• Ongoing review of GEO Continuum of Care®
• Ongoing review of in-custody rehabilitation programs
• Ongoing review of reentry services and programs
• Ongoing review of post-release support services
• Ongoing review of demographic information for in-custody programming & post-release

• Annual review of Corporate Responsibility Report
• Ongoing review of initiatives
• Ongoing review of GEO’s engagement with investors and external stakeholders
• Ongoing review of GEO’s workforce demographic information

• Ongoing review of GEO’s health services operations, in the U.S. and internationally
• Ongoing review of health services key performance indicators
• Ongoing review of patient demographic information

Ongoing review of GEO’s cybersecurity capabilities and privacy practices, periodic review of
potential cyber vulnerabilities and remediation measures, if needed

Risk management of cybersecurity threats

Ongoing review and evaluation of GEO’s environmental sustainability initiatives

• Periodic review of GEO's Security Services
• Periodic review of GEO's contract compliance and quality control program
• Annual review of GEO's Prison Rape Elimination Act Report

Corporate Governance

• Annual recommendation of Board nominees
• Periodic review of GEO’s bylaws
• Periodic review of GEO’s Code of Business Conduct and Ethics
• Periodic review of corporate governance guidelines

Political Contributions and Lobbying Expenditures

• Annual review of GEO’s Political Activities and Contributions Policy
• Annual review of GEO’s Political Activity and Lobbying Report
• Annual review of GEO’s political contributions and lobbying expenditures

GEO’s Global Human Rights Policy was adopted to further the company’s long-standing commitment to the protection of the human rights of all persons in our care. The principles enunciated in the policy were informed by the Universal Declaration on Human Rights and the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

In 2022, GEO conducted a Human Rights Due Diligence Assessment [HYPERLINK TO PDF]

GEO’s Whistleblower Program includes a strict Anti-Retaliation Policy that states GEO’s zero tolerance for retaliation against any employee who in good faith raises a concern or reports a violation or suspected violation of our Code of Business Conduct and Ethics, policies, or employee handbook. GEO also does not tolerate retaliation against any employee who provides information or assists a government or law enforcement agency regarding a violation of law, or files, testifies, or participates in a legal proceeding relating to a violation of law.

GEO’s EEO Policy states our commitment to being an equal opportunity employer and to prohibiting discrimination against employees, applicants for employment, or any individuals providing services to GEO in the workplace under any category protected by federal, state, or local law.

The policy also states our commitment to ensuring
that qualified individuals with disabilities under the Americans with Disabilities Act as Amended and other applicable laws are afforded a reasonable accommodation for their disability.

GEO’s Staff Misconduct Policy details procedures for the reporting and investigation of staff misconduct. GEO’s policy is to thoroughly investigate all allegations of staff misconduct. The Office of Professional Responsibility (OPR), at the direction of GEO’s General Counsel, serves as the central point of contact, so that employees,

GEO contractors, and other interested third parties have one location to report instances of misconduct. Every employee/contractor shall be able to report staff misconduct without fear of reprisal or retaliation.

GEO’s Code of Business Conduct and Ethics (Code) is publicly available and is also available to our employees in local languages, such as Spanish. Specific sections of the Code articulate the company’s policies and guidelines with respect to compliance with anti-bribery and anti-corruption laws, government contracting, health and safety, conflicts of interest, accurate record-keeping, confidentiality, improper gifts, political contributions, anti-discrimination and anti-sexual harassment, reporting illegal and unethical behavior, and senior leadership roles and responsibilities for meeting disclosure and accounting requirements set by the U.S. Securities and Exchange Commission.

• Audit & Finance Committee Charter  
• Compensation Committee Charter
• Corporate Governance Guidelines
• Cyber Security & Environmental Oversight Committee Charter
• Nominating & Corporate Governance Committee Charter
• Legal Steering Committee Charter
• Whistleblower Policy