Inventrust Properties Corp.
Code of Ethics and Business Conduct
In accordance with the requirements of the Securities and Exchange Commission (the “SEC”), the Board of Directors (the “Board”) of InvenTrust Properties Corp. (the “Company”) has adopted this Code of Ethics and Business Conduct (the “Code”) to encourage:
- Honest and ethical conduct, including fair dealing and the ethical handling of actual or apparent conflicts of interest;
- Full, fair, accurate, timely and understandable disclosure;
- Compliance with applicable governmental laws, rules and regulations;
- Prompt internal reporting of any violations of law or the Code;
- Accountability for adherence to the Code, including fair process by which to determine violations;
- Consistent enforcement of the Code, including clear and objective standards for compliance;
- Protection for persons reporting any such questionable behavior;
- The protection of the Company’s legitimate business interests, including its assets and corporate opportunities; and
- Confidentiality of information entrusted to directors, officers and employees by the Company and its customers.
All directors, officers (including Senior Financial Officers (as defined below)) and employees (each a “Covered Party” and, collectively, the “Covered Parties”) of the Company and all of its subsidiaries and controlled affiliates are expected to be familiar with the Code and to adhere to those principles and procedures set forth below. Covered Parties generally have other legal and contractual obligations to the Company. This Code is not intended to reduce or limit the other obligations that you may have to the Company. This Code must be read in conjunction with the Company’s employee handbook and other Company compliance and employment policies, practices and procedures. Covered Parties must conduct themselves accordingly, exhibiting the highest standard of business and professional integrity, and seek to avoid even the appearance of improper behavior. Disciplinary measures for violations of this Code may include, but are not limited to, counseling, oral or written reprimands, warnings, probation, suspension with or without pay, demotions, reductions in salary, termination of employment or service and possible civil and criminal prosecution.