Vendor Code of Conduct

Independence Realty Trust values ethics, integrity, sustainability and social responsibility. As a company, we have instituted corporate policies and undertaken initiatives to uphold and promote these values. We are committed to these values but we recognize that IRT does not operate alone. Our values will not be advanced unless they are shared and promoted by our vendors. Our Vendor Code of Conduct is intended to ensure our vendors operate ethically and employ sustainable and socially responsible business practices. We expect that vendors who provide products or services to our company comply with the letter and spirit of the principles set out in our Vendor Code of Conduct.

GIFTS & BRIBERY

IRT employees are required to conduct all business and interactions with vendors in strict compliance with the applicable provisions of IRT’s Code of Ethics. Vendors must not directly or indirectly give or receive improper business advantage via the giving or receiving anything of value in exchange for preferential treatment.

BUSINESS & FINANCIAL RECORDS

Vendors must provide honest and accurate invoices. Invoices should be itemized, quote the PO number (where relevant), be supported by appropriate documentation and comply with all other requirements as set out in the relevant contract(s). Invoices may not be split to circumvent approval requirements.

ETHICS & INTEGRITY

Vendors are expected to act with honesty and integrity and in good faith. Vendors must abide by fair business practices, including truthful and accurate advertising.

LEGAL COMPLIANCE

Vendors must comply with all applicable laws and regulations in effect in the United States as well as in each other country in which they operate.

LABOR

Forced Labor.Vendors must not utilize or benefit in any way from forced or compulsory labor, nor utilize factories or subcontractors that force unpaid labor.

Child Labor.

No vendor will use child labor. All employees shall be age 18 and over unless (1) a country’s legal age for employment or age for completing compulsory education is under 18 and (2) the work is non‐hazardous.

Health & Safety.

Vendors are expected to provide a safe and healthy working environment that complies with local laws and minimizes occupational hazards.Collective Bargaining.Vendors should respect their workers’ rights to associate together regarding working conditions, and to join unions, form work councils and engage in labor negotiations, including collective bargaining. Vendors shall not intimidate or harass any worker who participates in such associations.

Wages.

Vendors should provide wages at least equal to the applicable legal minimum wage and any associated statutory benefits. If there is no legal minimum wage, Vendors must ensure that wages are at least comparable to those at similar companies in the local area or to prevailing industry norms. Working hours should reflect applicable legal norms and overtime hours should be paid at the legally mandated premium or at least at the same rate as regular hours worked if there is no mandated premium.

NO DISCRIMINATION

Vendors are expected to maintain a discrimination‐free workplace and to employ workers based upon on their abilities, rather than their race, color, sex, pregnancy status, gender identity, marital status, political opinions, religion, age, disability, sexual orientation, social origin, national origin or any other characteristics unrelated to an individual’s ability to perform the work required by the job.

NO HARASSMENT

Vendors are expected to treat all workers and customers with dignity and respect and to provide a work‐place with is free of harassment. Vendors must not engage in, condone, or tolerate physical, verbal, mental or sexual harassment against or among their workers.

SUSTAINABILITY

We expect vendors to operate in compliance with all applicable environmental laws and to work to minimize their use of natural resources and any negative impact their operations have on the environment. Vendors are encouraged to avoid the use of hazardous materials where possible.

CONFIDENTIALITY, PRIVACY & DATA SECURITY

Vendors must make reasonable efforts protect the proprietary information of IRT and its residents. Where vendors handle personally identifiable information on behalf of IRT, then the vendor must apply customary privacy and information security safeguards.

EMPLOYEE COMPLAINTS

Vendors are expected to maintain a system for their workers to report any concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment. If concerns are reported, vendors will investigate and take corrective action where needed.

OVERSIGHT & ACCOUNTABILITY

Vendors are expected to oversee compliance with this Vendor Code of Conduct, to communicate the expectations of this code and provide training to its workers and to allocate appropriate resources to ensure compliance with this code. IRT reserves the right to request evidence from vendors from time to time and vendors are expected to be able to demonstrate compliance with this code upon request.

REPORTING MISCONDUCT

If you encounter what you believe to be a potential violation of local laws or regulations, IRT’s Vendor Code of Conduct, or unethical behavior, you may report your concerns to IRT by emailing vendorconduct@irtliving.com. The complaint should provide sufficient information so that a reasonable investigation can be conducted. If requested, efforts will be made to keep confidential the identity of any person making a complaint, although such confidentiality cannot be guaranteed in all circumstances. Retaliation of any kind against an individual who reports concerns in good faith violates IRT’s principles and will not be tolerated.