2017 CORPORATE RESPONSIBILITY REPORT
SUSTAINABLE GROWTH

Ethics & Anti-Corruption

Operating with Integrity and Openness—one of our core values—remains paramount to our business. Our proactive approach to ethics and compliance strengthens Forest City’s relationship with our communities and partners. Through the guiding principles of Forest City’s policies and programs, our associates uphold the utmost integrity in their work every day.

Underscoring the importance of behaving in an ethical manner at all times, we require all associates and board members to annually review and sign our Code of Legal and Ethical Conduct. Each year, our Legal and Human Resources teams conduct and provide training sessions focused on key ethical behaviors and legal requirements on topics such as confidentiality, conflicts of interest, insider trading, fair disclosures and records retention. In addition, we conduct targeted training on important and relevant ethics and compliance issues. In 2017, we met our target of 100 percent compliance with Forest City’s Code of Conduct among all associates and board members.

Supporting Policies & Procedures

In addition to our Code of Legal and Ethical Conduct, we maintain several specific policies and procedures governing our approach to ethics and compliance, including policies and procedures governing insider trading, related party transactions, conflicts of interest, lobbying and political contributions, Regulation FD, social media, anti-harassment and anti-discrimination, as well as other important topics. These policies, among others, uphold our approach to accountability, legal compliance, ethical behavior and transparency at the executive level. Also, complying with the Sarbanes-Oxley Act, all senior financial officers receive additional training specific to their roles and responsibilities. In addition, certain senior financial officers must annually acknowledge receipt of and compliance with a separate Senior Financial Officer Code of Ethical Conduct. Our Internal Audit department reviews our regulatory compliance on a quarterly basis and conducts an annual assessment to ensure our approach and performance surrounding ethics and compliance remains effective. We take seriously any accusations of wrongdoing within our organization and act quickly to take corrective measures.

Externally, we require each new supplier and all existing major suppliers to comply with our Supplier Code of Conduct. Forest City actively manages and evaluates supplier performance against the terms of this policy, and we evaluate our vendor agreements on a regular basis to confirm they remain mutually beneficial to Forest City and our vendors. Our Supplier Code of Conduct features standards related to health and human safety, and labor and human rights provisions related to gifts and gratuities.

Ethics Hotline

We partner with Global Compliance as the third-party operator of our ethics hotline, which is available 24 hours a day, seven days a week, 365 days a year. The hotline serves as a venue for associates, partners, customers and vendors to anonymously report concerns or behaviors of any kind that they feel may violate Forest City’s policies or practices or federal, state or local regulations. Each month, both the Legal Department and the Audit Committee of the board receive an anonymous summary report of all calls to the hotline. We communicate all ethical or legal concerns shared on the hotline to Human Resources, Legal or individual company officers.

Our system allows hotline callers to receive updates on whether their matter has been resolved while maintaining anonymity. Forest City has a strict non-retaliation policy for any reports of legal or ethical concerns. In 2017, our overall call volume remained low, and the most common concerns raised on the ethics hotline included allegations of workplace misconduct, such as favoritism and harassment. In compliance with our Audit Committee-approved Investigation Policy, our General Counsel continues to review each call and take appropriate action as needed.

2017 Ethics & Compliance Goals

Goal 1 Achieve 100% Compliance with applicable Code of Legal and Ethical Conduct and other legal policy acknowledgments

Goal 2 Effectively train associates on key components of Forest City’s ethical framework

DEFINITION