AMERICAN TOWER CORP MA

(c)Insider Trading Arrangements and Policies

Rule 10b5-1 Plans

Olivier Puech, our Executive Vice President and President, Latin America and EMEA, entered into a pre-arranged stock trading plan on May 3, 2024. Mr. Puech’s plan provides for the sale of up to 38,982 shares of our common stock between August 2, 2024 and December 31, 2024.

Eugene M. Noel, our Executive Vice President and President, U.S. Tower Division, entered into a pre-arranged stock trading plan on May 9, 2024. Mr. Noel’s plan provides for the potential exercise of vested stock options and the associated sale of up to 33,135 shares of our common stock between August 12, 2024 and March 10, 2025.

Rodney M. Smith, our Executive Vice President, Chief Financial Officer and Treasurer, entered into a pre-arranged stock trading plan on May 13, 2024. Mr. Smith’s plan provides for the potential exercise of vested stock options and the associated sale of up to 33,135 shares of our common stock between November 14, 2024 and February 21, 2025.

Each of these trading plans was entered into during an open insider trading window and is intended to satisfy the affirmative defense of Rule 10b5-1 under the Exchange Act and our policies regarding transactions in our securities. Generally, these trading plans pre-establish the amounts, prices and dates of future purchases or sales of our stock, including shares issued upon the exercise or vesting of equity awards. Under these trading plans, the individual director or officer relinquishes control over the transactions once the trading plan is put into place. Accordingly, sales under these plans may occur at any time, including possibly before, simultaneously with, or immediately after, significant Company events.