ethics compliance<p>​<img src="/SiteCollectionImages/Misc.%20Banner%20Images/CSR/Ethics_Compliance.jpeg" alt="" style="margin:5px;" /></p>ethics compliance00

 

 

Ethics and ComplianceEthics ComplianceEthics and Compliance1

 

 

Ethics and Compliance content​<span style="color:#009b48;font-family:proxima-nova, sans-serif;font-size:2.2rem;">​Disclosing and communicating sustainability initiatives and performance publicly via reputable reporting frameworks/standards.</span> <div> <font color="#ec802b" face="proxima-nova, sans-serif"> <span style="font-size:35.2px;"> <br></span></font> <h2 style="color:#478299;font-family:ff-tisa-web-pro, sans-serif;font-size:2rem;font-style:italic;">Board Diversity</h2><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;">Promoting diversity and inclusion on the Board of Directors and ensuring a non-discriminatory nomination process and culture.</p><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;">Forest City's core values, including Integrity and Openness, are the foundation upon which we operate. We take a proactive approach to ethics and compliance that fosters increased trust between Forest City and our stakeholders, further strengthening our company over time. We see ethical behavior as a fundamental requirement of our business. Our ethics policies and procedures convey the expectation that associates uphold the highest possible standards of ethical behavior at all times. </p><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;"> We require each associate and board member to review and sign our Code of Legal and Ethical Conduct on an annual basis. Each year, we determine additional policies and key components of legal requirements and our ethical framework that will require formal associate training and acknowledgment, which includes policies covering topics such as insider trading, hedging and pledging, fair disclosures and records retention. Achieving 100 percent compliance with the Code across our workforce is a primary goal for our Legal and Human Resources Departments. We are pleased to report that we achieved this goal in 2015, with all required full- and part-time associates (a total of 2,625) completing their requirements. </p><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;"> Our Legal and Human Resources departments conduct annual enterprise-wide ethics and compliance training on important and trending issues, such as SEC compliance and workplace harassment. These training sessions also serve as a forum for associate discussion about ethical decision-making and help to raise awareness of best practices across the company.</p><p> </p><h2 style="color:#478299;font-family:ff-tisa-web-pro, sans-serif;font-size:2rem;font-style:italic;">Supporting Policies and Procedures</h2><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;">In addition to our Code of Legal and Ethical Conduct, Forest City maintains several specific policies and procedures governing our approach to ethics and compliance. We have a formal written policy approved by the Board of Directors that dictates our approach to investigating accusations of fraud at the executive level. In compliance with Sarbanes-Oxley Act, all senior financial officers must receive and comply with a separate Senior Financial Officer Code of Ethical Conduct, governing behavior specific to their roles and responsibilities. Externally, each new supplier and all existing major suppliers are expected to agree to Forest City's Supplier Code of Conduct. </p><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;">Our Internal Audit department reviews our regulatory compliance on a quarterly basis and conducts an annual assessment to identify gaps in our approach and performance surrounding ethics and compliance. We take seriously any accusations of wrongdoing within our organization and act quickly to take corrective measures. </p><p> </p><h2 style="color:#478299;font-family:ff-tisa-web-pro, sans-serif;font-size:2rem;font-style:italic;">Ethics Hotline</h2><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;">We partner with Global Compliance as the third-party operator of our ethics hotline, which is available 24 hours a day, seven days a week, 365 days a year. The hotline serves as a venue for associates, partners, customers and vendors to anonymously report concerns or behaviors of any kind that they feel may violate Forest City's policies or practices, or federal, state or local regulations. Each month, both the Legal Department and the Audit Committee of the Board receive an anonymous summary report of all calls into the hotline, and all reported ethical or legal concerns are reported to HR, Legal or individual company officers. In 2015, our overall call volume remained low, and the most common concerns raised on the ethics hotline include allegations of workplace misconduct, such as favoritism and harassment. In compliance with our Audit Committee-approved Investigation Policy, our General Counsel reviews each call and takes action as appropriate. The system allows hotline callers to get updates on whether the matter has been resolved while maintaining their anonymity. The company has a strict non-retaliation policy in connection with any reports of legal or ethical concerns. </p><p> </p><h2 style="color:#478299;font-family:ff-tisa-web-pro, sans-serif;font-size:2rem;font-style:italic;">Board Diversity</h2><p style="color:#626366;line-height:1.75;font-family:proxima-nova, sans-serif;font-size:1.6rem;font-style:normal;">An inclusive work environment engenders acceptance, respect, engagement and productivity. At Forest City, this inclusive culture begins with our Board of Directors, who has spent the past 15 years driving initiatives that broaden and strengthen the diversity and inclusion of our company. Two of the Board's three standing committees are responsible for the review of Forest City's diversity plan and progress. Today, the Board continues to focus on increasing its own diversity. In recommending new nominees for membership on the Board, diversity in gender, ethnic background, geographic origin or personal and professional experience are among the primary attributes and traits our Corporate Governance and Nominating Committee of the Board considers. Currently, seven out of 13 members, or 53.8 percent, of the Board qualify as independent under our governing documents and the rules of the Securities and Exchange Commission and the New York Stock Exchange, 7.7 percent of members represent minority groups, and 23.1 percent are women. </p></div>Ethics ComplianceEthics and Compliance content0Generic Page Content Text0