GOVERNANCE
INTRODUCTION
ESG OBJECTIVES AND STRATEGY
ENVIRONMENTAL
SOCIAL
APPENDICES
67
Ethics and Compliance ESRT has a Code of Business Conduct and Ethics, which was adopted and applies to our board, directors, officers, and employees and is reviewed and overseen by our Nominating and Corporate Governance Committee. We also have a Vendor Code of Conduct that applies to our suppliers and vendors. We train our employees on the Code on an annual basis and provide additional compliance training on key topics, including insider trading, anti-harassment and discrimination including sexual harassment, human rights, and cybersecurity, on a rotational basis. All employees are required to annually reaffirm their compliance with the Code. The company actively monitors internal compliance with its Code of Business Conduct and Ethics. Employees are required to speak up about misconduct and 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 committees. We intend to disclose on our website any amendment to or waiver of any provision of the Code that would be required to be disclosed under the rules of the U.S. Securities and Exchange Commission or the New York Stock Exchange. Mandatory Training All employees must complete mandatory training annually, including: • Sexual Harassment • Insider Trading • Compliance Manual • Cybersecurity • Employee Manual Vendors and Procurement At ESRT, our culture of ethics extends to our entire supply chain. Our Vendor Code of Conduct outlines our expectations for our partners, service providers, suppliers, vendors, and contractors to work ethically and in a manner that is consistent with our high standards.
EMPIRE STATE REALTY TRUST: 2022 SUSTAINABILITY REPORT
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