Sincerely,

Morgan E. O’Brien

Executive Chairman

Robert H. Schwartz 
President & Chief Executive Officer

atex2022.

Director also provides performance feedback on our board'sBoard's behalf to our Executive Chairman and Chief Executive Officer. Our Board also considered that our Audit, Compensation, and Nominating and Corporate Governance Committees, which oversee critical matters such as the integrity of our financial statements, the compensation of executive officers, the selection and evaluation of directors, the development and implementation of corporate governance policies, and the oversight of our compliance with laws and regulations, each consist entirely of independent directors. Our Board intends to evaluate from time to time whether our Chief Executive Officer and Board Chairman positions should remain separate based on what our Board determines is best for the Company and its stockholders.

1.Prohibiting conflicts of interest (including protecting corporate opportunities);

2.Protecting our confidential and proprietary information and that of our customers and vendors;

3.Treating our employees, customers, suppliers, and competitors fairly;

4.Encouraging full, fair, accurate, timely, and understandable disclosure;

5.Protecting and properly using company assets;

6.Complying with laws, rules, and regulations (including insider trading laws); and

7.Encouraging the reporting of any unlawful or unethical behavior.

Any waiver of the code of business conduct for our executive officers or directors may be made only by our Audit Committee and will be promptly disclosed on our website. We have posted a copy of our code of business conduct, and intend to post amendments to this code, on our website at www.anterix.com, as permitted under SEC rules and regulations.

Anti-Harassment:

One of our top priorities is to create a culture and environment where every employee is treated with respect, free from any form of discrimination or harassment. The Company has zero-tolerance for inappropriate behavior. As part of our ongoing effort to maintain that culture, all employees must complete mandatory anti-harassment training.

Diversity, Equity, and Inclusion:

We recognize thatyear, we can thrive together when all perspectives are honored and all voices are heard. Together as Anterix, we will continue to speak out against racial injustice. Our commitment is to invest and dedicate resources to improve and leverage Diversity, Equity, and Inclusion as a key driver of differentiation and competitive success as we continue to educate and improve as an employer and collectively as employees.

Our Diversity, Equity, and Inclusion Plan includes investing in the next generation of innovative leaders through partnerships with organizations like INROADS and Talent Hue that tap diverse talent from under-represented communities, and DE&I Focused Learning through company-wide interactive Lunch ‘n Learn programs addressing inequities and promoting open discussion.

Employee Health and Safety:

As we continue to manage our business through the global coronavirus crisis proactively, we are focused on taking the right steps to protect our employees’ health and safety. We gathered resources from health experts and the CDC to develop and implement a plan. In addition to adhering to local public health authority guidelines everywhere we operate, we have established a return-to-office task force dedicated to ensuring we proactively implement the right measures to keep our employees safe.  To address the challenges of the pandemic while staying focused on our business goals, we implemented:

Mandatory Work-From-Home For Most Employees

Social Distancing At All Times – No Exceptions

Stringent Sanitizing Measures

Health Screenings & Protocol For Symptomatic Employees

Enhanced Employee Assistance Programs

Frequent Communication And Engagement Activities

Employee Benefits and Training:

We offer our employees a comprehensive and competitive benefits plan. This plan includes medical care options for our employees and their families along with life insurance, parental leave, tuition assistance, Paid Time Off, and a matched 401(k).

In addition to mandatory training on topics such as insider trading, anti-harassment, and our Code of Business Conduct, we provide (and encourage employees to partake in) optional career development, health and wellness, and employee engagement activities and training. 

Communities:

The pandemic has lessened our ability to be out in the community, but not our spirit to help our communities.  This year, at our New Jersey headquarters, we continued our partnership with our non-profit co-tenant, Circle of Care for Families and Children of Passaic County, Inc., which is dedicated to assisting Passaic County multiple-needs children and their families  For the first time, at HQ2 in Mclean VA, we initiated a community support effort in conjunction with Share of Mclean, which assists families in need, including food, clothing, furniture, and emergency funding. Through online gift portals and monetary donations, Anterix and its employees made an impact in our communities.

A Forward-Looking Governance Framework

We seek to maintain high standards of business conduct and corporate governance, which we believe are fundamental to our business’ overall success, serving our stockholders, and maintaining our integrity in the marketplace. In that regard, the Board has adopted a set of Corporate Governance Guidelines to provide a framework for our governance practices. These practices are regularly re-evaluated by the Board’s Nominating and Corporate Governance Committee in light of changing circumstances in order to continue serving the best interests of the Company and its stockholders. The Corporate Governance Guidelines address the Role of Board, Board Selection and Composition, Committee Structure, Board Meetings, including Executive Session, Assessment and Leadership Development – Management and Directors and other topics.  You can also access our Corporate Governance Guidelines, Code of Conduct, and other corporate governance materials, including our certificate of incorporation, bylaws, committee charters, and policies at anterix.com at “Governance Documents.”  You can request copies of these materials from the Assistant Corporate Secretary at the address given under “Contacting Us.”

Cybersecurity:

The cyber-threat landscape is constantly changing. We regularly report to our Board on the cost of mitigating cyber-risks as they pertain to our business goals, strategies, and risk tolerance. Additionally, it is critical that we take action to address these risks, including actively identifying and monitoring our system vulnerabilities and informing investors about material cybersecurity risks and incidents in a timely fashion. Internally, we educate staff on cyber hygiene and enforce good cyber practices. As a responsible cyber-citizen, we take seriously the risk of harm to our employees, contractors, customers, and other stakeholders from any effort to utilize our email, web presence, or other resources as a possible avenue for cyber-attack. We are vigilant in maintaining appropriate protections.

Stockholder Communications:

We proactively interactengage with our stockholders to obtainlearn their feedbackperspectives on our operations,a range of issues, including meeting with several of our large stockholders regularly. We also hosted our second Investor Day event on June 16, 2021, where our CEO, COO,company performance and CFO shared Anterix’s vision, the great progress we have made to date,strategy, corporate governance, executive compensation, and the improvements to our business model over the past several months. We also gave our investors some added insight into the momentumenvironmental, social, and governance issues. Through these interactions, we are experiencingable to better understand stockholder priorities and perspectives and receive constructive feedback. We take views and insights from our engagement with stockholders and other stakeholders into consideration as utilities learn more about the benefits of private LTE

we review and evolve our practices and disclosures and further share them with our Board as appropriate.

communicate with our Board, any Board committee, the independent directors as a group or any individual director may send communications directly to us at Anterix Inc., 3 Garret Mountain Plaza, Suite 401, Woodland Park, New Jersey 07424, Attention: Chief Legal Officer and Corporate Secretary. Other than unsolicited advertising or promotional materials, all clearly marked written communications are logged, copied, and forwarded to the director(s) to whom the communication was addressed. Please note that the foregoing communication procedure does not apply to (i) stockholder proposals pursuant to Exchange Act Rule 14a-8 and communications made in connection with such proposals or (ii) service of process or any other notice in a legal proceeding.