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 training for employees on a case-by-case basis. In particular, we instruct all our new employees in the rules of our CMS and discuss their questions with them. This is supported by presence trainings in sensitive areas and after compliance-relevant events. In addition, we are about to introduce a digital training tool that every employee must go through annually.

Responsibility for LEG's CMS lies with the Board of Management, while organisational and technical responsibility lies with the Legal & Compliance and Audit departments. The Board of Management appoints a Compliance Officer, who is assigned to the Legal & Compliance department and reports regularly to the Chairman of the Board of Management and the Audit Committee of the Supervisory Board. A compliance team headed by the Compliance Officer discusses issues, develops structures and measures within the CMS and informs management of any changes in 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 the supervisory authority as a contact person if required.

The CMS is reviewed as part of an annual risk inventory. In addition, compliance risks and countermeasures are recorded and evaluated quarterly by the risk management system.

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

www.bkms-system.com/LEG

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.

In 2019, 2020 and 2021 there have been no material reports received so far