Code of Ethics & Business Conduct
Prologis is committed to operating with integrity and in full compliance with laws and regulations.
Ahead of What’s Next Prologis Code of Ethics and Business Conduct
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 2 CEO message 3 Our Customers 22 Our Community 37 Our ethics committee 4 We market honestly 23 We protect human rights 38 We protect our reputation 24 We care for the environment 39 At Our Core 5 We use social media responsibly 25 We give back to the community 40 We put our trust in our code 6 Our Business Partners 26 We engage responsibly in political activities 41 We live our values 8 We take responsibility for what we do 9 We compete fairly 27 Our 昀椀nal thoughts 42 We speak up when something isn’t right 10 We are good business partners 28 Our resources 43 We cooperate with government audits Our People 11 and investigations 29 Our policies 44 We value diversity and inclusion 12 Our Industry 30 We respect others 13 We 昀椀ght crime and corruption 31 We put safety 昀椀rst 14 We follow the rules when it comes Our Company 16 to gi昀琀s and courtesies 33 We keep accurate records 17 We follow the laws, everywhere we operate 35 We protect what’s ours 18 We play fair when buying or selling stock 36 We keep private information private 19 We avoid con昀氀icts of interest 20 Code of Ethics and Business Conduct Ethics Helpline

TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 3 CEO message In the logistics real estate business, Prologis is unique. With unparalleled scale As a valued member of our team, we are relying on you to adopt these Values, and global reach, we are well-positioned to take the risks necessary to innovate and we want you to look to our Code of Ethics and Business Conduct (“Code”) in our industry. We anticipate needs by listening, learning and solving our for assistance. Read the Code and refer to it o昀琀en as it re昀氀ects what’s important customers’ concerns. We also respond with new models and frameworks that to us. It’s a living, working document to help guide you as you put our Values not only satisfy customer demand but build a lifelong and trusted partnership. into action on the job every day. However, as we continue to adapt and embrace change, we never lose sight of If you have any questions about our Code or suspect that it has been violated, the foundational elements of our Company. That is because, we take ownership we encourage you to speak up. Your voice and your commitment to our Values of who we are. We are a team with incredible IMPACT. Our Integrity, Mentorship, are critically important. Working together, with an adherence to the highest Passion, Accountability, Courage and Teamwork are central to our success. ethical standards, we’ll go beyond simply leading our industry. We’ll lead it with unparalleled integrity. Hamid R. Moghadam Chairman of the Board of Directors and Chief Executive O昀昀icer Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 4 Our ethics committee To help administer our Code, and to respond to any ethical issues or concerns, we have created the Prologis Ethics Committee. The Committee is here to help and guide you. Ed Nekritz Colleen McKeown Chief Legal O昀昀icer and General Counsel, Chief Human Resources O昀昀icer, champions Prologis’ believes that individuals within an organization core IMPACT Values of Integrity, Mentorship, Passion, must demonstrate high ethical standards, and the Accountability, Courage and Teamwork in her company’s culture must reinforce ethical behaviors: interactions with colleagues across the globe: “One “Ethics have got to be part of the makeup of your of my goals is to ensure that Prologis continues to being and fully ingrained in the culture. They are be a safe place to work and that colleagues can feel the cornerstone of a company that does the right empowered to speak.” thing every day of the week. Nothing is more important than running a business that has the highest ethical standards.” Tim Arndt Jan Kneisel Chief Financial O昀昀icer, believes ethics and Global Compliance O昀昀icer, oversees ethics training accountability are intimately linked: “I’m proud to and compliance for Prologis: “From the moment a have worked for so many years at a company that new employee joins the Prologis team, it is incumbent holds ethics and integrity as cornerstones in all that upon us to not only arm them with our Values, but also we do. We must hold ourselves accountable to inspire them to have the courage and strength to 昀椀ght these high standards every day and in every action for those Values, help their coworkers be true to those that we take.” Values and speak up when they believe those Values are threatened. We want to make sure our employees feel empowered to challenge dishonest conduct, regardless of rank, title or position.” Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 5 In our ever-changing business At Our environment, it’s important that we remain grounded in who we are as a company. Our Code and our Values guide Core and inspire us along the way. IN THIS SECTION: We Put Our Trust in Our Code We Live Our Values We Take Responsibility for What We Do We Speak Up When Something Isn’t Right Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 6 We put our trust in our code Our Code is the foundation for all we do. It incorporates our Values How do we respond to potential violations of the code? and helps inform our everyday actions. Before we hold someone accountable for violations of the Code, our Ethics How do we put our values into practice? Committee reviews any allegations of misconduct, thoroughly investigates the conduct that purports to violate the Code and then makes a recommendation If you’re reading this, chances are, at this point, you’ve discovered that no about how to address the issue. two days at Prologis are the same, and we are moving at a rapid pace to stay What are the consequences of violating the code? Ahead of What’s Next. There are hundreds of situations that can come up during a typical workday that we’ve never dealt with before and require Violations re昀氀ect poorly on all of us and make it less likely that our customers, quick responses —some of them involving ethical dilemmas. And because our business partners or our investors will want to do business with us. That’s we are a team, every decision one of us makes can impact someone else why we must take violations very seriously and hold each other accountable. We which in turn can a昀昀ect our whole Company. Consequently, it’s important must send the message that we don’t tolerate bad behavior and that bad actors that we get things right. are simply that – individual actors who don’t re昀氀ect our Values. If someone Our Code is here to help and provide you guidance. It gives us the tools we need violates the Code, it can result in disciplinary action, including the loss of their to make the right decisions, regardless of the challenges we might face. It can job. Depending on how serious the incident is, there can even be criminal help us answer common questions like – Is that a kind gesture or a bribe? consequences. Worse yet, it can instantaneously jeopardize the hard work each one of us does every day to build the reputation of the Prologis brand. Should I hold o昀昀 on buying more stock? How can I better protect myself and my coworkers? And more... Although the Code covers many situations that can arise in a workplace setting, it’s important to keep in mind that it cannot cover every possible scenario. No document could do that. We look to it instead as a guide that provides key takeaways and fact-based examples. When we pair our knowledge of the Code with good judgment and common sense, while never being afraid to speak up, we put our Values into practice. Who must follow the code? We all do. It applies to everyone, at every level of our Company, and to every person, entity and organization working with us, for us and on our behalf. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 7 We put our trust in our code How do I follow the code? Let it guide your decision-making. If you 昀椀nd yourself in a situation and don’t know how to proceed, ask yourself: Is it allowed Would I be Is it leIs it leggal?al? (by our Code Does it re昀氀ect comfortable if my and policies)? our Values? actions were reported by the media? If you answer “yes” to all these questions, it’s probably OK to proceed. But if you answer “no” or “I’m not sure” at any point, stop, speak up and ask someone for help. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 8 We live our values At Prologis, it’s not just about what we do, it’s about how we do it, which is our competitive advantage. We lead the world in logistics real estate, and we want to do so while making an IMPACT… Integrity Accountability Integrity is the cornerstone of every action we take. We are all accountable to each other, our customers Our word is our bond. We strive to demonstrate a and to our investors. Individual accountability is critical consistency of character that is transparent, genuine, to achieving the overall goals and objectives of the trustworthy and respectful. Company. Mentorship Courage The quality of our people is the key to our success. We live in a constantly changing world. What was good Through mentorship, we pass on our institutional enough yesterday will not be enough tomorrow. We knowledge, develop our talent pool and create a embrace change, and we have the courage to take sustainable and learning enterprise. calculated risks to exceed our business objectives. Passion Teamwork We are passionate about our work. We are We are one team. We believe that our collaborative committed to going above and beyond what is culture provides a competitive advantage. We expected of us. Decisive, nimble and results-driven, communicate openly with each other and value we endeavor to be thoughtful and thorough in diversity in perspectives and opinions. everything we do. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 9 We take responsibility for what we do We have a collective responsibility to live our values. Supervisors have additional roles and responsibilities. To help put them into action, let’s each 昀椀nd ways to: As supervisors, we always: + Constantly re昀氀ect on whether we are working to make an IMPACT. + Set the tone in the middle – be a leader for the team when it comes + Ensure our day-to-day activities are in line with our Code, our to integrity. policies and the law. + Stay current on all ethics-related trainings and ensure our team + Apply good judgment and common sense. does as well. + Reach out to supervisors or coworkers for advice when needed. + Encourage others to share ideas, questions and concerns and keep an open-door policy. + Speak up when we think something isn’t right. + Guide coworkers to the right resource if we don’t know the answer + Be cooperative, honest and transparent. to a question. + Help others when we are con昀椀dent that we can lead them in the + Report potential misconduct and escalate reports to the right direction. appropriate people when necessary. + Prevent retaliation against anyone who reports a concern in good faith or participates in an investigation. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 10 We speak up when something isn’t right Violations of our Code, our policies or the law can hurt us individually and as Our communications with the Ethics Committee can be anonymous, a company. To protect each other, we speak up whenever we become aware con昀椀dential or open, depending on personal preferences. We can reach out to of or suspect that something is wrong. Even if we are unsure, we know that them in multiple ways, including: speaking up is always the right thing to do. + Speaking with them in person When do we speak up? + Sending a written inquiry to [email protected] When we know of or suspect a violation of: + Contacting the Ethics Helpline » By using the Ethics Helpline, all communications will be anonymous Our Values or Code unless we choose to provide identifying information. We have several ways to access the Ethics Helpline: • Dialing 888.359.6331 (if outside of the United States Our policies and procedures or Canada, 昀椀rst enter the applicable country code • Making a web-based report Any applicable law or regulation • Utilizing our simpli昀椀ed mobile site • Scanning our QR code: How do we speak up? When we have an ethics-related question or concern, and feel comfortable What happens a昀琀er we speak up? enough to do so, we reach out to our supervisor or Human Resources Business Our concerns are promptly addressed and investigated, and the information Partner (HRBP). If neither of those options seem comfortable, we can contact we provide is shared only with the people who need to know in order to help our local internal Legal Team, the Global Compliance O昀昀icer or any member of investigate and resolve the issue. If a violation is found to have occurred, there the Ethics Committee. may be disciplinary action. Can we speak up without fear of retaliation? Absolutely. Prologis doesn’t allow any form of retaliation against anyone who reports a concern, makes a complaint in good faith or cooperates in an investigation. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 11 Our At Prologis, IMPACT matters, and People our people always come 昀椀rst. IN THIS SECTION: We Value Diversity and Inclusion We Respect Others We Put Safety First Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 12 We value diversity and inclusion Our promise THINK ABOUT IT To continuously foster a welcoming, inclusive and diverse community Q: Based on derogatory comments I overheard from her supervisor, I believe a coworker may have been turned down for a promotion because of her Our process recent announcement that she was engaged to be married to her long-time Our greatness comes from our diversity. And while we’re fortunate to have a female partner. Should I say something? talented team of people with various backgrounds, experiences and skill sets, A: De昀椀nitely. Job decisions should be based on a person’s abilities. By speaking we don’t stop there. We make sure that each of our unique team members up, you’re not only helping us stay welcoming and inclusive by championing feels valued, included and respected. Doing our Values, but you are also making sure we are following the law. so encourages the productivity we need to best serve our customers and investors. We focus on what matters. When making an employment decision, we LEARN MORE look at job-related criteria and individual quali昀椀cations, without considering Prologis Employee Handbook characteristics protected by law. Some of those characteristics include race, color, national origin, religion, sexual orientation, pregnancy, citizenship status, medical condition, age, marital status, disability, veteran status, gender identity and gender expression. We help each other. We provide reasonable accommodations for religious beliefs and practices, disabilities, pregnancy, childbirth and related medical conditions. If any of these circumstances make it hard for someone to do their job, we work with them to make the appropriate changes. We bring out the best in each other. Bringing out the best in others o昀琀en requires bringing out the best in ourselves 昀椀rst. That’s why we always strive to be honest, fair, constructive and kind. When we treat each team member with respect, we get to bene昀椀t from their individual viewpoints, ideas and talents. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 13 We respect others Our promise To promote an environment that’s free of harassment, bullying and abuse. What are some examples of harassment? Our process It takes many forms, but it might look like: We value you – not just the work you do – so we want to make sure you + Ethnic jokes, slurs or gestures. feel safe and respected. That’s why we have a zero-tolerance policy for + Threats or intimidation. harassment. By not tolerating bad behavior and speaking up whenever + Stalking. someone is being treated unfairly, we help maintain a positive and productive + Bullying. workplace for everyone, everywhere. + Sharing o昀昀ensive material. We know what harassment looks like. To put a stop to harassment, we must + Trying to force someone to do something. be able to recognize it 昀椀rst. Harassment is considered intimidating, hostile or o昀昀ensive conduct that: + Interferes with someone’s ability to work, or. We are aware of perceptions. Harassment doesn’t have to be intentional to + Creates a hostile work environment. be unlawful. In other words, saying, “That’s not what I meant” won’t excuse This is particularly the case if it’s based on a characteristic protected bad behavior. So be aware of how your words and actions may impact others. by law, like a person’s race, age, gender or sexual orientation. We get involved. We speak up if we become aware of harassing or unfair We stay alert for sexual harassment. This type of harassment could include: treatment, or if we’ve experienced it ourselves. + Sexual advances or requests for sexual favors. + Inappropriate touching. LEARN MORE + Sharing of sexual materials. + Continuing to make sexual advances a昀琀er being told “no”. Prologis Employee Handbook Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 14 We put safety 昀椀rst Our promise We watch out for signs of workplace violence. It’s important for us to To help ensure each of us ends our workday unharmed so we can spend time remember that workplace safety goes beyond avoiding hazards – it’s about with our loved ones. paying attention to our coworkers’ behavior as well. Ways we prevent workplace violence include: Our process + Speaking up immediately if we see any threats or warning signs We never lose sight of what matters most – each other. That’s why we put of workplace violence safety 昀椀rst by staying alert, following safety procedures and protocol and + Preventing unauthorized access into our facilities looking out for each other in all that we do. + Never carrying prohibited weapons into our facilities We protect each other. Each of us has a part to play in maintaining a safe workplace, including: + Watching out for hazards What are some warning signs of + Taking the appropriate trainings workplace violence? + Only taking on tasks for which we are trained + Mood swings + Following posted warning signs and restrictions + Paranoid or erratic behavior + Wearing any necessary personal protective equipment + Pacing, yelling or screaming + Reporting unsafe conditions or injuries right away + Verbal abuse or threats + Argumentative behavior + Persistent complaints about being treated unfairly + Poor relationships with coworkers or management We bring our best to work. We come to work in the right frame of mind— never under the in昀氀uence of alcohol or drugs (except over-the-counter medications or those prescribed by a physician), and we keep these substances out of our workplace. Also, if we’re taking any over-the-counter or prescription medication that could a昀昀ect the quality of our work, we speak to a supervisor. That way, we can come up with a plan to make sure everyone stays safe. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 15 We put safety 昀椀rst When do we speak up? THINK ABOUT IT Q: A n ew maintenance technician wants to access the roof of one of our When we have any non-emergency safety concern buildings because of a big wind storm the night before. They haven’t yet or potential safety violation, we can reach out to the received the appropriate safety training, but just want to take a quick look. Prologis Safety Committee. No big deal, right? Our communications with the Safety Committee can A: Wrong. Following all workplace safety rules, no matter how big or small, is be anonymous, con昀椀dential or open, depending on critically important. Allowing any violation undermines our promise to help personal preferences. We can reach out to them in ensure each of us ends our workday unharmed so we can spend time with multiple ways, including: our loved ones. + Speaking with them in person + Sending a written inquiry to [email protected] LEARN MORE + Contacting the Safety Hotline: Prologis Employee Handbook » By dialing 833.723.3753 (if outside of the United States Prologis Property Management Handbook or Canada, 昀椀rst enter the applicable country code) » Making a web-based report When using the Safety Hotline, keep in mind that all communications will be anonymous unless we choose to provide identifying information. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 16 Our Company’s success is based on Our our solutions – nothing more, nothing less. At Prologis, we work ethically and maintain high standards to stay Company Ahead of What’s Next. IN THIS SECTION: We keep accurate records We protect what’s ours We keep private information private We avoid con昀氀icts of interest Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 17 We keep accurate records Our promise What are some examples of business records? To make sure that our books and records accurately re昀氀ect our business. Our process There are lots of di昀昀erent types of business records, including: With thousands of buildings, customers and employees, we have a lot to keep + Leases up with. So, it’s crucial that we maintain good records in accordance with + Expense reports our Global Records Retention Policy. Doing so is at the heart of our business. + Payroll records When we record details in a timely and accurate way, we make smart 昀椀nancial + Purchase orders decisions and stay on the right side of the law. + Sales data We record carefully. To keep our business records as accurate as possible, we: + Record carefully, completely, honestly and in ways that are easy to understand. + Keep everything that supports what we record. THINK ABOUT IT + Never let anyone pressure us into recording something that’s not true. Q: Our local market o昀昀icer signed a lease with an important new customer. + Report any suspicions of fraud or other wrongdoing right away. The customer has requested early access to the space so they can “hit the ground running” when the lease starts. We should always try to We keep the law in mind. It’s important that we all have a good idea of what’s accommodate our customers, right? legally required in our area – laws can change depending on where we work. However, no matter where we are, we never toss or destroy any records tied to A: Yes, we should always try to accommodate our customers. However, our a lawsuit or other legal proceeding. records must accurately re昀氀ect our actions. In this case, the market o昀昀icer should work with the Legal Team to amend the terms of the lease and ensure the appropriate insurance and other contractual provisions are in place once the customer takes possession. LEARN MORE Prologis Global Records Retention Policy Prologis Global Policy Regarding Independent Auditors Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 18 We protect what’s ours Our promise To take good care of what’s ours. What are some examples of assets? Our process There are a few di昀昀erent types we should protect, including, for example: When thinking of our Company assets, our buildings may come to mind 昀椀rst, but they cover much more than that. From the chair you may be sitting in right + Physical assets, such as buildings, company vehicles and now to the laptop you use every day – our assets include every single thing we o昀昀ice furniture. own or use to do business, and it’s our job to protect them. + Technology assets, such as phones, computers and o昀昀ice We handle physical assets with care. We work to protect physical assets equipment. + Financial assets, such as cash and bank accounts. from damage, loss, misuse and the昀琀. And we only borrow, lend, sell or give away items if we have authorization to do so. + Informational assets, such as emails and corporate records. We secure all electronics. We take the appropriate measures to keep our + Intellectual property such as logos and trademarks. technology assets safe, such as: + Following Company guidelines + Protecting user IDs and passwords + Never opening suspicious emails + Never installing unauthorized so昀琀ware LEARN MORE We secure data. In a world where our business is becoming more data-driven Prologis Employee Handbook and data analytics drive value, we want to make sure we preserve our rights to keep what data is ours, and obtain the appropriate permissions to collect data Prologis Global Policy on Proper Use of Company Assets that impacts our buildings. Prologis Global Policy Regarding Privacy and Con昀椀dential Information We use common sense. Prologis has a responsibility to monitor Company Prologis Acceptable Use of Information and Technology Policy systems and devices (such as computers and phones) for certain content Prologis Global Policy on Protection of Company Data & Information to protect coworkers and customers. For this reason, although occasional personal emails or phone calls are permitted, it’s important to remember that anything we write, download, store or transmit on Company equipment may be monitored or reviewed in accordance with applicable laws. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 19 We keep private information private Our promise We remain diligent. We know that information can leak in many ways – intentionally and non-intentionally – so we don’t discuss anything private in To respect and protect personal and con昀椀dential information. a public setting, and we don’t leave personal or con昀椀dential information in a Our process place where someone else could access it. The information in our care is part of our Company’s strong foundation. With We respect the information of others. We use the same standard of care it, we can cater better to our customers, hire ideal candidates and maintain when handling the personal and con昀椀dential information of others as we our competitive edge. That’s why safeguarding it is so important. would our own. We also only acquire such information in appropriate ways and with the proper authorization in accordance with applicable laws. We protect informational assets. We never share personal or con昀椀dential information with unauthorized people, including anyone within our Company who doesn’t need it to do their job. When we do need to share it, we seek We remain loyal. The responsibility to protect personal and con昀椀dential information doesn’t end if our employment does. That’s why we never share appropriate approval 昀椀rst. Personal and con昀椀dential information includes such things as: Prologis’ personal and con昀椀dential information with other employers if we leave. We also never ask or expect new Prologis employees to share the + Private information, like someone’s employment, medical, 昀椀nancial or personal or con昀椀dential information of former employers with us. education history. + Intellectual property, like ideas, creative work, designs, know-how and trade secrets. THINK ABOUT IT + Proprietary information, like business plans, marketing strategies and Q: One of my coworkers is home on maternity leave. A supplier asked me for her customer lists. home address to mail her a card. That would be a nice thing to do–right? + Financial information, like budgets, forecasts and quarterly results. A: Although well-intentioned, you shouldn’t share her home address with We follow the rules. We comply with all records management policies anyone without her consent. A better approach would be to suggest when labeling, handling, storing and disposing of personal and that the supplier forward the card to the o昀昀ice. She will appreciate the thoughtfulness just as much. con昀椀dential information. LEARN MORE Prologis Employee Handbook Prologis Global Policy Regarding Privacy and Con昀椀dential Information Prologis Global Records Retention Policy Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 20 We avoid con昀氀icts of interest Our promise To promote loyalty and our shared success What is a “con昀氀ict of interest”? Our process A con昀氀ict of interest occurs when our personal interests (or the interests of a family member) work against – or even appear to We all have interests, activities and relationships outside of Prologis. However, work against – the interests of Prologis. there are times when these personal interests can create—or appear to create—a con昀氀ict of interest with our Company. This can damage the trust of those who invest and believe in us. As a result, we each have an obligation to act in the best interest of Prologis. We practice prevention. We do all that we can to know and avoid the kinds of We speak up. Most con昀氀icts can be avoided or mitigated if they are disclosed. Whenever we may have an actual, potential or perceived con昀氀ict situations where con昀氀icts of interest o昀琀en occur. Examples of con昀氀icts include: of interest, we know the best next step is to disclose it to our supervisor, + Hiring a company owned or controlled by a Prologis director, employee or Human Resources or the Ethics Committee right away. any of their family members + Owning, or having a substantial interest in, a customer, competitor or supplier to Prologis + Working for or with a Prologis competitor, supplier, vendor or agent + Receiving improper personal bene昀椀ts because of your position with Prologis + Taking advantage of opportunities discovered through a connection with Prologis + Supervising or making employment decisions about a loved one, family member or romantic partner + Conducting outside work with a business partner, competitor or any other organization that does (or seeks to do) business with Prologis Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 21 We avoid con昀氀icts of interest We ask the right questions. Spotting a con昀氀ict of interest is not always easy. That’s why it helps to ask: If the answer to any of these questions is “yes” or “I don’t Could this activity Could it a昀昀ect Could it look like know,” there may be a potential interfere with my the decisions I make on a con昀氀ict to con昀氀ict. We should seek ability to do my job? behalf of Prologis? someone else? guidance from our supervisor, Human Resources or the Ethics Committee before proceeding. THINK ABOUT IT Q: One of our third-party vendors tells me that my supervisor is on the board of directors for their company. When I ask my supervisor about it, he says that it’s nothing to worry about. What should I do? A: Contact the Ethics Committee. We each have a responsibility to not only disclose our own potential con昀氀icts, but to speak up if we suspect that others have con昀氀icts as well. LEARN MORE Prologis Global Con昀氀ict of Interest Policy Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 22 Our Where others measure success in transactions, we invest in relationships and work tirelessly to help our customers Customers stay Ahead of What’s Next. IN THIS SECTION: We market honestly We protect our reputation We use social media responsibly Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 23 We market honestly Our promise To build our reputation and our brand What are some examples of bad marketing? Our process Some things we never do include: We do everything with integrity – and that includes marketing and advertising + Using scare tactics + Badmouthing our competition our o昀昀erings and services. To us, integrity in advertising means providing accurate, fair and balanced information that highlights the bene昀椀ts and risks + Exaggerating our abilities of our o昀昀erings. Only by marketing honestly can we build trusted lifelong + Leaving out something material partnerships with our customers. We say what we mean. Our advertisements o昀昀er a great opportunity to tell our story – and we do so honestly, fairly and responsibly. We avoid any messaging that could be misleading and never promise something we can’t LEARN MORE deliver. We o昀昀er an excellent value proposition, so there is never a need to overstate our services or products. Prologis Global Policy on Proper Marketing Practices We know what’s required. We market accurately, fairly and honestly not just because of our integrity, but because the law requires it. If we are unsure of any legal requirements, we know to consult with the Legal Team or Compliance Team. We take the time to double-check. Our Marketing Team makes sure to get proper approval for every advertisement and double-check every claim. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 24 We protect our reputation Our promise To ensure our messaging is clear, accurate and consistent Who are the designated spokespeople Our process in our Company? We’ve spent decades building our reputation, but we know it can be For questions: damaged in moments with a careless word or communication. That’s why + From the media, contact Corporate Communications. we have a team of employees who specialize in sharing information about + From the government, contact Corporate Communications. our Company and responding to inquiries from the media, government, investors and general public. + About 昀椀nancial matters, contact Investor Relations. + About charitable donations, contact Sustainability. We rely on the experts. Unless designated as an o昀昀icial company spokesperson, we don’t speak on Prologis’ behalf. Instead we direct inquiries + About making speeches or participating to the proper resource. in events, contact Corporate Communications. We use our voice responsibly. We seek approval before participating in + About political contributions, contact the Compliance Team. any speaking engagements and before publishing any articles on behalf of our Company. We protect our reputation, while protecting employee rights. We follow the laws that protect the rights of employees to speak publicly about LEARN MORE matters of public concern and to engage in protected concerted activities related to the terms and conditions of employment. Nothing in our Code or Prologis Media, Social Media and Analyst Policy our policies is intended or should be construed to interfere with or limit legal rights in that regard. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 25 We use social media responsibly Our promise To promote honest and ethical online communications How do we “take responsibility for what we post”? Our process It’s o昀琀en as simple as adding a disclaimer that says, “The We believe that social media o昀昀ers a great way to build relationships, statements on this site are my own and do not re昀氀ect Prologis’ exchange ideas and share information about our Company. However, we must positions, strategies or opinions.” do so responsibly. When posting, we use good judgment and act in ways that are consistent with our Values, our policies and the law. We let people know who we are. When posting about work-related matters, we are transparent about our relationship with our Company and identify ourselves as Prologis employees. LEARN MORE We take responsibility for what we post. When posting company-related Prologis Media, Social Media and Analyst Policy content to our personal social media pro昀椀les, we make it clear that we are speaking for ourselves and not on behalf of Prologis. Prologis Global Policy Regarding Privacy and Con昀椀dential Information We communicate with respect. We have zero tolerance for cyberbullying and the use of social media to intimidate, harass or discriminate against fellow employees or members of our community. We don’t use ethnic slurs, personal insults, obscenity or engage in any conduct that would not be acceptable in the workplace. We protect con昀椀dential information. We know never to share con昀椀dential or other proprietary information about Prologis or a customer, partner, investor or supplier. We never discuss sensitive topics like our business performance, Company plans or 昀椀nancial information publicly unless appropriate prior approval is obtained, or the information is already publicly available. We respect copyright. We do not post content that does not belong to us. Before posting anyone else’s work, we check with the owner in order to get permission 昀椀rst. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 26 We take the time to get to know our Our Business partners —we understand their needs, recognize their aspirations and operate in ways that make them proud to do Partners business with us. IN THIS SECTION: We compete fairly We are good business partners We cooperate with government audits and investigations Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 27 We compete fairly Our promise What do we mean by “agree”? To earn business based on the quality of our o昀昀erings and services, not unfair practices. An “agreement” with a competitor, customer or business Our process partner could come in many forms, including something: + Stated or implied We stay ahead of the game by generating fresh ideas and 昀椀nding new ways to do business, not by working unethically to push others out of the market. That + Oral or in writing way, not only do we keep our customers – we keep them happy. + Direct or indirect We avoid improper agreements. We are careful in conversations with competitors, customers or business partners and never agree to: + “Fix” prices (by raising, setting or lowering them) LEARN MORE + Illegally split up markets, territories or customers Prologis Global Antitrust and Competition Policy + Inappropriately prevent another company from entering the market + Improperly in昀氀uence the outcome of a competitive bid + Unfairly restrict production, sales or output We work lawfully. To earn business the right way, we make sure to comply with all antitrust and competition laws. They can be complicated, so when in doubt, we ask questions about what’s appropriate (and what isn’t) to avoid even the appearance of something improper. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 28 We are good business partners Our promise To successfully cooperate and collaborate with our business partners What do we mean by “due diligence”? Our process In short? Research. Examples include: Working with responsible, reliable business partners allows us to tap into + Checking business registrations + Asking for product goods, services and information we wouldn’t have otherwise. That’s why + Checking public documents samples we foster good relationships by choosing our partners carefully and always + Verifying trade accreditations + Searching the internet interacting with integrity. + Speaking to previous customers + Reading news articles We select wisely. When we choose a vendor, supplier or other business partner, we exercise due diligence and only consider objective criteria such as their: + Values + Experience + Quality + Reputation THINK ABOUT IT + Cost + Availability Q: One of our contractors accidentally sent me con昀椀dential information. I 昀椀nd We work collaboratively. We consider every business partner an extension it interesting enough to share with a coworker over lunch. That should be of ourselves. That’s why we monitor them closely – to ensure they’re following 昀椀ne since I’m just telling someone else at Prologis, right? the law and exhibiting our Values. A: No, that’s not OK. Our contractors trust us with their information. We set the standard. We can’t expect our business partners to take our Code If you receive something by accident, delete it immediately and let the seriously if we don’t. That’s why we review our Code, our policies and the law sender know of their mistake. This will send the message that we always maintain con昀椀dentiality and that we expect them to do the same. regularly and always treat business partners fairly. More speci昀椀cally, we: + Honor their policies as well as ours + Watch for inappropriate gi昀琀s or other favors LEARN MORE + Protect their personal and con昀椀dential information Prologis Global Policy on Proper Relationships With Suppliers Supplier Code of Conduct Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 29 We cooperate with government audits and investigations Our promise To comply with all reasonable requests from the government Our process We honor our duty to always cooperate and provide honest information to governmental bodies and regulatory agencies. Whenever questioned as part of an audit or investigation, we respond appropriately and interact in ways that are open and transparent. We direct requests to the proper resource. To ensure the most appropriate response, whenever we receive an inquiry from the government, we promptly contact our Legal Team for assistance. We cooperate fully. When we have been authorized to respond to a government request, we make sure to: + Always provide truthful, accurate and complete information. + Never impede, obstruct or improperly in昀氀uence the audit or investigation. + Never lie or make false or misleading statements – verbally or in writing. + Never attempt to persuade someone else to provide false or misleading information. LEARN MORE Prologis Global Policy on Compliance With Laws and Regulations Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 30 Because we operate globally, we must Our ensure we meet certain universal ethical standards, we must hold each other, and ourselves, accountable. We do our part by Industry conducting business with integrity. IN THIS SECTION: We 昀椀ght crime and corruption We follow the rules when it Comes to gi昀琀s and courtesies We follow the laws, everywhere we operate We play fair when buying or selling stock Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 31 We 昀椀ght crime and corruption Our promise What is “anything of value”? To win the 昀椀ght against crime and corruption Our process It really can mean “anything.” Some examples include: + Cash or cash equivalents like gi昀琀 cards We believe that the quality of our o昀昀erings and services, not illegal business practices, should bring us success. That’s why we don’t tolerate any acts of + Special favors corruption, bribery or money laundering. + Inappropriate gi昀琀s or entertainment We never bribe. Although the laws on bribery and corruption can be + Discounts unavailable to the public complicated, doing the right thing is simple: We don’t bribe. That means + Charitable donations or political contributions we never o昀昀er or accept anything of value to win business, gain an unfair + Payment of travel expenses advantage or in昀氀uence a business decision. We keep accurate records. Of course, it’s important to never bribe—but it’s also important to avoid anything that even looks like a bribe. We make sure that our books and records accurately re昀氀ect our business so that we can easily explain the appropriate reason something was given and received. We work with those who share our Values. We understand that we can be held responsible for the things our business partners do. That’s why we choose them carefully, then watch them closely. We stay alert to money laundering. Money laundering happens when funds are generated through criminal acts, like drug tra昀昀icking or terrorist activities, and then hidden (or “laundered”) by being run through legitimate businesses. It’s a way for criminals to disguise the pro昀椀ts of their criminal conduct. We stay alert for this activity and work to keep these funds from entering the Company. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 32 We 昀椀ght crime and corruption We watch our interactions with government and public officials. We keep in mind that the rules about what we can give to government and public officials are strict. We don’t send anything to or accept anything from a government official without speaking to the Legal Team or Compliance Team first. Government and public o昀昀icials are more than just people elected or appointed to public o昀昀ice. They are also: + Customs and tax o昀昀icials + Regulatory agency o昀昀icials + Political candidates + Military personnel + Employees of state-owned businesses LEARN MORE Prologis Global Anti-corruption and FCPA Policy Prologis Global Anti-money Laundering and OFAC Compliance Policy Prologis Policy on Political Activity and Interaction With Public O昀昀icials Prologis Policy on Charitable and Other Non-pro昀椀t Giving Supplier Code of Conduct Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 33 We follow the rules when it comes to gi昀琀s and courtesies Our promise To foster healthy business relationships with the appropriate exchange of gi昀琀s, hospitality and courtesies Our process An occasional gi昀琀 or other courtesy can be a normal part of doing business, but an o昀昀er that’s lavish or extended too frequently can create a con昀氀ict of interest and erode the trust that people associate with the Prologis name. We must avoid crossing any ethical lines. Any gi昀琀 that creates, or appears to create, a sense of obligation or compromises your professional judgment is always inappropʳiate. We give with caution. Whenever we give or accept any gi昀琀, o昀昀er of hospitality or business courtesy, we make sure what’s o昀昀ered: Is reasonable under the circumstances – never excessive, extravagant or lavish. While not determinative in every situation, a 75 USD limit is a good guidepost absent approval by the Legal Team or Compliance Team. + Complies with local law, applicable business policies and customs + Is made on behalf of Prologis and not the individual + Is not cash or a cash equivalent (e.g., a gi昀琀 card) + Is done openly and in a way that avoids even the appearance of anything improper Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 34 We follow the rules when it comes to gi昀琀s and courtesies We pay attention to travel. Additional restrictions apply to expenses for travel, meals and lodging, so we’re always sure to: + Pay vendors directly whenever possible. + Comply with all applicable laws and policies. + Only cover business-related expenses. + Avoid paying travel expenses along with a per diem. We record accurately. We document any exchange accurately and completely in our books and records. THINK ABOUT IT Q: A potential customer wants to meet at one of our buildings. We have agreed to cover the necessary travel and lodging. However, they would like to stay in the area for an extra night to do some sightseeing. Would it be OK to cover the additional associated costs? A: No. We only pay for costs directly related to our business or the performance of a contract. The best thing would be to let the potential customer know we would be happy to provide travel to and from the meeting and reasonable accommodations for the duration of their business trip. Any additional accommodations would be inappropriate. LEARN MORE Prologis Global Anti-corruption and FCPA Policy Prologis Global Gi昀琀 and Entertainment Policy Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 35 We follow the laws, everywhere we operate Our promise To respect the laws that apply to our business everywhere we operate Our process We recognize that our ability to reach customers in every corner of the world is a privilege and not a right. To protect that privilege, we follow the law everywhere we work. Let’s all do our part to stay on top of what’s required so we can continue to be a world leader in our industry. We respect international regulations. Conducting business around the world can get complicated, especially when we have multiple sets of regulations, customs and practices to comply with. Whenever a con昀氀ict between laws arise, we make sure to contact our Legal Team or Compliance Team with questions. We evaluate all business opportunities. Some countries with which we do business may be subject to United States trade embargoes or economic sanctions from time to time. That’s why we evaluate these opportunities with additional scrutiny. Sometimes they are subject to stricter regulations or even prohibited altogether. And we never do business with any person or any organization that is known to support or is o昀昀icially identi昀椀ed as supporting terrorist activities. LEARN MORE Prologis Global Policy on Compliance With Laws and Regulations Prologis Global Anti-money Laundering and OFAC Compliance Policy Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 36 We play fair when buying or selling stock Our promise To never use or share inside information to gain an unfair advantage What are some examples of Our process “inside information”? There may be times when we learn information about our Company, or companies It could be nonpublic information about: we work with, that isn’t known to the public. If that nonpublic information is + Mergers or acquisitions + Changes in leadership signi昀椀cant enough that it could a昀昀ect the price of a stock (or other type of security) + New products and + Projected earnings then it is considered inside information. We never use inside information to our services or losses advantage, and we never pass along inside information so that others may do so. + Strategic business plans + Pending lawsuits We know how to identify inside information. Inside information is both: + Material, meaning it could in昀氀uence an investor to buy or sell stock + Nonpublic, meaning it hasn’t been released to the public THINK ABOUT IT We respect inside information. When we have inside information, we don’t Q: I am part of the broader team that is in the process of helping Prologis buy or sell stock or other securities (“trade”), and we don’t pass it along to acquire one of our competitors by merger. The proposed merger has not others (“tip”). We only share it with coworkers and business partners on a yet been publicly announced. I know I can’t share the inside information need-to-know basis. I have learned, but would it be OK if I just bought stock in the company at We pay attention to blackout periods. Depending on our jobs, some of us current stock market prices? may at times be subject to additional trading restrictions—meaning we can’t A: No. It’s against Company policy to purchase or sell shares in the company buy or sell Company stock regardless of what we know. It’s important that we that Prologis seeks to acquire by merger while you have inside information. learn the rules before we trade. Even though you’re not actually sharing the information, you would still be We follow our fair disclosure obligations. If we as a company do disclose gaining an unfair advantage. material, nonpublic information, whether intentional or non-intentional, we always do it in accordance with legal requirements and we do so publicly. This way, we can be sure that the investing public as a whole has the LEARN MORE same information. Prologis Insider Trading Policy Prologis Global Policy on Financial Reporting, Disclosure of Material Information and Fair Disclosure Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 37 We strive to be an exemplary Our corporate citizen, to minimize our environmental impacts and to maximize bene昀椀cial outcomes for Community our communities and stakeholders. IN THIS SECTION: We protect human rights We care for the environment We give back to the community We engage responsibly in political activities Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 38 We protect human rights Our promise To promote human rights, human dignity and fair employment practices Our process We are fortunate to work with and for people and communities all over the world, and we want to make a positive impact. That’s why we respect individual human rights in all our business operations and at every level of our supply chain. And we only work with business partners who strive to do the same. We take care of each other. Every member of our team invests valuable amounts of time and energy in our Company. So, it’s only right that we make sure everyone is compensated fairly and protected. That’s why Prologis: + Follows all laws dealing with pay, bene昀椀ts and working conditions. + Promotes the long-term health, safety and wellness of all employees. + Prohibits all forms of slavery, including involuntary, forced or prison labor, child labor and human tra昀昀icking. We only work with the best. We never knowingly do business with any company that violates human rights laws or engages in human rights abuses. As a result, we watch our business partners closely and do what we can to make sure they watch their business partners as well. We say something. As employees, we o昀琀en see 昀椀rsthand how our coworkers and business partners are treated. So, we stay alert and, if we ever see anything that breaks our commitment to human rights, we speak up. LEARN MORE Prologis Global Human Rights Policy Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 39 We care for the environment Our promise To reduce our environmental impact and promote sustainable What does environmental stewardship business practices. mean to us? Our process We see it as our duty to address two major global challenges We’re committed to being good stewards and limiting our environmental facing us all – climate change and overburdened ecosystems. impact. We do this by pursuing sustainable construction practices in our business, through operating cleanly and e昀昀iciently and conserving natural resources. We also inspire others to do the same. We practice environmental stewardship. We 昀椀nd ways to recycle, re-use THINK ABOUT IT and conserve materials like cardboard, plastic, glass, metal and Styrofoam whenever possible. We construct new buildings using sustainability certi昀椀ed Q: I have some ideas for how to use less paper in our o昀昀ices. We’re not construction practices. We also follow all applicable environmental laws violating any laws, but I do think we could do better. Who should I talk to? and regulations as well as our procedures for sustainability in procurement, proper disposal of waste and proper disposal, handling and storing of A: We welcome any ideas for lessening our environmental impact. Explore hazardous materials. your ideas with our ESG group to see if they can be implemented. We save energy and water. Sometimes it’s the little things that make a big di昀昀erence. That’s why we always take time to: + Turn o昀昀 electronics and lights when not in use. LEARN MORE + Use energy-e昀昀icient alternatives whenever possible. Prologis ESG Policy + Turn faucets on a low 昀氀ow, then turn them o昀昀 when 昀椀nished. We stay alert. We look out for and report any actual or potential environmental hazards right away. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 40 We give back to the community Our promise To strengthen our communities through charitable activities What are some ways Prologis gives back? Our process We love to give back. Some of the ways we’ve helped our community include: We are committed to making a positive impact in the communities where + Celebrating IMPACT Day we live and work. We highly value fundraising and volunteering our time to support causes – both locally and globally. By donating to programs that + O昀昀ering Dollars for Doers promote education, environmental protection and social well-being, we + Providing rent-free space and grants to nonpro昀椀ts recognize our responsibility to manage not only our corporate performance, + Matching employee contributions but our social impact. We give with Prologis. As a company, we have donated millions of dollars Keep in mind that anything we give on behalf of Prologis needs and thousands of volunteer hours to programs that promote causes we are to be approved by a Regional Head or the Prologis Foundation. passionate about. Before giving in Prologis’ name, we get approval from our Regional Head or the Prologis Foundation. We encourage others to give. To make a stronger impact, we appropriately THINK ABOUT IT encourage others including our stakeholders, customers, suppliers and Q: I am involved in a personal charitable activity in my community. May I investors to join in our commitment. use our Company’s letterhead to solicit some of our business partners We may also give personally. Because we are such a diverse group, we for contributions? understand that we may di昀昀er in our support of charitable causes. If giving on A: No, soliciting suppliers or other business partners for personal a personal basis, we make sure to: charitable activities may create a con昀氀ict of interest, or the appearance + Avoid con昀氀icts of interest. of one. Relationships with business partners and the procurement + Use our own time and resources. process should be based solely on legitimate business concerns. + Never pressure coworkers. + Make it clear our views are our own. LEARN MORE Prologis Policy on Charitable and Other Non-pro昀椀t Giving Matching Gi昀琀 and Dollars for Doers Programs Employee Volunteer Program Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 41 We engage responsibly in political activities Our promise To respect and support everyone’s right to participate in the political process What if I am unsure about making a Our process political contribution other than to a presidential election? We encourage everyone to exercise their civic duty, both personally and If you have any concerns about making a personal political professionally, and to support the political causes they’re passionate about. contribution and how that might impact Prologis, please talk However, we must ensure our personal politics remain separate from what we to the Compliance Team before donating. do at Prologis. We keep personal politics, personal. We follow all applicable laws and policies related to our individual participation in political a昀昀airs. Whether donating time or money or providing an opinion, we make sure it’s clear that our involvement is personal and not on behalf of Prologis. This includes not THINK ABOUT IT using any of the Company’s resources (e.g., time, money, email or facilities) for Q: I have a good friend who is running for political o昀昀ice and has asked if I would our own political activity as well. endorse her at a rally being held outside work hours. Is that a problem? We know the rules that apply to our roles. If we have a leadership role at Prologis (any Vice President or higher), we obtain approval before making or A: No, generally this should not be a problem. At minimum, you must make it soliciting any political contributions on our own behalf or on behalf of our clear that your endorsement is your own personal action and that you’re not immediate family members except as it relates to any presidential election. For speaking on behalf of Prologis. those of us working on our Strategic Capital business, additional rules o昀琀en apply, so we seek instruction in our Strategic Capital Compliance Manual. We don’t make political contributions to just anyone. No Company funds LEARN MORE may be used to make contributions or payments to any speci昀椀c candidates’ Strategic Capital Compliance Manual political campaign or any associated PAC. With the exception of RealPAC and REITPAC, any other political contributions (e.g., contributions to ballot Prologis Policy on Political Activity and Interaction With initiatives) must be pre-approved by the Ethics Committee. Public O昀昀icials Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 42 Our 昀椀nal thoughts As the world’s leader in logistics real estate, we understand that our employees are the key to our success. We depend on you. We depend on your talent, your passion and your dedication to our Values to set us apart. Help us stay true to our culture by working with IMPACT in all that you do. Start with understanding and following our Code but know that the guidance and support we provide doesn’t end there. We have policies with additional details as well as resources dedicated to addressing any remaining questions or concerns you may have. Further, be sure to complete all required Corporate Trainings. They are there to hone the knowledge and skills necessary for you to progress both personally and professionally, so we encourage you to take advantage of them throughout your time here at Prologis. We take pride in the work we do, but our singular focus will always be you. We owe you our best and we are here to invest in you as you do for us every day. Thank you for all that you do. Your commitment to our Values is how we stay Ahead of What’s Next. Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 43 Our resources Have a question or concern? We are here to help: Issues or Concerns Contact To ask questions, report potential misconduct or Prologis Ethics Helpline other ethical concerns https://secure.ethicspoint.com/domain/media/en/gui/20630/index.html For questions about the Code of Ethics and Global Compliance O昀昀icer Business Conduct [email protected] https://prologis.sharepoint.com/sites/ethics To view Company policies The Hub https://prologis.sharepoint.com/sites/thehub For legal questions or concerns Chief Legal O昀昀icer [email protected] https://prologis.sharepoint.com/sites/Legal/ To view information about Company Bene昀椀ts Global Human Resources Hub Site https://prologis.sharepoint.com/sites/HR For media inquiries Head of Global Corporate Communications [email protected] For Investor Relations Senior Vice President – Investor Relations [email protected] Code of Ethics and Business Conduct Ethics Helpline
TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED 44 Our policies Prologis Acceptable Use of Information and Technology Policy Prologis Global Policy on Proper Use of Company Assets Prologis Employee Handbook Prologis Global Policy Regarding Independent Auditors Prologis ESG Policy Prologis Global Policy Regarding Privacy and Con昀椀dential Information Prologis Global Anti-corruption and FCPA Policy Prologis Global Records Retention Policy Prologis Global Anti-money Laundering and OFAC Compliance Policy Prologis Insider Trading Policy Prologis Global Antitrust and Competition Policy Prologis Media, Social Media and Analyst Policy Prologis Global Con昀氀ict of Interest Policy Prologis Policy on Charitable and Other Non-pro昀椀t Giving Prologis Global Gi昀琀 and Entertainment Policy Prologis Policy on Political Activity and Interaction With Public O昀昀icials Prologis Global Human Rights Policy Prologis Property Management Handbook Prologis Global Policy on Compliance With Laws and Regulations Strategic Capital Compliance Manual Prologis Global Policy on Financial Reporting, Disclosure of Material Information and Fair Disclosure Supplier Code of Conduct Prologis Global Policy on Proper Marketing Practices Prologis Global Policy on Proper Relationships With Suppliers Code of Ethics and Business Conduct– April 2022 Ethics Helpline Code of Ethics and Business Conduct