Ethics

Our sustained operational and financial success has always been predicated on our commitment to doing business ethically and with integrity. We promote a corporate culture that is consistent from the senior management team and Board-level leadership to each employee in the organization and is guided by our Code of Ethics and Business Conduct Policy (Code of Conduct). We believe it is our responsibility to “lead from the top” to ensure we operate in an ethical manner.

This commitment has been acknowledged externally through our inclusion in the FTSE4Good® Index, which recognizes companies that meet international corporate responsibility standards regarding climate change and environmental responsibility, human rights and corruption prevention.

Our Code of Conduct establishes behavioral expectations and disciplinary protocols that apply to members of senior management, the Board and all other employees throughout the organization. Each year, our Code of Conduct must be certified by all our employees and Board members. In addition, the Code of Conduct also applies to our customers, vendors and suppliers when we are partnering on projects.

Vendor relations teams in each of our markets have processes and policies in place to ensure vendors understand our ethical standards and expectations. In addition, in connection with our Sanctions Compliance Policy, the legal teams throughout the markets review all customers, vendors and service providers of American Tower through managed software to confirm there are no Office of Foreign Assets Control (OFAC), or Bureau of Industry and Standards (BIS) or other sanctions applicable to such third parties.

In cases of potential misconduct, individuals are encouraged to contact our Ethics Committee at ethics.committee@americantower.com or Human Resources department directly. In addition, employees and other stakeholders can report a violation through our anonymous, confidential, third-party hotline.

FTSE4Good® is a registered trademark of The Financial Times, Ltd.

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Founded in 1995, American Tower, one of the largest global Real Estate Investment Trusts (REITs), is a leading independent owner, operator and developer of multitenant communications real estate, with a portfolio of over 160,000 communications sites, including approximately 40,000 towers in the United States and more than 109,000 towers internationally.

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American Tower was named one of America’s Best Mid-Sized Employers in 2018 by Forbes.