Policy against corruption and conflicts of interest

I. Scope of application

These guidelines are binding on the Board of Management and all employees of LEG Immobilien SE and all affiliated companies associated with LEG Immobilien SE pursuant to Section 15 of the German Stock Corporation Act.

II. Objective

1. Compliance with laws

Our corporate bodies, managers and employees comply with applicable standards and laws, regulations, internal rules and guidelines under all circumstances, including those relating to the prevention of bribery and corruption. We regularly inform ourselves about the current legal and ethical rules of our working environment and strictly comply with them. Violations of applicable anti-corruption laws and regulations may result in significant criminal and civil penalties, fines and penalties for the Group, its employees and any third parties acting as intermediaries. This must be avoided under all circumstances.

Even in cases where no specialist knowledge can be expected from an employee, our employees must still have sufficient basic knowledge to be able to decide when to consult another employee, their manager, the Compliance Officer or possibly a third party.

To ensure that our employees have the best possible knowledge in connection with their professional activities, they regularly receive special training. The Legal Department and the Compliance Officer are also available to answer any questions they may have.

Each manager must ensure that his teams act in accordance with the rules applicable to his field of activity, particularly with regard to the internal working rules in force in the company.

2. Integrity

Beyond compliance with legal regulations, morality and integrity shape the business culture of the LEG Group. This creates trust among our customers, employees, investors and business partners and contributes to the Company's good reputation. We fulfil our obligations to all LEG stakeholders (customers, suppliers, authorities and other LEG partners).

We treat our business partners and suppliers fairly: any preferential treatment may only be given on the basis of objective and transparent criteria in accordance with the rules and guidelines applicable in our company.

3. Conflicts of interest

Our employees avoid all situations in which their personal interests (or the interests of individuals or legal entities close to them) could conflict with those of LEG. Therefore, every employee is expected to contact the Compliance Officer in any situation that could influence his or her objectivity.

The purpose of this policy is to clarify existing prohibitions on bribery and corruption. The policy aims to sensitize employees to the emergence and dangers of situations susceptible to corruption in all business areas of the LEG Group and to clarify existing compliance requirements. It thus serves to prevent corruption.

III. Principle: Prohibition of corruption, bribery and improper influence

Preventing the risk of corruption, bribery, corruptibility and abusive influence is our top priority. It is the responsibility of every employee and every manager to comply strictly with the applicable legal requirements and internal regulations. LEG's reputation is at stake here, and there is zero tolerance.

It is prohibited by law:

• Promising, granting, accepting or demanding unjustified financial or non-financial benefits. Such unjustified benefits may include gifts, awards, promotions, donations, training or the prospect of employment
• directly or indirectly through an intermediary,
• to a public official or private person or their relatives
• in all countries,
• with the aim of requiring or rewarding someone within the scope of his functions to act or refrain from acting in violation of applicable law.

It is also prohibited for our employees:

• to make facilitation payments.

Facilitation payments are payments made to an official to induce the official to expedite or perform an official act.

Attention!

• Corruption can take place directly or indirectly through an intermediary (and may also constitute an abuse of influence)
• The reward for corruption can be either "doing" or "not doing".
• Corruption can be active (bribery) or passive (corruptibility), depending on whether it originates from the briber or the bribed person.

Therefore, any employee or manager who commits such acts in the course of his or her professional duties, whether as a briber or as a bribed party, is subject not only to criminal prosecution but also to disciplinary action, up to and including termination or loss of his or her employment or board membership.

IV. Exception: Permissible benefits

Employees may only accept and grant non-abusive benefits of small value only if the benefit

• adheres to the value limits set out in the "Group Works Agreement on Conduct in a Business Environment" (gifts: 40 euros, invitations: 80 euros), and
• is reasonable under consideration of the given circumstances (e.g. scope of the business relationship, time of grant).

In cases of doubt, the prior consent of the Compliance Officer must be obtained before accepting or granting a benefit.

V. Donations and sponsoring

The LEG Group permits and supports lawful and non-abusive, appropriate donations to charities and sponsorships.

VI. Employee transactions and transactions with related parties

• Transactions which employees conclude with LEG business partners for their own account or for the account of third parties must be conducted at normal market conditions.
• Employees who are in a marital/life partnership with LEG's business partners must obtain LEG's consent before placing orders for goods and services with these business partners.

VII. Sevondary Activities
Secondary activities require the consent of LEG. This also applies to honorary positions / honorary activities.

VIII. Prevention of money laundering

In order to prevent money laundering, employees may not accept cash payments under any circumstances. In addition, our employees adhere strictly to the legal requirements for the prevention of money laundering, in particular the provisions of the German Penal Code and the Money Laundering Act.

IX. Third parties

This Policy applies directly only to employees. Business partners are bound by the Business Partner Code to comply with applicable laws, rules and regulations, including applicable anti-corruption regulations. In the event of a proven violation of the anti-corruption regulations or the Business Partner Code, a permanent exclusion of the business partners from the award of contracts or a termination of the existing business relationship and the contractual/contractual relationship as well as the assertion of claims for damages must be examined.

X. Reporting violations or concerns; advice from the Compliance Officer

It is the responsibility of each employee to ensure compliance with this Policy. Employees who become aware of or suspect a violation of this Policy should contact their supervisor or the Compliance Officer or make a report through LEG's whistleblower system.

The Compliance Officer and the Legal Department are available at all times to provide advice on ethical conflicts and on the interpretation of the provisions of this Policy and its application to individual cases.

XI. Review of the Policy - Training

The content of this Policy is part of LEG's compliance training, which is mandatory for all employees.

The Policy was adopted by LEG's Board of Management and must be reviewed at appropriate intervals.

Related guidelines and manuals: Code of Conduct for Employees; Group Works Agreement on Conduct in the Business Environment; Compliance Manual; Whistleblowing Policy, Policy on Political Participation.

Düsseldorf, Germany, January 2023
(Validity confirmed in January 2023 - Next policy review in 2024)