Doing Things the Right Way
Anti-Corruption and Anti-Trust Our Anti-Bribery & Anti-Corruption Manual applies to all Greystar’s operations in all countries and to all business lines. To reinforce our longstanding expectations around ethical conduct, Greystar has further strengthened our approach to antitrust compliance and competitive conduct. Greystar hired a dedicated Antitrust Compliance Officer in December 2025, providing formal leadership and centralized accountability. During the same month, we introduced enhanced antitrust training, which is now part of our annual corporate compliance curriculum. This training reinforces expectations for competitive behavior, information sharing, and industry engagement and will be tracked annually going forward.
Supplier Management Our 2025 plan initially centered on the phased rollout of a centralized supplier management program designed to standardize how we evaluate suppliers. While this approach helped establish common processes and a unified technology platform, we have since shifted the model to pair centralized standards with regional ownership and execution. As part of this approach, we strengthened and centralized our global Terms & Conditions in 2025, providing a consistent baseline for supplier expectations across all regions. These updates introduced strengthened expectations related to modern slavery, emerging sustainability requirements, including those connected to future Scope 3 emissions reporting, and artificial intelligence (AI) governance. Looking ahead, we are initiating a multiyear effort to develop a source to settle solution that will further support consistency while maintaining regional accountability. Currently in the design phase, this system will ultimately support the entire supplier lifecycle, with the goal to bring greater consistency between bid estimates, contract terms, invoicing, and compliance with our global Terms & Conditions, while enabling regional teams to manage supplier selection, engagement, and performance in line with local needs.
Data Privacy Data privacy and cybersecurity continue to be core priorities within Greystar’s broader corporate compliance program. In 2025, we strengthened our governance framework and advanced employee training to reinforce strong data protection practices across the organization. Each year, we look for opportunities to enhance our training programs and update them in line with recent regulatory developments. This ensures that team members remain informed and well prepared to stay ahead of emerging obligations. Looking ahead to 2026, Greystar will continue monitoring regulatory trends, strengthening controls where needed, and enhancing training and reporting practices to protect the data entrusted to us.
Responsible AI Use and Governance AI and its applications across the business are rapidly evolving, and we are actively exploring where it can create efficiencies and enhance productivity across our business lines and assets, as well as deliver value for our residents. As part of this, we have taken a proactive approach to responsible adoption. We maintain an internal review and assessment process for new AI tools before they are introduced into the Greystar environment, helping ensure alignment with our Core Values, policies, risk standards, and data protection requirements. Throughout this year, we are developing a governance structure to guide the use of AI and planning bespoke training to support our teams in using AI responsibly. These resources will be designed to build understanding of appropriate use cases, mitigate potential risks, and ensure that AI tools are applied thoughtfully and consistently across the business alongside human expertise.
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