GOVERNANCE

Our Commitment To Effective Governance

In July 2018, Crescent Communities became an independently operated investment management affiliate of Sumitomo Forestry of America, Inc. Through our integrated services of development, construction, property operations, and investment management, Crescent Communities strives to deliver strong investment performance through the cycles, capture market opportunities with innovative products, and continue our research-driven investment approach executed by locally based teams.

We provide our investors with real estate investment opportunities to meet their investment objectives, mindful of our obligations to accountability, transparency, and trust. We also aim to provide healthy and productive spaces, develop and operate assets in a manner consistent with Crescent’s tradition of responsible corporate citizenship, and oversee the management of buildings to maximize resource efficiency and environmental sustainability.

Crescent Communities adheres to governance practices that will ensure our investors’ ongoing confidence and thoughtful risk management. This involves a continual review of how legislation, guidelines, and best practices should be embodied in our approach. Representing the company, the Chairman and CEO actively participates in the National Association of Corporate Directors, an organization dedicated to identifying and fostering best practices in governance.

Crescent Communities is governed by a seven-person board which includes four representatives of Sumitomo Forestry and the company Chairman & CEO. Sumitomo Forestry of America has one representative director and a small financial and operations oversight team based at Crescent’s Charlotte headquarters. Operating authority is delegated by our Board of Directors via a clearly delineated delegation of authority policy.

Business Ethics

Our governance policies include our Crescent Code of Business Ethics. The Code of Business Ethics sets forth principles that employees must follow. It describes ethical risks for colleagues, provides guidance on how to recognize and deal with ethical issues, and explains how to report what is believed to be unethical conduct. The Code is intended to foster a culture of integrity, compliance, respect, and accountability.

This Code applies to all colleagues of Crescent Communities, its subsidiaries, and its affiliates and requires annual certification by each colleague. Please refer to the Code document for details. The Code is managed by our internal Director of Risk Management and Internal Audit. We maintain a whistleblower hotline, EthicsLine provided by InTouch, and we take measures to ensure that every colleague is aware of the existence and purpose of the hotline.

Auditing

Crescent Communities engages an independent, nationally recognized audit firm to perform an annual audit of the organization and to ensure our financial statements and operations are presented accurately and in accordance with generally accepted accounting principles of the United States. The Company’s auditors have certified that our financial reporting accurately reflects the financial position of Crescent Communities and its subsidiaries.

Risk Management

Crescent Communities has developed standards and processes for risk management across our various disciplines and product types. Our Director of Risk Management works with our insurance brokers and risk consultants to maintain proper insurance coverages for the company and our assets, as well as insurance requirements for our contractors and service professionals. Our external legal teams are also key partners in mitigating risk.

DATA SECURITY, PRIVACY, AND CONTINUITY

Data security, privacy and business continuity are top priorities at Crescent Communities. We use both internal and external resources to help minimize cyber threats. We continually audit and test our systems, our infrastructure, and our organization to ensure we are working to effectively stop cyber treats before they happen. Crescent Communities also takes privacy very seriously and we work diligently to safeguard all personal data.