CODE OF BUSINESS CONDUCT AND ETHICS Our Board of Directors has adopted a Code of Business Conduct and Ethics, which applies to our directors, officers, and employees and is reviewed and overseen by our Nominating and Corp orate Governance Committee. We train our employees on the code on an annual basis and provide additional compliance training on key topics on a rotational basis, including insider trading, anti-harassment and discrimination, and cybersecurity. All employees are required annually to reaffirm their compliance with the code. Employees are encouraged to speak up about misconduct and required to report suspected or known code violations. The code prohibits retaliation against anyone who raises an issue or concern in good faith. Any waiver of the code for our directors or executive officers may be made only by our Board or one of our Board of Directors committees. MANDATORY TRAINING All employees must complete mandatory training annually, including: • Sexual Harassment • Insider Trading • Bribery & Corruption • Cybersecurity • Employee Manual Recertification • Core Competencies such as leadership and communication
40 EMPIRE STATE REALTY TRUST: 2020 SUSTAINABILITY REPORT
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