Compliance: Fair Play According to Clear Rules

103-2

We understand compliance to mean the lawful action of our company, its bodies and employees. Through the corresponding monitoring of our compliance rules, we protect the integrity of employees, customers and business partners and shield our company from negative consequences.

Our corporate compliance – in-house rules and guidelines, e. g. to protect the capital market, ensure data protection, secure information, manage risks or set out guidelines on how to deal with donations and sponsoring – is based on the relevant statutory requirements, the articles of association and the rules of procedure for the Supervisory Board and the Management Board. Compliance at Vonovia also includes product-related compliance.

Compliance Management System

Compliance Management System (graph)Compliance Management System (graph)

Compliance with all rules is monitored by a central compliance management system based on IDW Standard PS 980. Compliance management at Vonovia is part of the legal department.

A central compliance officer is assigned the task of identifying compliance risks, taking suitable measures to avoid and detect these risks, and taking appropriate action in response to determined compliance risks. This officer is supported by compliance managers and compliance specialists in individual departments who, along with the officer, are the key contacts for compliance matters and suspected cases at the company.

An external ombudsperson is available to all employees and business partners as a confidant for compliance matters. If necessary, the ombudsperson accepts information about suspected compliance cases on an anonymous basis.

A Compliance Committee also discusses and coordinates compliance issues. The Compliance Committee meets every quarter to discuss current cases as well as the refinement of Vonovia’s compliance management system. Along with the compliance officer, the compliance managers and the ombudsperson, other members of the Compliance Committee include representatives from the areas of internal audit, risk management, HR and the workers’ council.

Dealing with Antitrust Proceedings in a Forward-Looking Manner

As a rule, Vonovia deals with antitrust-related situations in a careful and forward-looking manner. Specifically, this means that Vonovia, for example, reports acquisitions as soon as possible to the German Federal Cartel Office and begins to integrate the acquired companies or portfolios only after approval has been granted by it. There were no violations of competition law guidelines. 103-2, 103-3, 206-1