Governance Documents

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

All of our employees are required to annually review our key policies, including our Global Anti-Corruption Policy and Global Code of Ethics and Business Conduct which contains anti-corruption guidelines. We also have periodic mandatory employee training focused on anti-corruption guidelines that are appropriate for our business. We encourage anyone (including employees, contractors, tenants and suppliers) to report in good faith any issues or concerns about potential ethical, legal or regulatory violations, including those regarding our internal controls or our accounting or audit practices, by contacting our Compliance Investigator (opens in new window).

For more information, see our Global Code of Ethics and Business Conduct and our Global Anti-Corruption Policy.

Ventas is committed to providing all employees, employment applicants, workplace contractors, unpaid interns and volunteers with a work environment that is free from harassment. Our Anti-Harassment Policy outlines behaviors and conduct that are prohibited, including sexual harassment, on any legally protected basis.

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 Vendor Code of Conduct embed the responsibility to respect human rights in all business functions, including our supply chain. Ventas further promotes human rights by encouraging social and environmental progress and better standards of life for our employees, those of our suppliers and the communities we serve. Fostering engagement with each of these groups is critical to our continued promotion of human rights.

Our minimum stock ownership guidelines require each executive officer to maintain a minimum equity investment in our Company based upon a multiple of their base salary. Pursuant to our guidelines, each executive officer must achieve the minimum equity investment within five years from the date they first become subject to the guidelines and, until that time, must retain at least 60% of the after-tax shares of our common stock granted to the executive officer or purchased by the executive officer through the exercise of stock options. Shares held in a trust or foundation that are not reported as beneficially owned by the executive, performance awards that have not yet vested and stock options that have not been exercised are not included when calculating an executive officer's share ownership. Stock appreciation rights, if granted, and shares subject to floors, collars or other hedging arrangements, if permitted, also would be excluded from this calculation pursuant to the Company's policy.