BLACKSTONE MORTGAGE TRUST, INC.

Cybersecurity Risk Management and Strategy

As an externally managed company, our day-to-day operations are managed by our Manager and our executive officers

under the oversight of our board of directors. Our executive officers are senior Blackstone Real Estate professionals and

our Manager is a subsidiary of Blackstone. As such, we are reliant on Blackstone for assessing, identifying and managing

material risks to our business from cybersecurity threats. Below are details Blackstone has provided to us regarding its

cybersecurity program that are relevant to us.

Blackstone maintains a comprehensive cybersecurity program, including policies and procedures designed to protect its

systems, operations, and the data utilized and entrusted to it, including by us, from anticipated threats or hazards.

Blackstone utilizes a variety of protective measures as a part of its cybersecurity program. These measures include, where

appropriate, physical and digital access controls, patch management, identity verification and mobile device management

software, new hire and annual employee cybersecurity awareness and best practices training programs, security baselines

and tools to report anomalous activity, and monitoring of data usage, hardware and software.

Blackstone tests its cybersecurity defenses regularly through automated and manual vulnerability scanning, to identify and

remediate critical vulnerabilities. In addition, it conducts annual “white hat” penetration tests to validate its security

posture. Blackstone internally reviews its cybersecurity program and conducts a third-party review every two to three years

to evaluate its effectiveness in part by considering industry standards and established frameworks, such as the National

Institute of Standards and Technology and Center for Internet Security, as guidelines. Further, Blackstone engages in

cybersecurity incident tabletop exercises and scenario planning exercises involving hypothetical cybersecurity incidents to

test its cybersecurity incident response processes. Blackstone’s Chief Security Officer, or CSO, and members of

Blackstone’s senior management, Legal and Compliance, Technology and Innovations, or BXTI, and Global Corporate

Affairs participate in these exercises. Learnings from these tabletop exercises and any cybersecurity events Blackstone

experiences are reviewed, discussed, and incorporated into its cybersecurity incident response processes, as appropriate.

In addition to Blackstone’s internal exercises to test aspects of its cybersecurity program, Blackstone periodically engages

independent third parties to analyze data on the interactions of users of Blackstone information technology resources,

including Blackstone employees, and conduct penetration tests and scanning exercises to assess the performance of

Blackstone’s cybersecurity systems and processes.

Blackstone has a comprehensive Security Incident Response Plan, the IRP, designed to inform the proper escalation

(including, as appropriate, to our executive officers and other representatives of our Manager or its affiliates) of non-

routine suspected or confirmed information security or cybersecurity events based on the expected risk an event presents.

As appropriate, a Security Incident Response Team composed of individuals from several internal technical and managerial

functions may be formed to investigate and remediate the event and determine the extent of external advisor support

required, including from external counsel, forensic investigators, and/or law enforcement. The IRP sets out ongoing

monitoring or remediation actions to be taken after resolution of an incident. The IRP is reviewed at least annually by

members of BXTI and Legal and Compliance.

Blackstone maintains a formal cybersecurity risk management process and cybersecurity risk register, designed to identify,

track and treat cybersecurity risks at the firm, and integrates these processes into the firm’s overall risk management

practices described above. Blackstone’s CSO periodically discusses and reviews cybersecurity risks and related mitigants

with its enterprise risk committee and incorporates relevant cybersecurity risk updates and metrics in the semi-annual

enterprise-wide risk management report.

Blackstone has a process designed to assess the cybersecurity risks associated with the engagement of third-party vendors,

including those of companies externally managed by Blackstone. This assessment is conducted on the basis of, among

other factors, the types of services provided and the extent and type of Blackstone data accessed or processed by a third-

party vendor. On the basis of its preliminary risk assessment of a third-party vendor, Blackstone may conduct further

cybersecurity reviews or request remediation of, or contractual protections related to, any actual or potential identified

cybersecurity risks. In addition, where appropriate, Blackstone seeks to include in its contractual arrangements with certain

of its third-party vendors provisions addressing its requirements and industry best practices with respect to data and

cybersecurity, as well as the right to assess, monitor, audit and test such vendors’ cybersecurity programs and practices.

Blackstone also utilizes a number of digital controls, which are reviewed at least annually, to monitor and manage third-

party access to its internal systems and data. For a discussion of how risks from cybersecurity threats affect our business,

and our reliance on Blackstone in managing these risks, see “Part 1. Item 1A. Risk Factors —Risks Related to Our

Company —Cybersecurity risks and data security incidents could result in the loss of data, interruptions in our business,

damage to our reputation, and subject us to regulatory actions, increased costs and financial losses, each of which could

have a material adverse effect on our business and results of operations” in this Annual Report on Form 10-K.

Cybersecurity Governance

Blackstone has a dedicated cybersecurity team, led by Blackstone’s CSO, who works closely with Blackstone senior

management, including Blackstone’s Chief Technology Officer, or CTO, to develop and advance the firm’s cybersecurity

program and strategy, which applies to us.

Blackstone’s CSO and CTO have extensive experience in cybersecurity and technology, respectively. Blackstone’s CSO is

a Senior Managing Director in BXTI and is responsible for all aspects of cyber and physical security across Blackstone. He

has over 25 years of information security, technology and engineering experience, including having previously led the

international security organization at a large credit bureau.

Blackstone’s CTO is a Senior Managing Director and the head of BXTI. Our CTO has over 24 years of information

security, technology and engineering experience, including having previously served as the Chief Technology and Chief

Innovation Officer at a large financial institution. Our CTO is responsible for all aspects of technology across Blackstone,

advises Blackstone’s investment teams and acts as a resource to Blackstone portfolio companies, and externally managed

companies, such as us, on technology-related matters.

BXTI conducts periodic cybersecurity risk assessments, including assessments or audits of third-party vendors, and assists

with the management and mitigation of identified cybersecurity risks. The CSO and CTO are responsible for the review of

Blackstone’s cybersecurity framework annually as well as on an event-driven basis as necessary. The CSO and CTO also

review the scope of Blackstone’s cybersecurity measures periodically, including in the event of a change in business

practices that may implicate the security or integrity of Blackstone’s information and systems.

Our board of directors is responsible for understanding the primary risks to our business. The audit committee of our board

of directors is responsible for reviewing our and our Manager’s IT security controls with management and evaluating the

adequacy of our and our Manager’s IT security program, compliance and controls with management.

Blackstone’s CSO reports to both ourexecutive officers as well as our board of directors and/or the audit committee

annually on cybersecurity matters, including risks facing us and our Manager and, as applicable, certain incidents. In

addition to such annual reports, our board of directors and/or audit committee receive periodic updates from Blackstone on

the primary cybersecurity risks facing us and our Manager and the measures we and our Manager are taking to mitigate

such risks, as well as on changes to our and our Manager’s cybersecurity risk profile or certain newly identified risks.