Sustainability

Invitation Homes maintains a Code of Business Conduct and Ethics (the “Code”) that is applicable to all of our directors, officers, and associates.  Our Code sets forth our policies and expectations on a number of topics, including, but not limited to, conflicts of interest, compliance with laws, use of our assets, gifts and entertainment, fraud, outside activities, political contributions, bribery, corruption, and business conduct and fair dealing. The Code is a tool designed to help guide us as we work to accomplish our goals together, while holding ourselves individually responsible for our work and accountable for our actions. 

Everyone who works at or with Invitation Homes should feel confident regarding our high ethical standards, our honesty, and our integrity. Invitation Homes’ Vendor Code of Conduct is an extension of our values to include our vendors, and it serves to highlight our commitment to ethical business practices, environmental stewardship, and regulatory compliance.  Vendors of Invitation Homes and their representatives are expected to conduct their business interactions and activities with integrity and in accordance with their obligations under their agreements with the Company and to adhere to the business practices set forth in the Vendor Code of Conduct. 

Invitation Homes’ financial information and statements are prepared in compliance with generally accepted accounting principles and statutory accounting practices and procedures for regulatory purposes. Invitation Homes’ records must accurately and fairly reflect, in reasonable detail, Invitation Homes’ assets, liabilities, revenues, and expenses. The records, data, and information owned, used, and managed by Invitation Homes must be accurate and complete. Associates are personally responsible for the integrity of the information, reports, and records under their control. Making false or misleading statements to anyone, including internal or external auditors, counsel, other associates or regulators, might be a criminal act that could result in severe penalties. 

Invitation Homes complies with the anti-corruption laws of the jurisdictions in which we do business. Associates and directors may not directly or indirectly offer or give anything of value to any government official, including employees of state-owned enterprises, for the purpose of influencing any act or decision in order to assist Invitation Homes in obtaining or retaining business or to direct business to anyone. Invitation Homes associates should ensure that any agents or independent contractors engaged to conduct business on behalf of Invitation Homes are reputable and comply with these requirements. 

Invitation Homes’ Code of Business Conduct and Ethics (the “Code”) specifically prohibits any conduct in violation of the Foreign Corrupt Practices Act, which prohibits any person from giving, offering, promising to pay, or authorizing the giving or payment of money or other things of value to any foreign government official for the purpose of obtaining or retaining business for any person, or directing business to any person, or for securing any improper benefit. 

It is the policy of Invitation Homes to procure goods and services and provide services on an impartial and objective basis, free from outside influence. Associates and directors may not: 

• offer, give, solicit, or receive any form of bribe or kickback; 

• give financial or other support to any outside activity or organization without appropriate authorization; 

• use or disclose proprietary or confidential company information for personal gain or to Invitation Homes’ detriment; or 

• borrow money from entities doing or seeking to do business with Invitation Homes, except where the borrowing is from a bank and is on generally available terms. 

Abusive conduct is defined as conduct of an employer or associate in the workplace, with malice, that a reasonable person would find hostile, offensive, and unrelated to an employer’s legitimate business interests. Abusive conduct may include repeated infliction of verbal abuse or bullying, such as the use of derogatory remarks, insults, and epithets, verbal or physical conduct that a reasonable person would find threatening, intimidating, or humiliating, or the gratuitous sabotage or undermining of a person’s work performance. A single act shall not constitute abusive conduct, unless especially severe and egregious. 

Invitation Homes is committed to strict observance of all applicable competition and antitrust laws and to the avoidance of any conduct that could be considered illegal. 

Invitation Homes associates may have access to customer/consumer non-public personal information (NPI), personal identification information (PII), confidential financial information, and/or payment card information (PCI). It is the policy of Invitation Homes to comply with federal and state consumer privacy laws that protect NPI, PII, and PCI from disclosure, including but not limited to the Gramm-Leach-Bliley Act and related regulations and state privacy statutes, Fair Credit Reporting Act, and any other applicable laws. These laws require certain privacy standards to protect and safeguard consumer financial and nonpublic personal information. 

Invitation Homes provides an inclusive, safe, and welcoming environment for all associates, residents, volunteers, subcontractors, vendors, clients, and others. Invitation Homes and its associates do not and shall not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, or military status, in any of its activities or day-to-day operations. These activities include, but are not limited to, hiring and firing of associates, selection of vendors, and provision of services and housing for residents. Invitation Homes is committed to fostering a positive work environment, free from discrimination and harassment of any form. 

Invitation Homes is an Equal Opportunity Employer that does not discriminate on the basis of actual or perceived race, creed, color, religion, alienage or national origin, ancestry, citizenship status, age, disability (including physical, mental, or visual or use of an aid, appliance, or service animal), sex, pregnancy, breastfeeding, marital status (married women and unmarried mothers), military or veteran status, sexual orientation (including actual or perceived orientation and gender identity or expression), gender expression, genetic information or testing, HIV or AIDS (actual or perceived), sickle cell trait or testing, homelessness (i.e. lack of a permanent mailing address or a mailing address that is a shelter or social services provider), arrest record, uniform service or veteran status, or any other characteristic protected by applicable federal, state, and local laws. Invitation Homes management is dedicated to this policy with respect to recruitment, hiring, placement, promotion, transfer, training, compensation, benefits, associate activities, and general treatment during employment. 

Invitation Homes endeavors to accommodate the sincere religious beliefs of its associates to the extent such accommodation does not pose an undue hardship on our operations.  

Invitation Homes will not allow any form of retaliation against individuals who raise issues of equal employment opportunity.

Invitation Homes is committed to providing equal opportunity in housing, and it is the policy of Invitation Homes to comply with all federal, state, and local fair housing laws. In each and every aspect of the housing process, Invitation Homes will not discriminate on the basis of race, color, religion, sex, disability, familial status, national origin, sexual orientation, gender identity or expression, age, ancestry, political affiliation, marital status, or any other basis deemed unlawful by state or local law. Invitation Homes provides reasonable accommodations upon request to its residents and occupants with disabilities. Additionally, Invitation Homes will not retaliate against anyone who attempts to enforce, or who assists someone in enforcing, their fair housing rights.  

In addition to complying with all applicable fair housing laws, Invitation Homes strives not to discriminate on any basis that does not bear on an applicant’s or resident’s ability to perform under the lease; therefore, our Fair Housing Policy may include additional protections against discrimination that extend beyond the scope of applicable fair housing laws. 

Invitation Homes allows flexible work arrangements on a case-by-case basis. Associates are considered for alternative work scheduling in situations where creative work schedules have been shown to contribute to the accomplishment of both work and personal goals, to provide coverage for individual department operations, and to serve Invitation Homes with increased productivity at no expense to quality output. 

It is the policy of Invitation Homes to prohibit the intentional and unintentional harassment of any individual by another person on the basis of any protected classification, including, but not limited to, race, color, national origin, disability, pregnancy, religion, marital status, U.S. veteran status, sexual orientation, gender identity, gender expression, and age. The purpose of this policy is not to regulate the personal morality of associates, but to ensure that no one harasses another individual in the workplace.  Harassment includes, but is not limited to: 

• Verbal conduct, including epithets, slurs, derogatory comments, or statements that are based on an individual’s protected status. 

• Visual conduct, including derogatory posters, photography, graphic material, cartoons, drawings, or gestures circulated or posted within the workplace concerning a protected classification. 

• Physical threats against or intimidation of an individual because of their protected characteristics. 

• Physical conduct such as threat, assault, unwelcome touching, blocking normal movement, or interfering with work. 

• Retaliation for reporting harassment or threatening to report harassment. 

At Invitation Homes, we are committed to the protection and advancement of human rights and to ensuring that our operations function with integrity. We endeavor to respect and promote human rights in our relationships with our associates, residents, and vendors.  The following principles apply to all Invitation Homes associates and anyone acting on behalf of Invitation Homes: 

• We prohibit the use of child labor, in accordance with International Labour Organization (ILO) Convention 138. 

• We reject the use of forced labor in all its forms, including but not limited to, prison or debt bondage labor, trafficking, and the lodging of deposits or identity papers by employers or outside recruiters. 

• We forbid any form of corporal punishment, mental or physical coercion, or verbal abuse. 

• We recognize the right to water as a fundamental human right. Invitation Homes respects the human need for sustainable water supplies, safe drinking water, and protection of both ecosystems and communities through proper sanitation. 

• We prohibit corruption in all its forms, including extortion and bribery. 

Invitation Homes’ officers may not purchase Invitation Homes securities on margin, borrow against any account in which Invitation Homes’ securities are held, or pledge Invitation Homes’ securities as collateral for a loan. Company directors who wish to pledge Invitation Homes’ securities as collateral for a loan must first submit a request for approval to the Office of the Chief Legal Officer prior to the execution of the documents evidencing the proposed pledge. The Office of the Chief Legal Officer is under no obligation to approve any request for pre-clearance and may determine not to permit the arrangement for any reason. 

Invitation Homes is committed to protecting the rights of associates who are pregnant, who have a child, or who receive a child for adoption. Invitation Homes is firmly committed to protecting the rights of expectant mothers and complying with Title VII of the 1964 Civil Rights Act, as amended by the Pregnancy Discrimination Act of 1978 and the Americans with Disabilities Act of 1990, and similar state and local laws. Invitation Homes’ policy is to treat associates affected by pregnancy, childbirth, or related medical conditions in the same manner as other associates unable to work because of their physical condition in all employment aspects, including recruitment, hiring, training, promotion, and benefits. 

As a further commitment to our associates and their families, Invitation Homes provides up to eight (8) weeks of paid parental leave related to bonding with a newly born or newly placed child to eligible associates 

Invitation Homes reserves the right to communicate its position on important issues to elected representatives and other government officials. It is Invitation Homes’ policy to comply with all local, state, federal, foreign, and other applicable laws, rules, and regulations with regard to political contributions. Invitation Homes’ funds or assets must not be used for, or be contributed to, political campaigns or political practices under any circumstances without the prior written approval of the Chief Legal Officer. Associates may engage in personal political activity on their own time; however, they must take particular care not to imply that they are acting on behalf of Invitation Homes. Associates who run for an elected office are required to inform the Chief Legal Officer. 

The federal securities laws prohibit any person who is in possession of material, non-public information from engaging in securities transactions on the basis of such information and from communicating such information to any other person for such use. Transacting in securities of Invitation Homes or any other company while possessing material, nonpublic information is known as insider trading. Tipping, which is also prohibited, refers to communicating such material, nonpublic information to another party for that party’s use. Any of these actions may amount to insider trading and are strictly prohibited. 

Associates may report any violations or suspected violations of accounting or auditing matters openly, confidentially, or anonymously. Unless necessary to conduct an adequate investigation or compelled by judicial or other legal process, Invitation Homes will protect the identity of any person who reports potential misconduct and who asks that their identity remain confidential. Invitation Homes will also use reasonable efforts to protect the identity of the person about or against whom an allegation is brought, unless and until it is determined that a violation has occurred. Any person involved in any investigation in any capacity of possible misconduct must not discuss or disclose any information to anyone outside of the investigation unless required by law or when seeking his or her own legal advice. Such persons are expected to cooperate fully in any investigation. 

Neither Invitation Homes, the Audit Committee, nor any director, officer, associate, contractor, subcontractor, or agent of Invitation Homes will, directly or indirectly, discharge, demote, suspend, threaten, harass, or in any manner discriminate or retaliate against any person who, in good faith, makes a report to or otherwise assists the Audit Committee, management, or any other person or group, including any governmental, regulatory, or law enforcement body, in investigating a report. 

Sexual harassment of any associate by any supervisor, fellow associate, resident, or vendor is prohibited at Invitation Homes. The purpose of this policy is not to regulate personal morality within Invitation Homes, but to ensure that all Invitation Homes associates are free from sexual harassment.