Ventas : Global Code of Ethics and Business Conduct

Global Code of Ethics and Business Conduct

High Standards, Strong Foundation

APRIL 15, 2024

Table of Contents

EXECUTIVE MESSAGE: OUR VALUES AND PRINCIPLES	2
WE HAVE A STRONG FOUNDATION.	3

• Our Code: High Standards, Strong Foundation
• Speak Up
• Anti-Retaliation

WE RESPECT OTHERS.

5

• Respect and Anti-Harassment
• Diversity, Equity and Inclusion

WE PROTECT OUR RESOURCES.

7

• Asset Protection
• Third Party Relationships
• Confidentiality
• Private Information
• Information Security

WE PROTECT OUR REPUTATION.

12

• Careful Communication
• Social Media

WE DEMONSTRATE TRANSPARENCY.

14

• Financial Integrity and Company Records

WE COMPLY WITH THE LAW.

15

• Tax Laws
• Securities Laws
• Healthcare Laws
• Anti-MoneyLaundering

WE CONDUCT BUSINESS FAIRLY.

19

• Gifts and Entertainment
• Conflicts of Interest
• Anti-Corruption
• Antitrust

WE VALUE OUR EMPLOYEES, NEIGHBORS AND COMMUNITY.

23

• Workplace Safety
• Care for the Community and the Environment

CONCLUSION	25

1 Global Code of Ethics and Business Conduct

EXECUTIVE MESSAGE

Our Values and Principles

DEAR COLLEAGUES,

At Ventas, we hold ourselves to the highest standards of performance and integrity. From delivering outsized value for our stakeholders to enabling exceptional environments that benefit an aging population, we succeed through our commitment to excellence and doing things the right way.

Our Code of Ethics represents our individual and collective responsibility to uphold that commitment and act consistently with integrity and respect for one another. This Code is designed to guide us in our work and in each of our interactions on behalf of Ventas.

The updated Code of Ethics is principle-based and is written to guide and empower you to make decisions and take actions that advance our shared success and protect the strong reputation we have earned over a quarter of a century. We also have a strong commitment to provide resources to you if you encounter a situation you believe could benefit from more detailed consideration.

The trust our colleagues and stakeholders place in us is a privilege we earn every day. We win together by consistently acting in a manner worthy of that privilege. Thank you for all you do to keep us winning the right way.

Sincerely,

DEBRA A. CAFARO

CHAIRMAN AND CHIEF EXECUTIVE OFFICER

2 Global Code of Ethics and Business Conduct

WE HAVE A STRONG FOUNDATION.

Our Code: High Standards,

Strong Foundation

At Ventas, our Global Code of Ethics (which we refer to as the Code) is the basis for our commitment to ethical business conduct. We take doing the right thing seriously, and we prioritize working with integrity in everything that we do.

The Code explains our obligations under the law and our own standards of conduct, which are expressed in our internal policies. And it serves as a resource for all of us when we are faced with difficult decisions.

How Do We Use the Code?

The Code does not address every ethical issue we may encounter, but it sets forth the standards of ethical business conduct that are fundamental to our business, and it serves as a resource for applying these standards to the work we do every day.

The Code provides the guidance you need to make good decisions consistent with the laws and regulations that apply to our business, and it directs you to other policies and resources when you need additional guidance.

To Whom Does the Code Apply?

The Code applies to all of us at Ventas, including directors, officers and permanent and contingent employees. We are expected to comply with the Code any time we perform work for Ventas, represent the Company or participate in Company-sponsored events. Ventas also expects all third parties who

work on the Company's behalf, such as operators and managers, investment bankers, law firms, real estate brokers, independent contractors, consultants and other vendors, suppliers and service providers to act in a manner consistent with our values and high ethical standards. It applies across all of our properties, by which we mean our senior housing communities, medical office buildings, life science, research and innovation centers, hospitals and other healthcare facilities, and other healthcare real estate that we own or operate.

Failure to comply with this Code could result in disciplinary action, up to and including termination of employment, and may subject you to civil liability, criminal prosecution, or both. Any director, officer, or employee of the Company who authorizes or permits another person to violate this Code may also be subject to disciplinary action, dismissal and other penalties.

3 Global Code of Ethics and Business Conduct

WE HAVE A STRONG FOUNDATION.

Speak Up

At Ventas, our ethical foundation relies on all of us feeling comfortable raising questions and reporting concerns. Reporting concerns about potential violations or misconduct is both a responsibility and a requirement. Speaking up takes courage - but our Company can only address and resolve issues when we are aware of them.

The sooner we raise questions or concerns, the sooner we can work to resolve them. This is a critical step in maintaining our High Standards, Strong Foundation.

What Happens When You Raise a Question or Concern?

We understand that it is not always easy to speak up or raise a concern - and Ventas takes the concerns you share seriously. We will review all reports, conduct any appropriate investigations, and take appropriate action, all while keeping the matters as confidential as possible.

Reporting Resources

There are many resources available if you need to ask a question or report a concern. You may raise a question or concern by speaking to your direct or indirect managers, contacting the Human Resources or Legal and Compliance Departments, contacting the Company's Compliance Investigator or anonymously through the EthicsPoint reporting hotline.

COMPLIANCE RESOURCES

Your Direct or Indirect

Managers

Human Resources Department

Any Vice President or above in Human Resources Ventas, Inc.

353 N. Clark Street, Suite 3300 Chicago, IL 60654

Legal and Compliance

Department

General Counsel, Ethics & Compliance Officer or any Deputy General Counsel Ventas, Inc.

353 N. Clark Street, Suite 3300 Chicago, IL 60654

Compliance Investigator

Vice President, Internal Audit Ventas, Inc.

353 N. Clark St., Suite 3300 Chicago, IL 60654

[phone]

EthicsPoint

anonymous reporting hotline (available 24 hours a day, seven days per week)

[phone] or www.ethicspoint.com

Anti-Retaliation

Ventas is committed to supporting anyone who speaks up about a potential violation or potential misconduct - we will not tolerate retaliation. Individuals who report concerns in good faith should never face mistreatment.

Retaliation is not only a violation of this Code but, in many cases, is also a violation of the law. Acts of retaliation could include denial of benefits, termination, demotion, suspension, threats, harassment or discrimination. If you feel that you are being treated differently because of a concern you raised or a question you asked, report it immediately.

4 Global Code of Ethics and Business Conduct

Respect and Anti-Harassment

Relationships are an important part of what makes us who we are at Ventas. When we treat one another respectfully, we leverage these relationships to perform at our best. At Ventas, we understand the importance of treating one another professionally and with the courtesy that we all deserve. We will not tolerate harassment or discrimination anywhere we do business, and we expect all third parties who partner with us or work on our behalf to take this commitment seriously.

Rules to Live By:

• Act professionally and respectfully and encourage this behavior by those around you.
• Speak up if you see someone acting inappropriately or if you have questions or concerns that someone is being mistreated
• • Make employment-related decisions based on an individual's qualifications and experience and not on legally protected characteristics, such as sex, race or age (see the discussion regarding discrimination, below).
  • Know that managers have additional responsibilities to act if they have questions or concerns about harassment.

WE RESPECT OTHERS.

RELATED RESOURCES

Employee Handbook Anti-Harassment Policy

HIGH STANDARDS, STRONG FOUNDATION

We are proud of our respectful culture - a place where we all feel comfortable coming to work each day. It's essential that we hold each other accountable for prioritizing how we treat one another.

This means modeling professional and respectful behavior at all times. It also includes speaking up when we see disrespectful behavior.

THE FINE PRINT

Harassment is any unwelcome conduct that, intentionally or not, violates a person's dignity or creates a hostile or offensive work environment. Harassment can be verbal or physical and includes conduct that could reasonably be expected to cause someone to feel intimidated, threatened, bullied or denigrated. Harassment can be sexual in nature.

Some examples of sexual harassment include:

• Written and Verbal Contact (such as making sexually suggestive comments or jokes about gender-specifictraits or sexual propositions, asking questions about another employee's sex life or sending sexually suggestive notes, emails or text messages)
• Physical Contact (such as patting, pinching or brushing against another person's body)
• Preferential Treatment (such as promising employment opportunities to an employee in exchange for dates or sexual activity)

Some examples of non-sexual harassment include:

5 Global Code of Ethics and Business Conduct

• Threatening, intimidating or humiliating behavior
• Insulting or teasing someone
• Intentionally excluding someone from workplace or social activities

Discrimination happens when someone is treated differently or unfairly based on certain legally protected characteristics, including those described below. Legally protected characteristics include:

• Race, religion, creed, color, national origin and ancestry
• Sex
• Sexual orientation, gender identity and gender expression
• Marital status (including registered domestic partnership status)
• Physical or mental disability
• Age
• Military and veteran status
• Any other consideration protected by federal, state or local law

WE RESPECT OTHERS.

Diversity, Equity and Inclusion

At Ventas, our goal is to create and foster an environment where our employees can be themselves, value each other's contributions and reach their maximum potential. We view these efforts as an important investment in our performance and ongoing success. This requires a collective awareness and commitment to a diverse and inclusive work environment that is rooted in employee engagement.

Rules to Live By:

• Listen to different opinions and perspectives; groups with diverse perspectives produce better results and make better decisions.
• Act inclusively towards one another and proactively include others in normal workplace interactions and conversations.

HIGH STANDARDS, STRONG FOUNDATION

At Ventas, it is the collection of unique individuals working together that allows our business to thrive. Understanding and celebrating the breadth of our backgrounds makes us who we are as a Company.

The Fine Print

THE FINE PRINT

At Ventas, we believe Diversity, Equity and Inclusion is about taking intentional actions to drive tangible change. This takes hard work and a collective effort to embrace our differences.

	At Ventas, we believe Diversity, Equity and Inclusion is about taking intentional actions to drive
For example:
•	tangible change. This takes hard work and a collective effort to embrace our differences. For example:
Seek opinions or support on a project from someone who often has a perspective that differs from yours.
•	Gather perspectives on an issue or predicament from everyone on your team; understanding the breadth
•	ofSeekouropinionsbackgroundsor supportmakesonusaaprojectbetter teafrom.someone who often has a perspective that differs from
•	yours.
	Treat people the way they want to be treated, not the way you want to be treated.

• Use gender-neutral language when creating and sending communications to a broad group of people or when presenting to a group.

6 Global Code of Ethics and Business Conduct

WE PROTECT OUR RESOURCES.

Asset Protection

The responsible use of assets is critical to our success as a business. Our assets include anything that belongs to Ventas, including Company funds, sensitive business information such as internal procedures, property, equipment, materials and communications technology systems. Theft, carelessness and waste could have a direct impact on our Company's success. We must demonstrate good judgment whenever we use Company assets.

Rules to Live By:

• Use Company assets for business purposes, making sure any personal use of Company equipment or systems is very limited and reasonable.
• Exercise good judgment when using Ventas funds, including when you incur expenses for business travel and entertainment.
• Do not use the name and logo of Ventas, Lillibridge or any other affiliate of Ventas to endorse or promote any product, commercial enterprise, opinion, cause or political candidate.
• Protect our intellectual property and contact the Legal Department if you have questions or concerns about unethical or unauthorized use of our intellectual property or other assets.

HIGH STANDARDS, STRONG FOUNDATION

When we use our assets responsibly, we can empower senior housing and health system operators and tenants and life science and research and innovation tenants to achieve their goals and help more people than ever before. Using our assets responsibly also protects the investments of our shareholders.

THE FINE PRINT

There are times when specific rules or regulations apply to our use of Ventas assets, such as when we engage in business travel or enter into business relationships. It is important that you familiarize yourself with applicable policies whenever your work for Ventas involves these types of responsibilities.

If you are asked to promote a product or service or to allow a vendor to promote or publicize their relationship with Ventas, contact the Legal Department for guidance.

7 Global Code of Ethics and Business Conduct

Third-Party Relationships

We do business with tenants, operators, managers, developers, investment bankers, law firms and other service providers who share our high standards and strong foundation. We rely on many of them - just as we rely on you - to responsibly use our assets and act in accordance with our commitment to ethics and integrity.

Rules to Live By:

• Choose business partners who share our ethical standards and values.
• Oversee the work of third parties and speak up if you have questions or concerns that their work does not align with our values and this Code.
• Do not share information provided by one third party with another third party without written permission.

THE FINE PRINT

Here are some things to look out for when working with third parties:

• Changes in third-party behavior
• Fee structures that increase the risk of wrongdoing
• Requests for payment in advance
• Invoices that lack details and supporting documents
• Ongoing investigations involving the third party

8 Global Code of Ethics and Business Conduct

WE PROTECT OUR RESOURCES.

RELATED RESOURCES

Vendor Code of Conduct

HIGH STANDARDS,

STRONG FOUNDATION

Our goal is to develop and maintain strong and positive relationships with third parties

• relationships that are fair, ethical and focused on growing our business. It is our responsibility to supervise third parties and together fulfill our commitment to ethical business conduct. We do this by sharing our Code with third parties and by demonstrating ethical conduct in all aspects of our work.

Confidentiality

Through our work for Ventas, we may have access to confidential information about the Company and its business partners. Confidential information supports our success as a business, and we all have a responsibility to recognize and understand how to safeguard it.

Rules to Live By:

• Know how to identify confidential information and treat it carefully and in accordance with Ventas policies.
• Discuss and share confidential information inside the Company only with those people who have a need to know the information - and outside the Company only with those who have an obligation to maintain the information in confidence.
• Keep all confidential information about our customers, coworkers and other business partners safe and confirm that the information is out of sight when not in use.

WE PROTECT OUR RESOURCES.

HIGH STANDARDS,

STRONG FOUNDATION

Protecting confidential information about Ventas helps us protect our competitive advantage so that we can continue to thrive and grow. It also helps us earn and preserve the trust of those with whom we work, including our coworkers, tenants, operators, managers and other business partners.

THE FINE PRINT

Confidential information is information that is not publicly available. For example, information about our investment or operator strategies, details about potential transactions, changes in executive management or potential partnerships would be considered confidential information.

Private Information

The positive relationships that we establish and maintain drive our success as a company. These relationships are built on trust and are some of Ventas's most important resources. In the course of our work, we may come across personal, private and sensitive information regarding individuals with whom we work or do business, such as social security numbers or other personal information. Coworkers and business partners trust us to protect this information.

There are laws designed to protect personal information. We are each responsible for safeguarding this information by complying with all data privacy laws that apply to our business. This is how we build trust with one another and our stakeholders.

9 Global Code of Ethics and Business Conduct