GOVERNANCE
INTRODUCTION
ESG STRATEGY
ENVIRONMENTAL
SOCIAL
APPENDICES
Code of Business Conduct and Ethics
Our Board 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 Corporate 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 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 SEC or the NYSE.
MANDATORY TRAINING All employees must complete mandatory training annually, including:
• Sexual Harassment
• Compliance Manual
• Cybersecurity
• Insider Trading
• Employee Manual
Disclosure Frameworks & Industry Alignment
Transparency is a key component of governance and accountability, as it informs our stakeholders of our actions and their results. We utilize internationally recognized disclosure frameworks as a part of our strategy to ensure full transparency and accurate reporting. REPORTING We submit the GRESB Real Estate Assessment annually and strive to align our disclosures with TCFD, which evaluates our organization on our climate-related risks. In 2021 we received a GRESB score of 94 out of 100 compared to our 2020 score of 88 and the global average of 72. We achieved the highest possible score in Leadership, Policies, Reporting, Stakeholder Engagement, Targets, Tenants & Community, Data Monitoring & Review, as well as the highest score of all peers in Disclosure. As an industry leader, this significant improvement demonstrates our commitment to and implementation of our climate resilience and ESG strategies.
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