Human Rights Policy

1. Commitment to recognised human rights standard

LEG is committed to respecting human rights on the basis of the UN Guiding Principles on Business and Human Rights.

As a responsible company, it is a matter of course for LEG to respect fundamental and universally valid human rights and to support their protection and preservation. In doing so, we pursue the vision of a sustainable and fair global economy in which entrepreneurial success is not based on exploitation and violence, but on mutual respect and integrity.

Internationally recognised conventions such as the United Nations' Charter of Human Rights (Universal Declaration of Human Rights), the eight core labour standards of the International Labour Organisation (ILO) and the United Nations' Guiding Principles on Business and Human Rights are essential foundations of our corporate culture and all our activities. The values and standards enshrined therein form the basis of responsible corporate governance and are incorporated into internal Group documents.

LEG's properties are located exclusively in Germany. LEG's business operations are conducted exclusively with business partners based in Germany or the EU. In its dealings with these business partners, LEG initially assumes that they comply with the legal system applicable in the Federal Republic of Germany or the EU and respect human rights in the manner prescribed by applicable law.

LEG combines all its business activities with clear ethical principles and values, which are summarised in a Code of Conduct. Our Code of Conduct brings together uniform, Group-wide guidelines for fair and righteous conduct in public and within our Group. The focus is on fair, transparent and responsible conduct in dealings with colleagues, customers and business partners. At LEG, the principles of the Code of Conduct have always been important for successful business activities and are applied by our employees in their daily lives. In accordance with applicable internal regulations, the validity of the Code of Conduct for business partners, which is based on LEG's Code of Conduct, is agreed with business partners. Framework agreements also contain other compliance rules such as adherence to industry and safety regulations, compliance with the Minimum Wage Act or appropriate accommodation for employees during a construction project. LEG thus ensures that its business partners feel bound by the same standards of ethical and legal conduct as LEG itself.

2. Exercise of human rights due diligence

As part of its human rights due diligence process, LEG regularly assesses human rights risks relating to its own business activities, our supply chains, the "housing" product and our investment decisions. Our focus is on the following areas:

Personal dignity and individual esteem

The personal dignity and individual appreciation of each person are essential elements in dealing with employees, business partners and customers. We attach particular importance and a fair and transparent letting process.

Employment and equal treatment

We do not commit unjustified discrimination against our employees, customers or business partners. In particular, we do not tolerate discrimination on the basis of race or ethnic origin, gender, religion or belief, disability, age or sexual identity.

Our employees are not discriminated against. Recruitment and personnel decisions are made in the interests of the company and free of any discrimination; all employees have equal access to social benefits and the same opportunities for professional advancement and further training.

Good and fair working conditions, safety at work

We offer our employees good and fair working conditions under which they can develop individually, grow personally and perform at their best. This includes comprehensive training and development opportunities.

We respect the right to rest and leisure time as well as the right to family life. With flexible working time models, we support our employees in reconciling professional and private interests.

We respect the freedom of association and the right to collective agreements of our employees. Employees who act as employee representatives are not disadvantaged. We work together with employee representatives in an open and constructive manner.

We want to offer our employees a safe workplace and to this end we implement systematic and comprehensive occupational health and safety measures.

Working conditions in the supply chain

We also expect our business partners to respect human rights and to oblige their employees and suppliers to do the same. Our expectations are expressed in our business partner code of conduct. The Business Partner Code represents the general basis for the cooperation with our business partners. It is an integral part of our contractual relationships and must be signed when the contract is concluded.

Environmental protection

We want to achieve high standards in environmental protection and thus make our contribution to a healthy living environment and the achievement of climate targets in Germany. For the coming years, we will therefore be placing a special focus on the topic of climate and CO2 reduction. In our "Climate Protection Competence Centre", measures to reduce emissions in LEG housing stock are discussed and implemented. At the beginning of 2020, LEG co-founded the climate policy alliance "Initiative Wohnen.2050 e.V.", which seeks solutions to make the housing stock in Germany climate-neutral by 2050.

Privacy and data protection

We respect the privacy of our customers and employees and protect confidential information and data of employees, customers and all stakeholders with whom we do business. The protection of privacy and confidential data is firmly anchored in our internal guidelines. Our data protection management and our external data protection officer provide advice on and monitor compliance with data protection regulations. Data protection management and the external data protection officer are available to our employees, customers and business partners as contact persons if required.

3. Reporting

We report annually on our handling of human rights in our sustainability report.

4. Complaint mechanisms

Our employees can report possible violations of human rights or possible infringements of laws or internal regulations to their supervisors or to the Compliance Officer. In addition, they and third parties can use an internet-based whistleblowing system to report possible violations around the clock ( Whistleblowers can remain anonymous if they wish. All reported incidents are investigated and processed promptly.

Lars von Lackum (CEO)

Susanne Schröter-Crossan (CFO)

Dr. Volker Wiegel (COO)

Düsseldorf, Germany, Autumn 2021
(Validity confirmed in Autumn 2022 - Next policy review in 2023)