We at Starwood Capital Group (the “Company”) are committed to the highest standards of business conduct in our relationships with each other, with companies with which we do business and with our investor and others. This requires that we conduct our business in accordance with all applicable laws and regulations and in accordance with the highest standards of business ethics.
We have adopted a Compliance Manual (the “Manual”) to help each of us in this endeavor. Reprinted herein are excerpts from the Manual which demonstrate the fundamental principles and key policies and procedures that govern the conduct of our business (the “Code”). The full Manual covers more than just our code of conduct and conflicts of interest policies and applies to all officers, managers, managing directors, members and employees of Starwood, and to other persons (e.g., independent contractors who establish policy for Starwood or pursuant to whose advice Starwood is guided in particular areas of operation) so designated by the Chief Compliance Officer (“CCO”) or one of the Company’s Co-General Counsels (collectively “Advisory Representatives”). A copy of the complete Manual is made available to our investors upon request.