It is the policy of Slate Grocery REIT that all activities be conducted with the highest standards of fairness, honesty and integrity and in compliance with all legal and regulatory requirements. In keeping with our commitment to best-in-class corporate governance, Slate has implemented numerous, policies and position descriptions for Slate Grocery REIT.



Code of Conduct and Ethics

Slate Grocery REIT’s Code of Conduct and Ethics (the “Code”) has been endorsed by the board of trustees of the REIT and applies to trustees, directors and officers of the REIT and Slate Asset Management LP. The objective of the Code is to provide guidelines for maintaining the integrity, reputation, honesty, objectivity and impartiality of the REIT. The Code addresses conflicts of interest, protecting the REIT’s assets, confidentiality, fair dealing with security holders, competitors and employees, insider trading, compliance with laws, and the reporting of any illegal or unethical behaviour.

Whistleblower Policy

The REIT, its subsidiaries, and Slate Asset Management L.P. have a strong commitment to the conduct of their business in a lawful and ethical manner. In line with that commitment, the REIT has adopted a Whistleblower Policy. The Whistleblower Policy outlines the process by which trustees, directors, officers, managers and employees may communicate with the REIT about concerns they may have in respect of illegal or unethical behavior and when in doubt about the best course of action in a particular situation, without retaliation.


Any employee with a good faith concern about any accounting or auditing matter or any other matter which such employee believes in violation of the Code is directed to contact the Chair of the Audit Committee of the REIT (who is independent of management of the REIT Entities) on a confidential basis.