T H E J O N E S R E A L T Y G R O U P

PURPOSE: The purpose of the Employee Code of Conduct policy is to strengthen the ethical environment of The JONES Realty Group by providing guidance on the principles, standards, and responsibilities of conduct for all employees in the performance of their duties. In addition, a Sustainable Partnership with our employees is key to a successful working environment.

These behavioral expectations are directly derived from The JONES Realty Group’s core values, which are:

Service
Accountability
Trust
Integrity
Success
Values
Leadership

Employment with The JONES Realty Group is at the mutual consent of The JONES Realty Group and the employee, and either party may terminate that relationship at any time, with or without advance notice.

SCOPE: The JONES Realty Group’s Employee Code of Conduct policy applies to all employees at The JONES Realty Group regardless of employment status, unless specifically excluded by contract or collective agreement.

This Employee Code of Conduct represents guiding principles only — it cannot anticipate all circumstances and situations that employees may encounter. The exercise of good judgment is still expected from employees at all times. If in doubt in regards to appropriate behavior or course of action, The JONES Realty Group, Inc. strongly encourages employees to seek out guidance from others in the organization.

RESPONSIBILITY AND AUTHORITY: All members of management are responsible for implementing and enforcing the Employee Code of Conduct in consultation with the Human Resources Department. On an annual basis, employees are required to sign an acknowledgement that they have read, understand, and agree to comply with the Employee Code of Conduct. If an employee becomes aware of a serious breach of this Employee Code of Conduct, the employee has a responsibility to report that breach to their supervisor. Any employee who reports a breach in good faith is protected from reprisal for doing so, even if the reported breach is not confirmed through investigation.

Any questions regarding the scope, interpretation, or application of the Employee Code of Conduct should be referred to your immediate supervisor.

EMPLOYEE CODE OF CONDUCT: The ethical behavior of The JONES Realty Group employees is essential to maintaining the public’s confidence and trust. This code emphasizes that The JONES Realty Group employees are professionals who are resolved to uphold The JONES Realty Group’s legal obligations and ethical ideals.

While employees must always be guided by their own professional judgment, The JONES Realty Group hopes that consideration of this code will help when difficulties arise.

COMPLIANCE WITH LAWS AND REGULATIONS: Employees must comply with the laws and regulations that impact The JONES Realty Group and how they do their jobs. All efforts should be made by employees to ensure their co-workers do the same.

CONFIDENTIALITY AND PRIVACY: Employees may come into contact with privileged information. The employee has the duty to the owners of the information to protect the confidentiality of all such information.

All appropriate effort should be made by the employee to enforce security measures to protect The JONES Realty Group’s confidential information and personal employee information.

RESPECT: The JONES Realty Group values courtesy, honesty, diversity, tolerance, equity and dignity. All employees have the right to feel safe and comfortable in their place of work. Employees must behave respectfully and professionally in all interactions with colleagues, suppliers, customers, or the public at large. Discriminatory, offensive, intimidating, humiliating and otherwise disrespectful behavior will not be tolerated.

PROTECTION OF ASSETS: Employees are provided access to The JONES Realty Group assets for the purpose of performing work-related activities. The JONES Realty Group name assets will not be used for anything other than legitimate JONES Realty Group business. Employees are expected to take good care of The JONES Realty Group assets in their possession and will take reasonable actions to protect these assets from damage, loss, misuse or theft, to include in appropriate removal or possession of company property.

HEALTH AND SAFETY: Leadership at The JONES Realty Group is committed to providing a clean, safe and healthy workplace for all employees. Employees must comply with all safety policies and directives and must take reasonable precautions to ensure not only their own safety and health, but also that of others affected by their work. Employees are obligated to report any unsafe conditions to their immediate supervisor.

CONFLICT OF INTEREST: A conflict of interest exists if an employee engages in activities or has any personal interests which might conflict with, or even have the appearance of conflicting with, the interests, obligations or duties of The JONES Realty Group or one of our customers. A conflict of interest may arise due to the following circumstances: access to information, community activities, dealings with competitors, consulting, endorsements, financial interest in another company, giving or receiving of gifts or hospitality, and other employment.

Employees shall not accept gifts or gratuities from suppliers. An exception to this rule includes promotional items of nominal value (not to exceed $50.00) or moderately-scaled entertainment within a reasonable and prudent limit (not to exceed $50.00).

Employees must avoid having financial interests in entities that could jeopardize their objectivity or create the appearance of impropriety in their dealings on behalf of The JONES Realty Group. If a conflict of interest exists or an employee knows of a conflict of interest existing with another employee, this information must be disclosed immediately. Employees are not to perform duties or accept compensation for duties for others during normal business hours where they are being compensated by The JONES Realty Group, Inc. Employees shall not work under the influence of alcohol or illegal drugs, possess, distribute, sell, or transfer alcohol or illegal drugs in the workplace, while on duty, or while operating employer-owned vehicles or equipment. Employees shall not falsify records — to include timekeeping records. Employees shall not abuse time off rights with excessive absenteeism or any absence without notice.

COMMUNICATION: The employee must keep other employees informed about matters that may affect them. This information must be presented in a manner designed to ensure understanding and awareness. An employee will answer questions and give support in a timely and effective manner, while openly declaring any limitations of personal knowledge and conflicts of interest.

MEDIA RELATIONS: All inquiries from the media must be directed to your immediate supervisor. The JONES Realty Group’s confidentiality, privacy, and security policies must be taken into consideration before any information is publically disclosed.

SOCIAL AND ENVIRONMENTAL RESPONSIBILITY: Employees are required to maintain and expand their understanding of the legal and social issues that arise in relation to their work environment and communicate that understanding to others where appropriate.

Employees must carry out their work in an environmentally responsible manner.

WORK ETHIC: A top-notch work ethic will be required to maintain high levels of quality in the work performed. Employees are placed in such a position of impact upon the business of The JONES Realty Group that the required level of trust can only be maintained by outstanding performance and moral conduct.

PROFESSIONALISM: Dealing with customers, co-workers, vendors, consultants, upper management requires the utmost care and patience to ensure that the highest level of respect is maintained.

Actions that enhance the image of the profession are highly encouraged. Employees will cooperate with and support their fellow professionals.

INFRINGEMENT: Employees will not act with, nor tolerate from others, discrimination against other employees in the performance of their work duties.

Employees will not exercise their authority other than is necessary for their role, and then only to a degree that is necessary to perform that role, while remaining within established policies. Any private information obtained by the employee must be kept confidential.

SUSTAINABLE PARTNERSHIP: Sustainable business practices are applicable to all business operations and go beyond the traditional “green businesses” or recycling and waste management. An innovative total systems approach to buildings pays special attention not only to the types of materials that are used (low waste, non-polluting, local original if possible, etc.) but also to the design process itself. By creating our design team consisting of the various professionals and technical groups we have engaged in this process, we can lead to dramatic results in terms of reducing material and energy needs. It is the responsibility of each and every employee and The JONES Realty Group collectively, to work with these professionals to collaborate new ideas, as well as, maintain our existing commitment.

The JONES Realty Group believes in practicing a sustainable working environment for our employees as with fairness in the workplace, commitment to competitive wages, continuing education, personal and professional development and a happy working environment. Laughter is the best sustainable practice available to us all. In addition, promoting healthy habits, massage, exercise for our employees is essential to their well being.

The company Sustainability Partnership places all employees and the corporation in a position to be Accountable for the Environment and each other.