Simon Sustainability Report 2020-2021

GRI 205: ANTI-CORRUPTION

Disclosure number

Disclosure title

2020 Response

103-1

Explanation of the material topic and its boundary The management approach and its components Evaluation of the management approach Operations assessed for risks related to corruption

Materiality Assessment

103-2

Can be found on Simon's Investor Relations Governance page titled Code of Business Conduct & Ethics at investors.simon.com/code-business-conduct-ethics. Can be found on Simon's Investor Relations Governance page titled Code of Business Conduct & Ethics at investors.simon.com/code-business-conduct-ethics. Simon regularly reviews its business operations and market conditions across the company’s portfolio to assess the various risk factors that may adversely affect our business including risks relating to retail operations, real estate investments and operations, risks related to debt and the financial markets, risks relating to income taxes, risks relating to joint ventures, and risks relating to environmental matters. These risk factors, including corruption-related items are reported annually as part of our SEC filing. Please refer to our 10-K filing. Additionally, Simon’s Audit Services completes an annual corporate risk assessment by engaging with internal departments, key executives, and external organizations. The discussions confirm or revise existing risk definitions as well as identify and define new risks. Additionally, the information gathered allows us to rank each risk based on its Significance to Simon and Management Preparedness. In the overall risk assessments corruption is included as a risk factor. Upon completion of risk assessment, a report is presented to the Audit Committee of the Company’s Board of Directors for review. Further, Simon’s Audit Services assesses corruption-related risks and the mitigating controls during the execution of its annual audit plan (based on the completed risk assessment). Simon is committed to the highest standards of business and professional conduct. We have designed our Code of Business Conduct to reflect the values that define the Company and the principles that guide us to avoid circumstances that may give rise to even an appearance of impropriety. The Code of Business Conduct can be found at investors.simon.com/code-business- conduct-ethics. We ensure that this Code is communicated to all directors, officers, employees, and if applicable, to business partners. All employees sign the Code and we use mandatory trainings to ensure that all employees have the guidance they need to apply the standards in their daily decision making and actions on behalf of Simon. Each employee is personally responsible for making sure that our business decisions and actions comply with this Code. The General Counsel is responsible for interpreting and making enforcement decisions regarding this Code. We maintain a confidential and anonymous 24-hours-a-day hotline that can be called in case of questions.

103-3

205-1

205-2

Communication and training about anti-corruption policies and procedures

205-3

Confirmed incidents of corruption and actions taken

Review our SEC filings for detailed reporting on Corruption, Ethics, and Compliance issues.

SIMON SUSTAINABILITY REPORT 2020-2021 | 55