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) charitable contributions 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 charitable contributions, 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.

In 2022, Equity Residential did not experience any material breaches in its Code of Ethics that would be reportable by law in our financial filings.

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 we design, renovate and operate our buildings, we systematically consider these issues in the early phase of projects as part of location-based biodiversity assessments where relevant. 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 measures intended to help it avoid creating negative impacts on biodiversity through site selection criteria, design, and planning. Generally, this means that Equity uses these various planning techniques to endeavor to avoid negative impacts to natural habitat areas, green fields, or wetlands, as well as areas of importance for wildlife, such as 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.

Minimize: Equity Residential seeks 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, Equity Residential adopts 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. This can be done by techniques such as reseeding and replanting, conserving water, integrating biophilic design and supporting local pollinator species.

Transform: Equity Residential also promotes 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 across our teams, contractors, and partners on biodiversity issues. For example, we plan to hold educational and engagement sessions with capital, development and other key leaders to learn about biodiversity issues.

Equity Residential is committed to continuous improvement of the management of issues related to the conservation of biodiversity and the protection of landscape through the study of methods to monitor performance and the definition of specific objectives, such as through wetland management plans.

When it comes to deforestation, Equity Residential has established a commitment to promote the reduction of deforestation relating to our development activities by 2030. This will include an evaluation to ensure clearance or conversion of forests in one area are compensated with an equal area replanted elsewhere. Strategies we will consider wherever possible to tackle deforestation include:

• Procuring FSC certified wood and paper products
• Using non-wood alternatives for building materials

This commitment to reduce deforestation means we encourage our suppliers to also commit to efforts to procure responsibly and reject products clearly linked to deforestation.

Cyber Security Oversight and Awareness

Our dedicated Information Technology (IT) Security Team, under the oversight of our Senior Vice President of IT, ensures the security, compliance, privacy and integrity of our information assets. Our Senior Vice President of IT reports to and updates our Chief Operating Officer, as well as the Audit Committee of our Board of Trustees on key issues and future plans every year. Our IT governance policies guide how we manage our data, deliver value and protect against threats. Processes include having external auditors audit our IT infrastructure and information security management systems annually and conducting third-party vulnerability analysis, which include simulated hacker attacks.

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.

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.

Incentive-Based Compensation Clawback Policy

If Equity Residential (the “Company”) determines it must prepare a restatement, the Company will seek to recover the amount of erroneously awarded compensation received by a covered officer, as provided below.

For purposes of this policy, the term (i) “restatement” means an accounting restatement due to the material noncompliance of the Company with any financial reporting requirement under the U.S. federal securities laws, including any required accounting restatement to correct an error in previously issued financial statements that is material to the previously issued financial statements (commonly referred to as “Big R” restatements), or that would result in a material misstatement if the error were corrected in the current period or left uncorrected in the current period (commonly referred to as “little r” restatements); (ii) “incentive-based compensation” means any compensation that is granted, earned or vested based wholly or in part upon the attainment of a financial reporting measure, including any proceeds realized from the sale of Company securities that were acquired upon the attainment of a financial reporting measure; (iii) “financial reporting measure” means any measure that is determined and presented in accordance with, or derived wholly or in part from, the accounting principles used in preparing the Company’s financial statements, as well as stock price and total shareholder return; (iv) “erroneously awarded compensation” means the amount of incentive-based compensation received by a covered officer during the three completed fiscal years immediately preceding the date on which the Company was required to prepare the restatement, that exceeds the amount of incentive-based compensation that otherwise would have been received had the amount been determined based on the restatement, computed without regard to any taxes paid; and (v) the term “covered officer” means a current or former “officer” of the Company as defined in Rule 16a-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The Compensation Committee (the “Committee”) of the Company’s Board of Directors shall have full and final authority to make all determinations under this policy, including as to the amount and form of recovery. The Committee must seek to recover from a covered officer all erroneously awarded compensation unless the direct expense paid to a third party to assist in enforcing this policy would exceed the recoverable amount, or applicable exchange listing standards otherwise do not require recovery. For incentive-based compensation based on stock price or total shareholder return, where the amount of erroneously awarded compensation is not subject to mathematical recalculation directly from the information in the restatement, the Committee may determine a reasonable estimate of the effect of the restatement on the stock price or total shareholder return. The Committee may determine that the form of recovery is to offset the recovery amount against other compensation (including through the cancellation of equity awards). In addition, the Committee may, to the extent permitted by law, take other remedial and recovery action, as determined by the Committee. The Committee may cause the Company to take such action as it deems necessary or appropriate to implement this policy. This policy is intended to comply with Section 10D of the Exchange Act, Rule 10D-1 thereunder, and the applicable rules of any national securities exchange on which the Company’s securities are listed, and this policy will be interpreted and administered consistently with that intent.

Occupational Health and Safety Management System and Policy

Commitment 

Equity Residential has created this OHS management system and policy which is inclusive of the principles of Plan-Do-Check-Act (PDCA), as outlined by ISO 45001. We periodically review and refine its processes to seek continual improvement. These principles are applied to our management system.

Equity Residential strives to create and maintain a safe workplace to prevent or minimize occupational injuries and illnesses at the corporate level. Consistent and continuous efforts by all employees shall be directed to preventing workplace accidents, maintaining the workplace and equipment in a safe condition, and awareness of one’s own physical safety and wellbeing. We are also committed to preventing hazards and understanding any health and safety concerns at the properties we manage. This includes knowledge of existing controls, applicable standards and regulations. 

Scope

This OHS management system and policy is applicable to all employees and aligns with Occupational Safety and Health Administration (OSHA) compliance requirements. 

OHS Governance

This OHS management system and policy is endorsed by our Executive Management, who receive updates on OHS topics during established meetings. 

Equity Residential 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 our safety operations 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. Equity Residential requires monthly safety meetings for all 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. Discussions of employee safety and potential risks occur between the Risk Management and Facilities and Property Operations as needed. Consultations around safety are held with employees and managers if counseling or a safety violation is warranted.

Plan

Equity Residential 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), how to reduce OHS incidents, and improvements to our Hazard Communication Program (which includes emergency response guidance and its own training). Safety Data Sheets (SDS) are required per contractual agreements to be collected from suppliers of all hazardous substances and reviewed by the Service Manager.

Equity Residential has an internal Safety Manual and Workplace Injury & Illness Prevention Program manual for employees to adhere to that outlines safety prioritization and action plans for various occupational health and safety related circumstances.

Do

Equity Residential implements the processes, activities, initiatives, and action plans as determined by its Risk Management Department and the Risk Management Task Force. We provide safety training to employees to raise awareness and reduce potential safety incidents.

We conduct workplace inspections and hazard assessments on a regular basis for the purpose of identifying and recording potential and actual hazards associated with buildings, equipment, environment, processes and practices. The inspection identifies any hazards that require attention and recommends corrective action. We also conduct internal property inspections and hazard assessments to identify any potential hazards at our properties. 

Every month, our team conducts safety meetings to proactively address and promote a safe and secure work environment. Topics addressed at meetings vary each month and are often relevant to the time of year as well as active or pertinent issues. 

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. In alignment with OSHA, Equity Residential has procedures in place to investigate work-related injuries, ill health, diseases and incidents. 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. Given the nature of our business, Equity Residential has limited OHS incidents. 

Act

In the event of a work-related accident, we will make sure that the injured employee is cared for and receives appropriate medical attention, if necessary. In addition, the accident will be reviewed to determine the cause(s) and to ensure that corrective action is taken to prevent a recurrence.

Equity Residential 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 Policy

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 2023, our Company Political Spending (as defined below) was $2,141,575, 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, by donation of time or supplies, or through any charitable contributions or sponsorship that could be perceived as connected to a government official.

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 2023, the Company spent approximately $800,000 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 and charitable activity and make political and charitable 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.

Supply Chain and Vendor Policy

At Equity Residential, we believe operating in a responsible manner is imperative to our business and our supply chain and vendors (collectively, “vendors”) should operate in alignment with our values. This Supply Chain and Vendor Policy outlines our expectations for our vendors, including contractors. 

Human Rights and Labor Standards
In alignment with Equity Residential's commitment to human rights, as stated in our Human Rights Statement (above), we expect our vendors to also commit to protecting human rights and treating others with respect and dignity, including when it comes to: 

• Workforce: Complying with all applicable wage and compensation requirements under applicable labor laws for regular work, overtime, maximum hours, minimum wage, public holidays, payday requirements and other elements of compensation and employee benefits.
• Labor Standards:
  • Not engaging in human trafficking in any capacity. 
  • Complying with all applicable minimum age labor laws and not using child labor. 
  • Ensuring workers below the age of 18 should not be involved in activities likely to jeopardize their health, safety or morals or interfere with their compulsory education.
  • Not using any forced, compulsory, or involuntary labor, whether bonded, indentured, or imprisoned.

Anti-Discrimination, Anti-Harassment and Anti-Retaliation

Equity Residential expects its vendors to meet the standards of all applicable anti-discrimination, anti-harassment, and anti-retaliation laws, and provide a work environment free of discrimination, harassment based on gender, race, color, national origin, age, religion, marital status, disability, sexual orientation or veteran status, or any other protected characteristic or identity under local, state or federal law of the country in which the vendor operates. Equity Residential expects its supply chain and vendors to be committed to equal employment opportunities for all job applicants and employees. 

Health and Safety
Equity Residential expects its vendors to comply with all applicable health and safety laws and take all reasonable and necessary actions to prevent accidents and injuries. 

Environmental Impact
Equity Residential encourages vendors to evaluate all facets of their products including manufacturing, packaging, shipping, etc., to reduce their environmental impact. Vendors are also encouraged to have environmental management systems or processes in place to reduce greenhouse gas emissions, follow pollution prevention plans, and use resources efficiently. Vendors may also decide to review internal environmental goals regularly, evaluate environmental impacts and develop action plans for improvement if necessary. Vendors will comply with all applicable

environmental laws, as well as may aim to comply with Equity Residential’s Biodiversity Commitment(above).

Code of Ethics and Business Conduct
Equity Residential expects vendors will act in accordance with Equity Residential’s Code of Ethics and Business Conduct available online, particularly as it relates to anti-corruption, competition, and anti-trust.

Vendor Management Processes
At Equity Residential, we have conducted a supplier screening approach that assesses our most significant suppliers based on business relevance by product type and sector and are in the process of expanding this to encompass screening of potential environmental, social, and governance risks. We aim to over time continue engaging with our most significant suppliers to ensure the continuity of business, as well as understand our alignment on ESG best practices.

Supply Chain Management Program

Context of the Organization 

Equity Residential’s Supply Chain Management Program document will be revised periodically as our Supply Chain Management Program evolves. This document establishes a systematic approach to Equity Residential’s sustainability activities as it pertains to our supply chain and vendors. 

Equity Residential aims to actively manage environmental, climate-related, and social impacts, risks, and opportunities for our direct operations as well as our value chain. Responsibly managing potential risks in our supply chain and engaging with vendors supports our broader ESG strategy and commitment to good corporate citizenship and maximizing investment performance.

Leadership Oversight

Our Board and executive oversight of environmental matters acts as a necessary foundation for Equity Residential’s ESG program, including our Supply Chain Management Program. The Corporate Governance Committee of our Board of Trustees has oversight of the Company’s ESG activities. 

Our executive-level ESG Steering Committee meets quarterly and oversees our ESG strategy and goals and has oversight of implementation of initiatives associated with our Supply Chain Management Program. The ESG Steering Committee Charter governs the group’s roles and responsibilities. At the corporate level, our cross-functional ESG Working Group manages progress on our strategy and directs communications between functional owners for procurement and the ESG Steering Committee. 

Supply Chain and Vendor Policy

Responsible action is not only important for our company, but through our Supply Chain and Vendor Policy (below) we aim to ensure that our supply chain and vendors (collectively, “vendors”) improve their social and environmental impact as well. 

Vendor Screening 

We have a systematic vendor screening approach to identify significant vendors. We take into consideration: i) the volume of business contracted with a vendor, ii) if we source critical components from them, or iii) if they would be considered a non-substitutable vendor. Significant vendors are screened from a business relevance by product type and sector and are in the process of expanding this to encompass screening of potential environmental, social, and governance risks. From an environmental perspective, we are focused on looking for vendors that are able to supply us with energy and water efficient products. We also assess if vendors are diverse. We seek to increase the diversity of the pool of potential vendors, including minority owned businesses, that we work with. Although we do not currently have ESG requirements for our vendors, we are evaluating whether to prefer vendors with stronger ESG performance.

Vendor Assessment and Development

We have conducted vendor desk assessments for a few suppliers as a pilot and plan to conduct further vendor desk assessments to verify the ESG-related policies our vendors have in place. If requested by a vendor, Equity Residential is open to supplying information on various ESG topics and providing guidance on types of operational initiatives the vendor could implement to improve their own environmental performance. We are evaluating methods to further assess vendors through engagement and other channels. We aim to over time continue engaging with our most significant suppliers to ensure the continuity of business, as well as understand our alignment on ESG best practices.