Apollo Commercial Real Estate Finance, Inc.

Climate Impact & Sustainability Data (2023, 2024-03-31)

adopted a Code of Business Conduct and Ethics and Corporate Governance Guidelines
implemented Whistle Blowing Procedures for Accounting and Auditing Matters
implemented an insider trading policy

competition for investments in our target assets
cybersecurity risks and cyber incidents
unintended consequences and market distortions from governmental intervention in the economic and financial system or from regulatory reform
loss of exclusion from registration under the 1940 Act
climate change and regulatory and other efforts to reduce potential climate change impacts and the increased focus on ESG issues

rigorous, credit-oriented evaluation of prospective investments
implemented comprehensive anti-money laundering policies and procedures
incorporate ESG considerations into the investment analysis and decision-making process, including conducting and completing environmental risk assessment for all of the properties underlying our loans
utilizing forward currency contracts to economically hedge interest and principal payments due under our loans denominated in currencies other than U.S. dollars
various actions involving intervention in the economic and financial system and regulatory reform of the oversight of financial markets
risk management and contingency plans and taken preventive measures and other precautions

Complete environmental risk assessments for all properties underlying our loans
Assess properties' sustainability by reviewing characteristics such as neighborhood walkability and transit ratings, and LEED and ENERGY STAR certifications
Median walkability and transit score for properties underlying U.S. loan portfolio were 91 and 86, respectively, based upon information provided by a leading third-party provider

Apollo's commitment to diversity and inclusion is reinforced throughout multiple firmwide initiatives including training, the Apollo Women Empower (AWE) initiative, which focuses on attracting, retaining, training and promoting women, and the Apollo Veterans Initiative, which champions and supports the hiring and retention of veterans
Apollo launched the Apollo Opportunity Foundation in 2022 with a commitment to invest more than $100 million over the next decade in non-profit organizations working to expand opportunity for underrepresented individuals

ARI’s Board of Directors and Management team are committed to operate our business at the highest level of ethical conduct
We regularly review and update, as appropriate, our policies governing ethical conduct and responsible behavior in order to support our continued success
Separate CEO and Chairman roles
Board is majority independent and strives for diversity