Letter from President and CEO of First Industrial Realty Trust, Inc.

First Industrial’s commitment to honesty and integrity in conducting our business is foundational to our ongoing success. As a valued vendor to First Industrial, you are an integral contributor to our business and the services and/or goods you provide to us help us serve our tenants, shareholders and other stakeholders effectively. 

First Industrial expects its vendors to embrace and share our commitment to highly ethical conduct. Consequently, we require that all vendors adhere to this Code.

Thank you for conducting your business with First Industrial in a manner consistent with our values and commitments. We look forward to a mutually beneficial relationship with you.

Peter E. Baccile

President and CEO

Index

                II             Compliance with Laws

                III            Compliance with Vendor’s Code of Conduct and Ethics and
                                Professional Standards

                IV            Human Rights and Labor Standards

                V             Integrity in Employment Practices

                VI            Integrity in Dealing with Others

                VII          Integrity in Business Practices

                VIII         Conflicts of Interest

                IX            Business Continuity and Crisis Management

                X             Environmental Sustainability Practices

                XI            Compliance with the Code

I. Introduction

This Code of Conduct and Ethics (“Code”) covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide the ethical delivery of services to First Industrial Realty Trust, Inc. (“First Industrial”) and its properties. We all must conduct ourselves with the highest ethical standards and adhere to best business practices. We must seek to avoid even the appearance of unethical behavior.

While this Code attempts to describe certain foreseeable circumstances and to state our vendor’s obligations in such circumstances, we are not able to anticipate all possibilities. Therefore, in addition to compliance with this Code and applicable laws, rules and regulations, vendor is expected to observe the highest standards of business and personal ethics in the discharge of their obligations and activities on behalf of First Industrial.

II. Compliance with Laws

Compliance with law, in letter and in spirit, is the foundation on which First Industrial’s ethical standards are built. Vendor must obey all applicable laws and regulations while conducting business with and/or on behalf of First Industrial. If a law conflicts with a policy in this Code, vendor must comply with the law.

III. Compliance with Vendor’s Code of Conduct and Ethics and Professional Standards

Vendor may have its own codes of conduct and ethics. Vendor must comply with its own code of conduct and ethics while conducting business with and/or on behalf of First Industrial. If First Industrial Code conflicts with a vendor’s code of conduct and ethics, vendor must comply with the more stringent requirement while conducting business with and/or on behalf of First Industrial. Vendor must provide services in compliance with the applicable professional standards of its industry, including requirements established by any organizations that regulate such activities. Vendor must have management systems in place to support compliance with laws, regulations, and this Code.

IV. Human Rights and Labor Standards

First Industrial expects vendor to treat people with respect and dignity, encourage diversity, protect fundamental human rights, and help create an inclusive and ethical culture.

Vendor must conduct itself in compliance with the following:

Wages and Benefits: Vendor must comply with all applicable wage and compensation requirements under applicable labor laws for regular work, overtime, maximum hours, piece rates, and other elements of compensation and employee benefits. First Industrial encourages vendor to work toward improving standards of living and quality of life for its employees and communities.

Prevention of Underage Labor: Vendor must comply with all applicable minimum age labor laws and not use child labor. Workers must be no younger than the minimum age for employment under applicable law.

Slavery and Human Trafficking: Vendor must not engage in the recruitment, transportation, or use of forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons. Vendor must ensure such activity is not engaged in or supported in any part of its supply chain.

Hazardous Labor: Vendor must ensure that neither it nor any part of its supply chain supports or engages in or requires any hazardous labor to be performed by any person under the age of 18. Hazardous labor involves any work that by its nature or the circumstances in which the work is undertaken, involves the substantial risk of harm to the safety or health of the worker or coworkers if adequate protections are not taken.

Health, Safety, and Sanitary Workplace: Vendor must provide a safe, healthy and sanitary working environment by implementing procedures and safeguards to prevent workplace hazards, and work-related accidents and injuries. This includes procedures and safeguards to prevent industry-specific workplace hazards, and work-related accidents and injuries, that are not specifically addressed in this Code and compliance with the Occupational Safety and Health Act (OSHA). General and industry-specific procedures and safeguards include those related to: health and safety inspections; equipment maintenance; maintenance of facilities; worker training regarding the hazards typically encountered in the scope of work; fire prevention; and documentation and recordkeeping. In addition, vendor must provide its workers with adequate personal protective equipment to protect workers against hazards typically encountered in the scope of the work.

V. Integrity in Employment Practices

First Industrial expects vendor to share our commitment to complying with employment-related laws and practices. We value the diversity of our employees and are committed to providing equal opportunity in all aspects of employment. We will not tolerate discrimination, harassment or retaliation.

Vendor must conduct itself in compliance with the following:

Not engage in discrimination in violation of laws, including, without limitation, in hiring, compensation, access to training, promotion, termination or retirement based on race, ancestry, color, religion, gender identity or expression, sexual orientation, marital status, national origin, age, disability, pregnancy, genetic information, citizenship, veteran status or military service obligation.

Cooperate with First Industrial’s commitment to a workforce free of unlawful harassment and discrimination.

Comply with laws regarding illegal drugs while on First Industrial’s properties.

Not retaliate against any individual for bringing a complaint of discrimination or harassment or for participating in an investigation or proceeding involving a complaint of discrimination or harassment.

Not retaliate against any person for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any federal offense.

VI. Integrity in Dealing with Others

First Industrial’s relationships with the communities in which we conduct business are critical to our success. We must deal fairly and lawfully with third parties.

Vendor must conduct itself in compliance with the following:

Communications with Government Officials: Be honest, direct and truthful in discussions with government officials and employees when conducting business on First Industrial’s behalf.

Dealing with Foreign Officials: Comply with the anti-corruption laws, including the U.S. Foreign Corrupt Practices Act. The Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business.

Relationships with Governmental Officials: Do not make illegal gifts, payments, donations or provide illegal hospitalities (including, without limitation, of food, lodging or transportation) to federal, state or municipal officials when conducting business on First Industrial’s behalf.

Fair Competition: When conducting business on First Industrial’s behalf, comply with applicable antitrust and fair competition laws. Unethical business practices such as improper exchange of competitive information, price fixing, bid rigging, or improper market allocation are prohibited. Do not make illegal gifts, payments, or donations to others on First Industrial’s behalf. We seek competitive advantage through superior performance, never through unethical or illegal business practices.

Trade Secrets of Others: Comply with all laws and regulations regarding the privacy of information and data protection.

Compliance with Legal Authorizations: Obtain all necessary licenses or permits to conduct the activities for which the vendor has been engaged by First Industrial.

VII. Integrity in Business Practices

Vendor must act with integrity and communicate honestly and openly when engaged in business interactions or activities on behalf of First Industrial.

Vendor must conduct themselves in compliance with the following:

Use of Assets: Responsibly use both the physical assets of First Industrial, including its property, supplies and equipment, when authorized by First Industrial and endeavor to protect First Industrial’s assets and ensure their efficient use. First Industrial does not condone fraud or theft. Any suspected fraud or theft should be immediately reported for investigation.

Anti‐Corruption, Anti‐Bribery, and Anti‐Money Laundering. Vendor must comply with all applicable laws relating to anti‐corruption, anti‐bribery, antimony laundering, and the prevention of fraud and other financial crimes.

Compliance with Environmental Laws: Comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste and wastewater discharges.

Insider Trading. Vendor may not, directly or indirectly, trade securities, including our securities, if in possession of material nonpublic information.

Intellectual Property: Comply with the intellectual property ownership rights of First Industrial and others including, but not limited to, copyrights, patents, trademarks and trade secrets and use software, hardware and content only in accordance with the law.

Proprietary Information: Protect First Industrial’s proprietary information. Proprietary information includes, without limitation, business, marketing and service plans, business data and trade secrets. Unauthorized use or distribution of this information may be illegal and result in civil or even criminal penalties.

Confidential Information: Safeguard all non-public information of First Industrial, First Industrial’s tenants and other third parties with which First Industrial conducts business, unless disclosure is authorized by First Industrial or legally required. Vendor should maintain the confidentiality of information entrusted to them by First Industrial or its customers or other vendors, except when disclosure is authorized by First Industrial or legally mandated. Confidential information includes all non-public information that might be of use to competitors or harmful to First Industrial or its customers, if disclosed. The obligation to preserve confidential information continues even after service to First Industrial ends.

Data Privacy: Comply with all applicable federal and state laws and regulations regarding the notification, capture, and usage of personal data gathered from First Industrial, its employees, and any of its tenants or other parties with which it does business. Implement and maintain prudent data protection practices, including, but not limited to, encryption of all confidential business data sent to outside parties on behalf of First Industrial or its affiliates.

Material Inside Information: Comply with federal securities laws when in possession of information about First Industrial or another company that is confidential and not generally available to the public

Records: Create, retain and dispose of business records and business data in full compliance with all applicable legal and regulatory requirements.

Communications with the Press; Public Communications: Do not speak to the press on First Industrial’s behalf unless specifically authorized by First Industrial. Do not make public appearance that tends to imply First Industrial representation without having obtained specific authorization in advance from First Industrial. Do not use First Industrial’s name, identity or any of logos in any marketing materials without First Industrial’s consent.

VIII. Conflicts of Interest

Vendor and its representatives must conduct its business interactions with First Industrial employees, officers and directors to avoid any conflicts of interest with any such representatives of First Industrial. Vendor must not seek to create conflicts of interest for First Industrial employees, officers and directors.

IX. Business Continuity and Crisis Management

Subject to the terms of any specific contractual provisions that apply, we expect that each First Industrial vendor will have adequate business continuity plans in place to continue to provide its services to a reasonable degree in the aftermath of any kind of operational crisis, including, without limitation, whether caused by a natural disaster, major equipment malfunction, computer systems failure, power failure, terrorist act, cyberattack, crisis, war or pandemic. Following request by First Industrial, vendor will disclose in reasonable detail and discuss the elements of its business continuity plans.

X. Environmental Sustainability Practices

First Industrial is committed to responsible environmental sustainability and energy management. We believe a healthy environment is good for business and essential to the well-being of our tenants and communities we work in.

First Industrial expects vendor to share our commitment to sustainability. We require that vendor comply with all applicable environmental laws and regulations and promoting acceptable levels of energy consumption, water use and waste management in order to reduce the environmental impacts of our business operations and those of our clients.

XI. Compliance with the Code

First Industrial does not assume any duty to monitor to ensure compliance with this Code. Vendor acknowledges that it is solely responsible for full compliance with this Code by the vendor’s directors, officers, employees, representatives, suppliers, contractors, subcontractors and other business partners. Vendor will nonetheless permit First Industrial and/or its representatives to assess vendor’s compliance with the expectations set forth in this Code when rendering services or furnishing products for First Industrial. Such assessments may include, without limitation, providing certifications of compliance, permitting on-site inspection of vendor facilities and review of related vendor information, including books, records, permits, and other documentation evidencing vendor’s compliance with this Code. Vendor will also fully cooperate with First Industrial in such assessments, and vendor will promptly correct any non-conformances identified during such assessments.

Reporting Violations of the Code

We require that vendor report inappropriate or unethical behavior (or suspected behavior) by any First Industrial employee, officer or director.

We require vendor to report any violations of this Code by any of the vendor’s directors, officers, employees, representatives, suppliers, contractors, subcontractors and other business partners.

Any vendor who believes that a violation of this Code has occurred should report it immediately to either First Industrial’s Confidential Whistleblower Hotline or First Industrial’s General Counsel.  Examples of reportable conditions include, but not be limited to, financial irregularities, kickbacks, conflicts of interests, bid rigging, human resource irregularities, fictitious business expenses, and any illegal practices. 

Communications through our Confidential Whistleblower Hotline should be directed to (866) 254-2856.

Communications to First Industrial’s General Counsel should be directed to:

First Industrial Realty Trust, Inc.

One North Wacker Drive, Suite 4200

Chicago, IL, 60606

Tel: (312) 344-4336

Email: Legal.Notices@firstindustrial.com

Attention: General Counsel

 Cooperation with Investigations

We expect that each vendor will cooperate with First Industrial in any investigation we may conduct regarding an allegation of inappropriate or unethical behavior involving either a First Industrial employee, officer or director or a violation of this Code by any of vendor’s directors, officers, employees, representatives, suppliers, contractors, subcontractors and other business partners. First Industrial will not tolerate any retribution or retaliation taken against any individual who has, in good faith, sought out advice or has reported questionable behavior or a possible violation.

No Creation of Third-Party Rights

This Code does not confer, nor will it be deemed to confer, any rights on the part of third parties, including any third-party beneficiary rights. For example, no employees of any vendor will have any rights against First Industrial by virtue of this Code, nor will such employees have any rights to cause First Industrial to enforce any provisions of this Code. The decision with respect to any such actions is reserved by First Industrial in its sole and absolute discretion.

Modifications to the Code

First Industrial reserves the right to change the requirements of this Code.

Waivers from the Requirements of the Code

Any waiver of this Code may be made only by the President and CEO and General Counsel of First Industrial.

Questions about this Code

Please direct any questions regarding this Code to First Industrial’s General Counsel.