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Vendor Code of Conduct

W. P. Carey believes that Investing for the Long Run® requires us to promote ethical business practices, transparent corporate governance and sustainability, and that these measures are key to sustaining our continued growth and long-term success. Our core principle, Doing Good While Doing Well® guides not only our actions, but also our relationships. Therefore, we are dedicated to bringing our commitment to ethics, compliance, transparency and sustainability beyond our own business to those of our vendors.

This Vendor Code of Conduct (“VCOC”) communicates our expectations for ethical business practices, regulatory compliance and sustainability to our vendors. We expect our vendors, representatives and suppliers to self-monitor and comply with all applicable laws, rules and regulations of the countries in which they operate and conduct business with or on behalf of W. P. Carey. These standards speak to our institutional values, while also incorporating internationally and nationally recognized laws, regulations and codes of practice.

We consider vendors to be any firm or individual that directly provides a service to W. P. Carey. It is the vendor’s responsibility to achieve and maintain the standards articulated in this VCOC. By continuing to work with W. P. Carey, vendors affirm that they share a commitment to ethical business practices and transparency. Please see W. P. Carey’s “Code of Business Conduct and Ethics” and “Corporate Responsibility Report”, as well as any related policies for further guidance on many of the issues discussed below. The expectations set forth in this VCOC supplement any other vendor-specific requirements outlined in individual vendor agreements with W. P. Carey.

Business Practices



Information Technology, Confidentiality and Intellectual Property

Vendors should only utilize information technology provided by W. P. Carey to conduct business or provide services related to W. P. Carey. Vendors must use best industry practices to preserve confidentiality of data and recordkeeping. Vendor shall protect the integrity and confidentiality of W. P. Carey’s intellectual property, including but not limited to, business know-how, trade secrets and trademarks.



Insider Trading

Vendors, including their employees and other service providers, must avoid purchase or sale of W. P. Carey’s securities while in possession of material, non-public information.



Conflicts of Interest

Vendors should have established processes and measures to disclose and/or prevent a conflict of interest, or the appearance of a conflict of interest, with W. P. Carey.



Antitrust

Vendors should comply with all antitrust and fair competition laws.



Anti-Corruption, Anti-Bribery

Vendors must comply with all applicable anti-corruption and anti-bribery laws of any country in which they operate, including the U.S. Foreign Corrupt Practices Act and the U. K. Bribery Act. Vendors should be direct, honest and truthful in all discussions with regulatory agency representatives and government officials.



Anti-Money Laundering (AML) and Office of Foreign Assets Control (OFAC)

Vendors must comply with all applicable AML rules and regulations, including the Bank Secrecy Act, the USA PATRIOT Act and applicable FINRA rules and regulations. Vendors should follow industry best-practices in establishing AML policies and/or responding to Know-Your-Customer requirements. Vendors must comply with all OFAC rules and regulations and have regular screening procedures in place for transactions with sanctioned countries and specially designated nationals.



Notice and Legal Consultation

Vendors must disclose and discuss any matter relating to actual or potential violations and noncompliance with laws and regulations with W. P. Carey’s legal counsel.



Sub-contractors

Vendors should encourage their sub-contractors to also abide by and apply this VCOC in undertaking any matter related to W. P. Carey’s business and should adhere to similar principles when interacting with their own vendors, suppliers and representatives.

Employment Practices



Anti-Discrimination

Vendors are encouraged to promote an inclusive workplace where employee differences and lifestyle choice are valued and must commit to creating a work environment free of any form of direct or indirect discrimination, harassment and bullying, including but not limited to gender, gender expression, race, color, national origin, age, religion, marital status, disability, sexual orientation and veteran status.



Employment Regulations

Vendors must adhere to all relevant local, state and federal laws and regulations pertaining to employment practices, including but not limited to, living wages, working hours, overtime, public holidays, freedom of association and right to collective bargaining, benefits, health and safety, acceptable living conditions and nondiscrimination. Vendors should commit to conducting business in accordance with U.S. equal employment opportunity laws, as well as the International Labour Organization (ILO) Discrimination Convention on protecting human rights.



Workplace Health and Safety

Vendors must commit to promoting a safe and healthy work environment that adheres to all relevant laws and regulations, including utilizing best efforts to prevent worker exposure to potential safety hazards and adhering to other Occupational Safety and Health Administration guidelines and regulations. Vendors should have a written health and safety policy and have a documented system in place for recording and reducing work-related injuries and illnesses.



Human Rights

Vendors will not employ any form of forced, bonded, indentured, prison or child labor. All workers must be engaged voluntarily, and they shall be free to leave work or terminate their employment with reasonable notice. In addition, Vendors must treat all employees with dignity and respect and prohibit any inhumane treatment or corporal punishment.



Training

Vendors are encouraged to offer training, learning and development opportunities relevant to their employment for all employees.

Environmental Practices



Environmental Footprint

Vendors are encouraged to manage and minimize their environmental impact in conducting their business, and to promote and support eco-friendly measures. Vendors should commit to reducing energy and water consumption and implement waste minimization programs, including only using what is needed and utilizing, reusing and recycling resources optimally for maximum material lifecycle.



Carbon Emissions

Vendors will work to reduce their carbon emissions in areas within their control and strive for carbon neutral products and services in their processes.



Permits

Vendors must comply with any local, state and federal environmental laws and regulations, including obtaining, maintaining and keeping current any required environmental registrations and permits.



Biodiversity and World Heritage Sites

Where possible, Vendors will make a positive contribution to biodiversity and avoid activities on or near UNESCO World Heritage Sites that could impact the integrity of such sites.



Corporate Responsibility Report

Vendors are expected to follow the same or similar environmental policies as those established in W. P. Carey’s Corporate Responsibility Report (the current version of which can be found on W. P. Carey’s corporate website).

Additional Information

All questions or concerns about compliance or ethics issues at W. P. Carey may be directed to our EthicsPoint hotline, which may be accessed here or by dialing toll free 1 (866) 384-4277. All comments and inquiries raised in good faith will be reviewed on a confidential and non-retaliatory basis.