Human Rights, Human Trafficking, and Child Labor

Due to the nature of our business and operations through triple-net leases, we have limited exposure to human rights risks.  Nevertheless, we believe that respect for all human rights reflects our core values and, therefore, that it is our responsibility to minimize human rights risks in all activities of the Company.  We are committed to supporting the United Nations Universal Declaration of Human Rights, Guiding Principles on Business and Human Rights and the Protocol to Prevent, Suppress and Punish Trafficking in Persons throughout our operations and support the efforts of our tenants and operators to abide by these principles in the operations at our properties.  These protocols and related instruments specifically address the protection of the human rights of individuals belonging to specific groups or populations (without discrimination) that require particular attention, including, indigenous peoples; women; national or ethnic, religious and linguistic minority groups; children; persons with disabilities; and migrant workers and their families.

The Company strongly supports eliminating human trafficking and child labor and strictly prohibits employees from engaging in human trafficking- and child labor-related activities, including, without limitation, sex trafficking, using force, fraud, or coercion to subject a person to involuntary servitude or obtaining labor from persons by threats of serious harm to that person or another person.   In addition, the Company also prohibits employees from engaging in practices related to trafficking in persons, including, without limitation, denying access to or destroying an employee’s identity or immigration documents and failing to provide an employment contract or other employment documentation where required by law.  As a triple-net REIT with operations primarily located in North America, we have determined through an initial screening for human rights issues across our business that human rights risks do not present a significant potential impact to the Company. Nonetheless, any director, officer or employee having credible knowledge of a violation of this human rights policy or human trafficking at any of our properties must report such information immediately.

Labor Practices

The Company is committed to fostering a workplace that prioritizes fairness, equality, and employee well-being. All of our employees are full-time, either professional or administrative, and salaried. We do not utilize contract or contingent employees or independent contractors in our operations, other than with respect to certain external advisors. 

We believe our compensation is competitive in the markets in which we operate, and all of our employees participate in the same cash bonus and/or equity incentive compensation programs as our named executive officers. In addition, all performance outcomes for these short- and long-term incentive programs are determined on the same basis across all participants. 

We are committed to providing a fair and living wage to all of our employees that meet or exceed cost-of-living benchmarks and appropriately acknowledge their workload expectations (including overtime to the extent applicable). Workload and responsibilities are monitored to support a healthy work-life balance. We annually benchmark employee compensation against similarly situated positions in related industries through a leading compensation database.

We also offer additional, differentiated benefits to our employees, such as our Portfolio Experience Benefit, August Work-from-Anywhere Initiative, and additional parenthood and family planning benefits. With our flexible paid-time off (“PTO”) policy, we encourage employees to take at least two weeks of their paid annual leave entitlements as vital for their continued health and well-being, and we support them in making the most of these opportunities by setting expectations regarding communication and responsibilities during employee PTO. Through these practices and our other employee policies and programs, we aim to create a workplace where transparency, fairness and inclusivity are integral to our culture and values.

Furthermore, the Company strives to create a workplace in which open and honest communication among all employees is valued. We respect our employees’ right to form, join or not join, labor unions, without fear of reprisal, intimidation or harassment. In the case of employees that may in the future be represented by a legally recognized union, we are committed to bargaining in good faith with that union. With respect to the Company’s operations, we adhere to the conventions of the International Labour Organization, including Freedom of Association and Protection of the Right to Organize (No. 87) and Right to Organize and Collective Bargaining (No. 98).

Last updated: September 8, 2025