Simon Sustainability Report 2019

GRI 102: Organizational Profile, continued

GRI 102: Governance

Disclosure Number

Disclosure Title

2018 Response

Disclosure Number

Disclosure Title

2018 Response

We work with hundreds of suppliers including construction contractors, engineering consultants, and service providers. We have a broad supply chain that consists of all materials and services needed to provide space, power infrastructure, as well as heating and cooling to our tenants. Examples of categories of our service providers include security personnel, janitorial services, and waste management companies. We expect high standards of ethics and environmental compliance from all our suppliers.

Governance structure and its composition

102-18

Simon 2019 Proxy section Corporate Governance of the company p. 7

102-19

Delegating authority

Simon 2019 Proxy section Corporate Governance of the company p. 7

102-9

Supply chain

Composition of the highest governance body and its committees

102-22

Simon 2019 Proxy section Corporate Governance of the company p. 7

We are committed to ensuring that our suppliers maintain high standards of ethics and environmental compliance.

Chair of the highest governance body

Significant changes to the organization and its supply chain

102-23

Simon 2019 Proxy section Corporate Governance of the company p. 7

102-10

No significant changes have been made to Simon's supply chain in 2018.

While conducting business, Simon meets or exceeds all applicable local, regional, and federal laws and regulations. Additionally, it is our ambition to reduce or to avoid negative impacts on the environment. Social and environmental considerations are incorporated into our design and development processes. We seek cost-effective measures to prevent environmental degradation. For example, over the last years Simon has expended approximately $70 million for LED lighting replacements that significantly improve energy efficiency across the portfolio. This amount excludes LEDs that are deployed as part of ground up and redevelopment projects.

Nominating and selecting the highest governance body

102-24

Simon 2019 Proxy section Corporate Governance of the company p. 9

Precautionary principle or approach

102-11

102-25

Conflicts of interest

Simon 2019 Proxy section Corporate Governance of the company p. 7

Role of highest governance body in setting purpose, values, and strategy

102-26

Sustainability Governance

Simon participates in CDP climate change questionnaire and the Global Real Estate Sustainability Benchmark (GRESB).

102-12

External initiatives

Collective knowledge of highest governance body

102-27

Sustainability Governance

• Business Round Table (BRT): Simon is a member of BRT and has made public presentations on various sustainability topics such as the benefits of PACE. • Real Estate Round Table (RER): As a member of RER, Simon is leading the discussion in proposing changes to the CBECS process to help ensure a more robust data collection effort. Simon supported efforts to make Section 179D of the Internal Revenue Code tax incentive usable for a broader range of real estate owners and other stakeholders. • International Council of Shopping Centers: Michael McCarty, EVP Development of Operations is on the Board of Trustees and Directors. • Member of National Association of Real Estate Investment Trusts (NAREIT) and Sustainability Policy Advisory Committee of the Real Estate Round Table.

Review of economic, environmental, and social topics

102-31

Sustainability Governance

Membership of associations

102-13

Highest governance body’s role in sustainability reporting

102-32

Sustainability Governance

GRI 102: Stakeholder Engagement

GRI 102: Strategy

Disclosure Number

Disclosure Title

2018 Response

Disclosure Number

Disclosure Title

2018 Response

102-40

List of stakeholder groups

Stakeholder Engagement

Statement from senior decision-maker

102-14

A Message From Our CEO

There are no collective bargaining agreements in place.

102-41

Collective bargaining agreements

Key impacts, risks, and opportunities

102-15

Simon CDP Response 2018

Identifying and selecting stakeholders

102-42

Stakeholder Engagement

Approach to stakeholder engagement

102-43

Stakeholder Engagement

GRI 102: Ethics and Integrity

102-44

Key topics and concerns raised

Stakeholder Engagement and Materiality Assessment

Disclosure Number

Disclosure Title

2018 Response

Simon's Code of Business Conduct can be found on Simon's Investor Relations Governance page titled Code of Business Conduct & Ethics at investors.simon.com/ code-business-conduct-ethics.

Values, principles, standards, and norms of behavior

102-16

Simon company values can be found at business.simon.com/about.

| SIMON PROPERTY GROUP, INC.

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SUSTAINABILITY REPORT 2019 |