Compliance at LEG
"LEG Immobilien SE has set itself the goal of being a successful provider of good housing at fair prices. Fairness is therefore an essential part of our self-image. This includes abiding by rules. Compliance is therefore an important pillar of our business activities - for LEG as a whole, but also for each individual. By compliance, we understand the legally and ethically impeccable conduct of our employees in their business environment. Compliance creates trust, reduces liability risks and is a prerequisite for longterm, sustainable growth and the reputation of our company. We do not tolerate any violations of the law or of internal guidelines and regulations and ensure that our compliance rules are adhered to through a corporate culture in which values such as integrity, professionalism, trust and sustainability are communicated and lived.“
– Lars von Lackum, Chief Executive Officer of LEG Immobilien SE (CEO)
Declaration of fundamental values
Our Declaration of Basic Values sets out our company's purpose and strategy, as well as the values that form the basis of our dealings with customers, employees, investors, business partners and society.
Code of Conduct
Our Code of Conduct for employees specifies LEG's mission statement and translates the values it contains for everyday business into rules for the conduct of our employees and managers. It contains rules for areas such as corruption prevention, conflicts of interest, information and data protection, discrimination and protection of company property and applies to all individuals working for LEG. Details of these standards of conduct are set out in Group-wide internal regulations and guidelines, which are published on the intranet.
Business Partner Code
Our Business Partner Code is bindingly agreed with our business partners. It applies to business partners and their subcontractors and contains principles of cooperation to ensure integrity, reliability and economically and ethically correct standards of conduct.
Human Rights Policy
LEG is committed to respecting human rights for all employees and all those impacted by its business activities and expresses this in its Human Rights Policy.
Compliance Management System (CMS)
LEG has a Compliance Management System (CMS) that bundles measures for compliance with legal regulations and internal company guidelines. The CMS measures also include regular and ad hoc employee training. We explain our Code of Conduct and the internal regulations and guidelines that substantiate it to all our new employees, show them how to obtain information and lodge complaints, and discuss open questions. This is supported by presence training in sensitive areas and after compliance-relevant events. In addition, LEG has introduced a digital training tool in 2021, through which annual refresher training must be completed. An essential purpose of the digital training tool is to inform employees of existing regulations and thus prevent non-compliance.
Responsibility for LEG's CMS lies with the Management Board, while organisational and technical responsibility lies with the Legal & Compliance and Audit departments. The Management Board appoints a Compliance Officer who is assigned to the Legal & Compliance department and reports regularly to the Chairman of the Management Board and the Audit Committee of the Supervisory Board. A compliance team headed by the Compliance Officer discusses issues, develops structures and measures within the framework of the CMS and informs the Management Board of any changes to the legal framework.
For the area of data protection, an external data protection officer advises on data protection regulations and monitors compliance with them. The data protection officer is available to LEG's management, employees, tenants and business partners as well as to the supervisory authority as a point of contact if required.
The CMS is reviewed as part of an annual risk inventory. In addition, compliance risks and countermeasures are recorded and evaluated by the risk management system on a quarterly basis. The CMS is also certified in accordance with the certification system of the Institute for Corporate Governance in the German Real Estate Industry.
Whistleblowing System
Employees who become aware of existing or potential violations of laws or internal regulations may contact their supervisor or the Compliance Officer or report the incident via
around the clock and under protection of anonymity to a digital whistleblower system. All confirmed compliance cases are dealt with appropriately and regardless of the position of the person concerned in the company (zero tolerance). In addition, the "principle of equal treatment" applies, i.e. equal violations of rules are treated equally. In this context, in accordance with our Code of Conduct for Employees and in line with our corporate culture, no adverse measures are taken against whistleblowers acting in good faith.
The measures taken in the event of a misconduct are documented in the legal department. The documentation of possible steps under labor law is carried out for data protection reasons in the HR department. According to our code of conduct and our company culture, our non-retaliation policy prohibits any adverse action being taken against whistleblowers.
