OUR CORPORATE GOVERNANCE COMMITMENT
We are committed to managing the company for the benefit of our stockholders and are focused on maintaining good corporate governance. Some of the ways in which we do that are through:
BOARD SKILLS
The Nominating/Corporate Governance Committee of our Board of Directors is responsible for the effective composition and operation of our Board, including structure, membership, and refreshment, which is balanced and diverse in terms of backgrounds, and expertise.
OVERSIGHT OVER SUSTAINABILITY MATTERS
Our Board is briefed on sustainability performance and disclosures and plays an active role in assessing risks and identifying opportunities for building a more resilient portfolio.
RISK IDENTIFICATION AND MANAGEMENT
An Enterprise Risk Management evaluation is conducted annually to identify and assess company risk, including climate-related risks. Additionally, the Sustainability department conducts an annual climate risk assessment to evaluate and identify high-risk areas across Realty Income's operations and portfolio.
INCENTIVIZING PERFORMANCE
Our Board Compensation and Talent Committee works with independent consultants to conduct annual compensation reviews for our key executives, such as current efforts to align to sustainability regulatory requirements and industry benchmarks.
REGULATORY COMPLIANCE
Our Board’s Audit Committee oversees the integrity of our financial statements and non-financial quantitative reporting, as well as compliance with legal and regulatory requirements.
GOVERNING SUSTAINABILITY
We believe that our commitment to sustainable corporate impact and responsibility is critical to our performance and long-term success. The Nominating/Corporate Governance Committee of our Board of Directors has direct oversight of sustainability matters.
In 2019, we advanced our sustainability and resiliency efforts, including creating a Sustainability department and creating a dedicated Vice President of Sustainability position.
Our business impact and sustainability program is overseen by the Board's Nominating/Corporate Governance Committee along with other standing committees to the extent issues come within the purview of their responsibilities. The Sustainability Department, who is responsible for advancing the company's sustainability initiatives, reports to the Executive Vice President, Chief Legal Officer, General Counsel & Secretary. The Sustainability Department reports to the Board and its committees regarding client engagement activities, the company’s sustainability framework, program development and business impact and sustainability reporting and disclosures.
BUSINESS ETHICS
We are committed to conducting our business according to the highest ethical standards and upholding our corporate responsibilities as a public company operating for the benefit of our stockholders. Our Code of Business Ethics includes our commitment to our basic values and helps ensure that we are dealing fairly with all of our clients, service providers, suppliers, and competitors. We conduct annual training with our employees regarding ethical behavior and require all employees to acknowledge the terms of, and abide by, our Code of Business Ethics.
Other facets of ensuring ethical conduct across our value chain, include:
ANTI-CORRUPTION
We operate in compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and, as such, have adopted an Anti-Corruption & Foreign Trade Control Policy as well as an Anti-Money Laundering & Anti-Terrorist Financing Policy. These policies prohibit team members and third parties acting on behalf of our company from corruptly paying, offering, promising, authorizing, taking, soliciting, or accepting for personal benefit, any bribe, kickback, illicit payment, or advantage, in money or in any kind, to or from any foreign official or to or from any other person or entity, including terrorist- related groups.
SUPPLY CHAIN MANAGEMENT
Though our suppliers are independent entities, the business practices and operations of our suppliers impact our business in material ways, and in order to enhance our corporate responsibility efforts, it is duly important that our suppliers acknowledge the guidelines set forth by our Supplier Code of Conduct.
CYBERSECURITY
Our management processes are aligned to the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Risk Framework and map back to National Institute of Standards and Technology (NIST) controls. The process, rooted in our Security Incident Response Policy, includes tabletop reviews, third-party assessments, training, and other compliance mechanisms.