on behalf of a family member whom they represent in a Transaction, provided that they first receive the prior written approval of their State Broker. q) Agents whose clients are operating as an attorney in fact under a power of attorney must confer with their State Broker prior to accepting such client. For avoidance of doubt, eXp cannot confirm the validity or enforceability of any powers of attorney. r) Agents shall not recommend third party services with whom the Agent has a familial relationship in any transactions the Agent is directly involved in or has a financial interest in unless the Agent discloses their familial and/or financial interest (if any) in writing to the client, and also provides at least one additional referral, preferably more, at the same time. s) Agents shall not, directly or indirectly (such as through a company an Agent owns or controls), perform or complete any repairs on a property for a client, that is or is intended to become the subject of a transaction in which the Agent is involved, regardless of whether the Agent is a licensed contractor. t) Agents shall not enroll or participate in auction websites without State Broker approval. 2. Competitor Affiliation is Prohibited An Agent shall not be affiliated with a competing real estate brokerage company. This means that an Agent (including an Agent’s spouse or partner, if applicable) shall not alone or in association with others, whether individually or through any legal entity (such as a corporation, limited liability company, joint venture, etc.) do any of the following: a) own, manage, operate, or control; b) be employed by, or engaged as an independent contractor with; c) serve as an officer, director, consultant, or agent to; d) capitalize or lend money to; or e) grant the use of his or her name to

eXp Realty (USA) Policies and Procedures Page 18 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES any residential or commercial real estate brokerage firm other than those within the eXp family of real estate brokerage companies. Notwithstanding the foregoing, an Agent may own, as a passive investor, the issued and outstanding stock of a publicly held company that competes with any real estate brokerage company within the eXp family of real estate brokerage companies. 3. Limited Representation is Prohibited Except as otherwise provided below, no Agent shall enter into any representation relationship with a seller, buyer, landlord, or tenant that limits the services to be provided to that person (“Limited Representation”), nor shall any Agent participate in any transaction that does not result in a fiduciary relationship between an Agent and the seller, buyer, landlord, or renter. However, an Agent may engage in any of the following Limited Representation relationships provided that, (1) each such relationship is disclosed in writing and signed by the client or customer, and such disclosure clearly establishes the Agent’s duties to the client or customer (including the limitations of the Agent’s relationship with the client or customer), (2) any such relationship is not prohibited by applicable law or regulations, and (3) any such relationship is not prohibited by State P&Ps: a) a “limited dual agency” relationship; b) a “transactional” relationship (i.e., a nonagency relationship where an Agent does not represent a buyer or seller, or landlord and renter, in the transaction, treating both as customers); and c) a “facilitator” relationship (i.e., a relationship where an Agent assists a buyer and seller, or landlord and renter, in reaching agreement in a real estate transaction but has no fiduciary duties to either party). If an Agent is unclear with the above, the Agent should contact their State Broker before engaging in any of these relationships. In any listing engagement (including where there is Limited Representation), no Agents shall encourage or place in any “MLS listing remarks,” directions that a buyer’s or renter’s agent (or potential buyers or renters themselves) contact the seller or landlord, directly, for any reason. VII. ANCILLARY AND AFFILIATED SERVICES A. Property Preservation Services Agents may only engage in property preservation services when working on behalf of clients that are asset managers or institutional clients (whether or not associated with eXp’s REO/Relocation division). Agents may not engage in property preservation services for clients that are not asset managers or institutional clients. The term “property preservation services’’ means tending to and managing only the physical aspects of any real property on behalf of a client (e.g., scheduling, coordinating, and/or setting up any repairs or maintenance concerning a client’s real property). For avoidance of doubt, “property preservation services” are distinct from “property management services” (defined herein). For example, and without limitation, an Agent may schedule plumbing repairs on behalf of a bank that

eXp Realty (USA) Policies and Procedures Page 19 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES owns an REO property, but an Agent may not schedule plumbing repairs for a mere, individual property owner that owns a property. B. Mortgage Loan Origination 1. Generally Except as may otherwise be prohibited by law, an Agent may perform mortgage activities in any Transaction in which they have a personal or financial interest. 2. Dual Capacity If an Agent is authorized by applicable law to perform both real estate brokerage activities and mortgage loan origination activities, the Agent may perform both sets of activities in the same transaction provided that the Agent has properly disclosed their “dual capacity” (as both real estate agent and mortgage loan originator) to his or her client. 3. Familial Relationship - Conditionally Acceptable An Agent may not refer the services of a mortgage loan originator, that has a familial relationship to the Agent, on any transactions in which the Agent is performing real estate brokerage activities, unless each of the following conditions are met: (1) the buyer/borrower is being represented through the Agent and is not an opposite party in the purchase transaction; (2) such familial relationship is disclosed to the buyer/borrower, in writing, in advance of making the referral (an email from the Agent to the buyer/borrower is acceptable; see below example); (3) if the disclosure is made through email, then a copy of the email is uploaded to the transaction file in eXp’s transaction management system; if the disclosure is made in any other written form, it must be signed and then uploaded to the transaction file in eXp’s transaction management system; and (4) the Agent must provide the name and contact information for at least one additional mortgage loan originator at the time the referral is made to buyer/borrower. Example: Agent sends the following email to the buyer/borrower: “Dear [Buyer/Borrower], Here are a couple of loan originators for your consideration: 1. Sally Smith of Smith Mortgage: (732) 123-4567 2. Jenny Jones of Jones Home Loans: (732) 321-7654 *Jenny is my spouse; you can pick any loan originator you choose and your options are not limited to the two individuals or companies listed in this email.” C. Title And Escrow Companies **(This section of these eXp P&Ps is applicable when an Agent has an ownership interest in a title and escrow company or is a member of any team whose team member owns a title and escrow company.)** 1. Step 1: Produce an Affiliated Business Arrangement (ABA) Disclosure Form Agents that own an interest in a title and escrow company must use their own ABA disclosure form in all purchase and sale Transactions that they participate in on behalf of eXp; this is to

eXp Realty (USA) Policies and Procedures Page 20 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES be used in addition to eXp’s own ABA disclosure form. Agents will have their own ABA disclosure form prepared. The proposed ABA disclosure form must name eXp (and the Agent) in the “From” line at the top of the form; the form must also contain language referencing eXp, substantially similar to the following: “eXp Realty, LLC, together with its subsidiaries and affiliates (collectively, “eXp”), does not have any relationship with Happy Harry’s Title and Escrow Company, Happy Harry’s Holdings, LLC, or Happy Harry’s Agency (collectively, the “Harry Companies”), nor will eXp receive any benefit, financial or otherwise, from any referral to any of the Harry Companies given by Agent.” *References to the Harry Companies are for exemplary purposes only; Agent to use only those company names applicable to Agent. (Agents are responsible for updating their ABA disclosure form from time to time so that it always remains in conformance with applicable law and any changes in factual circumstances. Each update to an Agent’s ABA disclosure form must be accompanied by an additional legal opinion letter, as more fully discussed, below.) 2. Step 2: RESPA Attorney Agent consults with an attorney of their choosing that is knowledgeable in the Real Estate Settlement Procedures Act (“RESPA”), for the purpose of having that attorney review the Agent’s proposed ABA disclosure form (and any updates to that form) at the Agent’s sole cost and expense. The attorney will also be responsible for confirming the truth and accuracy of any entities and entity-relationships referenced in the proposed (or updated) ABA disclosure form. If the Agent’s attorney determines that the proposed (or updated) ABA disclosure form does not conform with RESPA or is less than true and correct, then the Agent or attorney will revise it so that it conforms to RESPA and is true and correct. 3. Step 3: Legal Opinion Letter After the Agent’s attorney has determined that the proposed (or updated) ABA disclosure form conforms with RESPA, makes true and correct representations, and contains the recommended language that is needed for eXp, the Agent’s attorney proceeds to draft a legal opinion letter, for the benefit of Agent and eXp and upon which each may rely, that among other things, (1) provides that the attorney is conversant in RESPA, (2) affirms that the proposed (or updated) ABA disclosure form conforms with RESPA, (3) substantiates how/why it conforms with RESPA, and (4) affirms that the relationships spelled out in the ABA disclosure form are true and correct. (Agent must have a new legal opinion letter produced each time Agent’s ABA disclosure form is updated.) 4. Step 4: Delivery to eXp The Agent provides eXp with a copy of both the proposed (or updated) ABA disclosure form and the Agent’s attorney’s legal opinion letter. The proposed (or updated) ABA disclosure form and legal opinion letter are to be routed to eXp’s Legal Operations Department for its review.

eXp Realty (USA) Policies and Procedures Page 21 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 5. Step 5(a): Authorization for Proposed ABA Disclosure form If eXp receives Agent’s proposed ABA disclosure form and the accompanying legal opinion letter and its Legal Operations Department approves of each of them, then eXp will present Agent with a copy of its Title & Escrow eXp Addendum (“T&E Addendum”) for Agent’s signature. Thereafter, Agent will have eXp’s authorization to use, and shall use, Agent’s proposed ABA disclosure form in connection with each Transaction that they and any of their team members engage in. 6. Step 5(b): Authorization for Updated ABA Disclosure form If eXp receives Agent’s updated ABA disclosure form and the accompanying legal opinion letter and its Legal Operations Department approves of each of them, then eXp will formalize its approval, in writing, and thereafter, Agent will have eXp’s authorization to use, and shall use, Agent’s updated ABA disclosure form in connection with each Transaction that they and any of their team members engage in. 7. Step 6: Use Once theproposed (or updated) ABA disclosure form and Agent’s attorney’s legal opinion letter have been approved by eXp, Agent shall use, and shall cause each member of any team to which Agent belongs (if applicable) to use, Agent’s proposed (or updated) ABA disclosure form in all Transactions that they participate in on behalf of eXp. Note: Agent may not own a title and escrow company and also serve as a real estate licensee on behalf of eXp unless/until all the above referenced steps are completed. D. Home Warranty Companies **(This section of these eXp P&Ps is applicable when an Agent wants to work with and be compensated by a home warranty company.)** 1. Free to Contract with Home Warranty Company eXp will not prohibit an Agent from contracting directly with a home warranty company on their own, individual behalf (and not on behalf of eXp), for purposes of rendering a “compensable service” (as such term is used in Title 24 of the Code of Federal Regulations Section 3500.14 (Prohibition against kickbacks and unearned fees)) to that home warranty company. For avoidance of doubt, a compensable service is not conditioned on the referral of business to that home warranty company; rather, it is services actually performed by an Agent. Any such contract as between a home warranty company and an Agent is not to reference eXp in any way. 2. No Review of Contract eXp will not review or render any opinion on the sufficiency of any contract to be entered into between a home warranty company and an Agent as it relates to the Agent’s performance of a “compensable service” for that home warranty company. 3. No Referral Fees No Agent may receive compensation (i.e., a referral fee) from a home warranty company if the

eXp Realty (USA) Policies and Procedures Page 22 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES basis for such compensation is the making of a referral of a prospective customer to a home warranty company. 4. Free to Receive Payment for Compensable Services eXp will not prohibit an Agent from receiving compensation directly from a home warranty company as a result of the Agent’s rendering of a compensable service for that home warranty company. eXp will not be a payment intermediary, i.e., we will not receive payment from a home warranty company and then forward that payment along to an Agent. 5. No Amendment to ABA Disclosure Form eXp will not amend its ABA Disclosure Form, or produce or authorize the production of any new eXp ABA Disclosure Form, to include references to any home warranty company with whom an Agent may be individually contracted. VIII. AGENT FEES A. Standard Fees Agent fees include each of those listed below (note - unused portions of any monthly fees previously paid will not be credited/prorated). For avoidance of doubt, an Agent shall not be assessed, more than once per Transaction, any Agent fees that are generated on a Transaction-by-Transaction basis (such as Transaction Review Fees, Risk Management Fees, and Capped Status Transaction Fees). ● Sign-Up Fee: $149*. This sum includes an Agent’s first month Cloud Brokerage Fee. (*NYC REBNY Agents shall pay a Sign-Up Fee of $199.) ● Cloud Brokerage Fee: $85* per month, includes access to all platforms. (*NYC REBNY Agents shall pay a Cloud Brokerage Fee of $165 per month.) ● Washington Workers Compensation Insurance: Agents whose primary state of licensure is Washington shall pay the workers portion of the Washington Workers’ Compensation Insurance premium as stated on each annual Rate Notice issued by the Washington State Department of Labor & Industries prior to the start of each calendar year. ● Transaction Review Fee: $25 per Transaction. All Transactions (as defined in the ICA) will include a Transaction Review Fee taken as a charge against the Contractor Dollar (defined below) and shall be deducted from all Transactions, excluding all referrals, Broker Price Opinions (“BPOs”), and leasing/rental compensation under $1,000 Gross Compensation Income to eXp. ● Risk Management Fee: $60 per Transaction. All Transactions will include a Risk Management Fee taken as a charge against the Contractor Dollar Amount and shall be deducted from all closings, excluding all referrals, BPOs, and leasing/rental compensation under $1,000 Gross Compensation Income to eXp. The annual per eXp Agent cap on payment of Risk Management Fees for non-commercial Transactions is $750. Commercial Transactions do not have a Risk

eXp Realty (USA) Policies and Procedures Page 23 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Management Fee cap. ● Capped Status Transaction Fee: Once an Agent has reached their annual Company Dollar Cap amount and is in a “Capped Status”, then that Agent shall pay a “Tier 1” Capped Status Transaction Fee, per Transaction. The Tier 1 Capped Status Transaction Fee shall be in an amount that is the lesser of the following: (a) 20% of GCI, or (b) $250, per Transaction. The Capped Status Transaction Fee shall be collected until $5,000 has been collected (per Capping Period), at which point Agent shall pay a “Tier 2” Capped Status Transaction Fee, per Transaction. The Tier 2 Capped Status Transaction Fee shall be in the amount of $75 per Transaction for the remainder of that Agent’s Capping Period. For avoidance of doubt, the terms “Tier 1” and “Tier 2,” as used in connection with the Capped Status Transaction Fee, are entirely unrelated to the terms “Tier 1” and “Tier 2,” as used in connection with the Revenue Share Plan. This Capped Status Transaction Fee applies to each side of a Transaction closed by an Agent in a Capped Status, unless the Agent is in a “One eXp Agent, Two Transaction Sides” transaction (defined below), in which case the Agent is charged one Capped Status Transaction Fee per Transaction, not per Transaction side. The term “One eXp Agent, Two Transaction Sides” means a dual agency transaction in which one natural person represents a buyer and seller in the same transaction. For avoidance of doubt, if an Agent in a Capped Status is representing a seller, and another Agent in a Capped Status is representing a buyer, in the same Transaction, then the Agent that is representing the seller shall pay their 20% of GCI or $250 (if they have not already paid $5,000 in Capped Status Transaction Fees for that Capping Period), or $75 (if they have already paid $5,000 in Capped Status Transaction Fees for that Capping Period), and the Agent that is representing the buyer shall pay their 20% of GCI, $250, or $75 (as the case may be), for that Transaction. Revenue share will not be paid out on Transactions completed by Agents in a Capped Status. Capped Status Transaction Fees will be in addition to all other deductions and fees. The Minimum Company Dollar Rule (defined below) and the Capped Status Transaction Fee are separate from each other; when one applies, the other does not. The Minimum Company Dollar Rule applies when an Agent is not in a Capped Status, and the Capped Status Transaction Fee applies when an Agent is in a Capped Status. In situations where more than one Agent together represent either (or both) Transaction side(s) in any single Transaction, and because the Capped Status Transaction Fee is “per Transaction side” and not “per Agent,” then the Capped Status Transaction Fees are always split between Agents on the same Transaction side in an amount equal to the proportionate percentage of the compensation each Agent earns, as reflected in the applicable Disbursement Agreement. Example 1 (Two eXp Agents, One Transaction Side): If: ● Agent A and Agent B are both in a Capped Status; and ● Agent A has paid $1,000 and Agent B $2,500 in Capped Status Transaction Fees during

eXp Realty (USA) Policies and Procedures Page 24 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES their respective then-current Capping Periods; and ● Agent A and Agent B both represented the buyer in a sales Transaction; and ● GCI is $10,000 ● Agent A received 60% of the compensation and Agent B received 40% of the compensation. Then: ● The applicable Capped Status Transaction Fee for both Agent A and Agent B would be $250, because $250 is less than the amount that equals 20% of GCI (that is, $10,000 GCI x 20% = $2,000); and ● Agent A would pay $150 (60% of the $250) of the Capped Status Transaction Fee and Agent B would pay $100 (40% of the $250) of the Capped Status Transaction Fee. Example 2 (Two eXp Agents, One Transaction Side): If: ● Same facts as Example 1, except that Agent A has paid $5,000 in Capped Status Transaction Fees during his/her then-current Capping Period Then: ● The $250 Capped Status Transaction Fee would then be reduced to $75 for Agent A because Agent A has paid a total of $5,000 in Capped Status Transaction Fees; and ● Agent A would pay $45 (60% of the $75) of the Capped Status Transaction Fee and Agent B would pay $100 (40% of the $250) of the Capped Status Transaction Fee In the example above, each Agent will pay the percentage of their respective Capped Status Transaction Fee amount, if any, if the Agents have different applicable Capped Status Transaction Fee amounts. Example 3 (One eXp Agent, Two Transaction Sides): If: ● Agent A has not paid $5,000 in Capped Status Transaction Fees during his/her then-current Capping Period and has a Transaction in which they represent both sides. Then: ● One $250 Capped Status Transaction Fee will be split and then applied to each side ($125 per side). B. Minimum Company Dollar Rule Subject to the below-referenced exemptions, eXp is to receive a minimum amount of Company Dollar on each closed purchase Transaction, and on each closed sale Transaction, involving an Agent who is not in a Capped Status. This is known as the “Minimum Company Dollar Rule.” The Minimum Company Dollar Rule shall be applied as follows:

eXp Realty (USA) Policies and Procedures Page 25 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● When the final, gross sales price of the subject property is greater than or equal to $83,333, then the amount of Company Dollar to be received by eXp shall be the greater of, (a) $500, or (b) an amount that is equal to twenty percent (20%) of the GCI. ● When the final, gross sales price of the subject property is less than $83,333, then the amount of Company Dollar to be received by eXp shall be the lesser of, (a) $500 or (b) an amount that is equal to twenty percent (20%) of the GCI. Each Agent has an obligation to act in good faith in his or her dealings with eXp. Therefore, and except as it pertains to exempted Personal Transactions, no Agent shall credit, reduce, or otherwise waive his or her rights to receive a real estate compensation in amounts greater than thirty percent (30%) of the GCI, on any Transaction that is subject to the Minimum Company Dollar Rule, without first receiving their State Broker’s written approval. For avoidance of doubt, eXp does not mandate the amount of fees or percentages that an Agent charges clients. NOTE: The Minimum Company Dollar Rule applies to all purchase or sale Transactions, except as otherwise set forth in these P&Ps. The Minimum Company Dollar Rule and the Capped Status Transaction Fee are separate from each other; when one applies, the other does not. The Minimum Company Dollar Rule applies when an Agent is not in a Capped Status, and the Capped Status Transaction Fee applies when an Agent is in a Capped Status. For avoidance of doubt, the Minimum Company Dollar Rule does not reduce or eliminate an Agent’s obligation to pay any other applicable per Transaction fee; an Agent’s obligation to pay all such fees remain in full force and effect. 1. Exemptions from the Minimum Company Dollar Rule: The following Transaction types are exempt from the Minimum Company Dollar Rule and will be paid out according to the Agent’s regular payment plan per the terms of the Agent’s ICA and in these eXp P&Ps: a) 3 Personal Transactions per Anniversary Year; b) REO/HUD Listings; c) Short Sales; d) Rental Transactions; e) Referral Transactions; f) BPO Transactions; and g) Such other Transactions as may be determined by eXp in its sole and absolute discretion on a case-by-case basis. C. Late Fees All amounts charged to the Agent from eXp for recurring payments, monthly Cloud Brokerage Fees, and/or paid for programs opted in, and any other fees charged or back-charged for reimbursement per written agreements and policies are due within 10 days from the date of billing. Any billing that remains unpaid more than 30 days past due shall be assessed a late fee in an amount that is the lesser of: (a) $25 or (b) the maximum amount allowed under state law. For avoidance of doubt, no unpaid invoice shall be assessed more than one late fee.

eXp Realty (USA) Policies and Procedures Page 26 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES If an Agent’s account reaches 90 days past due/delinquent, eXp may terminate this Agreement pursuant to the Termination clause in the ICA and any/all pending compensation payments and/or revenue share payments shall be forfeited to the company. Each Agent shall pay eXp, in full, any past due fees and other amounts owing from that Agent upon demand, and any unpaid balances shall be subject to collections and/or formal legal proceedings. Additionally, if an Agent has elected to participate in the 2015 Agent Equity Program, the Agent’s participation will be temporarily suspended until eXp has been paid in full. D. eXp Right to Payment eXp has the irrevocable right to seek payment or reimbursement, as applicable, from each Agent, in connection with the Reimbursable Amounts. Payment or reimbursement of Reimbursable Amounts may be obtained by eXp, through any (or any combination) of the following methods: (i) offset against any fees, revenue sharing, other compensation, or any combination thereof, owed by eXp to an Agent; and (ii) using an Agent’s preferred payment method then on file with eXp. E. Agent Fees Non-Refundable All of the above referenced fees are non-refundable. Sales tax laws and regulations for each state determine whether a fee is subject to sales tax. If applicable, sales tax is applied as a separate line item on the Agent’s statement. eXp reserves the right to adjust this fee schedule. For the avoidance of doubt, nothing in this section shall preclude eXp from having the ability to make any adjustments or corrections; any such adjustments or corrections shall not constitute a refund to Agent. IX. ACCOUNTING AND COMPENSATION A. I.R.S. Form 1099 Agents will receive I.R.S. Form 1099 on or before January 31 of the calendar year following their earnings in compliance with requirements published by the Internal Revenue Service. Total earnings reported to Agents will include Agent compensation earned, revenue share earned, and stock issuances (ICON Agent Awards, stock awards, etc.). All information reported to the Internal Revenue Service is reported on a cash basis, thus all compensation reported is based on the calendar year in which the Agent was paid. For example, if a home closed for a client on December 30, but eXp did not receive final paperwork until January 2, and the Agent was paid on January 3, that transaction will be included on the next year’s I.R.S. Form 1099. Please consult a tax advisor for proper reporting of taxable income and deductions. Upon visiting MyEXP (https://my.exprealty.com/login) or submitting an email request to [email protected], Agents can receive an I.R.S. Form 1099 Report with the breakdown of earnings and fees paid within the period. (Note: A breakdown of earnings and fees will be available, whether or not eXp prepares and releases an I.R.S. Form 1099. Also note: If an Agent operates through a legal entity, that Agent and that Agent’s legal entity might not receive an I.R.S. Form 1099, if one is not required by law.) Agents that are licensed in more than one state will be paid in accordance with the real estate licensing laws and rules of the most restrictive state in which that Agent is licensed. On each I.R.S. Form 1099 prepared and released by eXp, eXp will identify, as “RECIPIENT” (see picture, below), that natural person or legal entity that received the payment, from eXp, this is being reported.

eXp Realty (USA) Policies and Procedures Page 27 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES B. Compensation; Other Fees From Clients A payment recipient’s name (whether a natural person or legal entity) must match across the State Department of Licensing records, the W-9 that is on file with eXp, and the applicable U.S. Federal Income Tax Return. eXp reserves all rights to withhold the payment of any compensation if a payment recipient’s name does not match across all three platforms. If the Agent elects to be paid as a PC or PLLC, LLC or Agent corporation/company name, as allowed by state and federal law, the Agent must amend his/her W-9 to reflect the proper name and tax identification number of the entity and advise eXp of the same. Agents shall not be paid in the name of a PC or PLLC, LLC or Agent corporation/company name without complying with all State Department of Licensing rules and regulations as well as federal and state law. For the avoidance of doubt, if Agent elects to get paid under a PC or PLLC, LLC or Agent corporation/company, the entity must be both, (1) duly licensed, active, and in good standing with the State Department of Licensing, and (2) validly formed, existing, and in good standing with applicable state office or agency that administers the formation and maintenance of legal entities (such as a state’s Office of Secretary of State, Corporation Commissions, or such analogous office or agency). An Agent cannot transact real estate brokerage business, for payment, in a state in which an Agent is not licensed. All compensation, including but not limited to, retainers (that is, all fees, deposits, or other monies requested from a consumer that are to be used to retain the professional real estate services of an Agent), rental compensation, administrative fees, document storage fees, broker price opinions, and any additional fees charged to the consumer by the Agent (such as, for example, any Administrative Transaction Fee), shall be made payable to eXp and shall be subject to any applicable splits. At no time shall the Agent accept client payments made payable to themselves directly. All compensation and Agent-collected fees are subject to applicable Company Dollar and Contractor Dollar splits. (Note:

eXp Realty (USA) Policies and Procedures Page 28 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Retainer fees shall be non-refundable, where permitted by law. Agents will consult with their State Broker before collecting any retainer). Any agreement to share compensation between Agents within eXp shall be done so in writing. All agreements shall be uploaded and stored in eXp’s transaction management system. In the absence of a signed written agreement between Agents, eXp shall pay the entire Agent share of the compensation to the Agent(s) whose name(s) appear on the transactional document between the principals (to be divided equally between those Agents if more than one and not otherwise specified). Except for team disputes, eXp will make the final determination regarding compensation disputes between Agents licensed with eXp. All referrals between Agent and any other eXp-related agent must be documented on that eXp-approved Referral Agreement for use in the originating brokerage jurisdiction. For example, if an eXp Agent in Utah were to refer a client to an agent in Italy that is affiliated with eXp Italia S.r.l. (that is eXp’s affiliate operating in Italy), then that referral relationship must be memorialized in the form of Referral Agreement as used and approved by eXp in Utah. Conversely, if an agent affiliated with eXp Italia S.r.l. were to refer a client to an eXp Agent in Utah, then that referral relationship must be memorialized in the form of Referral Agreement as used and approved by eXp Italia S.r.l. An Agent may only receive payment related to a transaction if any one or more of the following apply: (1) they are designated on the transaction paperwork as the Agent representing a party to the transaction; or (2) they have a written referral document in eXp’s transaction management system; or (3) they have the appropriate team documents on file with eXp indicating, with specificity, when and in what amounts compensation to the Agent is to be made; or (4) with the prior express written consent of an attorney within eXp’s Legal Operations Department or a Designated Managing Broker (“DMB”) (or higher) in eXp’s Brokerage Operations Department. This prohibition applies regardless of whether an Agent seeks to modify a general agreement concerning all transactions, an agreement concerning transactions within a specific category, or an agreement concerning a specific property. This prohibition extends to changes in compensation an Agent would otherwise receive even for theoretical transactions that are not yet under contract. Any sales incentive, gift, and/or bonus received shall be paid to eXp. eXp treats bonuses, gifts and incentives as any other compensation and will pay the Agent based on the Agent’s current split. C. Compensation Advances Compensation advance are not offered by eXp directly but may be obtained in accordance with the following procedures. All compensation advances must be approved in writing by the State Broker in advance. 1. Prior to signing any compensation advance agreement, the Agent must have the listing file (with an accepted purchase and sale contract) or the transaction file uploaded in eXp’s transaction management system, and it must have passed eXp’s approval process. 2. An Agent may only receive up to 70% of the net compensation due to the Agent as a compensation advance, or an amount less than $20,000, and up to $6,000 on active listing advances. (Note: Compensation advance companies outside of eXp Solutions may offer different amounts). Exceptions to this general rule may be made on a case by case basis in extenuating circumstances, as determined by eXp in its sole and absolute discretion. 3. Agents may receive multiple compensation advances but the aggregate of all compensation

eXp Realty (USA) Policies and Procedures Page 29 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES advances that an Agent may have outstanding at any one time shall not exceed $20,000. 4. A $100 service charge (“Service Charge”) will be added to: 1) any advances made from a compensation advance company that is outside of eXp Solutions; and 2) and UCC liens presented to eXp from a compensation advance company seeking payment of any unpaid compensation advance(s). D. Actions for Unpaid Compensation or Procuring Cause Claims A decision to proceed with legal action, mediation or arbitration against a party owing compensation to eXp will be made solely at the discretion of eXp. eXp shall not have any monetary obligations to the Agent or any other party, resulting from brokerage fees and/or compensation that is uncollected. Agents may obtain independent counsel as desired to pursue and/or defend their position during mediation or arbitration. eXp shall not supply counsel to pursue these items. Should the Agent be named in a mediation or arbitration as the respondent, eXp reserves the right to require that the total amount of the disputed compensation is held by eXp until the mediation or arbitration results are received. Should eXp and the Agent not prevail, the Agent shall pay all compensation amounts immediately to eXp. An Agent does not have the authority to reduce, defer or replace any portion of eXp’s splits or fees without the written consent of the State Broker, or eXp. E. Referral Payments and Relocation Companies Referrals shall only be paid to licensed Agents in conjunction with all Department of Licensing rules and regulations. However, as it pertains to any international referrals concerning jurisdictions that do not require licensing, such referrals will be facilitated in accordance with that jurisdiction’s laws, rules, and regulations. All referrals between an Agent and any other non-eXp agent or brokerage must be in writing and uploaded into eXp’s transaction management system. All third-party referrals are subject to eXp split and eXp cap rules. Outbound referral fees are taken off the top of a transaction and directed to the referral/relocation companies. F. Perceived Compensation Discrepancies Agents shall have ninety (90) days following original disbursement of a compensation to notify eXp’s Transaction Processing Team (via email only to [email protected]) of any perceived compensation discrepancy resulting in a payment shortage to the Agent. eXp will evaluate the Agent’s notification and if eXp agrees that there has been a payment discrepancy at the Agent’s expense, eXp will correct such a discrepancy. However, if the Agent fails to timely notify eXp’s Transaction Processing Team of any such perceived compensation discrepancy within the time and manner specified, then the subject compensation payment amount will be deemed correct and final by eXp, and that amount, whatever it may be, will be used and relied upon by eXp for all purposes under

eXp Realty (USA) Policies and Procedures Page 30 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES the Agent’s ICA. For the avoidance of doubt, nothing in eXp’s P&Ps shall preclude eXp from reopening any matters or revisiting any files, at any time, in instances where there may have been any compensation discrepancy resulting in a payment shortage to eXp (e.g., an overpayment to an Agent); eXp reserves all rights to seek immediate reimbursement from an Agent for such amounts in such instances. X. MARKETING AND ADVERTISING As a representative of eXp, Agents are expected to adhere to the highest standards of conduct and professionalism. This extends to all marketing and advertising activities including social media, digital, print and other forms of content used to communicate with potential clients and prospective Agents. A. Compliance with Laws, Guidelines, and Regulations 1. Agents are prohibited from posting inaccurate or misleading information in all of their content whether intended for clients or prospective Agents; Agents’ marketing, advertising and communication must be completely factual. 2. All marketing, advertising, and communication, whether for property listings, Agent Attraction, or general purposes, must adhere to all federal, state, and local laws and regulations (e.g., any REALTOR® Code of Ethics, fair housing, antitrust, license, copyright, etc.), including, when using any tools or communications provided by or on behalf of eXp. This includes broad-based mandates like the Telephone Consumer Protection Act (“TCPA”), including “do not call list” guidelines, the Telemarketing Sales Rules (“TSR”), the CAN-SPAM Act, Federal Trade Commission (“FTC”) rules, Securities and Exchange Commission (“SEC”) regulations, NAR antitrust practice changes (see https://www.nar.realtor/the-facts/nar-settlement-faqs), and state and national tortious interference laws, and their implementing rules and regulations (collectively, “Solicitation Laws”). For avoidance of doubt, eXp cannot and does not make any representations to Agents concerning the lawfulness of the content and/or manner of transmission of any communication or communication tools provided to Agents that may be provided or offered by eXp or any of eXp’s affiliated partners, any eXp provided lead generation vendors, or in or through any training classes or materials provided by or through any other Agent or eXp employee. Agents must consult their own legal counsel before using any eXp tools and/or communication. 3. Agents are solely responsible for the content of any and all communications and the means of communication (phone, fax, text, etc.) with any third parties, including customers, potential customers, leads or other individuals or entities, and Agents are solely responsible for complying with any laws, and payment of taxes and tariffs applicable in any way to an Agent’s real estate practice and marketing or any other service offerings contemplated in an Agent’s real estate practice. AGENT IS EXPRESSLY PROHIBITED FROM ENGAGING IN ANY COMMUNICATIONS VIOLATIVE OF THE SOLICITATION LAWS OR ANY SIMILAR FEDERAL, STATE, OR LOCAL LAW, RULE, OR REGULATION AS AN AGENT OF EXP, AND DOES NOT HAVE EXPRESS, IMPLIED, OR APPARENT AUTHORITY TO MAKE SUCH COMMUNICATIONS. If eXp becomes aware that it has received compensation from any transactions in which an Agent engaged in violative calls, eXp will return any such compensation and such a return shall be intended to constitute full rejection (as opposed to ratification) of such conduct.

eXp Realty (USA) Policies and Procedures Page 31 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 4. Agents are responsible for ensuring that all advertisements are compliant with all applicable federal, state, and local laws, rules, and regulations, including, without limitation, each of the following: HUD rules and regulations, RESPA (including its implementing rules and regulations), and rules and regulations promulgated by state-level real estate regulatory bodies (such as, for example, a state’s Dept. of Real Estate, Real Estate Commission, or analogous bodies having a different name). Furthermore, Agents must adhere to the standards of the REALTOR® Code of Ethics and the rules of Boards or MLSs. 5. Agents may not use the name, likeness, or reference to or of any other Agents in their own marketing materials without first obtaining the referenced-Agent’s prior written consent. 6. In regards to communicating offers of compensation, such offers shall be at a seller’s written direction and made in compliance with eXp State P&P’s. B. eXp Brand Guidelines 1. Use of eXp logo and name are considered advertising and must be approved in advance. Please send your Agent-created content to your State Broker through their designated email address. 2. Agents must read and comply with the eXp Brand Guidelines, which can be found at join.exprealty.com/brand, for brand and logo usage. 3. eXp provides Agents with access to a vast library of pre-produced and pre-approved marketing and advertising content through the eXp Canva which can be found at www.expmarketingcenter.com. Agents are encouraged to utilize this tool to the furthest extent possible. All content in eXp Canva has been reviewed and approved by eXp’s Marketing, Agent Compliance, and Legal teams. Note: Any content used by Agents from eXp Canva must also be reviewed and approved by the State Broker prior to publication to ensure compliance with state guidelines (see more about Review and Approval below). 4. Agents must properly brand their content to avoid leading viewers to believe that their website, social media profile, presentation, or other marketing content is official eXp marketing collateral. Agents must prominently identify themselves and provide their contact information on all content. Specific to websites, Agent’s name and/or team name, as well as eXp’s logo should be visible above the fold. 5. Use of the letters or trademark “eXp” or “eXp Realty” in DBA, entity names, domain names, social media handles, channel names, and other social media is prohibited (e.g., @exprealtyjohn, @exprealtytx, etc.). 6. Agents may use a combination of their name or team name along with the phrase “eXp Realty”“ to name pages on Facebook and other similar platforms (e.g., The John Doe Team – eXp Realty). 7. The use of the letters “eXp” or the name “eXp” in social media profiles or page names to claim a geographic area or specific location is prohibited (e.g., eXp of Bellingham, eXp Washington, etc.). C. Intellectual Property Rights eXp respects the valid intellectual property of others, and we fully expect our employees and Agents to do the same, in the same way we expect others to respect our intellectual property. Agents shall not

eXp Realty (USA) Policies and Procedures Page 32 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES infringe the intellectual property rights of others in the course of providing real estate agent services, including (a) avoiding the use of any trademarks that would in any way be confusingly similar to the senior trademarks of others, and (b) avoiding the use of any unlicensed images or other media of others. 1. Permission to Use eXp Trademarks a) In order to keep the eXp brand strong and enforceable, eXp is required to control its use and maintain consistency and quality associated with its use. As an Agent of eXp, in the course of promotion of real estate services, Agents may only use eXp trademarks (e.g., eXp, eXp Realty, and/or the logos associated therewith), in a manner consistent with the eXp Brand Guidelines, which can be found at join.exprealty.com/brand. b) Moreover, Agents should not do anything that would damage or dilute the goodwill associated with eXp trademarks. To the extent eXp determines that an Agent’s use of an eXp trademark is, in any way, harmful to eXp, or its trademarks, the Agent will modify his/her use immediately after notice from eXp to conform to eXp’s standards. c) eXp may revoke any permission to display eXp trademarks if an Agent does not comply with the policies in this document. 2. eXp Trademark Usage a) Agents may only use eXp trademarks to promote their activities as Agents with eXp and not for any other purpose. Prohibited uses include using eXp trademarks to promote Agent-hosted events without obtaining permission from eXp. b) Agents may not use any eXp trademarks or branding content to sell products or services online or elsewhere, such as accessories, or apparel, etc., or to promote the products or services of others, unless eXp grants a written license to do so. c) Agents should use the eXp Realty logo, together with their team name and/or team logo, in their advertising and communication content to avoid confusion with official eXp created advertising and communication. d) Agents must not use the trademark eXp, eXp Realty, EXP, or variations thereof, or any other eXp trademark, in any website domain, email address (other than provided by eXp), social media handle, or social media page. e) Agents may not use any eXp Commercial related trademark for any purposes unless they are also affiliated with eXp Commercial and subject to an eXp Commercial-specific Independent Contractor Agreement. Use of eXp Commercial-related trademarks shall be subject to those terms and conditions set forth within eXp Commercial U.S. Policies and Procedures, which, for the avoidance of doubt, is distinct and separate from the policies set forth within these eXp P&Ps. f) Agents must never register, or attempt to register, with any agency, any trademarks, business names, or legal entity names, that include the trademarks eXp, eXp Realty, EXP, or variations thereof, or any other eXp trademark, whether as a stand-alone trademark/name, or in combination with another trademark/name.

eXp Realty (USA) Policies and Procedures Page 33 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 3. Unlicensed Content and Trademarks a) Agents must never use unlicensed images or other unlicensed media (e.g., photos, including photos of properties, videos, music, etc.) in promoting any real estate advertisements/listings or any real estate services. Violations of this policy may result legal costs to Agent, sanctions and potentially termination. b) Other than original media created by Agent, all media (including images, photos of properties, videos, music, etc…) used by the Agent must be acquired from a vetted and/or reputable source (e.g., reputable stock image licensor, or a licensor that Agent has verified to be a reputable provider of the media with authority to grant the rights or license required for Agent’s purposes). c) Agents are prohibited from using trademarks or names in promoting their real estate services that are confusingly similar to the trademarks of others. Agents shall not infringe the trademark rights of others in promoting their real estate services. D. Review and Approval All content used by Agents for marketing and advertising must be reviewed and approved prior to publication by the applicable State Broker, and by Regulatory Relations (where applicable). Agents can submit custom-created content for review and approval by following the Review and Approval Process set out below. E. Review and Approval Process 1. Agents shall perform a self-review of their custom-created content and make updates consistent with the eXp Brand Guidelines, which can be found at join.exprealty.com/brand. 2. Custom-created content must be submitted for review and approval via email to the applicable State Broker team. 3. The applicable State Broker team will receive the request and initiate the review process. 4. As soon as necessary reviews and approvals are completed (within two (2) business days for most submissions), the State Broker will notify the Agent of required changes or approval for publication. 5. With final approval, Agents can freely use their custom content in their marketing and advertising efforts. F. Property-Related Advertising All property-related advertising including yard signs, flyers, door hangers, digital ads (web, social media, etc.) may not be published or placed until eXp has the executed listing agreement. 1. Yard Signs a) Signs must comply with all local, state and federal requirements. b) Signs used must be signs designed by or expressly approved by eXp. This includes sign riders, directional signs, sold signs, and other signs as needed to support the listing.

eXp Realty (USA) Policies and Procedures Page 34 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Approval can be obtained through the review process outlined above. c) Most MLSs prohibit putting up a “For Sale” sign before entering the listing in the MLS. A listing must be reported when it is taken and when it is sold within certain limitations. Agents must follow the MLS rules and comply. Any fine that results due to a violation of this policy will be paid by the Agent and not the State Broker or eXp. 2. Flyers, Door Hangers, etc. a) Printed content must comply with all local, state and federal requirements. b) Review and approval of flyers, door hangers, etc. can be obtained through the review process outlined above. 3. Online Advertisements and Content a) Agents may post property-related content to their own websites, blogs, and social media profiles and pages provided. b) Agents may use paid or boosted advertisements through social media, search engines, or other online platforms for the purchase or sale of client property. c) Online advertising and content marketing must be approved by the State Broker or eXp prior to posting. G. MLS Advertising Agents are prohibited from advertising offers of compensation in a multiple listing service (“MLS”) as directed in their State P&P’s. Agents are also prohibited from using MLS data or data feeds to directly or indirectly establish or maintain a platform containing offers of compensation from multiple brokers or other buyer representatives. H. General Advertising 1. In Any Medium Under no circumstances may an Agent hold themselves out to the public, or advertise in any medium (including, without limitation, in their email signature block, or when engaging in recruiting efforts), that they are an “owner agent” of eXp, even if the Agent owns one or more shares of stock in eXp World Holdings, Inc. For avoidance of doubt, the foregoing prohibition is entirely unrelated to, and distinct from, an Agent’s obligation to disclose and/or advertise that they are an “agent owner” of any real property that they maintain as a listing. 2. Business Cards Unless the Agent has the express permission (through the official review process) on a design different from those provided by eXp, the Agent will use an eXp-approved design. Template designs are available to Agents in eXp Canva. All Agent business cards will have the following identifying information on the cards: a) Brokerage name. b) Agent name as it appears on state licensing documents. c) Agent title. (1) Title may include any of the following where allowed:

eXp Realty (USA) Policies and Procedures Page 35 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES (a) REALTOR® (b) Real Estate Professional (c) Buyer’s Agent (d) Listing Agent (2) Title may also list a professional designation as recognized by the National Association of REALTORS®. (a) CRS, ABR, SRS, RSPS, etc. (3) Agents cannot use a title that would reasonably lead someone to believe that the Agent is an employee of eXp or representing themself as an employee of eXp (e.g., Recruiter, Recruiting Manager, Vice President of Agent Attraction, Growth Leader) or any other such term or title that may cause confusion as to the Agent’s position with eXp. (4) Additional items which may be included on the front of business cards: (a) eXp provided alias email address (b) Agent’s direct phone number (c) eXp website or Agent’s careers site (d) Social media accounts such as LinkedIn, Facebook and/or Twitter (e) Personal business website or blog d) Business cards must adhere to all applicable state-specific requirements such as real estate license number(s), MLS number(s), font size, etc. 3. Social Media a) Agents must learn and abide by the terms of service of any social networks or online advertising platforms. b) Shareable social media content can be found at www.expmarketingcenter.com and on eXp’s respective social media channels, including those that are linked at www.expworldholdings.com/social. c) Agents may not use social media to compete with eXp or engage in conduct that could create a conflict of interest. d) Social media content that is discourteous, aggressive, defamatory, discriminatory, sexually explicit, offensive, or in any other way damaging to viewers is prohibited. (1) Attacks or harassment against protected classes based on race, religion, age, gender, familial status, sexual orientation, disability, national origin, veteran status, and/or genetic information are not allowed. (2) Agents are to avoid arguments and aggressive language on social media that could leave a negative view of eXp and/or impact the Agent’s business. (3) Agents shall demonstrate respect to other eXp Agents, staff, clients, and potential clients and Agents, by not using social media to make defamatory or negative comments about eXp or other persons affiliated with eXp (e.g., staff, customers, vendors, contractors, service providers, etc.). (4) Agents are responsible for their social media channels and content. Any violation of these policies can lead to sanctions, up to termination. e) Agents must identify themselves clearly and avoid deceptive titles that would reasonably lead the public to believe the Agent is an employee of eXp (e.g., Director of Agent Attraction at eXp, CEO of Revenue Share at eXp, etc.) (1) Agents must identify themselves as Agents, sales representatives, brokers, etc. with

eXp Realty (USA) Policies and Procedures Page 36 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES eXp Realty, and in accordance with state guidelines. (2) If an Agent is using a title within their team structure, they should clearly state their position in the team, the team’s name, and include that the team is with “eXp Realty” (e.g., John Doe, Team Lead – Team Excellence, with eXp Realty). (3) Agents are prohibited from claiming they own or have rights to exclusively represent eXp for any given geographical territories via social media, websites, job ads, etc. (e.g., “John Doe – eXp Bellingham, Washington”). (4) Agents must adhere to state-specific rules and guidelines for profile and page names, as well as all other content on social media networks. f) Social media pages, profiles or handles that contain eXp branding and content may contain Agent team names if the Agent’s team name has been appropriately registered with eXp and the state department of real estate where required. g) Shared statistics about eXp (Agent count, rankings, etc.) should be cited and verified with eXp before posting. h) Paid advertisements for Agent Attraction are not allowed through social media platforms or search engines. See the Agent Attraction section for more information. i) See something, say something. If an Agent sees something on social media that requires an official eXp response or violates the policies and procedures or ICA, they are encouraged to contact [email protected]. The team will respond within two business days. 4. Websites a) Websites containing eXp brand or logo must have prominent above-the-fold co-branding for the Agent/Agent team and eXp. Users should be able to reasonably differentiate between Agent-created sites and official eXp sites. b) Domain names used for real estate or relating to eXp’s business may not use the trademark “eXp” or the letters “exp” in the domain name (e.g., expbellingham.com, expwashington.com, realestateeXperts.com, etc.). c) Agents are responsible for ensuring articles, blogs, downloadable files, and all online content are accurate and not misleading. d) If content (blog post, article, etc.) is hosted on a site other than the Agent’s, approval should be obtained through the Review and Approval process mentioned above. (1) Upon publication and distribution, Agents should monitor channels daily for the first week, then weekly thereafter for any false or defamatory comments. (2) Comments that are false or misleading should be removed or addressed through proper communication channels. e) The creation and use of online revenue share calculators by eXp Agents or third parties is strictly prohibited. However, eXp Agents may use the official eXp Revenue Share Calculator at https://revsharecalculator.exprealty.com, provided they comply with all applicable terms of use and company guidelines. I. Promotional Discount Advertisements From time to time an Agent may decide to offer and advertise promotional discounts in order to generate additional listings for themselves. Any Agent that elects to offer and advertise such promotional discounts must ensure that such advertisements clearly and conspicuously state that the

eXp Realty (USA) Policies and Procedures Page 37 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES promotional discount is being offered exclusively by the Agent, and not by eXp, and approved as outlined above. J. Co-Marketing and Co-Listing Arrangements eXp does not prohibit Agents from engaging in co-marketing arrangements and/or co-listing arrangements, as between eXp, on the one hand, and a non-eXp brokerage firm, on the other hand, provided that any such arrangements conform with, and are not violative of, all applicable law, rules, and regulations. If Agents are interested in engaging in any such arrangements, they must first consult with their State Broker. K. Employment Ads and Job Postings Agents may not create employment ads or job postings for the sole purpose of attracting prospective Agents to grow their Revenue Share Group within eXp’s Revenue Share Plan. Advertisements for open positions may only be used to recruit prospective Agents to join a registered team in a salaried or shared compensation position or to hire individuals for paid support positions. All employment ads or job postings must adhere to local laws and regulations, eXp policies, and National Association of REALTORS® advertising guidelines. The use of job websites, online classifieds, employment-related search engines, and paid advertisements for the purpose of posting a job or creating an employment ad is limited to the following criteria: 1. Only teams (defined as one lead Agent or team leader and at least one or more licensed Agents working as a team member with a Team Agreement, as defined in the Teams section below) that have registered with and been approved by their state commission, State Broker, and by eXp’s Agent Transitions team may advertise for available Agent positions on their team. These are positions for Agents who will join a registered team (not to be confused with Revenue Share Group) participating in a predetermined compensation split. 2. Any employment ad or job posting that results in direct affiliation with eXp (i.e., an Agent joining your team who also signs an ICA with eXp) must be reviewed and approved by the State Broker and by eXp’s Agent Compliance team prior to publication. The job description must also include the following disclaimer: “[TEAM NAME] is a team of licensees independently contracted with eXp. The position in this ad is not a listing for direct employment. The earning potential, perks, benefits, and access to systems listed within this description are contingent upon the applicant signing an Independent Contractor Agreement with eXp.” 3. Employment ads or job postings for support staff (scheduling coordinator, valuation specialist, transaction coordinator, etc.) must also be reviewed and approved by the Agent Compliance team via [email protected]. Independent Contractors not affiliated with a team may also post jobs and employment ads to build their support staff. 4. An independent Agent who wishes to form a registered team may use job sites, online classifieds, or employment-related search engines to advertise for their first salaried position or Agent team member. The Agent should submit their intention to form a team and their advertisement to their State Broker and to eXp’s Agent Compliance team for review and approval prior to posting and indicate that it is an advertisement for the initial team member. 5. Agents shall not advertise under false pretenses and/or offer what appear to be positions of

eXp Realty (USA) Policies and Procedures Page 38 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES employment with eXp, eXp World Holdings, Inc., or any of its subsidiaries and/or advertise content which is otherwise misleading. Employment ads should include Agent team name and indication of affiliation with eXp (e.g., John Doe Real Estate Team – by, with, or of, eXp). 6. Job listings must not contain eXp branding, official images, logos, or other intellectual property with the exception of an eXp logo. Employment advertisements must not contain links to official eXp job listings or websites. 7. Income as an eXp Agent through compensation or revenue share is not guaranteed and is based on productivity. Unless the position for which the Agent is hiring has a set base hourly rate or salary amount, then the amount listed in the wages or salary section of the employment ad must say “compensation-based” or an equivalent. If platform rules do not allow a non-specific amount, Agents must select the lowest wage or salary amount allowed and provide information about earning potential within the body of the description. Job postings must follow platform guidelines for independent contractor, non-employee (1099) positions if there is no base wage or salary offer. L. Media Relations eXp has furnished Agents with the “Media Relations Guidelines and Best Practices” resource that they should read and understand before engaging with the media. This resource can be found at exprealty.com/publicrelations. Any additional questions or requests related to media relations should be sent to [email protected]. All press releases mentioning eXp must be pre-approved prior to distribution and include the following language: “[insert name] is an independent contractor of eXp and this is not an official press release of eXp, its parent company eXp World Holdings, Inc., or any related subsidiary.” Once approved via the above email address, the press release cannot be modified without additional approval for the modifications. Please refer all media requests to talk about eXp, services, products, data, stock price, market expansion, etc. to [email protected]. Media requests about the Agent’s opinion on the local market are acceptable. Agents should refrain from speaking directly about eXp or speculating on the stock price of eXp World Holdings, Inc. We discourage Agents from discussing national industry issues or local/national competitors. M.Content License And Model Release Provided By An Agent Unless otherwise expressly agreed upon in writing between eXp and Agent, to the extent an Agent provides to eXp or any of its affiliates or licensees (not to be confused with real estate licensees) (collectively, “eXp Licensees”), any photographs, images or content of any type created or otherwise owned by the Agent (collectively, “Agent Content”) including, without limitation, by uploading such Agent Content via any online network operated by an eXp Licensee, Agent retains ownership to such Agent Content but Agent hereby grants eXp Licensees a royalty-free, irrevocable, world-wide, perpetual, non-exclusive license to publicly display, distribute, reproduce and create derivative works of the Agent Content, in whole or in part, in any media, including on any eXp Licensee website, for any purpose, including advertising and promotion of eXp Licensee services and/or products.

eXp Realty (USA) Policies and Procedures Page 39 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 1. Agent warrants and represents that Agent Content provided by Agent to eXp Licensees does not violate the intellectual property of others. eXp Licensees will not be required to pay any additional consideration or seek any additional approval in connection with using the Agent Content provided by Agent, and eXp Licensees retain exclusive and sole discretion as to whether to use such Agent Content or reject or remove such Agent Content from any online systems operated by any eXp Licensees. 2. Moreover, to the extent Agent provides to any eXp Licensees, or otherwise consents to allow eXp Licensees to receive and/or record any photographs and/or verbal statements of the Agent as a model, Agent hereby provides eXp Licensees with the irrevocable right to use Agent’s name (or any fictional name), likeness, picture, portrait, photograph, video, and voice in all forms and in all media and in all manner, without any restriction as to changes or alterations (including but not limited to composite or distorted representations or derivative works made in any medium) for advertising, trade, promotion, exhibition, or any other lawful purposes, and Agent waives any right to inspect or approve such photograph(s) or finished version(s) incorporating such photograph(s), including any written materials or other content that may be created and appear in connection therewith. Agent acknowledges and agrees that eXp may record any instances occurring within eXp World, and that all Agent avatars and/or voices are subject to recordation and subsequent use by eXp. For example, if you attend any eXp in-person events (as an Agent), and photographs are taken, those photographs may be used by eXp for any purposes; that is, eXp is free to use them in advertising, on social media sites, etc. The preceding is but one example, and is not intended to limit the license being granted to eXp. 3. Agent hereby waives all moral rights as to such photographs and releases and shall hold harmless eXp Licensees, and their assigns, licensees, successors in interest, agents, employees and representatives from any liability by virtue of any blurring, distortion, alteration, or use in composite form whether intentional or otherwise, that may occur or be produced in the taking of the photographs, or in any processing thereof. XI. REALTOR® ASSOCIATION AND MULTIPLE LISTING SERVICE BOARDS OF DIRECTORS A. Associations of REALTORS® eXp is a member of local Associations of REALTORS® where appropriate for access to MLS, access to standardize forms, and for other localized member benefits. Agents may not join a Board of Directors of any local Associations of REALTORS® without eXp first becoming a member. B. Multiple Listing Services Agent access to their local/regional MLS is always via the broker participant; Agents cannot join an MLS without the broker first becoming a participant of the service.

eXp Realty (USA) Policies and Procedures Page 40 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES When serving on the Board of Directors of an MLS, eXp Agents and regional brokers will bear in mind that because we are a brokerage, not a franchise model, access to the MLS is conditional upon eXp’s approval. As a result, policy and business decisions regarding MLS on the national, state and local levels will conform precisely to stated eXp policies and positions and to any NAR antitrust practice changes. In the absence of a stated position, elected volunteers usually cannot go wrong by choosing consumer-friendly policies that enhance data collaboration, consolidation and the freedom of the broker to use MLS data in ways conforming to generally accepted practices on the internet. XII. EXP’S REVENUE SHARE PLAN A. Overview eXp’s Revenue Share Plan (the “Revenue Share Plan”) provides a financial incentive to Agents who help grow sales within the eXp World Holdings Inc. family of real estate brokerage companies. The plan is funded through eXp’s collection of Company Dollar from Qualifying Transactions. One-half of the Company Dollar earned and received is used for eXp’s operating expenses and other management purposes (this is known as “Retained Company Dollar”), while the remaining half is placed in the “Revenue Share Pool.” Each brokerage within eXp World Holdings, Inc. has its own Revenue Share Pool, determined on a per-country basis. eXp calculates the Revenue Share Plan across all seven Tiers, monthly. If the total amount calculated to be paid out in a given month is less than the full amount in the Revenue Share Pool (known as the, “Calculated Company Dollar”), the difference (the “Adjustment Bonus” or “Adjustment Amount”) is added to the payout. In this way, eXp ensures that all money within the Revenue Share Pool is fully paid each month. eXp reserves the right to apply the Adjustment Bonus to any Tier or combination of Tiers in its sole discretion. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

eXp Realty (USA) Policies and Procedures Page 41 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES B. Revenue Share Explained As an Agent sponsors productive agents, they earn 17.5% of the Revenue Share Pool from the Qualifying Transactions of their directly sponsored agents (Tier 1). As these agents sponsor others, additional Tiers are unlocked, allowing the Agent to earn through eXpansion Share and eXponential Share. Example: Suppose that Agent sponsors 15 new eXp agents (Tier 1), who sponsor 25 agents (Tier 2), who sponsor 40 agents (Tier 3), and so on. If 10 of the Tier 1 agents are FLQA, the Agent unlocks earnings from Tiers 4 and 5, as follows: 1. 17.5% from Tier 1 transactions. 2. 20% from Tier 2 (1% eXpansion Share + 19% eXponential Share) 3. 12.5% from Tier 3 (0.5% eXpansion Share + 12% eXponential Share) 4. 7.5% from Tier 4 (0.5% eXpansion Share + 7% eXponential Share) Revenue share is paid on the 22nd of each month for the previous month’s transactions. No revenue share is paid on transactions from agents in Capped Status, as no Company Dollar is generated. C. Qualifications To Receive Revenue Share To receive both eXpansion Share and eXponential Share, an Agent must: 1. Be Revenue Share Eligible at the time of payout. 2. Hold an active real estate license or registration with eXp in any area where both parties conduct business.

eXp Realty (USA) Policies and Procedures Page 42 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES D. Manipulating Revenue Share Plan Prohibited Each Agent has an obligation to act in good faith in his or her dealings with eXp. Agents shall not attempt to manipulate the Revenue Share Plan. Examples of attempts to manipulate the Revenue Share Plan include, without limitation, each of the following: (1) engaging in the practice of sponsoring Straw Agents, and (2) adding any other Agent’s name(s) to transaction documentation who was not a true party to the transaction solely for the purpose of artificially qualifying that eXp Agent as an FLQA. eXp shall have the right and sole discretion to determine who is manipulating the Revenue Share Plan, and reserves the right to terminate Agents for such activities. eXp will also notify an Agent that it has released the licenses of any Agent(s) that it believes are Straw Agents and review the Agent’s recruiting practices with the Agent. If, after reviewing the recruiting practices with the Agent, the Agent continues to engage in, or appears to be engaged in, the practice of manipulating the Revenue Share Plan, the Agent may be restricted from sponsoring agents and/or released from eXp. E. Revenue Share Vesting Policy 1. Achieving Vested Status Except as otherwise provided elsewhere in these eXp P&Ps, to become vested in the Revenue Share Plan, an Agent must satisfy each of the following two conditions for not less than 36 consecutive calendar months (the “Vesting Period”): a) be in Good Standing; and b) be affiliated with eXp as a real estate licensee. 2. Maintaining Vested Status Once vested, an Agent shall remain vested in the Revenue Share Plan, subject to the following additional conditions: a) Within thirty (30) days from an Agent’s Offboard Date, if the Agent has achieved a vested status, as described above, the Agent must submit a request to eXp via email to [email protected] to be recognized as a vested Agent. b) For eXpansion Share: An Agent shall maintain their vested status in the eXpansion Share earned under the Revenue Share Plan from and after their Offboard Date, provided that they maintain a real estate license that is active and in good standing, even if they affiliate with a competitor (as described in the Competitor Affiliation is Prohibited section in these P&Ps). c) For eXponential Share: An Agent shall maintain their vested status in the eXponential Share earned under the Revenue Share Plan from and after their Offboard Date, provided that (i) they maintain a real estate license that is active and in good standing, and (ii) they do not affiliate with a competitor (as described in the Competitor Affiliation is Prohibited section in these P&Ps).

eXp Realty (USA) Policies and Procedures Page 43 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 3. Losing Vested Status Despite the statements in the “Maintaining Vested Status” section, above, eXp reserves the right, as determined in its sole discretion, to withdraw an Agent’s Vested Status if any of the following conditions are true: a) an Agent is convicted of a crime; b) an Agent commits or attempts to commit or admits to committing acts of moral turpitude or that are inconsistent with eXp’s core values; c) an Agent has engaged in legal action against eXp or acted in a manner that facilitates, or is in any way connected to, legal action against eXp; or d) an Agent has violated one or more obligations that survive the termination of their ICA. 4. Discretionary Regaining of Vested Status upon Reaffiliation If a vested Agent offboards from eXp, and subsequently re-affiliates with eXp, regardless of whether reaffiliation occurs during or after the Agent’s Original Sponsor Window (defined below), then that Agent may, in eXp’s sole and absolute discretion, be restored to their original position in the Revenue Share Plan (and regain their vested status), subject to the following conditions: a) Agent re-affiliates under their original sponsor; and b) Agent did not lose their vested status for any of the reasons specified in Section 3 (Losing Vested Status), immediately above. The “Original Sponsor Window” is the one (1) year period beginning on an Agent’s Offboard Date, during which time, if an Agent rejoins eXp, that Agent’s Sponsor will continue to serve in the same capacity. For avoidance of doubt, Agent’s failure to satisfy the conditions of maintaining their vested status under Section 2 (Maintaining Vested Status), above, shall not adversely impact the potential restoration of Agent’s original position in the Revenue Share Plan. Agent will not be entitled to receive any “back payments”; Agent will only be entitled to receive payments arising from their original position in the Revenue Share Plan which are generated from and after Agent’s new Onboard Date. F. Agent Succession Policy An Agent may nominate a successor to his or her position in eXp’s Revenue Share Plan (collectively, an “Agent position” or “Agent’s position”) in the event of the Agent’s death or permanent incapacitation. Upon the death or permanent incapacity of an Agent, such Agent shall automatically be considered Vested in the Revenue Share Plan regardless of whether the Agent has met the requirements under the Revenue Share Vesting Policy. Nomination of a successor may only be accomplished by correctly completing the “Rev. Share Position” Successor Nomination Form (the “Successor Nomination Form”), which can be found at www.exprealty.com/successornomination, and submitting it to the Onboarding team (for newly joining agents) or the eXpert Care team (for existing agents), as applicable, within eXp prior to such Agent’s death or permanent incapacity. Any Successor Nomination Form(s) submitted to eXp that is/are not properly completed will not be accepted. Nomination of a successor(s) becomes effective once the

eXp Realty (USA) Policies and Procedures Page 44 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Onboarding Team receives a correctly completed and signed copy of the Successor Nomination Form. Completed Successor Nomination Forms submitted by newly joining Agents shall be submitted together with the rest of their new agent documentation to the Onboarding team; all other Agents must submit their completed Successor Nomination Forms to the eXpert Care Team via email to [email protected]. Successor nomination(s) will only apply to the Agent’s position as identified by the Agent ID number provided in section 1 of the Successor Nomination Form. An Agent may nominate no more than one primary and one secondary successor at a time. A minor, trust, or entity cannot be nominated as a successor because the successor must be eligible to obtain and hold a valid real estate license. An Agent’s position may be transferred to the Agent’s secondary successor if no primary successor is living or able to accept the Agent’s position for any reason at the time of the Agent’s death or permanent incapacitation, or if the Agent’s primary successor is not approved by eXp. If both of the successors nominated by an Agent predecease the Agent then the Agent must change his or her successor nomination(s) or that Agent’s position will close upon that Agent’s death and no further successor nomination(s) will be accepted, with the exception of any surviving spouse that was not previously nominated. It is the sole responsibility of an Agent to change any nominated successors, except that, if the Agent was married and does not nominate a successor, or no nominated successor survives the Agent, the Agent’s spouse shall be deemed to be nominated as the Agent’s successor, provided that proof of marriage or a legally recognized union be provided to eXp upon request, and provided also that the Agent’s spouse meets all of the requirements to become an approved, succeeding Agent. In the event of divorce where a former spouse was a nominated successor to an Agent, such nomination will automatically lapse and will not be recognized by eXp unless a new nomination, dated after the divorce or termination, is submitted. An Agent can change his or her successor nomination(s) at any time by submitting one of the following to the eXpert Care Team at [email protected]: (i) a new Successor Nomination Form; or (ii) a letter of instruction to revoke the then current successor nomination(s) on file with eXp. The submitting Agent must sign and date the Successor Nomination Form or letter of instruction, as described immediately above, for his or her nomination change or revocation of nomination to be valid. A successor nomination may not be changed or revoked by will, codicil, trust, request made by email, telephone conversation, or any method other than by the Successor Nomination Form or letter of instruction, as described above. Before any nominated successor can be placed into another Agent’s position within eXp, the nominated successor must first be approved (through appointment) by eXp. eXp reserves the right, in its sole discretion, at any time and without prior notice, to decline to approve or accept any nominated successor for any or no reason. eXp shall not be required to approve the appointment of the nominated successor for an Agent that was not in Good Standing with eXp or for a nominated successor that is an existing Agent not in Good Standing. A nominated successor shall have a reasonable time, but in no event more than twelve (12) months from the date of Agent’s death or permanent incapacity, to become a licensed real estate professional and join eXp, which shall be determined by the nominated successor’s Onboard Date. All requests to exercise a successor’s nomination must be submitted to the Agent Compliance team via email to [email protected].

eXp Realty (USA) Policies and Procedures Page 45 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Nomination as a successor does not create any legal right(s) to, legal interests in, or any guarantee of approval and appointment as a successor by eXp. Additionally, an Agent’s position is not a property right that can be transferred through a will, trust instrument, probate proceedings, guardianship/conservatorship proceedings, divorce proceedings, sale and/or assignment, and/or any other legal process. For avoidance of doubt, an Agent’s legal representative (under a will), trustee (under a trust), attorney in fact (under a power of attorney), guardian or conservator (under a guardianship/conservatorship), or a court of competent jurisdiction (in legal proceedings), cannot nominate (or appoint) an Agent’s successor; only an Agent can nominate his or her successor by completing and submitting the Successor Nomination Form to eXp and only eXp can approve an Agent’s nomination and appoint a successor to an Agent’s position. An Agent’s position cannot be bought, sold, traded, or otherwise conveyed by an Agent; eXp reserves the right to deny approving and accepting the appointment of an Agent’s nominated successor if eXp, in its sole discretion, believes that an Agent’s position is being bought, sold, traded, or otherwise conveyed. Any revenue share earnings that would otherwise become payable during the period of time beginning on the date of an Agent’s death or permanent incapacitation and the nominated successor’s Onboard Date (if the successor is not already an Agent), or appointment approval date (if the successor is already an Agent), shall accrue for a period not to exceed twelve (12) months following Agent’s death or permanent incapacitation. The accrued revenue share earnings shall be paid to Agent’s approved and appointed successor. If Agent’s nominated successor does not become approved and appointed on or before the twelve (12) month period, then all such accrued revenue share earnings shall lapse and will not be paid out to the Agent’s successor or held for payment at a later date. An Agent’s position may be transferred through Agent Succession in perpetuity. If an Agent holds more than one Agent position through Agent Succession, that Agent can only earn an ICON Agent Award on one Agent position. If an Agent holds more than one Agent position, that Agent may nominate different successor(s) to each Agent position that they hold. G. Modifications to the Revenue Share Plan The stated revenue share payout structure may be modified to allow eXp to better compete, attract and retain agents as well as to maintain a base level of profitability. The terms and conditions of this policy, or to eXp’s Revenue Share Plan, are subject to modification as and when determined by the Executive Management of eXp and/or the Board of Directors of eXp World Holdings, Inc., without notice to or approval from Agents. An explanation about revenue sharing calculations as well as other aspects of the Revenue Share Plan can be obtained by contacting eXp’s Revenue Share Support Team at [email protected]. Notwithstanding anything to the contrary in the ICA or in eXp’s P&Ps, no modifications to the Revenue Share Plan will require eXp to provide notice of such modifications to Agents, or to obtain signatures from Agents, in order for such modifications to be binding against Agents. **In acknowledgment of certain contributions made to eXp’s growth and infrastructure, eXp reserves the right to designate certain managing brokers, executives and key personnel as being in Good Standing with eXp notwithstanding any discrepancies that may exist from time to time between their own personal production and the criteria set forth in the ICA and the eXp P&Ps. In addition, such personnel may be deemed to be in Good Standing even though no monthly Cloud Brokerage Fee is assessed against such personnel.

eXp Realty (USA) Policies and Procedures Page 46 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES XIII. AGENT ATTRACTION Agents can influence prospective Agents not yet affiliated with an eXp brokerage firm to join eXp and leverage their efforts to earn Revenue Share. “Agent Attraction” is the process of engaging credible, ethical, and productive real estate professionals and inviting them to join an eXp Brokerage (defined below). The policies in this section are based on eXp’s core values and serve as a guide for Agents as they participate in ethical and successful Agent Attraction activities. All efforts related to Agent Attraction that violate any law, rule, or regulation on a national, state, and local level are prohibited. A. Sponsorship Interference Prohibited 1. Agents are prohibited from encouraging prospective Agents already engaged in the Agent Attraction process with another Agent to change their intended sponsorship declaration. 2. It is the responsibility of each Agent to discover if a prospective Agent is already engaged in the Agent Attraction process with another Agent and shall refer them back to their prior contact as a professional courtesy. 3. Each Agent is responsible to ensure that the recipients of their Agent Attraction communication are not currently eXp Agents. These types of solicitations and any other actions encouraging a change of sponsorship by a current Agent are considered to be interference and are prohibited. 4. Agents are prohibited from encouraging existing Agents to strategically offboard from eXp; this includes the practice of encouraging existing Agents to offboard from eXp, with the intention to later rejoin eXp, but only after the closing of the Original Sponsor Window. 5. Any effort to interfere with, coerce, or otherwise unethically convince a prospective or current Agent to change their intended sponsorship declaration (or current sponsor) is subject to corrective action up to and including termination of their affiliation with, and severance, from eXp. 6. Incentives may not be used as a means to persuade a prospective Agent to change their intended sponsorship declaration. This includes offering benefits outside of eXp business model such as cash, access to paid services, gifts, office space, guaranteed leads, the payment of monthly technology and registration costs with eXp, etc. 7. Disparaging fellow Agents in an effort to persuade a prospective Agent to change sponsorship or their intended sponsorship declaration is strictly prohibited. B. Income and Lifestyle Claims Agents at eXp can generate income through three primary opportunities: real estate compensation, equity opportunities, and eXp’s Revenue Share Plan. When discussing these opportunities with others, Agents must ensure that any statements about potential earnings follow the income claim guidelines outlined below. Income claims include any communication or content that shows, states, or implies how much an Agent has earned or could earn through the eXp opportunity. This includes earnings statements, visual content, presentations, social media posts, and other materials shared verbally, digitally, or in writing.

eXp Realty (USA) Policies and Procedures Page 47 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Lifestyle claims, such as images or videos that imply financial success from eXp’s revenue share model, whether stated explicitly or implicitly, must follow income claim rules and include the required disclaimer. All claims related to earning income with eXp must adhere to the following guidelines: 1. Income claims must be truthful, accurate, and not misleading in any way. 2. All claims must set appropriate expectations by providing context, including the time, work, and effort required to achieve the stated or implied outcome. 3. Income claims must be accompanied by eXp’s income disclaimer statement that also includes a link to eXp’s U.S. average income disclosure chart. Agents shall place the following statement clearly and conspicuously in their content: “These figures are not a guarantee, representation or projection of earnings or profits you can or should expect. They also do not include expenses incurred by agents in operating their businesses. eXp makes no guarantee of financial success. Success with eXp results only from successful sales efforts, which require hard work, diligence, skill, persistence, competence, and leadership. Your success will depend upon how well you exercise these qualities. Visit www.exprealty.com/income for average agent earnings and additional information about earning opportunities with eXp.” 4. Agents may use eXp-produced marketing materials or create their own content to describe income opportunities. Agent-created content that includes income claims or earnings examples must be submitted for review and approval by their State Broker team and the Agent Compliance team at [email protected] before it is shared in any form. 5. Agents are not permitted to use terms such as “residual income,” “passive income,” or similar phrases that suggest income can be earned without meaningful effort when promoting the eXp opportunity. Any language that implies income is easy, automatic, or guaranteed violates this policy. 6. The creation and use of online revenue share calculators by agents or third parties is strictly prohibited. However, agents may use the official eXp Revenue Share Calculator at https://revsharecalculator.exprealty.com, provided they follow all terms of use and guidelines set by the company. C. Recruiting 1. Except as expressly provided by eXp, in writing, real estate licensees who hang their license with eXp are the only individuals authorized to present the eXp opportunity to prospective Agents. 2. Agents may employ the services of assistants (including licensed, unlicensed and virtual) to engage in limited Agent Attraction-related activities provided they adhere to these guidelines: a) Assistants may not actively recruit individuals or present eXp opportunity.

eXp Realty (USA) Policies and Procedures Page 48 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES b) Compensating individuals, in any manner, either directly or through affiliation, who are not real estate licensees affiliated with eXp, to recruit or attract agents to eXp is strictly prohibited. Agents shall not hire or engage any third parties for the purpose of engaging in recruitment or attraction activities on that Agent’s behalf. c) Assistants may set appointments for the Agent who employs them to present eXp opportunity to prospective Agents. d) Assistants must clearly identify the Agent or team they are representing, provide opt-out instructions, and present the Agents’ contact information to the prospective Agent they are communicating with. For example, if an assistant is engaged by a particular Agent and not by eXp (as a company), that assistant cannot say that they are calling on behalf of eXp; they may only say they are calling on behalf of the Agent on whose behalf they are engaged. e) The hiring of assistants whose responsibilities will include participation in the above Agent Attraction activities must comply with the policies found in these eXp P&Ps (respectively titled “Agent Assistants - Unlicensed,” and “Agent Assistants – Licensed”) that regulate the utilization of assistants. 3. The use of agents, hired agents, staff, recruitment companies or other similar third-party services to send unsolicited text messages, emails, place phone calls, etc. is not allowed in the Agent Attraction process. 4. Compensating individuals, in any manner, who are not real estate licensees affiliated with eXp, to recruit or attract agents to eXp is strictly prohibited. An Agent shall not hire or engage any third parties for the purpose of engaging in recruitment or attraction activities on such Agent’s behalf. 5. Agents may utilize prospective-agent prospect lead-generating services provided that the prospective-agent leads have given permission to be contacted and the initial contact with such leads is in compliance with the terms and services of platforms where the contact takes place and adheres to any applicable laws such as the Solicitation Laws. Lead-generating services and their representatives may not present the eXp opportunity. 6. Agents are prohibited from offering cash or stock incentives as a means to recruit prospective Agents. However, Agents may offer to help cover some de minimis transition (trivial or minor) expenses such as, new signs, business cards, etc. 7. Unless expressly authorized by eXp’s Agent Compliance Group, in writing, Agent-created content that includes comparative advertising of eXp to a competing real estate brokerage is prohibited. D. Sponsorship 1. Definition and Responsibilities The Revenue Share Plan is a way for eXp to say “thank you” to Agents who attract serious and productive professionals who fit culturally with eXp and its core values. Once a joining Agent selects a Sponsor and joins eXp, their Sponsor enters into a financial relationship with eXp where eXp pays a percentage of Company Dollar to that individual in the form of revenue share. If the Sponsor leaves eXp, that financial relationship is severed and their position in the Revenue Share Plan reverts to eXp. It is the right of a prospective Agent to identify and select the individual they choose to name

eXp Realty (USA) Policies and Procedures Page 49 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES as their Sponsor. The Sponsor is the Agent who a joining Agent (sometimes referred to as a “Sponsee” in this context) identifies as the person who most influenced them to join eXp. This declaration is made during the process of completing the ICA. An Agent’s sole requirement to qualify as a Sponsor is selection by the joining Agent as the individual who most influenced them to join eXp. While Sponsors are encouraged to support joining Agents throughout the joining process and beyond; Sponsors are not required to do so. The role of Sponsor is distinctive from other roles like a mentor, coach, or team leader. In some cases, these roles are assumed by the same person, but they are not mandatory for a Sponsor. A Sponsor has no binding authority, on behalf of eXp, as it pertains to establishing or modifying the terms of any relationship between Agent and eXp. 2. Change Requests In order to maintain the integrity of eXp’s Revenue Share Plan, eXp may only grant changes in sponsorship in very limited situations. Changes in sponsorship are only permitted under very extraordinary conditions that meet one or more of the criteria below. Except in situations with extenuating circumstances as determined by eXp, sponsorship change requests must be submitted to eXp via email at [email protected] within thirty (30) business days of the Onboard Date of the Agent requesting the sponsorship change. Sponsorship change request criteria: a) Errors (1) Clerical, administrative, or system errors on the part of eXp. (2) Misidentification of sponsoring Agent by eXp or joining Agent (e.g., John Smith as opposed to Jon Smith). (3) Omission of sponsor name during the enrollment process (if requested by eXp, in its sole discretion, Agent may be required to provide evidence of prior relationship with the requested sponsor and their attraction efforts). (4) Sponsor change requests within the same Revenue Share Group in cases where the Agent has misidentified sponsor as the upline/team leader (requires written approval from the current sponsor). b) Misconduct (1) Misleading or fraudulent attraction efforts where a prospective Agent is led to believe they are signing up under a specific individual, but the listed sponsor is another Agent not previously discussed or disclosed to the prospective Agent. (2) Sponsorship change based on improper enrollment of the prospective Agent without their authorization or signing up a prospective Agent without disclosing eXp as the brokerage. c) Brokerage Migration (1) In situations where an independent brokerage moves to eXp and the joining Agent had previously been with eXp and is still within the Original Sponsor Window, eXp will allow the joining Agent to select a new sponsor under the joining team. Agents wishing to leave eXp of their own volition (and not at the prompting of any other eXp Agent) in order to change their selected sponsor must remove their license from eXp and allow the Original Sponsor Window to expire before they can rejoin under a different sponsor. If the

eXp Realty (USA) Policies and Procedures Page 50 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Agent returns before expiration of the Original Sponsor Window, the Agent must name their original sponsor. Sponsorship changes outside of the preceding criteria will only be made at eXp’s discretion. All other sponsorship selections, placements, and decisions are considered irrevocable. 3. Co-Sponsor To provide better support for new Agents, eXp offers a “Co-Sponsor” option alongside existing sponsor concepts. When joining eXp, an eligible new Agent may select a “Co-Sponsor” (provided that Agent has also selected a Sponsor). While a Sponsor remains that individual who most influenced Agent to join eXp, a Co-Sponsor is an existing Agent who agrees to take on extra responsibilities to support the new Agent (sometimes referred to as a “Sponsee” in this context). When a Sponsee selects a Co-Sponsor, two things will happen: First, and from the perspective of a Sponsor, that Sponsee and each individual within that Sponsee’s Revenue Share Group will move down one Tier within eXp’s Revenue Share Plan. For example, prior to selecting a Co-Sponsor, Sponsee was a “Tier 1” of their Sponsor; but, after selecting a Co-Sponsor, Sponsee becomes a “Tier 2” of their Sponsor. Second, and from the perspective of a Co-Sponsor, that Sponsee and each individual within that Sponsee’s Revenue Share Group will make a lateral move under Co-Sponsor within eXp’s Revenue Share Plan. For example, prior to selecting a Co-Sponsor, Sponsee was a “Tier 1” of their Sponsor; but, after selecting a Co-Sponsor, Sponsee becomes a “Tier 1” of their Co-Sponsor. Additional terms and conditions pertaining to the “Co-Sponsor” option are available for viewing at https://exptoolkit.com/co-sponsor. Unless otherwise specified at https://exptoolkit.com/co-sponsor, the same limitations and conditions that apply to changing Sponsors also apply to changing Co-Sponsors, including application of the “Original Sponsor Window” (which shall apply to a Co-Sponsor in the same way it does to a Sponsor). E. Agent Prospects, Contacts, and Leads Agents shall not engage in the unlawful recruitment of prospective Agents, including, but not limited to, intentionally and knowingly encouraging or facilitating a franchise broker/owner to (i) abandon their franchise prior to the expiration term in the franchise agreement or (ii) otherwise breach their franchise agreement to affiliate with eXp. Any violation of state or national law during Agent Attraction activities is, at eXp’s exclusive election, grounds for termination of an Agent’s ICA with eXp or exclusion from participation in eXp’s Revenue Share Plan. Agent Attraction contacts and leads must be sourced and managed appropriately in accordance with the following guidelines: 1. Agent is responsible to verify that Agent prospect contacts and leads are not currently Agents who are licensed with eXp. “Blind” attraction efforts between existing Agents may constitute

eXp Realty (USA) Policies and Procedures Page 51 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES interference and are strictly prohibited. 2. Agents are prohibited from harvesting prospective Agent contact information from databases such as the MLS, Boards, or other sources in order to broadcast attraction-related information to large groups through mass emailing, robo-dialers, text messages, mailers (flier), online messenger, or other channels. 3. Leads and contacts obtained from third-party services or other forms of recruiting assistance must be verified by the Agent as having given permission to be contacted regarding eXp opportunity. It is the sole responsibility of the Agent to certify this information. 4. Prospective Agent contacts must knowingly opt-in to receive information regarding eXp opportunity and must be provided with easily-accessible means to opt-out of future solicitations related to Agent Attraction. Agents must honor opt-out requests promptly and cease further contact. Outreach must be performed in accordance with the Solicitation Laws, and all other applicable federal, state and local guidelines, and their implementing rules and regulations. Transmitting unsolicited voice and text messages (as well as other forms of communication) is heavily restricted and regulated under the Solicitation Laws and other federal laws and regulations as well as various state and local jurisdictions’ laws and regulations. Each Agent should consult their legal advisor to ensure compliance with the Solicitation Laws. 5. Agents shall not engage in the unlawful recruitment of prospective Agents, including, but not limited to, intentionally and knowingly encouraging or facilitating a franchise broker/owner to (i) abandon their franchise prior to the expiration term in the franchise agreement or (ii) otherwise breach their franchise agreement to affiliate with eXp. Any violation of state or national law during Agent Attraction activities is, at eXp’s exclusive election, grounds for termination of an Agent’s ICA with eXp or exclusion from participation in eXp’s Revenue Share Plan. F. Attraction Marketing and Communication 1. All content (both offline and online) related to Agent Attraction must adhere to the guidelines and approval process found in the Marketing And Advertising section of these eXp P&Ps. 2. Any communication for the purpose of Agent Attraction (whether solicited or unsolicited) through email, telephone, text message, social media, messenger, etc. must be done so in adherence with national, state, and local laws that regulate communication including, but not limited to, the Solicitation Laws. 3. Social Media a) Paid ads for the purpose of Agent Attraction through social media, search engines or other online advertising platforms are prohibited. b) Agents are encouraged to leverage their social media networks and execute their own organic social media campaigns to share the eXp opportunity. c) Accurate and truthful representation in professional profiles, whether online or otherwise, is required. Agents must avoid using titles which would reasonably lead someone to believe that they are an employee of eXp or representing themselves as an employee of eXp.

eXp Realty (USA) Policies and Procedures Page 52 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 4. In-person and online meetings must be advertised and conducted in accordance with our core values of transparency and integrity. Agents must deliver on advertised content and avoid “bait and switch” tactics to entice attendees to join an Agent Attraction event. a) “Lunch and Learns”, webinars, conference calls, and other similar opportunities must be advertised and executed in such a way that prospective Agents do not feel deceived or misled in any way. If Agents host such events the intent to share eXp opportunity must be clearly stated in all communications advertising for the event. b) Paid ads for Agent Attraction are not allowed. Therefore, any event with the intention of Agent Attraction may not be advertised through paid means. These types of events may be shared organically through social media, through opted-in email lists, etc. c) If an Agent event provides education or training on a real estate-related topic (not Agent Attraction), you may advertise (paid and non-paid) for this event. At the conclusion of an Agent-hosted event you may let attendees know that you will be taking a short break allowing them to leave. If they choose to stay, you may then engage those who remain in the Agent Attraction process after a clear break has been taken from your original presentation. The intention and spirit of this provision is that an Agent cannot advertise for an attraction event; consequently, Agent cannot “bait and switch” by advertising for an education or training event on a real estate-related topic, provide token coverage of that topic, and use the balance of that event to engage in the attraction process. G. Reporting Agent Attraction Violations It is at eXp’s sole discretion to determine if a practice not mentioned in the policies above is aligned with its culture and core values. eXp reserves the right to ask Agents to discontinue any Agent Attraction practice that it deems to be in conflict with these policies and procedures and eXp’s core values. Agents must abide by the articles set forth in the National Association of REALTORSⓇ Code of Ethics, eXp’s Core Values, and these eXp P&Ps. Agents must always represent eXp and its business model with the highest degree of accuracy, integrity, and professionalism. Agent Attraction and participation in the revenue share plan is a privilege and not a right. Any violation of these guidelines must be reported to the Agent Compliance team by email at [email protected]. H. Stock Solicitations Prohibited As a business having a parent corporation with publicly traded common stock, eXp is subject to requirements relating to the substance and manner of public communication. Federal securities laws generally require that, in the absence of an exemption, offers to buy stock, and solicitations regarding stock, need to be preceded by a filed registration statement relating to the offer. All Agents of eXp shall follow the guidelines below (in addition to the eXp World Holdings, Inc. Insider Trading Policy, also below) for the protection of eXp and those affiliated with it. Failure to adhere to these guidelines will result in immediate release from eXp. 1. All directors, officers, employees and Agents are subject to SEC Insider Trading regulations which include the obligation not to disseminate confidential information of eXp.

eXp Realty (USA) Policies and Procedures Page 53 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 2. Agents cannot solicit interest in, or encourage others to buy eXp World Holdings, Inc.’s stock, or promote eXp World Holdings, Inc.’s stock or stock’s growth as the basis for encouraging others to join eXp, unless expressly authorized by eXp World Holdings, Inc. and pursuant to applicable securities laws. 3. Agents should only discuss the equity program or similar stock incentives according to official eXp literature. 4. Agents may not post their equity account balances on social media whether it is in the form of a screenshot, a graphic, or in a text description. This prohibition also extends to inclusion in presentations, videos, and other content that is used for Agent Attraction. 5. Agents must adhere to all guidelines found in the Income Claims section of the eXp P&Ps when discussing, presenting, or sharing their participation in the equity opportunities with eXp both in public and private conversations (including social media). Agents are encouraged to direct potential Agents to eXp approved resources or publicly available information. I. Event Sponsorship Requests from Vendors From time to time, opportunities may arise for vendors to sponsor local events for eXp (for example, and without limitation, eXp Regional Rallies events). Individuals that are not eXp Agents may or may not attend such local events. By contrast, EXPCON events are not “local” events for purposes of this section of this eXp P&Ps. If Agent learns of a vendor that desires to sponsor a local event for eXp (hereinafter, a “Potential Local Sponsor”), the Agent will ask their State Broker to submit a sponsorship request to eXp’s Brokerage Operations department at least two weeks prior to the event. eXp reserves all rights to refuse such sponsorship by a Potential Local Sponsor for any reason. At NO time is the Agent to handle the funds without written approval from eXp’s Brokerage Operations department (through one of its Regional Directors). If the Potential Local Sponsor is not a participant in eXp Solutions (formerly referred to as Affiliated Services, and Preferred Partners), eXp will not advertise or otherwise promote Potential Local Sponsor in eXp World, on eXp’s Slack application, in eXp’s newsletters, or in eXp-generated emails; however, an acknowledgement of the Potential Local Sponsor’s sponsorship (in the form of a “thank you”) may be made on eXp’s Slack application, in eXp’s newsletters, and in eXp-generated emails. XIV.COMPANY TOOLS AND INFORMATION A. eXp Communication and Training Platforms Through Slack, eXp Enterprise and eXp World, eXp provides best practices in different parts of the business. It is the responsibility of the Agent to stay up to date on the latest policies and procedures, as well as the latest best practices relative to working with any tools and services eXp has deployed or is being recommended for Agents to use. 1. Agents shall not give out usernames or passwords or any other access to any internal or eXp provided third party system. 2. Agents may not share any recorded video (e.g., event instances in eXp World, sessions from

eXp Realty (USA) Policies and Procedures Page 54 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES eXp Shareholders Summit, sessions from eXpCON, etc.) intended for internal use by eXp without receiving written approval from eXp. 3. When hosting a session in eXp World, Agents may record the session but only with the consent of the attendees. 4. Distribution of recorded or captured content through websites and social media (e.g., Facebook, LinkedIn, YouTube, etc.) is not allowed without eXp’s written consent. 5. eXp reserves the right to limit the use of any video content to the extent eXp determines in its sole discretion that the video content does not contain accurate information about eXp or does not accurately represent eXp’s desired image or brand. B. Slack Slack is a core internal communication platform used by eXp and its Agents to communicate, collaborate, share information, and foster community. In keeping with eXp’s Core Values – particularly Community, Collaboration, and Transparency – all users are expected to engage respectfully, responsibly, and professionally. ‘.The following guidelines apply to all Agents’ use of Slack to ensure a safe, productive, and compliant digital environment. 1. Agent Conduct Guidelines a) Agents may not post or share content that is aggressive, defamatory, discriminatory, sexually explicit, offensive, or otherwise harmful to the eXp community. This includes public channels, private channels, and direct messages. Content of this nature may be removed, and disciplinary action may follow’. b) Disparagement of fellow Agents, eXp staff, eXp leadership, or competitors is strictly prohibited. c) Self-promotion, marketing of services or merchandise, and recruiting other Agents is only permitted in approved channels. Posting promotional content in non-designated channels or using direct messages for solicitation without prior consent is not permitted. d) Agents may not use Slack to “cold message,” recruit, or send unsolicited promotional messages to other users through direct messages, group chats, or channels. e) Use of “@channel”, “@here”, or similar mass notifications should be limited to urgent, relevant communication and never used for marketing or self-promotion. 2. Channel and Creation Guidelines Slack channels are designed to promote collaboration and community. Agents may create or join channels depending on their workspace permissions, but they must follow ..these guidelines: a) Before creating a channel, Agents must ensure a similar channel does not already exist. b) Channels must not include “eXp” in the name unless specifically approved by the company. Official company channels will be labeled accordingly and may be moderated or administered by eXp staff. c) Channels should be created for business-relevant discussions, projects, or shared interests aligned with eXp’s mission and Core Values.

eXp Realty (USA) Policies and Procedures Page 55 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES d) Agents must not create channels or chats that imply eXp endorsement, sponsorship, or support unless expressly authorized, in writing. Support requests must be directed to official support channels. e) Agents are discouraged from adding users to private channels or DM groups without prior consent. Communication should always be respectful of others’ time, privacy, and professional boundaries. f) Channels or messages that violate these guidelines may be removed, and eXp reserves the right to assign or remove moderators as needed to maintain community standards. 3. Reporting & Oversight While administrative access and oversight tools are limited within Slack, eXp is developing a custom reporting function that, once enabled, will allow inappropriate content to be flagged and routed to a designated moderation team. In the interim, concerns should be reported to [email protected]. Slack conversations are subject to these eXp P&Ps and eXp’s Code of Conduct, regardless of whether they take place in public or private settings. Violations may result in content removal, channel moderation, loss of Slack access, or further disciplinary action. C. eXp World Even though eXp World is a virtual work environment it should be treated as a professional place of business. Appropriate workplace etiquette must be observed including the personal conduct and behavior of all users. Agents shall adhere to eXp’s Code of Conduct, Core Values, and avoid any actions or content that are argumentative, discourteous, or otherwise unprofessional while in eXp World. Agents should also become familiar with the platforms’ Terms of Service and Privacy Policy found at https://learn.framevr.io/tos-privacy-policy. Failure to adhere to these guidelines could result in disciplinary action. D. eXp Email for Agents eXp provides to each Agent an eXp email alias, also known as a forwarding or alternate email address, that is configured to forward to the personally owned and controlled email address an Agent provides to eXp for purposes of conducting eXp business. eXp email aliases do not have a mailbox of their own, and instead only forward all incoming emails to an Agent’s personal email address. Email aliases may be delivered by various providers from time-to-time as requirements and costs dictate. eXp email aliases enable forwarding to other email addresses and systems. eXp does not and cannot access Agent personal email accounts and only receives logs of forwarding activity related to each eXp provided email alias. eXp provided email aliases are not configured for sending email from the provided email alias, Agents are responsible for that configuration. Agents are responsible for ensuring their respective eXp email alias forwards incoming email to their correct email account, so that important communication from eXp, their State Broker, and/or actual or prospective clients is not missed. For avoidance of doubt, eXp employees use eXp provided email accounts using the “@exprealty.net” email domain to communicate with Agents and other eXp employees, and to conduct eXp business, as opposed to Agents’ eXp email aliases which use the “@exprealty.com” email domain.

eXp Realty (USA) Policies and Procedures Page 56 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Agents are strongly encouraged to use email security best practices to protect their email accounts from unauthorized access and avoid wire fraud attempts. Agents are also strongly encouraged to use the Wire Fraud Email Notice Template provided by the National Association of Realtors® at https://www.nar.realtor/law-and-ethics/wire-fraud-email-notice-template. XV. ICON AGENT AWARD The ICON Agent Award is aimed at attracting and incentivizing top Agents into eXp. The ICON Agent Award provides each qualified “ICON” with publicly traded eXp World Holdings, Inc. common stock upon the achievement of certain production and cultural goals within an Agent’s Anniversary Year. The ICON Agent Award Program is subject to approval by the Board of Directors each year. Full qualification details can be found by visiting the ICON Agent Award webpage at join.exprealty.com/icon-agent-award. An Agent is not eligible to receive an ICON Agent Award (or receive ICON status), unless the Agent is in Good Standing with eXp. XVI.EXP MENTOR PROGRAM Generally, if an Agent has not completed three purchase Transactions or sale Transactions (or any combination thereof) within the twelve (12) month period immediately preceding the Agent’s Onboard Date (collectively, the “Mentor Program Requirements”), the Agent will be required to participate in the eXp Mentor Program, as a mentee, upon transfer of their license to eXp. In that event, Agent will be required to enter into the eXp Mentor Program Addendum to ICA, the form of which will vary depending upon the state in which the Agent is licensed. Notwithstanding the preceding, eXp reserves the right to require an Agent to participate in the eXp Mentor Program, as determined in its sole discretion. eXp reserves the right to require any Agent to re-enroll in the eXp Mentor Program as may be required by applicable law. If an Agent enrolled in the eXp Mentor Program has not been assigned a mentor, then that Agent’s mentor shall be that Agent’s State Broker. eXp may share the mentee’s personal contact information with other Agents that provide assistance in the eXp Mentor Program. XVII. EXPRESSOFFERS INVESTOR REFERRAL FEE Agents desiring to participate in eXp’s ExpressOffers program and generate additional referral fees by referring investors to eXp must first complete the ExpressOffers training and enter into the ExpressOffers Investor Referral Addendum to Independent Contractor Agreement. XVIII. MULTI-GLOBAL LICENSE PROGRAM A. Background The eXp World Holdings, Inc. family of real estate brokerage companies is comprised of the following brands: eXp® Realty and eXp® Commercial. Each brand conducts its own in-country operations through specific brokerage companies that are licensed or registered to engage in the real estate brokerage

eXp Realty (USA) Policies and Procedures Page 57 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES business in their particular jurisdiction (whether country, state, province, region, etc.) (each, an “eXp Brokerage”). Except as it pertains to the brokerage companies operating under the eXp® Realty (USA) brand, and eXp® Commercial (USA) brand, respectively, each eXp Brokerage operating outside of the United States maintains its own form of Independent Contractor Agreement that is to be used by any individual desiring to affiliate with that eXp Brokerage, in that jurisdiction, for the purpose of engaging in real estate brokerage activities on that eXp Brokerage’s behalf in that jurisdiction. B. Multi-Country Affiliation (Generally) The “Multi-Global License Program” is applicable in instances where an Agent desires to affiliate with two or more eXp Brokerages, each in a different country (e.g., with eXp Commercial, LLC in Arizona, and with eXp Italia S.r.l. in Italy). The Multi-Global License Program is not applicable in instances where Agents that are or desire to become affiliated, (1) with two or more eXp Brokerages within the same brand and operating within the same country (e.g., with eXp Realty, LLC in Arizona, and with eXp Realty of California, Inc. DBA “eXp Realty” in California), or (2) with two or more eXp Brokerages across different brands and operating within the same country (e.g., with eXp Commercial, LLC in Arizona, and with eXp Realty of California, Inc. DBA “eXp Realty” in California). C. Agents’ Additional Affiliation Under our Multi-Global License Program, Agents are permitted to affiliate with any eXp Brokerages, provided that, (1) the eXp Brokerages are in different countries, and (2) the Agent satisfies all of the terms, conditions, and requirements of each such eXp Brokerage. By affiliating across national borders with more than one eXp Brokerage, an Agent automatically becomes subject to all of the terms and conditions of the Multi-Global License Program. D. Agents’ Independent Obligations Unless other terms apply, all Agents participating in the Multi-Global License Program shall abide by all monetary, policy, and contractual obligations imposed upon them by each eXp Brokerage with whom they are affiliated. An Agent’s affiliation with more than one eXp Brokerage will not excuse that Agent from any of his or her payment or performance obligations to any other eXp Brokerage with whom the Agent is affiliated. Agents’ payment and performance obligations to each eXp Brokerage are distinct obligations. So, for example (and without limitation), Agents will have to pay all fees imposed upon them by each eXp Brokerage with whom they are affiliated; Agents will have to honor all policies and procedures applicable to each eXp Brokerage with whom they are affiliated; and Agents will have to honor the terms and conditions of each Independent Contractor Agreement to which they are a party. E. “Capped Status” Matters Unless other terms apply, all matters concerning achieving a “Capped Status,” as applied by each eXp Brokerage with whom an Agent is affiliated, shall co-exist and apply independently. An Agent’s Company Dollar Cap, Capping Period, Cap Reset Date, and Anniversary Year, will be applied separately as between each eXp Brokerage with whom the Agent is affiliated. This means, for example, that if an Agent is affiliated with two eXp Brokerages, that Agent can (and likely will) have two different Cap Reset Dates, Capping Periods, and/or achieve a Capped Status at two different times (if at all), and so on. In addition, Company Dollar earned and collected from an Agent by any eXp Brokerage with whom that Agent is affiliated will not be aggregated with Company Dollar earned and collected from the Agent by

eXp Realty (USA) Policies and Procedures Page 58 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES any other eXp Brokerage with whom that Agent is affiliated (for the purpose of determining whether the Agent is considered to be in a Capped Status in any country). For example, assume that an Agent is affiliated with two eXp Brokerages, namely eXp Realty, LLC (in the USA) and eXp Italia S.r.l. (in Italy). If the Agent has satisfied all of the requirements to reach a Capped Status under eXp Italia S.r.l., then the Agent shall be considered to be in a Capped Status with respect to only eXp Italia S.r.l., and not with respect to eXp Realty, LLC. Company Dollar collected by eXp Realty, LLC (in the USA) will not be combined with any Company Dollar collected by eXp Italia S.r.l. for the purpose of determining whether that Agent is to be considered in Capped Status at eXp Italia S.r.l. F. ICON Agent Awards All matters concerning ICON Agent Awards, as applied by each eXp Brokerage with whom an Agent is affiliated, shall co-exist and apply independently. Agents can earn an ICON Agent Award in each country where an Agent is affiliated with an eXp Brokerage, according to each such eXp Brokerage’s own rules. However, earning an ICON Agent Award in one eXp Brokerage does not mean that an Agent has or will earn an ICON Agent Award in any other eXp Brokerage. G. Sponsor; FLQA; Initial FLQA Period Agents cannot have more than one Sponsor at any given time when associated with any eXp Brokerage (i.e., Agents can only have one Sponsor, regardless of how many eXp Brokerages they are affiliated with). Agents shall only be considered an FLQA once, at any given time, for their Sponsor. The Initial FLQA Period shall only apply one time, and with respect to that particular eXp Brokerage with whom an Agent first satisfies the applicable FLQA requirements. We have no obligation to notify any Sponsor that an Agent sponsored by that Sponsor, is a participant in the Multi-Global License Program. XIX. LEGAL, INSURANCE, AND COMPLIANCE WITH THE LAW A. Antitrust The amount or rate of real estate compensation is not fixed by law. They are set by each Agent individually and may be negotiable between a buyer or seller, and Agent. eXp is a full service real estate brokerage company. As such, compensation rates of eXp are determined by each Agent on a transaction by transaction basis, and such rates are to be based on the value of the services provided and competitive market conditions. Compensation rates are determined solely by agreement between the Agent and the selling party or buying party. Agents shall not participate in any discussions with individuals affiliated with any other company concerning the compensation rates charged by eXp or any other real estate company. When soliciting a listing or negotiating any agreement, Agents shall not make any reference to “prevailing” or “standard” compensation rates in the market or any other words that suggest that the compensation rates are uniform, standard, set by law, or otherwise non-negotiable. Any advertised compensation rate for service must be clear and prominent, and specify that it is the Agent (or team) that is setting the compensation rate, and not eXp. Listing Agents shall work with sellers to determine the buyer-broker compensation to be offered, if any.

eXp Realty (USA) Policies and Procedures Page 59 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES B. Conflicts of Interest Agents shall avoid engaging in activities that would result in a question of business ethics or a compromise in the Agent’s loyalty to eXp or clients. Questions regarding potential conflicts must be directed to the Agent’s State Broker. When purchasing an eXp listing, it must be disclosed in the contract that the Agent is a member of eXp. Additionally, no Agent shall be involved in any form of settlement service or receive income or benefits “for value” directly from a settlement service company while actively licensed with eXp. Buyer Agents shall enter into a written agreement with the buyer prior to touring a home and shall not filter out or restrict listings communicated to customers or clients based on the existence or level of compensation offered. C. Data Security and Client Privacy Agents will come in contact with personal and confidential information in the day-to-day course of their business. All Agents of eXp are expected to become familiar with and follow a course of action concerning the transmission, handling, storage, and disposal of all personal and confidential information that is in alignment with all local, state, and federal laws regarding data security and client privacy. Agents may have multiple roles with regard to data privacy and security depending on the stage of the client relationship. For example, Agents may engage with many prospective clients and build a book of contacts that have not entered into a contractual relationship with eXp. In this example, Agent is determining the data collection and processing activity and must do so in accordance with applicable law. Once a client enters into a contractual relationship with eXp, Agent now plays a dual role where Agent is asked by eXp to process specific data to complete a transaction and such data must be processed in accordance with applicable law and eXp’s Privacy Policy and Data Processing Policy, which may be found by visiting https://expworldholdings.com/privacy-policy/. Agents are encouraged to review the National Association of REALTORS® Data Security and Privacy Toolkit found at https://www.nar.realtor/data-privacy-security/nars-data-security-and-privacy-toolkit (including its Cybersecurity Checklist: Best Practices for Real Estate Professionals found at https://www.nar.realtor/law-and-ethics/cybersecurity-checklist-best-practices-for-real-estate-professionals), and to adopt those “best practices” presented by the National Association of REALTORS®. If an Agent fails to secure their client’s data and confidential information, the Agent will defend, indemnify, and hold eXp, and its principals and affiliates harmless against any and all claims, complaints, or actions that may arise from such a departure. In addition, failure to comply with this Policy is grounds for the immediate release of the Agent’s license and removal from eXp. D. Do Not Call Rules Agents must stay up-to-date on rules relating to the National Do Not Call Registry (See: www.ftc.gov/donotcall), as well as all anti-spam laws and regulations (See: www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/can-spam-rule). Cold calling must be done in compliance with applicable state and national laws. Any fines that result from any violation of the “do not call” law or any other solicitation law will be paid for by the Agent who broke said rule. Agents are encouraged to leverage “eXp Dial Safe” for scrubbing of all telephone numbers against applicable Do Not Call lists prior to making initial contact. “eXp Dial Safe” may be located via MyEXP

eXp Realty (USA) Policies and Procedures Page 60 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES (https://my.exprealty.com/login) or via Okta dashboard and provides Agents the ability to scrub against the Canadian National Do Not Call List, the United States National Do Not Call List, and each of the United States’ state specific Do Not Call Lists, e.g. the Louisiana Do Not Call List. E. Drones Agents who desire to use drones must be familiar with and follow all Federal Aviation Administration (FAA) drone rules, and any other applicable laws and regulations. (See: www.faa.gov/uas for more information.) F. Drug and Alcohol Use 1. Illegal Drugs. Agents shall not be under the influence of illegal drugs while representing eXp. 2. Prescription or Over-the-Counter Medication. eXp shall not preclude Agents from being under the influence of prescription or over-the-counter medication while representing eXp, provided that, (a) their ability to represent eXp, including the servicing of our clients, is not compromised; (b) the health, welfare, and safety of eXp clients, eXp agents, and all other persons, is not compromised; and (c) their behavior would not be considered unbecoming of an eXp representative, or otherwise disrepute or negatively impact eXp’s reputation. 3. Alcohol. Agents shall not be under the influence of alcohol while performing real estate brokerage services. However, and except as provided in the preceding sentence, eXp shall not preclude Agents from being under the influence of alcohol when representing eXp outside of the scope of performing real estate brokerage services (such as at agent attraction events where alcohol may be served), provided that, (a) their ability to represent eXp is not compromised; (b) the health, welfare, and safety of eXp clients, eXp agents, and all other persons, is not compromised; (c) their behavior would not be considered unbecoming of an eXp representative, or otherwise disrepute or negatively impact eXp’s reputation; and (d) they are of legal drinking age. Agents shall also discourage the use of drugs or alcohol by any party when making decisions or taking action concerning a Transaction. Upon discovering that a party is under the influence of either drugs or alcohol, Agents should take appropriate action to terminate that day’s activity and suggest that they discuss or complete the Transaction another time. G. Harassment eXp takes all forms of harassment seriously. This includes but is not limited to verbal, physical or sexual. All reported or suspected occurrences of harassment will be promptly and thoroughly investigated. Any Agent that is found to have harassed another Agent, employee, client, customer, or any member of the public shall be immediately, and without warning, released from eXp at eXp’s sole discretion. If an Agent feels they have been harassed in any way, the Agent shall notify the State Broker or a member of the corporate team immediately.

eXp Realty (USA) Policies and Procedures Page 61 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES eXp will not permit or condone any acts of retaliation against anyone who files harassment complaints or cooperates in the investigation of the same. H. Prohibition on Changes to Compensation Splits and Referral Fees During Legal Action; No Split Checks When a lawsuit, garnishment, or other legal action has been served upon eXp, or eXp has been made aware that such an action is pending, any Agents that are a party to such legal action shall be prohibited from changing any compensation split agreement(s), including, but not limited to, Team Agreement(s), existing referral agreements with fellow Agents, co-listing agreements, etc., without the prior express written consent of the Agent’s State Broker. This prohibition applies regardless of whether the Agent seeks to modify a general agreement concerning all transactions, an agreement concerning transactions within a specific category, or an agreement concerning a specific property. This prohibition also extends to changes in compensation that the Agent would otherwise receive, even for future transactions, listing assignments, or co-listings until no further legal action is pending. For so long as an Agent is not in Good Standing or has any legally required withholdings (such as, for example, garnishments, tax levies, child support orders, or UCC-1 liens from unpaid compensation advances) being withheld from an Agent’s compensation or other earnings from eXp, that Agent shall not partake in receiving a “split check” in states where such practices are permitted. I. Products and Services Agents may not offer any non-eXp business plan, opportunity, product or incentive (including any multi-level marketing programs) utilizing any eXp platform such as eXp World or otherwise in conjunction with offering eXp products or services. 1. Selling, Offering To Sell, Or Promoting Any Competing Products Or Services Agents may not directly sell, offer to sell or directly promote to other Agents competing products or services. Any product or service in the same generic category as an eXp product or service is deemed to be competing. J. Reporting Problems It is understood that Agents, though operating as independent contractors, act as agents of eXp and must, therefore, keep eXp informed of their activities. Agents shall immediately, but in no event longer than five (5) calendar days after the time that they become aware of any of the following situations, bring any of the following situations to their State Broker’s attention and provide eXp with copies of any correspondence or legal process in connection with such situations. Failure to timely notify the State Broker and eXp may, in certain circumstances and in eXp’s sole discretion, result in termination of Agent’s ICA and disaffiliation from eXp. 1. Any substantive complaint involving a real estate transaction or the providing of real estate brokerage services, whether brought by a client, the state real estate licensing authority or a third party. 2. Any disclosure, or potential disclosure, of confidential client information. 3. Any accident or injury that occurs while providing real estate brokerage services. 4. Any criminal charge, judgment, or court order (including, without limitation, DUIs and felonies)

eXp Realty (USA) Policies and Procedures Page 62 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES against an Agent other than a traffic infraction. 5. Any civil suit (including bankruptcy), judgment, order, subpoena, or other legal document concerning real estate activity of an Agent or that would adversely affect the licensing status of any of an Agent’s real estate license(s). 6. Any contact by or with the state real estate licensing authority. 7. Any threat of any legal or administrative action against an Agent or eXp resulting from that Agent’s real estate brokerage services. 8. Any act(s) of discrimination witnessed. 9. Any unresolved dispute with another Agent or a real estate professional affiliated with another brokerage firm. 10. Any foreseeable dispute or problem relating to the payment or collection of compensation. 11. Any other situation involving professional real estate activity that could lead to liability on the part of eXp or anyone associated with eXp. 12. Any notification received from the state real estate licensing authority regarding the status of an Agent’s real estate license. Pre-Existing Matters Disclosure Requirement: During the onboarding process, each Agent must disclose any of the following matters to eXp: 1. Any past or pending criminal charges, or civil or criminal judgments against themselves (including, without limitation, DUIs and felonies), but excluding minor traffic infractions. 2. Any past or pending lawsuits, legal actions, or unresolved disputes related to Agent’s real estate activities, prior real estate brokerage(s), or real estate compensation payments. 3. Any past or pending interactions with a real estate licensing authority that have adversely impacted, or have the potential to adversely impact, Agent’s real estate license. Failure to disclose such pre-existing matters during the onboarding process may, in eXp’s sole discretion, result in immediate termination of Agent’s ICA and disaffiliation from eXp. K. Legal Action Between eXp Agents No Agent shall file a Civil or Administrative Action (defined in the ICA) against any other Agent affiliated with the eXp family of real estate brokerage companies (including eXp Realty, LLC, eXp Commercial, LLC, and/or eXp International Holdings, Inc., and any of their respective subsidiaries, divisions, affiliates, or assigns) for any issue arising out of or relating to the actual or alleged real estate brokerage activity of that other Agent without providing seven (7) days prior written notice to their own State Broker advising of their intent to do so and identifying, with specificity, the basis of the Agent’s dispute with the other Agent. To the extent there is any dispute as between two or more Agents, of a real estate nature (for example, but without limitation, compensation disputes, referral fee agreement disputes, procuring cause disputes, REALTOR® Code of Ethics disputes, etc…), such disputes may be resolved through eXp’s own “internal dispute resolution” procedures; this option shall not apply to any disputes among members of any particular team. Agents should reach out to their State Broker for details on this process. In addition, an Agent shall provide written notice to their own State Broker within twenty-four (24) hours following their own filing of a Civil or Administrative Action advising of the occurrence of such filing.

eXp Realty (USA) Policies and Procedures Page 63 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES An Agent’s failure to comply with the foregoing notice requirements shall constitute a material breach of these eXp P&Ps. Nothing in this section shall prohibit an Agent from notifying a licensing or other governmental entity of allegations that he or she is required by law to report. However, all requirements in this section must be complied with to the maximum extent possible, with performance excused only to the extent that he or she is legally required to take some action which precludes compliance with a particular requirement in this section. L. Legal Action Against eXp Prohibited By acknowledging and accepting the terms within these eXp P&Ps, each Agent represents, warrants, and covenants to eXp that they will not cause or participate in the filing of any Civil or Administrative Action against eXp, its holding companies, and it’s or their respective subsidiaries, affiliates, directors, officers, managers, members, or employees. Each Agent acknowledges and agrees that the filing of any such Civil or Administrative Action shall constitute a material breach of these eXp P&Ps, and that eXp may thereafter terminate the offending Agent’s ICA in accordance with its terms, as determined by eXp in its sole and absolute discretion. Nothing in this section shall prohibit any Agent from notifying a licensing or other governmental entity of allegations that he or she is required by law to report. However, all terms in this section must be complied with to the maximum extent possible, with performance excused only to the extent that he or she is legally required to take some action which precludes compliance with a particular requirement in this section. M.Claims Reimbursement Each Agent shall be responsible for and shall reimburse eXp up to $2,500 (two thousand five hundred dollars) incurred in the defense or resolution of any claim made against that Agent and/or eXp as a result of the Agent’s actions or inactions (except for any procuring cause claims), regardless of whether or not the claim is eligible for insurance coverage. Even where the Agent does not believe the claim or cause of action has merit and/or does not believe any money should be expended in the defense or resolution of the matter, the Agent expressly agrees in advance, by signing his or her ICA, that he or she will reimburse eXp up to $2,500 expended in defense or resolution of the matter within thirty (30) days of receipt of a request for reimbursement from eXp. An Agent may elect to have all or any portion of the reimbursable amount withheld from any compensation and/or revenue share payments due to the Agent in lieu of making payment directly to eXp. However, if an Agent does not reimburse eXp directly within the thirty (30) day period then eXp shall deduct the full amount due from any and all compensation and revenue share payments due to the Agent until eXp has been fully reimbursed. If it is determined that an Agent acted fraudulently, grossly or recklessly negligent, or willfully, the Agent shall be responsible for the full amount of the damages and costs recovered against eXp, along with all costs of defense. This language in no way limits the liability of an Agent to eXp and in no way limits any covenants or conditions stated in an Agent’s ICA. N. Claims That Are Not Covered By Real Estate E&O Insurance eXp’s real estate errors and omissions (“E&O”) insurance extends coverage to eXp Agents solely in the performance of real estate sales and leasing services for a fee or compensation. All eXp Agents should be aware and understand that eXp’s E&O insurance policy, like many others, has certain limitations and exclusions and only provides insurance coverage for specific types of claims. It is particularly important for eXp Agents to know that there are certain types of claims that, when made against eXp

eXp Realty (USA) Policies and Procedures Page 64 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES or an eXp Agent, are not covered under eXp’s E&O insurance policy. Some of these uninsured claim types include, but are not limited to: 1. Claims made under the Telephone Consumer Protection Act (“TCPA”), including “do not call list” guidelines, the Telemarketing Sales Rules (“TSR”), the CAN-SPAM Act, Federal Trade Commission (“FTC”) rules; a. Example: An eXp Agent makes cold calls or text messages to prospects but does not follow one or more of the above laws; these claims are not covered by any insurance available on the market and carry hefty statutory fines, which means there is no defense to these claims outside of proving that you did not place the call(s) or send the text message(s); 2. Personal injury claims; a. Example: A person slips and falls, injuring themselves while at a property and the person claims the eXp Agent is at fault for their alleged injuries; an eXp Agent’s for sale sign in the yard falls over and injures someone, etc. 3. Intellectual property infringement claims, including copyright infringement; a. Example: An eXp Agent uses a photo or image on their website that they have not obtained permission to use. 4. An eXp Agent’s Personal Transaction, regardless of whether eXp or the eXp Agent/Owner earned a fee or compensation; a. Example: A buyer makes any kind of claim against an eXp Agent in a Transaction where the eXp Agent was selling a property they owned (or had any kind of interest in) or controlled and neither eXp nor the eXp Agent earned a compensation on the Transaction. 5. Class action claims of any kind whatsoever. eXp Agents should determine whether they want, or are required by their state regulations, to obtain their own individual insurance coverage for activities such as those listed in the examples above. Lastly, like most insurance policies, eXp’s E&O insurance policy will not cover claims in which it is determined that eXp’s or an eXp Agent’s actions were fraudulent, grossly or recklessly negligent, or willful. XX. OFFICE POLICIES A. Agent Business Expenses eXp shall not be responsible for any expense incurred by Agents in the performance of their business duties unless approved in advance and in writing by the State Broker. No inducements, including inspections or other services associated with real estate brokerage services customarily paid by customers or clients, shall be offered or paid by an Agent without advance approval by the State Broker, and then shall be at the Agent’s sole expense. An Agent shall disclose, in writing, any compensation or

eXp Realty (USA) Policies and Procedures Page 65 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES profit received or to be received by such Agent (whether directly or indirectly), in connection with any expenditures advanced on behalf of that Agent’s client. B. Agent Assistants - Generally eXp fully supports the use of licensed and unlicensed assistants (which include transaction coordinators) by the Agents. By delegating tasks that may be performed by those other than the Agent, the Agent’s time can be spent more efficiently on tasks directly related to maximizing earning potential. eXp advises all Agents using assistants to seek legal counsel regarding employment laws and obligations within their state. All assistants, whether licensed or unlicensed, must have their own individual login credentials to any eXp-supported platforms or systems, including, but not limited to, eXp’s CRM of Choice, transaction management systems, communication tools, and cloud-based environments. Shared usernames or passwords are strictly prohibited, and all logins must comply with eXp’s identity management and Single Sign-On (SSO) protocols. Agents must have a written contract with their assistants. Said contract must be submitted to the State Broker for approval within ten (10) business days of joining eXp or entering into an agreement for these services. Copies of the contract are to be filed in the Agent’s file. Assistants (including transaction coordinators) are to be compensated for their services directly by those Agents with whom they are respectively engaged. Assistants that are licensed with eXp are to be paid for their services through escrow. Agents shall not use the services of any licensed assistants that are licensed with any real estate brokerage company other than eXp. C. Agent Assistants - Unlicensed Agents are responsible for training their assistants, making sure they are familiar with and abide by all eXp policies and procedures and all federal and state regulations. The Agent must review these eXp P&Ps with the assistant and present a copy of the eXp Agent and Assistant Cloud Brokerage Access Agreement (“Access Agreement”) to the assistant, for their review. An unaltered copy of the Access Agreement that has been signed by both the Agent and assistant shall be returned to the Agent’s State Broker, and must be approved and signed by that State Broker before the assistant may access any eXp systems. To the extent that an Agent grants any assistants with access to any eXp systems, without first securing the State Broker’s prior written consent in the manner provided above, then eXp may exercise any rights or remedies (including terminating the Agent’s ICA) as provided in the Agent’s ICA or these eXp P&Ps. An unlicensed assistant may not perform the following tasks or duties, including but not limited to: ● Host an open house. ● Solicit sellers or buyers in any manner. ● Provide advice or guidance to a consumer with regards to a listing contract or a contract of purchase and sale. ● Meet with owners to obtain or renew listing agreements. ● Present or negotiate an offer. ● Communicate with consumers about real estate transactions.

eXp Realty (USA) Policies and Procedures Page 66 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● Be paid from compensation at closing, or be paid compensation that is in any way predicated upon closing, regardless of timing. ● Open listings for clients or prospective clients. An unlicensed assistant may: ● Perform office filing. ● Fill out a document at the instruction of the Agent. ● Place or remove signs. ● Witness signatures. ● Perform Agent’s bookkeeping. ● Draft correspondence for approval by the Agent. ● Draft forms for review by the Agent. ● Make and deliver copies of any public records. D. Agent Assistants - Licensed Licensed assistants must be licensed with eXp and with no other real estate brokerage company. Licensed assistants are bound by the same licensing requirements as an Agent including, but not limited to, executing an ICA and fully associating themselves with eXp. They shall pay all fees due under their ICA and follow all policies and procedures of eXp. Licensed assistants may only assist other Agents and may not work for or with any agents outside of eXp. E. Administrative Transaction Fees Agents are free to determine whether or not they will assess their respective clients an administrative transaction fee (“Administrative Transaction Fee”), provided that doing so is not precluded by applicable federal or state law, please refer to your State P&Ps for guidance. An Administrative Transaction Fee is a fee amount, determined by each respective Agent, that consists of an Agent’s cost of doing business (e.g., costs for any assistants and transaction coordinators used in a transaction). The Administrative Transaction Fee is distinct from and in addition to any real estate compensation to be earned by eXp and the Agent. If an Agent elects to assess his or her clients an Administrative Transaction Fee, they must first receive each such client’s prior written consent; a sample form, referred to as an “Administrative Transaction Fee Agreement,” is available by request to the Agent’s State Broker. If working with a buyer, this consent must be signed prior to showing any property. The Administrative Transaction Fee Agreement must be signed by each such client before an Administrative Transaction Fee may be assessed, and each must specify all of the following: 1. that the Agent has the discretion to establish, set, and assess each or any of his or her clients an Administrative Transaction Fee; 2. that eXp does not require its Agents to charge any Administrative Transaction Fee, and that eXp does not establish the amount of any Administrative Transaction Fee to be charged by any of its Agents; 3. that the Administrative Transaction Fee amount may fluctuate from client to client depending upon the specific costs incurred and/or additional services rendered by the Agent; 4. that the Administrative Transaction Fee is separate from, and in addition to, any real estate compensation to be earned by eXp and the Agent;

eXp Realty (USA) Policies and Procedures Page 67 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 5. the exact amount of the Administrative Transaction Fee to be assessed to the respective client; 6. the time that the Administration Transaction Fee will be due and payable, whether at closing or prior to the Agent’s rendering of any brokerage related services. If used by an Agent, the fully executed Administrative Transaction Fee Agreement must be uploaded into eXp’s transaction management system. Administrative Transaction Fees are subject to the same Contractor Dollar/Company Dollar split applicable to an Agent at the time of receipt of payment of the Administrative Transaction Fee. Administrative Transaction Fees may also be considered part of a referral fee that is to be paid to an outside company or vendor. F. Associations and Board Memberships Unless specifically waived by eXp in an addendum to an Agent’s ICA, all Agents must be members (active and in good standing) of the National Association of REALTORS®, as well as both the state and local Association of REALTORS® where that respective Agent is situated. An Agent’s participation in an MLS is optional and is not required by eXp, unless eXp will be charged a fee as a result of that Agent’s license being affiliated with eXp, in which event that Agent’s participation will be required. If an Agent holds real estate licenses in more than one state, that Agent may, in eXp’s discretion, be required to join each state Association of REALTORS® in such additional states, as well as one or more local Association(s) of REALTORS® and/or MLS(s) in such additional states, as determined by eXp. Subject to the foregoing paragraph, an Agent shall maintain an active membership in a local association or board of REALTORS® affiliated with the National Association of REALTORS®, as determined by eXp, unless that Agent maintains an active membership in the Real Estate Board of New York (“REBNY”) and/or the Brooklyn MLS. Any state that requires eXp to pay the Agent’s portion of the membership dues will be handled accordingly. For any REALTORS® associations that require eXp to pay membership fees upfront on behalf of an Agent, that Agent shall reimburse eXp within 10 days of invoice for the same. Agents who fail to timely reimburse eXp will be subject to removal from eXp. Agents who are billed directly by the Association and MLS are expected to pay those bills in a timely manner as directed by the Association and MLS. eXp will not pay late dues on behalf of the Agent and the Agent will be subject to removal from eXp. Please check with your State eXp P&Ps for state specific information and any variances to this policy. Agents shall abide by the REALTORS® Code of Ethics and Standards of Practice of the National Association of REALTORS®, the statutes and rules of the state within which they are licensed, and any requirements of the MLS of which they are a member. G. Contact Information Agents MUST use their legal name as it appears on their real estate license in all advertising, on contracts and in all real estate correspondence. Agents using any name other than their full legal name may only do so if allowable within their state and must have the State Broker’s approval. Agent’s business address is the eXp office address in the state in which the Agent’s license is

eXp Realty (USA) Policies and Procedures Page 68 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES registered. Agents must use this address in all activities if an address is required by the state licensing department. All business correspondence related to transactions must be sent to this address, not to the Agent’s home. No personal mail may come to the office. Any mail coming to the office will be considered official business and subject to being opened by the State Broker or admin team. Agents shall make arrangements to pick up any parcels that are delivered to the office by vendors and will work to properly inform all vendors that parcel deliveries are to be scheduled directly with the Agent. All unclaimed parcels are subject to disposal within seven (7) days of delivery. Escrow companies, title companies and other closing agencies must send all communications pertaining to a transaction to our company address. Agents may receive a duplicate copy of escrow documents for the file. Agents are solely responsible for keeping their personal contact information (including mailing address, forwarding email address used to forward Agent’s eXp email alias to, and telephone number) current in Enterprise. eXp will rely upon the information provided by an Agent, in Enterprise, as being true, correct, and complete. Agents can update their forwarding email address, telephone number, and emergency contact information directly in Enterprise. Any failure by an Agent to provide or maintain the most current information in Enterprise shall not affect the validity of any notice from eXp to the Agent. H. Contacting the State Broker(s) Each state has a different State Broker, as a result, please review any state specific information with regard to broker communication. Each State Broker will make themselves available inside of eXp World for general communication and discussions. Consult the State Broker’s public calendar or State P&Ps for their availability. If an Agent has a specific urgent need for the State Broker to address outside of business hours, the Agent should call or email the State Broker directly. I. Open Houses Agents shall only hold open houses for other eXp Agents. No open houses shall be held for any listings other than eXp listings or For Sale By Owner where written authorization has been given and where prospective buyers complete a “touring agreement” or an eXp Single Property, Buyer-Broker Representation Agreement. Agents holding open houses for sellers who do not have their house listed for sale must have appropriate state approved documentation completed giving them the right to do so. eXp listings shall only be held open by other eXp Agents who are appropriately licensed and acting within their area of expertise for the geographic location of the listing. J. Out of Town or Unavailable When an Agent has listings and/or open escrows and is out of town, or otherwise unable to provide services to clients, the Agent is required to notify the State Broker and fill out the appropriate company form establishing someone to manage the business in Agent’s absence. K. Physical Office Space eXp has a cloud-based office and as such does not invest in physical bricks-and-mortar infrastructure,

eXp Realty (USA) Policies and Procedures Page 69 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES except where required by the State Department of Licensing laws. Agents are encouraged to contact their local affiliates, title and escrow companies, lenders, banks and other organizations with whom they work if they need physical space to meet clients. Where allowed by law and Association/Board rules, Agents who have achieved the level of associate broker and have agreed to policies relating to the opening of an eXp office may, with approval from eXp, be permitted to have a branded eXp office. Agents shall be responsible for compliance with all local and state laws regarding their branch office. This includes, but is not limited to, meetings, licensing, advertising, and signage requirements. eXp may itself open and operate, or authorize the opening and operation of, an eXp office (“Branch Office”). Any Branch Office that eXp authorizes an Agent to open and operate will be paid for by the Agent or Agents who have agreed to open that office, and no obligation relating to that office will transfer to eXp. Any financial obligation with regard to opening and/or maintaining a Branch Office will be at the expense of the Agent(s) who opened the Branch Office including any fines for non-compliance and renewal fees. Please ask the State Broker for the Branch Office Agreement and talk to the State Broker to see if the Agent qualifies. Branch Offices must be pre-approved in writing (through a Branch Office Agreement) by eXp prior to operation, advertising, or opening. Except for any Branch Offices that have been approved by eXp, Branch Offices shall not be situated within any Agent’s (or other person’s) personal residence. L. Data Privacy & Artificial Intelligence (AI) Use Policy 1. Purpose. To establish clear standards for safeguarding personal and confidential clients or customer information and to provide guidance on the ethical and compliant use of Artificial Intelligence (AI) tools in the course of real estate practice. 2. Definitions. (Only for purposes of this Data Privacy & Artificial Intelligence Use Policy) • Personal Information (PI): Any information related to or linked with a client or customer, including name, address, phone number, financial details, email, and digital identifiers. • Personally Identifiable Information (PII): A narrower subset of personal information (PI) that refers specifically to information that can identify a specific client or customer, either on its own or when combined with other information (e.g., full name, driver’s license number, etc…). • Confidential Information: Information related to a real estate transaction that is not publicly known and must be protected in fulfillment of eXp’s fiduciary duties. • Artificial Intelligence (AI) tool: Any software, application, or system that generates output using algorithms, machine learning, or natural language processing, with or without human prompts. 3. Agent Responsibilities. • Collect only the minimum necessary clients or customer information for each Transaction.

eXp Realty (USA) Policies and Procedures Page 70 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES • Retain client or customer information in secured, encrypted company tools approved by eXp. • Never disclose clients or customers or client/customer data (written, verbal, or digital) to third parties without written consent, unless legally required. • Immediately report data breaches or suspected unauthorized access to the Designated Managing Broker and to eXp IT Security at [email protected]. Fair Housing laws and regulations must always be followed. It is each Agent’s responsibility to safeguard and protect client and customer personally identifiable information (PII). State and Local rules and regulations are ever evolving and must be adhered to in the implementation of AI as a business practice. 4. Permissible Use of AI with Client and Customer Data. • The following use cases are offered as examples only and Agents must use their own best judgment as it relates to using AI tools and client and customer personal information in accordance with fair housing laws and regulations and other applicable law:  Drafting listing remarks, marketing materials, or transaction summaries without including personally identifiable information (PII).  Assisting with contract drafts, templates, or standard documents where clients or customers, or client/customer data is anonymized.  Analyzing market trends, property data, or comparable sales using aggregated or public data only.  NOTE: AI tools should be used as assistants, not decision-makers. Human review is required for any clients or customers or client/customer-facing material. 5. Prohibited AI Use Involving Client and Customer Data. • The following prohibited use cases are offered as examples only and Agents must use their own best judgement as it relates to using AI tools and client and customer personal information in accordance with fair housing laws and regulations and other applicable law:  Upload or enter client or customer PII or financial information into AI platforms that are not explicitly approved and secured by eXp.  Use AI to predict buyer/seller motivations, personal preferences, or financial capabilities based on characteristics of protected classes (e.g., race, gender, religion).  Use AI to generate automated communication to clients or customers that impersonates Agent without clear disclosure.  Allow AI tools to transmit or store client or customer information in non-U.S. jurisdictions or unknown cloud environments that are not controlled and limited to U.S. locations, including backups.  Use AI to generate or disseminate false, deceptive, or misleading content, including fake reviews, impersonation without consent, or misrepresentative media such as deepfakes.  Employ AI for profiling or automated decision-making that may have a legal or significant impact on a client or customer, such as lending, housing, or eligibility decisions, without human oversight, transparency, and legal disclosure.  Utilize AI for any purpose prohibited by law, including harassment, discrimination, political campaigning, social scoring, or behavioral manipulation.

eXp Realty (USA) Policies and Procedures Page 71 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES 6. Approved Company Tools & Security Practices. • Agents must only use AI or Customer Relationship Management (Customer Relationship Management (CRM)) tools that: o Have published data privacy and retention policies. o Use end-to-end encryption. o Do not retain user-entered data for training purposes without explicit consent. • All devices (laptops, phones, tablets) used to access client or customer information must have: o Active antivirus software o Two-factor authentication (2FA) o Automatic lock screens when idle 7. AI & Disclosure Requirements. • When AI is used in any form of communication with clients or customers, or the public: o It is strongly encouraged that Agents add a disclosure such as, “This message was drafted with the assistance of AI and reviewed by a licensed real estate professional”. o Clients or customers must be informed when AI virtual assistants or chatbots are interacting on an Agent’s behalf. o All advertising generated or assisted by AI must comply with truth-in-advertising, fair housing, and state-specific marketing regulations. 8. Broker Oversight & Enforcement. • The brokerage reserves the right to audit the use of AI tools and data handling practices at any time. • Violations of this policy may result in disciplinary action, including: o Retraining or compliance coursework o Written warnings o Suspension or termination of Agent affiliation XXI. TEAMS AT EXP REALTY A. Generally A “team” is generally defined, in most states, as a lead Agent (“team leader”) and at least one other Agent working as a team member (“team member”). For more information on teams, Agents may review eXp’s, “Teams at eXp Realty - Understanding Types and Compensation” informational sheet (available here), and eXp’s, “Teams at eXp Realty Policy” (available here); or contact eXp’s Team Services Department at [email protected]. B. Team Names Team names shall conform with the real estate licensing laws and rules in effect in the state(s) in which the team name is being used. A team leader shall select a proposed team name upon formation of a team. Regardless of whether or not state requirements allow use of the terms “Realty” or “Real Estate” in a team name, eXp does not allow the use of such terms in a team name of any Agents. The proposed team name must be presented by the team leader to his or her State Broker for approval. A team name

eXp Realty (USA) Policies and Procedures Page 72 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES may only be used if, and after, it has been approved in writing by the team leader’s State Broker. For team registration requirements, Agents should consult their State P&Ps and their State Broker team. C. Team Composition A team of any kind cannot be composed of members from both eXp and eXp Commercial. All team members must be affiliated with the same brokerage as their team leader (i.e., eXp or eXp Commercial; eXp and eXp Commercial being distinct brokerages). For example, a team that has a team leader affiliated with eXp must also have all team members associated with eXp; those team members could not be associated with eXp Commercial. Unless advance arrangements are made with eXp, in writing, a team leader’s departure from a team (whether because they leave the team, offboard from eXp, or otherwise) shall cause a team to dissolve automatically as of that date the team leader leaves the team or offboards from eXp, whichever occurs first. D. Team Agreements “Team Agreements” are to be made based on mutually agreed upon terms between a team leader and the team member(s). These agreements must be in writing, fully executed, and carefully considered to ensure compliance with all federal, state and local law as well as eXp’s policies. A team leader shall maintain a copy of each fully executed Team Agreement in their files at all times. Team leader shall provide a signed copy of their written Team Agreement with each team member, to eXp. Adjusted Company Dollar Cap amounts for team members shall only be provided within applicable team structures. eXp will not allow a team to stay affiliated with eXp if the team enforces or attempts to enforce a restriction against a former team member which would prevent them from staying with eXp after leaving the team; nor will eXp intervene in any disputes between team members and team leaders. E. Team Disputes Any disputes that may arise between or among current or former team leader(s) and/or team member(s) (collectively, the “disputing parties”), concerning any Team Agreement entered into between them, shall be resolved between and among the disputing parties and without eXp’s participation. In no event will eXp assist any of the disputing parties to enforce the terms of any Team Agreement against the other disputing parties (including enforcement of any restrictive covenants such as non-compete or non-solicitation provisions), nor will eXp preclude a former team member from remaining affiliated with eXp after his or her departure from a team. By executing their eXp ICA, each Agent agrees that if they wish to remain affiliated with eXp, they will not attempt to enforce any restrictive covenants (including, without limitation, the terms of any non-compete provisions) under any Team Agreement, against any former team member that remains affiliated with eXp after leaving the applicable team, and regardless of whether or not such former team member joins a new team or remains unaffiliated with any team. If team leader(s) or team member(s) nevertheless attempt to enforce any restrictive covenant in contravention to the preceding sentence, then eXp may terminate such team leader(s)’ and/or team member(s)’ ICA(s) and end such team leader(s)’ and/or team member(s)’ engagement with eXp.

eXp Realty (USA) Policies and Procedures Page 73 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES F. Team Fee Distribution 1. Transaction Review Fee: Can be paid by either the team leader or the team member or split between the two as agreed upon in their written Team Agreement. 2. Risk Management Fee: Shall be divided equally between the team leader and the team member. Each Agent shall be responsible for their annual Risk Management Fee cap. 3. Compensation: GCI, as defined in Agent’s ICA, shall be first divided between the team leader and the team member based on the percentages agreed to between the team leader and team member. From there, each Agent’s compensation split will be divided according to the Company Dollar and Contractor Dollar split in effect for that Agent at the time of the Transaction closing, less any applicable Transaction fees. 4. Capped Transaction Fees: Once an Agent has reached their Company Dollar Cap (as that term is defined in the Agent’s ICA), that Agent will pay a percentage of the Capped Transaction Fee equal to the percentage of GCI they received. In certain cases, eXp will reduce a team member’s annual Company Dollar Cap. Team members with a reduced Company Dollar Cap are not eligible to receive the “capping equity award” or the ICON Agent Award, as paying a full cap amount is required for both. For a team member to qualify for a reduced Company Dollar Cap, the team and team leader must meet any requirements prescribed to the applicable team. G. Non-Solicitation of Other eXp Team Members No Agent may solicit, recruit, employ, or entice (either for themselves or another), directly or indirectly through a third party, any individuals that are members of other existing teams at eXp, to leave those teams and join Agent’s team. H. Application of Non-Solicitation and Non-Disparagement Policy To Teams To the extent that eXp’s Non-Solicitation and Non-Disparagement Policy, as described in the Code of Conduct, above, would prohibit an Agent who is a team leader of an eXp approved real estate team from leaving eXp and taking his or her team members with them to a competing brokerage, the non-solicitation portion of this particular policy shall not apply. XXII. OMISSIONS FROM POLICY AND PROCEDURES Any items or procedural issues not covered in the eXp P&Ps are subject to State Broker and eXp approval. Any decisions rendered on the items not covered in the eXp P&Ps are final and are to be made at the sole discretion of eXp. XXIII. UPON TERMINATION OF ICA An Agent shall forfeit all rights to any Transactions, transactional compensation or proceeds if the Agent does not affiliate with a new (non-eXp) brokerage company within three (3) business days following the Agent’s Offboard Date (as that term is defined in Section 6 of the ICA). Each Agent shall

eXp Realty (USA) Policies and Procedures Page 74 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES communicate with his/her State Broker in advance of, and following, their Offboard Date regarding any pending Transactions to ensure that such Transactions are not adversely impacted by the termination of the Agent’s affiliation with eXp. A. eXp’s Transfer of Pending Transactions Subject to the terms in the opening paragraph of this section above, an Agent may execute a pending escrow transfer form and transfer any pending Transaction(s) to his/her new brokerage company. Eligibility to transfer pending Transactions in this way is conditioned upon satisfaction of each of the following: (1) the Agent must be in Good Standing as of his/her Offboard Date, (2) the Agent’s new brokerage company must be willing to accept the transfer of such pending Transactions from eXp, (3) eXp must receive each affected client’s prior written consent authorizing the transfer to the new brokerage company, and (4) eXp must approve in writing of each such transfer (which eXp may withhold in its sole and absolute discretion). For each such Transaction that is to be transferred, if any of the preceding conditions are not met, that pending Transaction will remain with eXp. For Agents not in a Capped Status, the transfer of any pending Transaction(s) away from eXp to the Agent’s new brokerage company shall require the payment of a twenty percent (20%) referral fee from that new brokerage company back to eXp. In addition, for all Agents, regardless of Capped Status, any other applicable referral fees that may be due upon the closing of that pending Transaction shall be paid to eXp (by Agent through Agent’s new brokerage firm), who will then remit payment to the originating brokerage company pursuant to the terms of any preexisting referral agreement. B. eXp’s Retention of Pending Transactions Subject to the terms in the opening paragraph of this section above, eXp will pay Agent’s compensation, less any splits, Agent fees, deductions or withholdings (including, but not limited to, invoices issued from accounting, transaction coordination fees, garnishments or any other outstanding fees or legally required withholding) upon closing of any pending Transactions that remain with eXp following Agent’s affiliation with a new brokerage company. In addition to Section 6 under the ICA, an Agent’s ICA shall also immediately, and automatically terminate, without prior notice, if for any reason, the Agent breaches his or her obligations hereunder, or if the Agent’s license expires, is restricted, suspended or is revoked. In the event an Agent leaves eXp, his/her Offboard Date will be determined in accordance with Section 6 of the Agent’s ICA titled, “Termination.” Termination of an Agent’s ICA could, and likely will, result in a significant financial loss to an Agent, including but not limited to: (1) loss of certain pending transactions, as more fully described above; (2) if an Agent is not in a vested status, loss of eXpansion Share payments and eXponential Share payments, including those that would otherwise have been earned on or before the Agent’s Offboard Date, but paid following the Agent’s Offboard Date; (3) if an Agent is in a vested status, loss of eXponential Share payments, including those that would otherwise have been earned on or before the Agent’s Offboard Date, but paid following the Agent’s Offboard Date; and

eXp Realty (USA) Policies and Procedures Page 75 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES (4) loss of UNVESTED eXp World Holdings, Inc. stock awards. Example 1: An Agent is in a vested status and is receiving eXpansion Share and eXponential Share payments. That Agent leaves eXp, having an Offboard Date of August 15, 2022, and the Agent retains their vested status following their Offboard Date. Also, the Agent maintains a real estate license that is active and in good standing and the Agent does not affiliate with a competitor. It then follows that the Agent will receive their eXpansion Share payments and eXponential Share payments earned for the month of July 2022, when each is paid by eXp on August 22, 2022. Example 2: Same facts as Example 1, except that the Agent affiliates with a competitor effective as of their Offboard Date. In that event, it then follows that the Agent will receive only their eXpansion Share payments earned for the month of July 2022, when such payments are released by eXp on August 22, 2022. However, the Agent will not receive any eXponential Share payments that otherwise would have been earned for the month of July 2022 and paid by eXp on August 22, 2022. Upon termination of their affiliation with, and severance from eXp, Agents will lose access to all eXp tools, emails, files, and eXp provided third party sites. eXp strongly encourages Agents to backup any files they desire access to prior to requesting offboarding. C. Leads Upon Departure Upon an Agent’s actual or pending departure from eXp (the “Departing Agent”), eXp shall maintain and preserve the Departing Agent’s database of eXp-generated and non-eXp generated leads within any eXp-provided consumer relationship management applications for a period of up to 30 days (the “Preservation Period”) following the Agent’s Offboard Date. If the Departing Agent would like to obtain a list of his/her non-eXp generated leads, then the non-eXp generated leads can be exported upon written request to eXp’s Technology and Technical Support at [email protected] (an “Export Request”) provided that, (1) the Export Request is received within the Preservation Period, and (2) the Departing Agent is in Good Standing. If the Departing Agent does not provide an Export Request as set forth herein during the Preservation Period, then the Departing Agent’s non-eXp generated leads are subject to forfeiture and deletion after the Preservation Period expires. Notwithstanding the foregoing, any eXp-generated leads (such as, for example only, and without limitation, those generated through REVENOS®, eXp’s Bundle Select® program, eXp’s REO division, eXp’s Relocation division, and eXp’s ExpressOffers program) may not be released to Agent. D. Rejoining eXp If an Agent terminates his or her ICA while there remain any Amounts Owed to eXp, and the Agent wishes to rejoin eXp, then eXp may, in its sole discretion, provide the Agent with a one-time option to rejoin eXp under the following conditions:

eXp Realty (USA) Policies and Procedures Page 76 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES (1) the entirety of the Agent’s Amounts Owed to eXp must be repaid to eXp (assuming that such Amounts Owed to eXp have not already been satisfied in full); and (2) at eXp’s discretion, by and through the Regional Director responsible for managing the Agent’s state, such Amounts Owed to eXp must be repaid to eXp as follows: either (i) in one lump sum prior to the Agent’s rejoining eXp, or (ii) in accordance with those terms and conditions set forth in a written repayment plan (“Repayment Plan”) presented by the Agent’s forthcoming Regional Director, which Repayment Plan shall not have a term longer than sixty (60) days following the date of the Agent’s rejoining eXp; (3) the Agent enters into a new ICA with eXp; and (4) the Repayment Plan shall take the form of an addendum to the Agent’s new ICA with eXp. If the Agent breaches any of the above conditions, or if the Agent’s new ICA is terminated for any reason, by either the Agent or eXp, and at the time of this additional ICA termination there again exists any Amounts Owed to eXp, then Agent is forever precluded from rejoining eXp as a real estate licensee, as determined in eXp’s sole and absolute discretion. XXIV. EXP’S COMPLIANCE COMMITTEE eXp has a Compliance Committee whose members are senior eXp executives who review, evaluate, and make determinations for the fair resolution of serious violations by Agents of their ICA and/or eXp P&Ps. A. Appeal of Determination made by eXp’s Compliance Committee If a disciplinary determination was made against an Agent by eXp’s Compliance Committee, and such disciplinary determination results in any disciplinary action to be taken against an Agent, then an Agent (or former Agent) may appeal the disciplinary action to eXp’s Compliance Committee (which is distinct from, and not to be confused with, the Agent Compliance team). The Agent’s appeal must be in writing (together with any supporting documentation) and must be delivered to, and received by, the Agent Compliance team within fourteen (14) calendar days following the date that the Agent received notice of the disciplinary determination (send to [email protected]). Thereafter, the Agent Compliance team will present the Agent’s written appeal to eXp’s Compliance Committee. If the written appeal (and any supporting documentation, if any) is not received by the Agent Compliance team within the fourteen (14) calendar day period, the disciplinary determination made by eXp’s Compliance Committee will be considered final by eXp. In its review of the Agent’s appeal, eXp’s Compliance Committee will take under consideration any newly presented evidence and the previously enacted disciplinary action and notify the Agent of its decision to accept or reject the appeal. The decision of eXp’s Compliance Committee concerning the Agent’s appeal will be final. Agents who have had their ICA’s terminated as a disciplinary action must fully exhaust eXp’s appeals process before engaging in any legal action, as may be permitted under the ICA and these eXp P&Ps. For avoidance of doubt, the appeals process described in this section is limited only to those situations where a disciplinary determination was made by eXp’s Compliance Committee, and corresponding disciplinary action was taken by eXp through eXp’s Compliance Committee.

eXp Realty (USA) Policies and Procedures Page 77 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES XXV. INTERPRETATION If any provision in these eXp P&Ps requires interpretation, the resolution of such ambiguity shall not be held against eXp. In these eXp P&Ps, the singular includes the plural and the plural the singular; words importing any gender include the other genders; references to statutes are to be construed as including all statutory provisions consolidating, amending, or replacing the statute referred to; the word “or” shall be deemed to include “and/or”, the words “including,” “includes,” and “include” shall be deemed to be followed by the words “without limitation”; and section headings are included for convenience of reference only and shall not constitute a part of these eXp P&Ps for any other purpose. XXVI. CONFLICTS To the extent there may be any conflict between the terms of an Agent’s ICA and the terms in these eXp P&Ps, the more restrictive terms (in eXp’s favor) shall be controlling. XXVII. REVISIONS TO THESE EXP P&PS eXp reserves the right to revise these eXp P&Ps, in its sole discretion. Revisions to these eXp P&Ps shall be consistent with revisions to Agent’s ICA, as provided by the terms of Agent’s ICA. XXVIII. GLOSSARY OF DEFINED TERMS ● Adjustment Bonus - This is the difference between the total amount of money within the Revenue Share Pool, on the one hand, and the Calculated Company Dollar, on the other hand. This is also known as the “Adjustment Amount.” ● Adjustment Amount - (See “Adjustment Bonus”) ● Affiliated Business Arrangement (ABA) - The definition of the term “affiliated business arrangement” is defined in 12 USCS § 2602(7) of the Real Estate Settlement Procedures Act. The term “affiliated business arrangement” means an arrangement in which (A) a person who is in a position to refer business incident to or a part of a real estate settlement service involving a federally related mortgage loan, or an associate of such person, has either an affiliate relationship with or a direct or beneficial ownership interest of more than 1 percent in a provider of settlement services; and (B) either of such persons directly or indirectly refers such business to that provider or affirmatively influences the selection of that provider; and (8) the term “associate” means one who has one or more of the following relationships with a person in a position to refer settlement business: (A) a spouse, parent, or child of such person; (B) a corporation or business entity that controls, is controlled by, or is under common control with such person; (C) an employer, officer, director, partner, franchisor, or franchisee of such person; or (D) anyone who has an agreement, arrangement, or understanding, with such person, the purpose or substantial effect of which is to enable the person in a position to refer settlement business to benefit financially from the referrals of such business.

eXp Realty (USA) Policies and Procedures Page 78 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● Access Agreement - An abbreviated term referring to the eXp Agent and Assistant Cloud Brokerage Access Agreement that, once completed and accepted, allows support staff (such as administrative and/or transaction coordinator assistants) to access eXp’s various systems. ● Administrative Transaction Fee - A fee amount, determined by each respective Agent, that consists of an Agent’s cost of doing business (e.g., costs for any assistants and transaction coordinators used in a given transaction) and is distinct from and in addition to any real estate compensation to be earned by eXp and Agent. ● Agent - An independent contractor real estate licensee who has entered into an agreement with eXp through an eXp Independent Contractor Agreement (referred to as Agents collectively). ● Agent Attraction - The process of engaging credible, ethical, and productive real estate professionals and inviting them to join eXp, or its commercial affiliate, eXp Commercial. ● Agent Content - Content such as photographs, images or content of any type created, commissioned by, or otherwise owned by Agent. ● Agent-Owned - Ownership is held or controlled by an Agent, whether through an Agent’s own name, a spouse’s name, a business entity, a trust, or that is otherwise owned and/or controlled by Agent and/or Agent’s spouse (also referred to as an “Agent-Owner”) ● Branch Office - Any eXp office, whether opened and operated by eXp, or authorized by eXp to be opened and operated by an Agent. Agent opened and operated Branch Offices must be pre-approved in writing (through a Branch Office Agreement) by eXp prior to operation, advertising, or opening. ● BPO - An abbreviation for the term “Broker Price Opinion.” ● Calculated Company Dollar - The total amount of revenue share that is calculated to be paid out in a given month, exclusive of any Adjustment Bonus. ● Capped Status - An Agent reaches Capped Status when the amount of Company Dollar required under that Agent’s ICA or ICA addendum has been collected by eXp within that Agent’s Capping Period. ● CAN-SPAM - Abbreviation for the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 which is a law passed in 2003 establishing the United States’ first national standards for the sending of commercial email. ● Commercial Property - Any real property that is not Residential Property. (See definition for “Residential Property” below). ● Departing Agent - Agent departing from eXp. ● DMB - An abbreviation for the term “Designated Managing Broker.”

eXp Realty (USA) Policies and Procedures Page 79 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● E&O – Errors and omissions insurance. ● eXp - The applicable eXp Realty entity licensed as a real estate brokerage company in the Agent’s state(s) of licensure: eXp Realty, LLC (in all states except those that follow); eXp Realty of California, Inc. (in California); eXp Realty of Northern California, Inc. (in northern California); eXp Realty of Greater Los Angeles, Inc. (in central California); eXp Realty of Southern California, Inc. (in southern California); eXp Realty North, LLC (in N. Dakota, Minnesota, and portions of New York, except as further qualified); eXp Realty of Connecticut, LLC (in Connecticut, and Brooklyn, New York); eXp Realty Associates, LLC (in Brooklyn, mid-town, and downtown, New York City); and eXp Realty of Charlotte Metro NC, LLC, eXp Realty of Northwest NC, LLC, eXp Realty of Northeast NC, LLC, eXp Realty of Piedmont NC, LLC, eXp Realty of Southeast NC, LLC, and eXp Realty of Triangle NC, LLC (in North Carolina). ● eXp Brokerage – This is a specific brokerage company, within the eXp World Holdings, Inc. family of real estate brokerage companies, that conducts business under any of the eXp® Realty or eXp® Commercial brands, and that is licensed or registered to engage in the real estate brokerage business in its particular jurisdiction (whether country, state, province, region, etc.). ● eXp’s Compliance Committee - A committee whose members are senior eXp executives who review, evaluate, and make determinations for the fair resolution of serious violations by Agents of their ICA and/or eXp P&Ps. ● eXp Licensees - eXp or any of its affiliates or licensees (not to be confused with real estate licensees), as it pertains to Agent Content. (See definition for “Agent Content” above). ● eXpansion Share - eXpansion Share is revenue share money within the Revenue Share Pool that is earned and received from Qualifying Transactions closed by an Agent’s Revenue Share Group, and that is paid out to the Agent in an amount that is based on the Tier group of the Agent(s) who closed the Transaction(s). See the Revenue Share Plan Chart (“Revenue Share Chart”), above, for a breakdown of the amount of eXpansion Share paid for each Tier group. ● eXponential Share - eXponential Share is revenue share money within the Revenue Share Pool that is earned and received from Qualifying Transactions closed by an Agent’s Revenue Share Group, and that is paid out to the Agent in an amount that is based on the Tier group of the Agent(s) who closed the Transaction(s). In order to unlock eXponential Share earning potential, the Agent must have the minimum number of Front-Line Qualifying Active agents (as defined below). See the Revenue Share Chart, above, for a breakdown of the amount of eXponential Share paid for each Tier. ● Export Request - A written request from a Departing Agent to eXp’s Technology and Technical Support team, sent via email to [email protected], for a list of all of the Departing Agent’s non-eXp generated leads. ● Front-Line Qualifying Active (FLQA) - A Front-Line Qualifying Active agent is a licensed Agent who has been sponsored into eXp and has been active and productive with eXp during the prior rolling six-month period by closing a minimum of $5,000 in Gross Compensation Income. In

eXp Realty (USA) Policies and Procedures Page 80 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES order to unlock eXponential Share earning potential beyond Tier 1, an Agent must have the minimum number of Front-Line Qualifying Active agents in his or her Revenue Share Group. ● FTC - An abbreviation for the Federal Trade Commission which is an independent agency of the United States government whose principal mission is the enforcement of civil U.S. antitrust law and the promotion of consumer protection. ● Good Standing - To be considered in Good Standing, an Agent must: (1) be current on all financial obligations and not have any unpaid fees, charges, repayments, or any other amounts owed by Agent to eXp; (2) have and maintain an active and current status on: (i) all required licenses; (ii) local, state, and national REALTOR® Association/Board memberships, where applicable; and (iii) any other subscriptions which are required to conduct real estate business in Agent’s state(s); and (3) not be deemed in breach of any term, covenant, condition, obligation (including monies owed) or duty set forth in the ICA and these eXp P&Ps, as determined by eXp in its reasonable discretion. ● ICA - An abbreviation for eXp’s form of Independent Contractor Agreement ● ICON - A status awarded to Agents who have received an ICON Agent Award. ● ICON Agent Award - An award earned by Agents who have achieved certain production and cultural goals within an Agent’s Capping Period. Each qualified “ICON” receives publicly-traded eXp World Holdings, Inc. common stock. ● Income Claims - Statements or representations that depict earnings obtained by Agents as a result of participating in the eXp opportunity. Such claims can consist of direct statements, presentations, videos, social media posts, charts, and images that directly state or imply what earnings an individual Agent made or makes and what earnings a prospective Agent might be able to make with eXp. Income and earnings claims also include implied claims such as lifestyle representations. ● Initial FLQA Period: A six (6) month period that begins at the moment that an Agent satisfies the Initial FLQA Period Productivity Requirement, during which time Agent will be classified as FLQA for his or her Sponsor. ● Initial FLQA Period Productivity Requirement (a.k.a. “Productivity Requirement”) - The requirement that a new Agent must close a minimum of $5,000 in Gross Compensation Income during the prior six (6) month period to qualify for the Initial FLQA Period. ● Limited Function Referral Offices - Offices that are solely engaged in referring clients or customers to non-eXp real estate brokerage companies. Agents shall not operate limited function referral offices through eXp. ● Limited Representation - Any representation relationship with a seller, buyer, landlord, or tenant that limits the services to be provided to that person.

eXp Realty (USA) Policies and Procedures Page 81 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● Mentor Program Requirements - Generally, if an Agent has not completed three (3) purchase Transactions or sale Transactions (or any combination thereof) within the twelve (12) month period immediately preceding the Agent’s Onboard Date, then the Agent will be required to participate in the eXp Mentor Program, as a mentee, upon transfer of their license to eXp. ● Minimum Company Dollar Rule - The rule providing that eXp is to receive a minimum amount of Company Dollar on each closed purchase Transaction and on each closed sale Transaction involving an Agent who is not in a Capped Status. ● MLS - An abbreviation for Multiple Listing Service. ● NAR - An abbreviation for the National Association of REALTORS®. ● One eXp Agent, Two Transaction Sides - A dual agency transaction in which one natural person represents a buyer and seller in the same transaction. ● Original Sponsor Window - The one (1) year period beginning on an Agent’s Offboard Date, during which time, if an Agent rejoins eXp, that Agent’s Sponsor will continue to serve in the same capacity. ● Personal Transaction - Any Transaction concerning a property that is owned or leased by an Agent (whether in an Agent’s own name, a spouse’s name, a business entity, a trust, or that is otherwise controlled by Agent and/or Agent’s spouse), regardless of whether Agent chooses to represent themselves or have another eXp Agent represent them. ● Potential Local Sponsor - A vendor that desires to sponsor a local event for eXp. ● Preservation Period - A period of up to 30 days in which a Departing Agent’s database of eXp-generated and non-eXp generated leads within any eXp-provided consumer relationship management applications is preserved. ● Property Management Services - Engaging in any activities concerning an actual or prospective tenant on behalf of a client, whether or not such activities are coupled with any property preservation services (as that term is defined herein) (e.g., collecting rents, performing inspections, setting up repairs and maintenance, running a background check, making or assisting with tenant selection, etc.). ● Property Preservation Services - Tending to and managing only the physical aspects of any real property on behalf of a client (e.g., scheduling, coordinating, and/or setting up any repairs or maintenance concerning a client’s real property). ● Qualifying Transaction: A Qualifying Transaction is either, (a) a purchase Transaction, sales Transaction, or (in the case of eXp Commercial) a business brokerage Transaction, that generates Company Dollar; or (b) BPOs, rental/lease Transactions, or referrals that respectively generate Gross Compensation Income of at least $1,000. A Personal Transaction does not generate Company Dollar, and is therefore not a Qualifying Transaction.

eXp Realty (USA) Policies and Procedures Page 82 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● Residential Property - Any real property that is zoned to accommodate a residential dwelling having not less than one (1) and not greater than four (4) dwelling units, whether such real property is vacant land or improved real property. ● REBNY - An abbreviation for the Real Estate Board of New York. ● RESPA - An abbreviation for the Real Estate Settlement Procedures Act. ● Retained Company Dollar - That one-half of Company Dollar earned and received, and used for eXp’s operating expenses and other management purposes. ● Revenue Share Group - An Agent’s Revenue Share Group consists of (i) the Agents that he or she personally sponsors to join eXp (also referred to as “Sponsees”), who are situated at the Agent’s “Tier 1” in eXp’s Revenue Share Plan, and (ii) an unbroken chain of sponsorship relationships extending downward through successive Tiers, from Tier 2 through Tier 7. Each Tier is comprised of Agents who were sponsored by the Agents in the preceding Tier, maintaining a continuous, direct lineage of sponsorship from the original sponsoring Agent. ● Revenue Share Eligible - For an Agent to remain eligible to collect revenue share (also referred to as “Revenue Share Eligibility”), the Agent must be in Good Standing. ● Revenue Share Plan - The Revenue Share Plan exists to provide a financial incentive to the Agents with eXp who have helped grow sales within the eXp family of real estate brokerage companies. ● Revenue Share Pool - That one-half of Company Dollar earned and received which supports the Revenue Share Plan. ● SEC - An abbreviation for the U.S. Securities and Exchange Commission which is an independent agency of the United States federal government whose primary purpose is to enforce the law against market manipulation. ● Service Charge - A $100 service charge that is added to: 1) any advances made from a compensation advance company that is outside of the eXp preferred partners network; and 2) and UCC liens presented to eXp from a compensation advance company seeking payment of any unpaid compensation advance(s). ● Solicitation Laws - Laws encompassing broad-based mandates like the Telephone Consumer Protection Act (“TCPA”), the Telemarketing Sales Rules (“TSR”), the CAN-SPAM Act, Federal Trade Commission (“FTC”) rules, Securities and Exchange Commission (“SEC”) regulations, and state and national tortious interference laws, and their implementing rules and regulations. ● Sponsee – A Sponsee is a joining Agent that has selected another Agent as their Sponsor (and, if applicable, their Co-Sponsor). A Sponsee is in the “Tier 1” position of their Sponsor’s Revenue Share Group, unless they have selected a Co-Sponsor, in which event the Sponsee is in the “Tier 2” position of their Sponsor’s Revenue Share Group, and in the “Tier 1” position of their Co-

eXp Realty (USA) Policies and Procedures Page 83 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES Sponsor’s Revenue Share Group. ● Sponsor - A Sponsor is the Agent who a joining Agent selects (as identified in their ICA) as the person who most influenced them to join eXp. ● Sponsorship - An Agent’s sole requirement to qualify as a sponsor is selection by the joining Agent in their ICA as the individual who most influenced them to join eXp. The role of sponsor is distinctive from other roles like a mentor, coach, or team leader. In some cases, these roles are assumed by the same person, but they are not mandatory for a sponsor. ● Sponsorship Interference - Any effort(s) or action(s) taken by an Agent to interfere with, coerce, or otherwise unethically encourage or convince a prospective or current Agent to change their intended sponsorship declaration (or current sponsor); Sponsorship Interference is prohibited and subject to corrective action up to and including termination of their affiliation with, and severance from eXp. ● State Broker - Designated Managing Broker or applicable Managing Broker(s) (individually, and collectively). ● State P&Ps – Means those policies and procedures applicable to a particular state. ● State Department of Licensing - A State’s department or agency that is charged with administering the issuance of any real estate licenses in that State. ● Straw Agent - Straw Agents are Agents who are not engaged in the business of selling real estate or engaged in the process of attracting other productive agents to join eXp and help grow company sales. ● T&E Addendum - An abbreviation for the term “Title & Escrow eXp Addendum.” ● TC - An abbreviation for the term “Transaction Coordinator.” ● TCPA - An abbreviation for the term “Telephone Consumer Protection Act of 1991.” This law restricts marketing through certain types of phone calls and text messages, and provides protection for private citizens through the National Do Not Call List. It also places restrictions on the use of automated dialing systems and artificial or prerecorded voice messages. ● Team - A “team” is generally defined, in most states, as a lead Agent (“team leader”) and at least one other Agent working as a team member (“team member”). ● Team Agreement - An agreement outlining mutually agreed upon terms between a team leader and the team member(s). These agreements must be in writing, fully executed and carefully considered to ensure compliance with all federal, state and local law as well as eXp’s Policies. ● Team Leader - Lead Agent on a team.

eXp Realty (USA) Policies and Procedures Page 84 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES ● Team Member - An Agent (other than a team leader) that is working as a team member with a team leader. ● Tier - In the Revenue Share Plan, the hierarchy of Agents that are sponsored in succession beginning with the Agent and each group of Agents thereafter, as follows: ● Agent. ● Tier 1: the group of eXp Agents sponsored by the Agent. ● Tier 2: the group of eXp Agents sponsored by Tier 1 eXp Agents. ● Tier 3: the group of eXp Agents sponsored by Tier 2 eXp Agents. ● Tier 4: the group of eXp Agents sponsored by Tier 3 eXp Agents. ● Tier 5: the group of eXp Agents sponsored by Tier 4 eXp Agents. ● Tier 6: the group of eXp Agents sponsored by Tier 5 eXp Agents. ● Tier 7: the group of eXp Agents sponsored by Tier 6 eXp Agents. ● TSR - An abbreviation for the Telemarketing Sales Rule, enacted in 1995; it is the FTC’s regulation on telemarketing authorized by the Telemarketing and Consumer Fraud and Abuse Prevention Act. ● Vested - Subject to certain qualifications and conditions, as described in these P&Ps, an Agent that is Vested in the Revenue Share Plan may continue to receive benefits payable thereunder after Agent terminates his or her ICA or discontinues actively engaging in licensed real estate activities. ● Vesting Period - The time period, consisting of not less than 36 consecutive months, during which time an Agent must satisfy the following two conditions in order to become vested in the Revenue Share Plan: (1) be in Good Standing; and (2) be affiliated with eXp as a real estate licensee. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

eXp Realty (USA) Policies and Procedures Page 85 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES **(This section of these eXp P&Ps is an excerpt taken directly from the Insider Trading Policy of eXp World Holdings, Inc. (adopted as of March 31, 2023). Part II has been intentionally omitted as it does not apply to Agents of eXp, unless they are also “insiders,” in which event they will receive Part II separately.)** XXIX. INSIDER TRADING POLICY OF EXP WORLD HOLDINGS, INC. This Insider Trading Policy (“Policy”) describes the standards of eXp World Holdings, Inc. and its subsidiaries (the “Company”) on trading, and causing the trading of, the Company’s securities or securities of certain other publicly traded companies while in possession of confidential information. Part I of this Policy (below) prohibits trading in certain circumstances and applies to all directors, executive officers, employees, agents, and brokers, and their respective immediate family members, of the Company. One of the principal purposes of the United States federal securities laws is to prohibit so-called “insider trading.” Simply stated, insider trading occurs when a person uses material nonpublic information about the Company to make decisions to purchase, sell, give away or otherwise trade the Company’s securities or the securities of certain other companies or to provide that information to others outside the Company. The prohibitions against insider trading apply to trades, tips and recommendations by any person, including all persons associated with the Company, if the information involved is “material” and “nonpublic.” These terms are defined in this Policy under Part I, Section 3 below. The prohibitions would apply to any director, executive officer, employee, agent or broker of the Company who buys or sells securities on the basis of material nonpublic information that he or she obtained about the Company, its businesses, partners, competitors or other companies with which the Company has contractual relationships or may be negotiating transactions. PART I 1. Applicability. This Policy applies to all trading or other transactions in (i) the Company’s securities, including common stock, options and any other securities that the Company may issue, such as preferred stock, notes, bonds and convertible securities, as well as to derivative securities relating to any of the Company’s securities, whether or not issued by the Company and (ii) the securities of certain other companies, including common stock, options and other securities issued by those companies as well as derivative securities relating to any of those companies’ securities, where the person trading used information obtained while working for the Company. 2. No Trading or Causing Trading While in Possession of MNPI. (a) No director, executive officer, employee, agent, or broker or any of their immediate family members may purchase or sell, or offer to purchase or sell, any Company security, whether or not issued by the Company, while in possession of material nonpublic information (“MNPI”) about the Company. (The terms “material” and “nonpublic” are defined in Part I, Section 3(a) and (b) below.) (b) No director, executive officer, employee, agent, or broker or any of their immediate family members who knows of any material nonpublic information about the Company may communicate that information to any other person (“tip”), including family members and friends, or otherwise disclose such information without the Company’s authorization. (c) No director, executive officer, employee, agent, or broker or any of their immediate family members may purchase or sell any security of any other publicly traded company while in possession of material nonpublic information related to that company that was obtained in the course of his or her involvement with the Company. No director, executive officer, employee, agent, or broker or any of their immediate family members who knows of any such material nonpublic information may communicate that information to, or tip,

eXp Realty (USA) Policies and Procedures Page 86 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES any other person, including family members and friends, or otherwise disclose such information without the Company’s authorization. (d) For compliance purposes, you should never trade, tip or recommend securities (or otherwise cause the purchase or sale of securities) while in possession of information that you have reason to believe is material and nonpublic unless you first consult with, and obtain the advance approval of, the Compliance Officer (which is defined in Part I, Section 3(c) below). (e) Directors and executive officers of the Company must “pre-clear” all trading in securities of the Company in accordance with the procedures set forth in Part II, Section 3 below. 3. Definitions. (a) Material. Insider trading restrictions come into play only if the information you possess is “material.” Materiality, however, involves a relatively low threshold. Information is generally regarded as “material” if it has market significance, that is, if its public dissemination is likely to affect the market price of securities, or if it otherwise is information that a reasonable investor would want to know before making an investment decision. Information dealing with the following subjects is reasonably likely to be found material in particular situations: (i) significant changes in the Company’s prospects; (ii) significant write-downs in assets or increases in reserves; (iii) developments regarding significant litigation or government agency investigations; (iv) liquidity problems; (v) changes in earnings estimates or unusual gains or losses in major operations; (vi) major changes in the Company’s management or the board of directors; (vii) changes in dividends; (viii) extraordinary borrowings; (ix) major changes in accounting methods or policies; (x) award or loss of a significant contract; (xi) cybersecurity risks and incidents, including vulnerabilities and breaches; (xii) changes in debt ratings; (xiii) proposals, plans or agreements, even if preliminary in nature, involving mergers, acquisitions, divestitures, recapitalizations, strategic alliances, licensing arrangements, or purchases or sales of substantial assets; and (xiv) offerings of Company securities. Material information is not limited to historical facts but may also include projections and forecasts. With respect to a future event, such as a merger, acquisition or introduction of a new product, the point at which negotiations or product development are determined to be material is determined by balancing the probability that the event will occur against the magnitude of the effect the event would have on a company’s operations or stock price should it occur. Thus, information concerning an event that would have a large effect on stock price, such as a merger, may be material even if the possibility that the event will occur is relatively small. When in doubt about whether particular nonpublic information is material, you should presume it is material. If you are unsure whether information is material, you should either consult the Compliance Officer before making any

eXp Realty (USA) Policies and Procedures Page 87 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES decision to disclose such information (other than to persons who need to know it) or to trade in or recommend securities to which that information relates, or assume that the information is material. (b) Nonpublic. Insider trading prohibitions come into play only when you possess information that is material and “nonpublic.” The fact that information has been disclosed to a few members of the public does not make it public for insider trading purposes. To be “public” the information must have been disseminated in a manner designed to reach investors generally, and the investors must be given the opportunity to absorb the information. Even after public disclosure of information about the Company, you must wait until the close of business on the second trading day after the information was publicly disclosed before you can treat the information as public. Nonpublic information may include: (i.) information available to a select group of analysts or brokers or institutional investors; (ii.) undisclosed facts that are the subject of rumors, even if the rumors are widely circulated; and (iii.) information that has been entrusted to the Company on a confidential basis until a public announcement of the information has been made and enough time has elapsed for the market to respond to a public announcement of the information (normally two trading days). As with questions of materiality, if you are not sure whether information is considered public, you should either consult with the Compliance Officer, or assume that the information is nonpublic and treat it as confidential. (c) Compliance Officer. The Company has appointed the General Counsel as the Compliance Officer for this Policy. The duties of the Compliance Officer include, but are not limited to, the following: (i) assisting with implementation and enforcement of this Policy; (ii) circulating this Policy to all covered persons and ensuring that this Policy is amended as necessary to remain up-to-date with insider trading laws; (iii) pre-clearing all trading in securities of the Company by directors and executive officers in accordance with the procedures set forth in Part II, Section 3 below; and (iv) providing approval of any Rule 10b5-1 plans under Part II, Section 1(c) below and any prohibited transactions under Part II, Section 4 below. 4. Exception. The trading restrictions of this Policy do not apply if you are exercising stock options granted under the Company’s 2015 Equity Incentive Plan (or any successor plan) for cash or the delivery of previously owned Company stock. However, the sale of any shares issued on the exercise of Company-granted stock options and any cashless exercise of Company-granted stock options are subject to trading restrictions under this Policy. 5. Violations of Insider Trading Laws. Penalties for trading on or communicating material nonpublic information can be severe, both for individuals involved in such unlawful conduct and their employers and supervisors, and may include jail terms, criminal fines, civil penalties and civil enforcement injunctions. Given the severity of the potential penalties, compliance with this Policy is absolutely mandatory. (a) Legal Penalties. A person who violates insider trading laws by engaging in transactions in a company’s securities when he or she has material nonpublic information can be sentenced to a substantial jail term and required to pay a criminal penalty of several times the amount of profits gained or losses avoided.

eXp Realty (USA) Policies and Procedures Page 88 of 88 Version_R_USA_EN_09.15.2025 POLICIES AND PROCEDURES In addition, a person who tips others may also be liable for transactions by the tippees to whom he or she has disclosed material nonpublic information. Tippers can be subject to the same penalties and sanctions as the tippees, and the SEC has imposed large penalties even when the tipper did not profit from the transaction. The SEC can also seek substantial civil penalties from any person who, at the time of an insider trading violation, “directly or indirectly controlled the person who committed such violation,” which would apply to the Company and/or management and supervisory personnel. These control persons may be held liable for up to the greater of $2,301,065 or three times the amount of the profits gained or losses avoided. Even for violations that result in a small or no profit, the SEC can seek penalties from a company and/or its management and supervisory personnel as control persons. (b) Company-Imposed Penalties. Persons who violate this Policy may be subject to disciplinary action by the Company, including dismissal for cause. Any exceptions to the Policy, if permitted, may only be granted by the Compliance Officer and must be provided before any activity contrary to the above requirements takes place. 6. Inquiries. If you have any questions regarding any of the provisions of this Policy, please contact the Compliance Officer at [email protected]. [END OF DOCUMENT]

PRIMARY STATE	LICENSE NUMBER

NON-PRIMARY STATE(S) (if applicable)	LICENSE NUMBER(S)


Name	Jurisdiction of Organization
eXp Realty, LLC	Washington
eXp Realty of California, Inc.	Washington
eXp Realty of Canada, Inc.	Canada
SUCCESS Enterprises LLC	Delaware


Date:	February 24, 2026

By:	/s/ Glenn Sanford
	Glenn Sanford
	Chief Executive Officer (Principal Executive Officer)