This Code includes topics including but not limited to ethics: conflicts of interest; corporate opportunities: gifts, bribes and kickbacks; improper use or theft of Welltower property; maintaining accurate and complete company records; protection of Welltower, customer and vendor information; competitive information, defamation and misinterpretation; use of Welltower and third party software; fair competition and antitrust laws; securities trading; political contributions; anti-money laundering; retention of business records; a healthy and safe workplace and no harassment; waivers; and reporting possible violations. Mechanisms for advice and concerns about ethics Our Code of Business Conduct and Ethics details the mechanisms available to report concerns about unethical behavior, and other violations of the Code.