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Adopted by Board of Trustees on December 12, 2003, and last amended on December 12, 2024

Centerspace (together with its subsidiaries and affiliates, the “Company”) is committed to conducting business in accordance with the highest ethical standards and complying with all applicable securities laws and regulations, accounting standards, accounting controls and audit practices. The Audit Committee of the Board of Trustees of Centerspace determined that it is in the best interest of the Company, and in accordance with the Sarbanes-Oxley Act of 2002 and NYSE listing standards, to establish procedures for: (a) the receipt, retention, and treatment of complaints received by the Company regarding accounting, internal accounting controls or auditing matters and (b) the confidential, anonymous submission by team members of the Company of concerns regarding questionable accounting or auditing matters.

In accordance with these requirements, the Audit Committee has adopted the following procedures:

1. The Company shall promptly forward to the Audit Committee any complaints that it has received regarding financial statement disclosures, accounting, internal accounting controls or auditing matters.  
2. Any team member of the Company may submit, on a confidential, anonymous basis if the team member so chooses, any concerns regarding financial statement disclosures, accounting, internal accounting controls, auditing matters or violations of the Company’s Code of Ethics for Senior Financial Officers or Code of Conduct. Regular business matters that do not require anonymity should continue to be directed to the appropriate supervisor, and employment-related concerns should continue to be reported through normal channels such as supervisors or the Human Resources Department. Any such concerns may be submitted by means of the Company’s independently-operated “whistleblower hotline” as detailed on Attachment 1 hereto. Alternatively, any such concerns may be set forth in writing and forwarded in a sealed envelope to the Chair of the Audit Committee, in care of the Company’s General Counsel or Secretary, in an envelope labeled with a legend such as: “To be opened by the Audit Committee only. Being submitted pursuant to the Whistleblower Policy adopted by the Audit Committee.”  If a team member would like to discuss any matter with the Audit Committee, the team member should indicate this in the submission and include a telephone number at which he or she might be contacted if the Audit Committee deems it appropriate. Any such envelopes received by the Company’s General Counsel or Secretary shall be forwarded promptly and unopened to the Chair of the Audit Committee. 
3. Following the receipt of any complaints submitted hereunder, the Audit Committee will investigate each matter so reported and take corrective and disciplinary actions, if appropriate, including termination of employment.
4. The Audit Committee may enlist team members of the Company, including the Legal Department, Human Resources Department, and risk management teams, and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints regarding financial statement disclosures, accounting, internal accounting controls, auditing matters or violations of the Company’s Code of Ethics for Senior Financial Officers or Code of Conduct. In conducting any investigation, the Audit Committee shall use reasonable efforts to protect the confidentiality and anonymity of the complainant.
5. The Company does not permit retaliation of any kind against team members for complaints submitted hereunder that are made in good faith.
6. The Audit Committee shall retain as part of the records of the Audit Committee any such complaints or concerns received for a period of no less than seven (7) years.

Non-Retaliation. Neither the Company nor any officer, trustee, employee, contractor, subcontractor or agent of the Company will discharge, demote, suspend, threaten, harass or in any manner discriminate against any associate with regard to his or her employment (a) based upon any lawful action of that employee of the type contemplated by this Policy, Section 806 or Section 1107 of the Sarbanes-Oxley Act of 2002 or Section 922(a) or Section 748 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, (b) because the employee has provided information to, or assisted in an investigation by (i) supervisory personnel of the Company, (ii) any federal regulatory or law enforcement agency or (iii) any member or committee of the Congress, regarding the activities the associate reasonably believes are a violation of federal fraud laws or any rule or regulation of the SEC, or (c) because the employee filed, testified, participated in or otherwise assisted in a proceeding that has been filed or is about to be filed relating to alleged fraudulent activities or violations of SEC rules and regulations. The Company further hereby prohibits its officers, trustees, employees, contractors, subcontractors and agents from taking any such retaliatory action. For the Company to implement this policy effectively, it is critical that all employees and other persons respond to and report any concerns of retaliatory behavior. If an employee or other person believes that he or she has been subject to retaliation because he or she has taken any of the actions referenced above, or an employee or other person is aware that any such retaliation may have been made against any other employee, the employee or other person should report such conduct to the persons designated to receive a report under this Policy or to a member of the Company’s Human Resources Department.

Attachment 1 to Whistleblower Policy

The Company’s third-party provider of Whistleblower Hotline services is Syntrio 630 Freedom Business Center, 3rd Floor King of Prussia, PA 19406.  The following methods may be used to report serious concerns and improper conduct that could have a significant impact on Centerspace, such as actions that may lead to incorrect financial reporting, are unlawful, are not in line with Company policy (including the Code of Conduct and Anti-harassment policy) or otherwise amount to serious improper conduct:

Policy Owned By: Legal

Also found in the Centerspace Policy Manual.