Investors Bancorp : Insider Trading Policy

INSIDER TRADING

AND CONFIDENTIALITY OF INFORMATION

POLICY

Re-adopted July 26, 2021

INVESTORS BANCORP INC.

INSIDER TRADING

AND CONFIDENTIALITY OF INFORMATION POLICY

1.	PURPOSE...............................................................................................................................................	2
2.	SCOPE OF COVERAGE ...........................................................................................................................	2

3. PROHIBITION AGAINST TRADING WHILE IN POSESSION OF UNDISCLOSED MATERIAL

INFORMATION..............................................................................................................................................	2
4.	CONFIDENTIALITY.................................................................................................................................	3
5.	APPLICABILITY OF POLICY TO INSIDE INFORMATION REGARDING OTHER COMPANIES...................	4
6.	PROHIBITION AGAINST INTERNET DISCLOSURES AND DISCUSSION..................................................	4
7.	ADDITIONAL RESTRICTIONS ON PURCHASES AND SALES OF COMPANY STOCK...............................	4
8.	EFFECTIVE DATE....................................................................................................................................	5
9.	ADOPTION HISTORY .............................................................................................................................	6

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PROPRIETARY

INVESTORS BANCORP INC.

INSIDER TRADING

AND CONFIDENTIALITY OF INFORMATION POLICY

1. PURPOSE

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Investors Bancorp, Inc. (the "Company") is a public company, the common stock of which is quoted on the Nasdaq Global Select Market and registered under the Securities Exchange Act of 1934, as amended (the "Exchange Act"). Pursuant to the Exchange Act, the Company files periodic reports and proxy statements with the Securities and Exchange Commission (the "SEC"). Investors Bank (the "Bank") is the Company's wholly-owned subsidiary.

As a public company, the directors, officers and employees of the Company have a responsibility not to participate in the market for the Company's common stock while in possession of "material information" about the Company that has not been publicly disclosed. There are harsh civil and criminal penalties if you use such material, or if you give that information to another person who uses it, when deciding whether to buy or sell Company securities. You may be sentenced to a substantial jail term and required to pay a criminal penalty of several times the amount of profits gained or losses avoided. The Company also may be held liable for your violations of the insider trading laws.

To avoid violations of the federal securities laws, the following policy and provisions have been adopted with respect to insider trading and the confidentiality of information for the employees, officers and directors of the Company. This policy applies to all employees, officers and directors of the Company and the Bank. The insider trading policy also applies to persons whose transactions are attributable to you for the purpose of the policy, including your family members who reside with you, anyone else who lives in your household, any family members who do not live in your household but whose transactions in Company securities are directed by you or are subject to your influence or control (such as parents or children who consult with you before they trade in Company securities), and entities (e.g. family trusts) that are controlled by you or any person whose transactions are attributable to you. Such persons are subject to the same civil and criminal penalties described above. You are responsible for the transactions of these persons and therefore should make them aware of the need to confer with you before they trade in the Company's securities.

This policy will be reviewed periodically to ensure that it remains current. Subsequent changes will be submitted to the Board of Directors for readoption. However, these guidelines do not address all possible situations that you may encounter. If you have any questions, please contact the Company's General Counsel.

2. SCOPE OF COVERAGE

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This policy applies to all employees, officers and directors of the Company and the Bank, as well as the other persons and entities described in Section 1 above.

3. PROHIBITION AGAINST TRADING WHILE IN POSESSION OF UNDISCLOSED

MATERIAL INFORMATION

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If you are aware of material information relating to the Company that has not been publicly disclosed, you are prohibited from purchasing or selling (or offering to purchase or sell) the Company's common stock, directly or indirectly, and also from disclosing such information to any other persons that may trade in the Company's stock, directly or indirectly.

• It is difficult to describe exhaustively what constitutes "material" information, but you should assume that any information, positive or negative, that may be significant to an investor in determining whether to buy, sell or hold the Company's common stock, or that is likely to affect the market price of the Company's common stock, would be material. Information may be

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PROPRIETARY

INVESTORS BANCORP INC.

INSIDER TRADING

AND CONFIDENTIALITY OF INFORMATION POLICY

significant for this purpose even if it alone would not determine an investor's decision. When in doubt about whether particular nonpublic information is material, you should presume that it is material.

• Examples of material inside information include significant changes in the Company's prospects, a potential business acquisition, a change in management, projections of future earnings or losses, internal financial information that departs in any way from recent data or trends, a change in dividend policy, the declaration of a stock split, developments regarding significant litigation or government agency investigations, cybersecurity risks and incidents including vulnerabilities and breaches, an offering of additional securities or an important financing transaction. It must be emphasized that this list is merely illustrative and there are many additional instances in which non-public material would be considered material.
• To be "public", information must have been disseminated in a manner designed to reach investors generally, and the investors must be given the opportunity to absorb the information. Even after public disclosure of information about the Company, you must wait until after the close of business on the second trading day after the information was publicly disclosed before you can treat the information as public. Information would likely not be considered widely disseminated if it is available only to the Company's employees.
• The prohibition on direct and indirect purchases and sales made while in possession of material information applies to your spouse, children and relatives living in the same household as you, anyone else who lives in your household, as well as to any arrangements or agreements with other persons, family members or otherwise, as to the purchase or sale of shares.
• Directors, executive officers and certain other employees of the Company and the Bank must "pre-clear" all trading in the Company's securities in accordance with the protocol set forth in Section 7(A) below.

4. CONFIDENTIALITY

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1. General

Serious problems could be caused for the Company by unauthorized disclosure of internal information about the Company or the Bank, whether or not for the purpose of facilitating improper trading of the common stock. Company personnel may not discuss non-public internal matters or developments with anyone outside of the Company, except as required by law or in the performance of regular corporate duties.

1. Third Party Disclosure

Personnel of the Company may assume that its legal counsel, accountants, consultants and other advisors will not disclose to third parties or trade on inside information given to them in confidence. However, with regard to negotiating with third parties at arms-length for various transactions, including the sale of assets such as loans, material confidential information should not be given to such third party unless the third party enters into a confidentiality agreement with the Company. Such agreement should expressly address the issue of trading in the Company's common stock.

1. Disclosure to Others in the Company

Personnel of the Company with knowledge of material non-public information should only disclose such information to other such personnel on a need-to-know basis. The group of individuals with knowledge of the material information should therefore be kept as small as possible.

1. Third Party Inquiries

This prohibition applies specifically (but not exclusively) to inquiries about the Company and the Bank that may be made by the financial press, investment analysts or others in the financial community.

• It is important that all such inquiries and responses thereto be channeled through executive management under carefully controlled circumstances.

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PROPRIETARY

INVESTORS BANCORP INC.

INSIDER TRADING

AND CONFIDENTIALITY OF INFORMATION POLICY

• Unless you are expressly authorized to the contrary, if you receive any inquiries of this nature, you should decline to comment and refer the inquirer to executive management, including the Company's General Counsel.

If you have any doubt as to your responsibilities under these guidelines, seek clarification from your immediate supervisor or executive management before you act. The Company expects the strictest compliance with these provisions by all personnel at every level. Failure to follow these provisions may result in severe legal difficulties for you, as well as for the Company. A failure to follow both the letter and the spirit of this policy shall be considered a matter of extreme seriousness and may be grounds for termination of employment or other disciplinary action.

5. APPLICABILITY OF POLICY TO INSIDE INFORMATION REGARDING OTHER

COMPANIES

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This policy and the guidelines described herein also apply to material non-public information relating to other companies, including the Company's customers, vendors, suppliers or acquisition candidates ("business partners") when that information is obtained in the course of employment with, or other services performed on behalf of, the Company. Civil and criminal penalties and termination of employment may result from trading on inside information regarding the Company's business partners. All employees should treat material non-public information about the Company's business partners with the same care required with respect to information related directly to the Company.

6. PROHIBITION AGAINST INTERNET DISCLOSURES AND DISCUSSION

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It is inappropriate for any unauthorized person to disclose Company information on the Internet, including on any social media platform or in any forum or chat room where companies and their prospects are discussed. No director, officer or employee may disclose nonpublic information in any Internet forum or chat room, regardless of the circumstances.

7. ADDITIONAL RESTRICTIONS ON PURCHASES AND SALES OF COMPANY STOCK

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The following additional provisions with respect to the participation in the market for the Company's common stock by directors, executive officers and certain other officers and employees of the Company have been adopted by the Board of Directors in order to decrease the likelihood of violation of the federal securities laws. It should be emphasized that these provisions are designed to: (i) avoid even the appearance of trading on insider information, (ii) as a cautionary matter, eliminate the ongoing question of when knowledge of unreported quarterly and year-end financial information may be considered "material" under the insider trading laws, and (iii) enable the Company to monitor stock trading to some extent.

These provisions are in addition to the general prohibition against participation in the market for the Common Stock while in possession of material, non-public information, regardless of the time period. The additional officers and employees to whom these provisions apply will be set forth in an addendum to this policy, to be modified from time to time as appropriate, under the direction of the General Counsel, and communicated to these additional employees.

1. Quarterly Blackout Periods. During the period commencing with the sixteenth day of the third month of each calendar quarter (March 16, June 16, September 16 and December 16), and ending at the beginning of the second business day after the financial results of the quarter/year end have been publicly announced, directors and executive officers may not trade Company securities except as otherwise expressly provided in this Policy.
2. Temporary Blackout Periods. The Company may also institute temporary blackout periods, during which trading in the Company's securities is prohibited, in the event of a material corporate development. Notice of temporary blackout periods may be distributed by means of a written or electronic

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PROPRIETARY