OUR BUSINESS | DIGITALBRIDGE | PORTFOLIO | CITIZENSHIP | APPENDIX | DIGITALBRIDGE.COM 31 Ethics and Compliance A culture of ethics and a commitment to integrity provide the foundation for all our business operations. We seek to instill a spirit of integrity throughout Compliance DigitalBridge as well as our portfolio companies DigitalBridge recognizes the importance of building that will guide their interactions with all stakehold- a culture of compliance. All employees are expected ers and the communities in which we operate. At to act with integrity, competence and dignity, and DigitalBridge, our employees are guided by a Code in an ethical manner when dealing with the public, of Business Conduct and Ethics, which requires customers, investors, prospects and each other. We adherence to our own company values as well as communicate our expectations for behavior in established standards such as the Foreign Corrupt various circumstances and provide training and Practices Act. resources on a series of topics such as anti-money Training laundering, gifts and entertainment, insider trading and related party transactions. This content is To promote this ethical culture, we provide our available online to all employees. employees various training programs and opportu- Our Chief Compliance Officer is responsible for nities to enhance their understanding of responsible ensuring that DigitalBridge’s practices are designed behavior and our strict ethical standards. In 2020, to help prevent and detect violations of the federal some of the topics covered in our mandatory and securities laws. Management recognizes its duty on-demand training courses included: anti-corrup- to supervise the actions of our employees to tion, conflicts of interest, confidentiality, insider trad- ensure compliance with DigitalBridge’s policies ing, lobbying compliance, and preventing discrimi- and procedures. nation and harassment. All of our directors, officers and other employees sign an acknowledgment and certification of their understanding of and adherence to our Code of Business Conduct and Ethics when they join the company and annually thereafter. Whistleblower Hotline We provide a variety of ways for all of the company’s stakeholders to report existing or potential violations, including a confidential and anonymous whistleblow- er hotline. Our Complaint Procedures for Accounting and Audit Matters also provides employees or other interested parties with specific guidance on how to report any good faith complaint or concern regarding accounting, internal accounting controls and auditing matters related to the company.