Corporate Responsibility - Policies

Policies

Anti-Bribery/Anti-Corruption

Anti-Bribery Policy, Anti-Corruption Policy and Relationships with Government Officials, including Foreign Officials

Bribery of any nature is illegal under U.S. law and the laws of many other countries. You are strictly prohibited from offering or accepting any kind of bribe, kickback, or inducement to or from any person, whether that person is a government official or a private party. For this reason, subject to the terms of our Political Contributions Policy set forth in this Code, the Company forbids any payments, entertainment (other than meals where Company-related

work activities are conducted) and gifts to government officials at any level. A relationship with public officials must not jeopardize the reputation of the officials or the Company should the full

details of the relationship, including any gifts or entertainment, become public. Relationships that could be perceived as questionable should be disclosed. Situations must be avoided where

judgment might be influenced by or appears to be influenced by unlawful or unethical behavior.

The U.S. Foreign Corrupt Practices Act (FCPA) generally prohibits giving money or anything of value to foreign government officials, foreign political parties, or candidates for foreign political office for the purpose of influencing a foreign government. This includes making any payments

through intermediaries, such as sales representatives or consultants. Before making any payment or giving anything of value to a foreign official, employees should consult with the General Counsel. Violations of the FCPA can result in significant civil and criminal penalties for

both the Company and the individuals involved.

If you suspect a transaction in which you are participating with new or existing customers, vendors or other third parties has indicators of bribery or corrupt practices as described above, please contact the General Counsel or the Call to Action hotline.

Anti-Money Laundering

Money laundering is the process by which individuals or organizations try to conceal illicit funds or make these funds look legitimate. Money laundering is strictly prohibited. The laws in certain countries require the Company to report suspicious activity. If you deal directly with new or existing customers, vendors or other third parties, the following examples may be indications of potential money laundering: attempts to make large payments in cash; payments by someone who is not a party to the applicable contract; requests to pay more than what is provided by the contract; payments made in currencies other than those specified in the contract; payments from an unusual account; and transactions forming an unusual pattern or many repetitive cash payments. If you suspect a transaction in which you are participating has indicators of money laundering, please contact the General Counsel or the Call to Action hotline.

Biodiversity

As an owner and operator of real estate in various markets nationwide, Equity Residential interacts with various species, habitats, ecosystems, and landscapes and strives to promote and protect the biodiversity of ecosystems in a manner intended to support sustainable development and usage of real estate. We do this by developing new projects in a sustainable manner.

To ensure that biodiversity is taken into account when wedesign, renovate and operate our buildings, we systematically consider these issues in the early phase of projects. In line with best practice of applying the mitigation hierarchy framework, Equity Residential’s approach is grouped into four sequential phases:

Avoid: Equity Residential considers necessary measures to avoid creating negative impacts on biodiversity through site selection criteria, design, and planning. Generally, this means that Equity uses these various planning techniques to avoid negative impacts to natural habitat areas, green fields, or wetlands, as well as areas of importance for birds and key biodiversity areas. In many cases, native landscaping is integrated into site design to improve the quality of the air, soil, and water, help to prevent flooding, control erosion, and enhance habitats to promote biodiversity. We follow all proper permitting approvals per the local jurisdiction.

Minimize: Seek to reduce the duration, intensity and/or negative impacts on biodiversity that cannot be reasonably avoided, such as interactions with flora and fauna, and abatement operations by containing development activities to within certain parameters on the site, to the extent appropriate. An example is fencing in the building area so that native wildlife does not come in contact with the construction site.

Restore and regenerate: When reasonably appropriate, adopt measures to restore and/or regenerate the ecosystems degraded by impacts that cannot be avoided or minimized, such as developing green infrastructure to limit flooding, activities intended to help re-establish habitat, and reintroducing biodiversity and ecosystem services. This can be done by techniques such as reseeding and replanting, pest management, eliminating hazards, and supporting local pollinator species.

Transform: Promote gradual transformation to tackle the systemic drivers of loss of biodiversity by engaging with internal and external stakeholders. Our commitment is based on raising awareness by our teams, contractors, and partners on biodiversity issues.

Equity Residential is committed to continuous improvement of the management of issues related to the conservation of biodiversity, the development of ecosystem services and the protection of landscape through the study of methods to monitor performance and the definition of specific objectives.

Cyber Security Awareness

The company is focused on reducing risk and exposure to a data breach of our employee and customer information. This policy is in place in an effort to create awareness and increase the likelihood of secure outcomes by identifying and correcting individual behaviors, such as when employees fail phishing tests or when security incidents are triggered as a result of employee actions. Employees are expected to complete IT Security Awareness training upon hire and complete a refresher training annually. In addition, if an employee fails a phishing test, the employee will be re-enrolled in the corresponding IT Security Awareness training and the employee’s manager will be notified. It is expected that the manager will meet with the employee to review the employee’s experience and discuss a prevention plan.

It is the responsibility of every employee to protect our company’s data by taking IT Security Awareness seriously, thinking before clicking, being vigilant and reporting any suspicious activity.

Executive Clawback

If Equity Residential (the “Company”) is required to restate its financial results due to material noncompliance with any financial reporting requirement, other than due to a change in applicable accounting methods, rules or interpretations, the result of which is that any performance-based compensation received by an executive officer during the 3-year period preceding the publication of the restated financial statement (the “Awarded Compensation”) would have been lower (the “Actual Compensation”) had it been calculated based on such restated results, the Compensation Committee of the Company’s Board of Trustees (the “Committee”) may seek to recover for the benefit of the Company all or a portion of the after-tax difference between the Awarded Compensation and the Actual Compensation. In determining whether to seek recoupment and the amount and form of recoupment (the amount or proportion of which need not be the same for every executive officer), the Committee shall take into account any factors it deems reasonable or appropriate, including without limitation the likelihood of success under governing law versus the cost and effort involved, whether the executive officer engaged in wrongdoing or committed grossly negligent acts or omissions or was directly responsible for the events that led to the restatement, and its good faith estimate of the value of any tax deduction available to the executive officer in respect of such repayment. Recoupment of any performance-based compensation may be made, in the Committee’s discretion, via the cancellation of vested or unvested share options, forfeiture/cancellation of unvested restricted stock, cancellation of restricted units (f/k/a LTIPs) and/or cash payments. For the purposes of this policy, the term “executive officer” shall refer to any “officer” of the Company for purposes of Section 16 of the Securities Exchange Act of 1934, and “performance- based compensation” means any cash or equity award, the amount of which is determined in whole or in part upon the achievement of specified performance measures. Following the SEC’s adoption of final rules regarding executive recoupment policies pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act, this policy will be amended, if necessary, to conform with the final rules. The Committee has the authority to administer, amend, interpret and enforce this policy on behalf of the Company.

Human Rights

Respect for Human Rights

Respect for human rights is a fundamental value at Equity Residential and its affiliates (“Equity”). We encourage all persons to be treated with dignity and respect, and have adopted the following Human Rights Policy, which is our own, but was developed by looking to, among other sources, the United Nations’ Universal Declaration of Human Rights. Equity strives to respect and promote the human rights of all persons impacted, both directly and indirectly, by our business.

Anti-discrimination, Anti-harassment, and Anti-retaliation

Equity is committed to treating all our employees with dignity and respect. We value diversity and inclusion and provide equal opportunities to all employees regardless of race, religion, color, creed, sex, sexual orientation, gender, sexual/gender identity/expression, age, disability, pregnancy, national origin, citizenship, military or protected veteran status, marital status, genetic characteristics or information, ancestry or any other characteristic protected by applicable law. We are committed to maintaining a workplace free from harassment, intimidation, and hostility.

Health and Safety

Equity strives to provide safe and healthy workplaces, including providing employees with the resources and training necessary to perform their jobs safely, as well as providing programs that encourage personal health and wellbeing.

Compensation and Labor

Equity provides fair compensation, benefits and working hours to all its employees.

Equity does not and will not engage in human trafficking in any capacity, and does not use child labor. Workers below the age of 18 are not and will not be involved in activities likely to jeopardize their health or safety or interfere with their compulsory education. Equity does not and will not use any forced, compulsory, or involuntary labor, and employees shall be able to terminate their employment within reasonable notice.

Employee Training and Reporting Violations

Equity’s Human Resources Department is responsible for implementing Equity’s Code of Ethics and Business Conduct, which includes concepts contained in this Human Right Policy, and all employees are required to complete annual training on Equity’s Code of Ethics and Business Conduct. Employees can report a violation of this Human Rights Policy by calling the Company’s Call to Action Hotline at (800) 231-5699. Calls may be anonymous if the employee chooses. The Company will promptly investigate all calls. Employees can also notify Human Resources, the Legal Department, or the Internal Audit Department at the contact information listed below.

Contact Information

Legal Department
Equity Residential
Two North Riverside Plaza, Suite 400
Chicago, IL 60606
312-474-1300

Internal Audit Department
Equity Residential
Two North Riverside Plaza, Suite 400
Chicago, Illinois 60606
(312) 474-1300

Human Resources Department

Employees choosing to contact Human Resources regarding the Code should direct their communications to their Regional Human Resources Director or Manager. A list of Human Resources Department Directors and Managers appears on Equity’s Intranet.

Equity Residential re-assess the needs of our Human Rights Policy as the company grows appropriate to its size and circumstances.

Operational Health & Safety (OHS) Management

OHS Management System

Overview

Equity Residential (the “Company”) has created this OHS management system which is inclusive of the principles of Plan-Do-Check-Act (PDCA), as outlined by ISO 45001. The Company periodically reviews and refines its processes to seek continual improvement. These principles are applied to our management system and to our property operations.

OHS Governance

The Company has established a full service Risk Management Department within its Legal Department and also has a Risk Management Task Force, consisting of Facilities, Legal, Property Operations and Risk Management, responsible for coordinating the safety operations of the Company in order to ensure the protection of our most valuable asset, our employees. At each property, the Community Manager/General Manager is ultimately responsible for safety. The Company requires monthly safety meetings for all Company property staff. Items that may be discussed during these meetings are identified by the Risk Management Department based on seasonal conditions, recent incidents and trends.

Plan

The Company determines and assesses OHS risks and opportunities, and establishes OHS objectives including, but not limited to, general safety rules (such as equipment and machinery maintenance and operation, personal protective equipment, safe use of chemicals and first aid), and our Hazard Communication Program (which includes Safety Data Sheets (SDS), emergency response guidance, and training).

The Company implements the processes, activities, initiatives, and action plans as determined by its Risk Management Department and the Risk Management Task Force.

Check

The Risk Management Department continuously monitors and measures activities and processes with regard to the Workplace Safety Manual and OHS objectives and reports the results promptly to the appropriate parties. The Risk Management Department periodically re-evaluates OHS objectives and the measures implemented to achieve these objectives, with a focus on identifying what was successful in reaching OHS goals and what failed to reach the desired impact.

Act

The Company takes action on objectives directed by the Risk Management Department and Risk Management Task Force to work with the appropriate stakeholders to make modifications as needed and continually improve OHS performance to achieve the intended outcomes.

Political Contributions

From time to time, employees of the Company inquire as to whether or not the Company (or the employee on behalf of the Company) is permitted to contribute money towards a political candidate or in support of a political cause that the employee believes would further the interests of the Company.

As part of actively managing its portfolio and related risks, the Company monitors political developments nationally and in the jurisdictions in which it does business that could positively or negatively impact its business. Where significant business interests of the Company would be directly impacted by proposed legislation or regulatory action, the Company may consider Company Political Spending (as defined below) in support of its position directly or through industry groups provided that such spending complies with this Policy. Historically the Company’s Political Spending has been very limited but increased in recent years, and may remain elevated for some time, due to recent legislative activity in our various markets seeking to permit, impose, or expand rent control and other restrictions on our ability to operate our properties and collect rent. In 2021, our Company Political Spending (as defined below) was $707,900, and was approved in accordance with the policy below.

Even though this amount is small in relation to the size of our business, politically-related expenditures may subject the Company (and the employee) to serious legal consequences and negative publicity. Laws governing corporate political spending are complex and vary by jurisdiction, and penalties for noncompliance can be severe. Also, most jurisdictions have complicated and detailed rules for disclosure of these types of expenditures.

Consequently, the Company has established the following policy to ensure that any political spending activity by the Company is done in a transparent and legal manner that clearly serves the interests of the Company as a whole and its shareholders:

Unless approved in advance by the Chief Executive Officer as provided below, the Company’s policy is that the following types of contributions by or on behalf of the Company (i.e. “Company Political Spending”), are strictly prohibited:

contributions to or on behalf of any officeholders or candidates for any election or referendum, initiative or proposition (note that contributions to the campaigns of candidates for federal office are prohibited by law and will not receive approval in any event);
contributions to or on behalf of political parties;
contributions to or on behalf of Political Action Committees (“PACs”), “SuperPACs”, or other political entities organized and operating under 26 U.S.C. Sec. 527 of the Internal Revenue Code (i.e. “527s”); and
indirect support of the above through paying for advertisements or other campaign expenses, or by donation of time or supplies.

Should any employee of the Company desire to seek approval for Company Political Spending, the following provisions shall apply:

Any Company Political Spending must receive prior written approval from the Chief Executive Officer.
Any Company Political Spending approved by the Chief Executive Officer shall be legitimately linked to the Company’s business purposes and strategic intent, and not those of its individual officers or trustees.
No contribution or expenditure will be given or made in anticipation of, in recognition of, or in return for, any official act.

The Corporate Governance Committee of the Company’s Board of Trustees shall review Company Political Spending under this policy (and the disclosures in this policy shall be updated by March 31st of each year) at least once per calendar year.

The Company may belong to various industry trade associations and state apartment associations that may engage in political spending from time to time. At the present time, the Company is a member of several of these groups, most notably the National Association of Real Estate Investment Trusts (“NAREIT”) and the National Multifamily Housing Council (“NMHC”). In 2021, the Company spent approximately $650,000 in membership dues for these types of groups. Disclosures on the amounts spent by these groups on political activities are available online or at the Federal Election Commission.

Any amounts spent by such industry trade associations on political spending are generally not attributed to the Company, provided that such activities are not controlled by the Company and are generally undertaken for the benefit of the industry or members of the organization as a whole. From time to time, the Company may ask its employees to consider contributions towards these types of associations, provided that any such contributions are purely voluntary.

Employees, acting solely in their personal capacity, may participate in political activity and make political contributions at their own expense, but may not seek reimbursement from the Company for contributions that are prohibited by the above policy. Personal, non-corporate contributions, for which no reimbursement is sought, are not affected by the restrictions of this policy.

Sustainability Policy

Equity Residential’s Sustainability Program actively manages environmental impacts and climate-related risks and opportunities through optimized, financially responsible capital investments and technologies. We methodically focus on energy, water and emission to advance the Program’s policies, targets, and resilience outcomes. Together our Program drives long-term asset value, responsibly manages risk, and engages our communities, residents, employees and shareholders as part of our broader ESG strategy, and commitment to good corporate citizenship and maximizing investment performance.

Vendor Sustainability Policy

Sustainability and social responsibility is not only important for our company, but through our Vendor Sustainability Policy we aim to ensure that our vendors improve their social and environmental impact. Employment Equity Residential expects vendors to be committed to equal employment opportunity for all job applicants and employees. No job applicant or employee should be discriminated against because of race, religion, color, creed, sex, sexual orientation, gender, sexual/gender identity, age, pregnancy, disability, national origin, citizenship, military or veteran status, marital status, genetic characteristic or information, ancestry or any other characteristic protected by law.

Vendors will adhere to applicable laws pertaining to age minimums and employment restriction based on age.

Vendors will not use forced labor. Employment must be voluntary.

Vendors will adhere to all applicable laws regarding wages, compensation and benefits.

Code of Ethics and Business Conduct

Vendors should act in accordance with Equity Residential’s Code of Ethics and Business Conduct available online: https://s1.q4cdn.com/843629197/files/doc_downloads/governance_docs/2021/09/Code_of_Ethics_2021-(1).pdf Opens in new window