Policies

POLICIES

Codes of Conduct

Ventas is committed to fair and ethical business conduct, consistent with its Global Code of Ethics and Business Conduct and Global Anti-Corruption Policy. The Company requires its partners, suppliers, and vendors, as well as their employees, agents and subcontractors, to embrace this commitment to integrity by complying with the Ventas Vendor Code of Conduct.

Human Rights

Respect for human rights is fundamental at Ventas. We are committed to upholding human dignity and equal opportunity under principles outlined in the United Nation’s Universal Declaration of Human Rights. In addition to our Human Rights Policy, our Global Code of Ethics and Business Conduct and the Vendor Code of Conduct embed the responsibility to respect human rights in all business functions, including our supply chain. Ventas also promotes human rights by encouraging social and environmental progress and better standards of life and freedom for our employees, those of our suppliers, and the communities we serve. Fostering engagement with each of these groups is critical to our continued identification and promotion of human rights.

Political Contribution, Expenditure and Activity

In accordance with our Political Contribution, Expenditure and Activity Policy, Ventas participates in the political process by contributing prudently to state and local candidates and political organizations when such contributions are permitted by state and local law. Direct corporate contributions to federal candidates and national political party committees are prohibited by law. As a result, we do not make such contributions.

In the interest of transparency for our stockholders and other stakeholders, a list of our corporate contributions to state and local political candidates, political parties and initiatives is updated and published semi-annually as below:

Ventas, Inc. Corporate Political Contributions: January – December 2017

Contributions to Political Organizations

Democratic Governors’ Association

State

Rhode Island

Amount

$25,000

The Company’s political contributions and activities for the period from January 1, 2017 to December 31, 2017 adhere to the Ventas, Inc. Political Contribution, Expenditure and Activity Policy.