CODE OF ETHICS The success of our business depends on the trust and confidence we earn from our employees, members, and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals through honorable conduct and living WeWork’s mission and values.

This code is designed to help officers, directors, and employees (collectively, “employees”) make the right choices by outlining how WeWork conducts business. If you ever have questions about this code or suspect that this code is being violated, you should contact your manager, the Legal Department at compliance@wework.com, or the ethics helpline at wework.ethicspoint.com or +1-646-604-9588. You will never be penalized for reporting a possible ethics concern in good faith.

WeWork’s mission is to create a world where people work to make a life, not just a living.

Our Values

Inspired We do what we love and are connected to something greater than ourselves.

Entrepreneurial We are creators, leaders, and self-starters. We try new things, we challenge convention, and we’re not afraid to fail.

Authentic We are genuine to our brand, mission, and values. We’re not perfect, and we don’t pretend to be. We are, though, always honest and as transparent as we can be.

Tenacious We never settle. We get stuff done and we get it done well. Be persistent and knock down walls—literally if you have to. You have our permission.

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Grateful We are grateful for each other, for our members, and to be part of this movement. We don’t take success for granted. We’re happy to be alive.

Together We are in this together. This is a team effort. We always look out for one another. We have empathy, we know we’re all human, and we know we can’t do any of this alone.

Underscoring our values is our aim to be ethical in our work and to strive for excellence while doing business in the right way. When considering an action, ask: does this adhere to our core values and build WeWork’s reputation? Will it help create a working environment in which WeWork can succeed over the long term? To maximize our ability to succeed and become a true and credible community of creators, we must always answer “yes” to those questions, and work and act in ways that conform to our core values at all times.

Upholding the Law Our integrity begins with complying with laws, rules, and regulations applicable to WeWork wherever we do business. You are required to comply with these laws, rules, and regulations. Further, you are required to have an understanding of company policies and procedures that apply specifically to you, including this code.

Violations of laws, rules, and regulations may subject both you and WeWork to criminal or civil liability. If you are unsure of whether an action is permitted by law or WeWork policy, you should seek the advice of your manager and/or our Legal Department by contacting compliance@wework.com or contact the helpline at wework.ethicspoint.com or +1-646-604-9588.

Open and Honest Communication At WeWork, we are committed to fostering an open environment where everyone feels comfortable speaking his or her mind, especially with respect to ethics concerns. Whether you have a question about any of our policies or programs, or a concern about a decision affecting your job or a possible violation of this code, you should make yourself heard so that your question or concern may be addressed and appropriate steps are taken toward a resolution. WeWork expects its employees to report improper conduct if and promptly after they become aware of it.

You may share your concerns with your manager and/or the Legal Department by contacting compliance@wework.com. WeWork also has an ethics helpline (wework.ethicspoint.com or +1-646-604-9588) where you can share your concerns anonymously if you prefer. In return for your open and honest communication, WeWork is committed to non-retaliation. In our community of trust and respect, retaliating against someone who has made a good-faith report or participated in an investigation is not tolerated.

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Respect for the Individual WeWork believes that we all deserve to work in an environment where we are treated with dignity and respect. We are committed to creating this environment because it brings out the full potential in each of us, contributing to our collective success.

WeWork is an equal employment / affirmative action employer and is committed to providing a workplace free of discrimination and abusive, offensive, or harassing behavior. WeWork does not engage in, and will not tolerate, discrimination or harassment against any employee or candidate for employment because of race, color, national origin, gender, sexual orientation, religion, age, creed, ancestry, veteran status, marital status, disability, or any other protected class category covered under applicable laws. Any employee who feels harassed or unfairly discriminated against should report the incident to his or her manager and/or to Human Resources at HR@wework.com.

Tone at the Top A company’s culture begins with the tone at the top. In any business, ethical behavior does not simply happen, but is the result of our collective behavior. Each manager has the responsibility to demonstrate the importance of this code through his or her actions. Managers must promptly address ethical questions and concerns raised by employees and take appropriate steps to deal with such issues. At WeWork, managers should not consider employees’ ethics concerns as threats or challenges to their authority, but as an encouraged form of professional communication.

Conflicts of Interest WeWork expects that employees will perform their duties conscientiously, honestly, and in a manner consistent with the best interests of the company. Employees must not exploit their position for personal gain by giving, offering, or promising anything of value to, or soliciting or accepting anything of value from, a customer, supplier, or competitor of the company. For example, it would be inappropriate to accept a personal gift or compensation from a vendor that provides services to WeWork.

Furthermore, employees should refrain from activities, investments, and associations that compete, directly or indirectly, with the company. For example, employees must not enter into investments involving a competitor or potential competitor of WeWork.

Insider Trading An exciting part of being a WeWork employee is that you may learn things about our company or other companies, such as suppliers or members, before the general public does. However, if your position at WeWork has resulted in you receiving non-public information about a public company that may be significant in making a decision to buy or sell securities, you are prohibited by law and company policy from executing such a transaction on the basis of that information, as well as from communicating such information to others who might trade based on the information.

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Corporate Opportunities Employees owe a duty to WeWork to advance its legitimate interests in a legal and ethical manner when the opportunity arises. WeWork employees are prohibited from (a) taking for themselves personally, or for their family members, opportunities that are discovered through the use of WeWork property, information, or their WeWork position; (b) using WeWork property, information, or their WeWork position for personal gain or for the gain of their family members; and (c) competing with WeWork.

Outside Activities, Employment, and Directorships All WeWork employees share a serious responsibility for our good public relations — especially at the community level — within our WeWork member communities and the ones in which we all live. Their readiness to help with religious, charitable, educational, and civic activities brings credit to WeWork and is encouraged. However, these outside activities must not create an excessive demand upon employees’ time and attention such that they prevent them from fulfilling job-related responsibilities. In addition, employees must not engage in outside activities that compete, directly or indirectly, with WeWork’s business. For example, employees should not enter into an employment relationship with, or otherwise provide services to, a company that competes with WeWork or start a new enterprise that competes with WeWork, while employed by WeWork.

Antitrust, Fair Dealing, and Competition WeWork believes in fair, ethical, and vigorous competition. We will operate based on the merit, superior quality, functionality, and competitive pricing of WeWork services — from our spaces and services to additional products that we may introduce. We will always comply with applicable antitrust and competition laws (including those which relate to price discrimination, price fixing, restraint of trade, and monopolies) throughout the world. Each employee should endeavor to deal fairly with WeWork’s members, suppliers, competitors, and other employees. Employees must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practices.

Government Contracting WeWork strictly observes the laws, rules, and regulations that govern the acquisition of goods and services by any governmental entity of any country and the performance of government contracts. These laws often prohibit or strictly limit offering gifts, entertainment, and travel to government officials. They also often apply to hiring current or recently retired government officials or members of their families, and to any conduct that may be viewed as improperly influencing objective decision-making by the government. WeWork employees who deal with any governmental agency, including international organizations, are responsible for learning and complying with all rules that apply to government contracting and interactions with government officials and employees. Employees must avoid any activity that either is or appears to be illegal or unethical.

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Bribes and Other Improper Payments WeWork is committed to operating and competing on the merit of our work, products, and services. All employees are prohibited from offering, promising, giving, soliciting, authorizing, or receiving a bribe, kickback, or any other improper payment. A bribe, for purposes of this Code, can be anything of tangible or intangible value, including cash, cash equivalents, gifts, travel, entertainment, charitable contributions, or employment, that is provided to a government official or commercial party with the intent to influence that person’s judgment to obtain or retain a favorable business outcome. WeWork may not make improper payments directly or through any third party, such as a landlord, contractor, consultant, architect, engineer, broker, member, or other third party that might act on WeWork’s behalf.

Be sure to review WeWork’s Global Anti-Corruption Policy for more details and to contact your manager, the Legal Department at compliance@wework.com, or the ethics helpline (wework.ethicspoint.com or +1-646-604-9588) with any questions concerning that policy.

Gifts and Business Courtesies All employees should avoid any actions that create the perception that favoritism was applied to outside entities based on the exchange of gifts, gratuities, or personal courtesies. The use of company funds or assets for gifts, gratuities, or other favors to government officials or other commercial parties is prohibited, except to the extent that such gifts, gratuities, or other favors are in compliance with applicable law as preapproved in writing by the Legal Department, insignificant in value and amount, and not given in consideration of any reciprocal action by the recipient. WeWork and its employees must never give or accept courtesies that constitute or could be reasonably perceived as constituting unfair business inducements that would violate laws, regulations, or policies of WeWork or that reflect negatively on WeWork’s reputation.

Anti-Money Laundering WeWork is committed to complying with all applicable anti-money laundering laws. Money is “laundered” to conceal related criminal activity, such as drug trafficking, terrorist activity, or illegal tax avoidance so that the funds can be used freely. We will never knowingly participate in a scheme to launder money, under-report the size of cash transactions, or wrongfully avoid tax liability. Furthermore, we will make reasonable efforts to become familiar with our members in order to reduce the chance that we will be unknowingly used to assist in money laundering. WeWork will not tolerate “willful ignorance” of money laundering. If you observe any transaction that looks suspicious, report it to your manager, the Legal Department at compliance@wework.com, or the ethics helpline (wework.ethicspoint.com or +1-646-604-9588).

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Trade Restrictions and Anti-Boycott Laws WeWork will comply with all export control, economic sanctions, and customs laws that regulate cross-border transfers of goods and technology. WeWork will also comply with all anti-boycott laws, which prohibit us from participating in boycotts that have not been sanctioned by the U.S. government. We will not engage in business with any government, entity, organization, or individual, or within any country, where doing so is prohibited by applicable laws. If you are unsure whether we may legally conduct business with a government, entity, organization, or individual, or within a certain country, please consult the Legal Department at compliance@wework.com.

Political Contributions WeWork employees must comply with all local, state, federal, and other applicable laws, rules, and regulations regarding political contributions. WeWork funds and assets must not be used for, or be contributed to, political campaigns, political parties, or political action committees without prior written approval from the Legal Department at compliance@wework.com.

Financial Integrity, Records, and Accounting WeWork’s books, records, accounts, and financial statements must be maintained in accordance with all applicable regulations and standards and in appropriate detail so that they properly reflect the company’s business activities. Employees must honestly, timely, and accurately report all business transactions. Financial statements must conform to generally accepted accounting rules and the company’s accounting policies.

Accurate information is essential to WeWork’s ability to meet legal and regulatory obligations. No undisclosed or unrecorded account or fund will be established for any purpose. No false or misleading entries will be made in WeWork’s books or records for any reason, and no disbursement of company funds or other company property will be made without adequate supporting documentation.

Employees with concerns regarding questionable accounting or auditing matters or complaints regarding accounting, internal accounting controls, or auditing matters may confidentially, and anonymously if they wish, submit such concerns or complaints to the Legal Department at compliance@wework.com or the ethics helpline (wework.ethicspoint.com or +1-646-604-9588). These concerns and complaints will be forwarded to the Audit Committee, unless they are determined by the Legal Department to be without merit. The Audit Committee will receive a record of all complaints and concerns received each fiscal quarter. The Audit Committee will evaluate the merits of any concerns and complaints received and authorize any necessary follow-up actions to address these concerns or complaints. WeWork will do its best to protect an individual’s identity when he or she raises a complaint or concern; however, the investigation process may reveal the source of the information and a statement by the individual may be required as part of the

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evidence. WeWork will not discipline, discriminate against, or retaliate against any employee who reports a complaint or concern in good faith.

Dealing with Independent Auditors WeWork employees will not make or cause to be made, directly or indirectly, false or misleading statements to an accountant in connection with any audit, review, or examination of the company’s financial statements or the preparation or filing of any document or report with the U.S. Securities and Exchange Commission or any other government entity. This includes omissions of material facts. In addition, no employee will, directly or indirectly, take any action to coerce, manipulate, mislead, or fraudulently influence any independent public or certified public accountant engaged in the performance of an audit or review of the company’s financial statements.

Confidential Information WeWork’s business success depends on our protection of confidential and proprietary company information, including non-public information entrusted to us by employees, members, and other business partners. WeWork is committed to maintaining the privacy and security of all personal information as required under applicable data privacy laws. WeWork and its employees will not disclose confidential and non-public information without a valid business purpose and proper authorization, except when disclosure is legally permitted or required. Additionally, employees should take appropriate precautions to ensure that confidential or sensitive business and personal information, whether it is proprietary to WeWork, WeWork employees, members, or another company, is not communicated within the company except to employees who have a need to know such information to perform their responsibilities. WeWork will take all reasonable measures to protect confidential information from unauthorized access or disclosure. Proprietary Information Every employee at WeWork must respect property rights — our own as well as those of others. All employees must honor the property rights and non-disclosure policies of the company. We do not engage in unauthorized use, copying, distribution, or alteration of software or other intellectual property.

Protection and Proper Use of WeWork’s Assets WeWork’s employees must protect company assets and ensure that they are used efficiently and for legitimate business purposes of WeWork. Any unauthorized use or distribution of WeWork assets is a violation of this Code. These assets include, but are not limited to, intellectual property; strategic, operational, business, and marketing plans; engineering ideas; designs; salary and other compensation information; and all unpublished financial data of WeWork.

WeWork also trusts its employees with a wide range of technology and other tools that make it possible to do their jobs effectively, and these tools must be used wisely. Each employee is responsible for the company-issued computer equipment

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he or she is assigned. An employee should immediately notify his or her supervisor of any loss or theft of computer equipment. If computer equipment is damaged, it should be reported immediately to the Information Technology Service Desk at hqit@wework.com. WeWork expects all employees to use company-provided equipment with care and to take all reasonable precautions to prevent theft, loss, breakage, or damage.

Interacting with the Media and Social Media WeWork is a high-profile company in our community, and, from time to time, members of the media may approach our employees. In order to ensure that we speak with one voice and provide accurate information, all media inquiries must be directed to press@wework.com without exception. This includes casual information requests from social media as well as traditional media outlets.

WeWork expects you to comply with all applicable laws, government guidelines, this Code and WeWork policies when using social media. When you use social media, you represent WeWork’s brand and are a keeper of our reputation. WeWork will not tolerate inappropriate conduct, sharing of confidential information, harassment, or fraud on any platform or by any medium.

Waivers of This Code WeWork expects all employees to strictly adhere to the policies contained in this Code. However, there may be cases where exceptions may be appropriate. In such cases, waivers may be granted only by WeWork’s Board of Directors and records of such requests and their determinations will be maintained by WeWork’s Legal Department. Any waiver of this Code for executive officers or directors or any change to this Code that applies to executive officers or directors may be made only by WeWork’s Board of Directors, and will be disclosed as required by law or regulation.

Investigations and Discipline WeWork is committed to upholding this Code. WeWork expects its employees to report improper conduct if and promptly after they become aware of it. Reports of any possible violations of this code will be investigated in a professional manner as promptly as possible.

Nothing in this code or otherwise prohibits you from reporting potential illegal activities to any government agency or entity, or making other disclosures that are protected under the whistleblower provisions of applicable laws. You do not need prior approval from the Legal Department or anyone else at WeWork to make any such reports or disclosures, and you are not required to notify us that you have made such reports or disclosure.

If you are asked to cooperate with an investigation, you are required to do so. Consequences for violating this code or other company policies or obstructing an investigation of violations may include, but are not limited to, warning, reprimand,

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probation, or suspension without pay, demotion, reduction in salary, termination, and restitution.

Dissemination and Amendment This code will be distributed to each new employee upon commencement of his or her employment and will also be redistributed electronically on an annual basis to each employee. The company reserves the right to amend, alter, or terminate this code at any time for any reason. The most current version of this code can be obtained by contacting Human Resources at HR@wework.com.

Inconsistencies with Your Employment Agreement or Non-Disclosure Agreements To the extent any of these provisions conflict with or are inconsistent with either the terms of: (A) your employment agreement or offer letter; or (B) your restrictive covenants agreement (that is, the agreement that you signed regarding invention and intellectual property assignment, non-disclosure and confidentiality and non-competition and/or non-solicitation), the terms of that agreement would apply.

Information and Resources If you have any questions regarding this Code of Ethics, please contact compliance@wework.com or:

• Emily Meyers, Senior Counsel, Compliance (+1-646-604-9588) • Douglas Curtis, Deputy General Counsel, Head of Legal Operations

(+1-646-603-3808)