14. Employment Rights

The company reports on how it complies with nationally and internationally recognised standards relating to employee rights as well as on how it fosters staff involvement in the company and in sustainability management, what goals it has set itself in this regard, what results it has achieved thus far and where it sees risks.

All business activities of Deutsche Wohnen are fundamentally subject to the laws of the Federal Republic of Germany, which clearly lay down employees’ rights. At Deutsche Wohnen, staff interests are represented by a focus group which was set up back in 2007. FACILITA has a works council for this purpose. The focus group consists of 20 employees from different sections of the company and various sites; they meet regularly to discuss current issues. The Chief Executive Officer (CEO) of Deutsche Wohnen usually attends these meetings as well. All members of staff can contact the members of the focus group personally and also have the option of drawing attention to important matters anonymously. We inform our workers about the topics dealt with by the focus group and the outcome of their discussions both on the Intranet and via the staff newsletter.  FACILITA has a works council for this purpose.

For instance, employees and executives are incorporated into strategic sustainability management through the 2018 sustainability stakeholder survey. Moreover, they are kept up to date on current projects and developments via staff information and the employee magazine ‘bruno’. They can additionally contribute thoughts and feedback related to the topic of sustainability through an email contact address.

Deutsche Wohnen only operates in Germany, as do its direct suppliers.

15. Equal Opportunities

The company discloses in what way it has implemented national and international processes and what goals it has for the promotion of equal opportunities and diversity, occupational health and safety, participation rights, the integration of migrants and people with disabilities, fair pay as well as a work-life balance and how it will achieve these.

Diversity
We promote diversity at our company and oppose any form of discrimination on the grounds of gender, age, ethnic origin, world view, disability or sexual orientation. Our approach to this issue is based on a Code of Conduct which is binding for our employees and managers. Its primary aim is to strengthen trust and mutual respect in our staff members’ dealings with one another and with third parties.

Remuneration structure
Our performance-related remuneration structure is tailored to market requirements and comprises four salary levels. These are based on a comparison of all the occupations at the individual Deutsche Wohnen companies and on wage agreements within the industry. We assign the employees to these four levels in accordance with their job description and qualifications. With this remuneration system based on transparent rules, we ensure that employees in comparable positions receive the same amount of remuneration. This illustrates our dedication to equal opportunities and fairness along with our commitment to equal pay for male and female employees. We also offer special voluntary benefits to provide assistance to employees experiencing particular personal circumstances, such as the birth of a child, a wedding or the death of a family member.

Work-life balance
We promote work-life balance in a family-friendly working environment via a wide range of measures. These include flexible working time models, such as working from home, part-time and flexitime options, each of which are taken up by a different number of staff. Employees have been able to work from home for up to two days a month since 2017. Generally speaking, all staff members who have been at the firm for a continuous period of more than six months can work from home on request and if necessary.  At FACILITA, employees can work from home if this is compatible with their role.
 

16. Qualifications

The company discloses what goals it has set and what measures it has taken to promote the employability of all employees, i.e. the ability of all employees to participate in the working and professional world, and in view of adapting to demographic change, and where risks are seen.

Training and education 
We need highly qualified, motivated staff in order to successfully continue on our growth trajectory. In return, we offer them interesting development and career opportunities and a stimulating working environment.

In-house training is the main method used to develop junior professionals. We offer young individuals the opportunity to gain a foothold in the form of work experience when they are still at school, as well as training for careers such as real estate agent and management assistant for marketing and communication. Students can enter the world of work by joining us as an intern, a student employee or – following the successful completion of their degree – as a trainee. We support and offer dual courses of study in Business Administration/Real Estate Industry, Business Studies/Tax and Auditing, and Technical Facility Management, combining practical experience within our company with a theoretical course of study at the Berlin School of Economics and Law (Hochschule für Wirtschaft und Recht Berlin).
Our HR strategy rests on structured staff development which enables employees to hone their personal strengths. Based on the development potential and needs identified in this way, we have been using a company-wide education programme accessed via a dedicated online portal since 2016. The education programme consists of staff development, specialist and interdisciplinary training, managerial skills and talent management. It bundles similar development needs and offers in-house training designed to cater for these requirements. With this approach, we proactively help our employees and managers to progress in their careers, create synergies and promote interdepartmental networks. 

The continuing professional development programme at FACILITA is geared towards sharing the knowledge needed for specific roles. For instance, all caretakers receive training in electrical engineering and communicating with customers in the housing industry. Meanwhile, operating staff and managers are prepared for new challenges via specially designed courses on focal topics. As part of this, for example, FACILITA and the Academy of Real Estate Management (Akademie der Immobilienwirtschaft e. V. – BBA) in Berlin jointly planned and ran a course lasting several weeks entitled “Facility management in brief: focus on residential properties”.

Occupational health and safety 
We want to offer our employees a safe, healthful working environment.  Each of our administrative locations is inspected once a year by the company’s safety officers, the occupational health and safety specialist and, if applicable, the company physician. The latter two are appointed externally. The issues of occupational health and safety, the equipping of workstations and possible preventive measures are discussed at the on-site meetings, which are also attended by a company representative, and any improvements are initiated.  Deutsche Wohnen and FACILITA have established occupational health and safety committees as required by law. They support and monitor our company-wide health and safety programmes and offer advice when needed. We also ensure that all workplace accidents are documented thoroughly. Such incidents are recorded in a central logbook and assessed once a year. At FACILITA, a logbook is kept at each site.  Our occupational health management scheme ensures that employees can take responsibility for maintaining their own health via a range of offerings. These include regular health awareness days, free massages, bowls of fruit to promote a balanced diet or sporting events. 
We have also introduced a corporate integration management scheme for people returning to work after a lengthy illness.

The strategic and operational goals for the “Responsibility for employees” area of action can be found under Criterion 3, Objectives.

Key Performance Indicators to criteria 14 to 16

Key Performance Indicator GRI SRS-403-9: Work-related injuries
The reporting organization shall report the following information:

a. For all employees:
i. The number and rate of fatalities as a result of work-related injury;
ii. The number and rate of high-consequence work-related injuries (excluding fatalities);
iii. The number and rate of recordable work-related injuries;
iv. The main types of work-related injury;
v. The number of hours worked.

b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number and rate of fatalities as a result of work-related injury;
ii. The number and rate of high-consequence work-related injuries (excluding fatalities);
iii. The number and rate of recordable work-related injuries;
iv. The main types of work-related injury;
v. The number of hours worked.

You will find the remaining numbers c-g of the indicator SRS 403-9 in the GRI standard and may additionally report them here.


Key Performance Indicator GRI SRS-403-10: Work-related ill health
The reporting organization shall report the following information:

a. For all employees:
i. The number of fatalities as a result of work-related ill health;
ii. The number of cases of recordable work-related ill health;
iii. The main types of work-related ill health.
b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number of fatalities as a result of work-related ill health;
ii. The number of cases of recordable work-related ill health;
iii. The main types of work-related ill health.

You will find the remaining numbers c-e of the indicator SRS 403-10 in the GRI standard and may additionally report them here.

 
Occupational health and safety  
  Unit 2016 2017
Workplace accidents recorded1) number 37 46
Lost day rate2) number 105 131
Illness rate3) % 5.9 5.6
Absenteeism rate4) % 5.9 5.6
Work-related fatalities number 0 0
Injury-frequency rate5) % 0.02 0.02


1) Incl. accidents on the way to work
2) Period (days) in which work was not possible due to employees not being able to perform their   usual duties as a result of a workplace accident
3) Persons on long-term sick leave
4) Lost days based on calculation of actual absenteeism (as a percentage) of the total number of work days designated for the employees over the same period
5) Workplace accidents in relation to total working hours of all the employees
 

Key Performance Indicator GRI SRS-403-4: Worker participation on occupational health and safety
The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by the organization:

a. A description of the processes for worker participation and consultation in the development, implementation, and evaluation of the occupational health and safety management system, and for providing access to and communicating relevant information on occupational health and safety to workers.

b. Where formal joint management–worker health and safety committees exist, a description of their responsibilities, meeting frequency, decision-making authority, and whether and, if so, why any workers are not represented by these committees.

None.

Key Performance Indicator GRI SRS-404-1: Average hours of training
The reporting organization shall report the following information:

a. Average hours of training that the organization’s employees have undertaken during the reporting period, by:
i. gender;
ii. employee category.

Average hours of training and education
  2016 2017
Senior management 45,6 in total 23,4 in total
40,7
m
51,6
w
25,3
m
21,3
w
Middle management 45,2 in total 39,6 in total
48,0 
m
42,2
w
36,6
m
41,9
w
Rest of workforce 16,5 in total 16,2 in total
17,8
m
15,5
w
17,6 
m
15,4
w


In the year under review, our staff and managers spent a total of 1,450 days participating in our education programme. We increased our investments in continuing professional development by around 20% to EUR 740,000 in 2017. The related improvements in quality yielded good assessments of the offering. As a result, we received a predominantly positive response to the quality of the education programme from our employees, with a further increase on the previous year. The quality score for seminars improved from 1.65 to 1.52 while speakers were given a rating of 1.26, up from 1.40. 

 

Key Performance Indicator GRI SRS-405-1: Diversity
The reporting organization shall report the following information:

a. Percentage of individuals within the organization’s governance bodies in each of the following diversity categories:
i. Gender;
ii. Age group: under 30 years old, 30-50 years old, over 50 years old;
iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

b. Percentage of employees per employee category in each of the following diversity categories:
i. Gender;
ii. Age group: under 30 years old, 30-50 years old, over 50 years old;
iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

Diversity
  2016 2017
People on the Management Board by gender %
m/w
100
m

m
100 
m
 
w
People on the Supervisory Board by gender  %
m/w
100
m

w
100 
m
 
w
People on the Management Board by age group %
m/w
       
Under 30 years of age     0   0
30 – 50 years of age     66   66
Over 50 years of age     34   34
People on the Supervisory Board by age group %        
Under 30 years of age     0   0
30 – 50 years of age     0   0
Over 50 years of age     100   100
Workforce by gender %
m/w
43.4 
m
56.6 
w
45.8 
m
54.2  
w
Management by gender  %
m/w
55.8 
m
44.2 
w
56.6 
m
43.4  
w
Workforce by age group          
Up to 35 years of age     37.2   37.6
36 – 45 years of age     21.0   23.8
46 – 55 years of age     28.1   25.0
More than 55 years      13.7   13.6
Average workforce age years   41.2   41.0
Management by age group %        
Up to 35 years of age     14.9   11.2
36 – 45 years of age     47.3   58.8
46 – 55 years of age     27.0   21.2
More than 55 years     10.8   8.8
Proportion of disabled employees %   2.2   0.4
 

Key Performance Indicator GRI SRS-406-1: Incidents of discrimination
The reporting organization shall report the following information:

a. Total number of incidents of discrimination during the reporting period.

b. Status of the incidents and actions taken with reference to the following:
i. Incident reviewed by the organization;
ii. Remediation plans being implemented;
iii. Remediation plans that have been implemented, with results reviewed through routine internal management review processes;
iv. Incident no longer subject to action.

We are not aware of any incidents of discrimination during the reporting period.

Apprenticeship quota (optional)

At the end of 2017, 46 trainees worked at Deutsche Wohnen; this corresponds to a training ratio of 4.1%. 

Employee fluctuation (optional)

Employee turnover
  Unit 2016 2017
Total employee turnover number 88 107
  % 8.8 9.6
of which employee-initiated terminations1) number 43 57
  % 4.3 5.1
 
1) The figures comprise salaried and temporary employees (headcount) who left between 1 January 2017 and 31 December 2017.

The turnover rate at FACILITA was 2% in 2017.
 
Kooperation mit Sozialeinrichtungen
Berlin, Caritas project: new housing for women  
Again and again, women are forced to seek refuge with their children in a women’s shelter. To make it easier for these women to find a new home after staying at a shelter, the Caritas charity established the project NeuRaum (NewSpace) in 2016. This involves the sponsor Caritas renting residential units which it makes available to women and their children and then transferring the units to them after an initial sixmonth period. Together with socio-educational advice, this allows the women to regain their independence. Deutsche Wohnen has supported this project from the beginning by making housing available and currently provides 28 residential units.
 

17. Human Rights

The company discloses what measures it takes, strategies it pursues and targets it sets for itself and for the supply chain for ensuring that human rights are respected globally and that forced and child labour as well as all forms of exploitation are prevented. Information should also be provided on the results of the measures and on any relevant risks.

Deutsche Wohnen only operates in Germany, as do its direct suppliers. Compliance with national legislation virtually rules out the possibility of human rights violations. The applicable statutory regulations include, for example, the ban on child labour and forced labour, anti-discrimination legislation, the right to freedom of association and the right to collective bargaining.
The protection of human rights is a matter of course for us: this is an integral part of our corporate culture. Deutsche Wohnen encourages diversity and prohibits all discrimination against our employees, among other things on grounds such as gender, age, ethnic origin, disability or sexual orientation.

Key Performance Indicators to criteria 17

Key Performance Indicator GRI SRS-412-3: Investment agreements subject to human rights screenings
The reporting organization shall report the following information:

a. Total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening.

b. The definition used for ‘significant investment agreements’.

None.

Key Performance Indicator GRI SRS-412-1: Operations subject to human rights reviews
The reporting organization shall report the following information:

a. Total number and percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country.

None.

Key Performance Indicator GRI SRS-414-1: New suppliers subject to social screening
The reporting organization shall report the following information:

a. Percentage of new suppliers that were screened using social criteria.

The Deutsche Wohnen Group operates solely in Germany, where business practices are governed by clear statutory regulations with regard to human rights, social impacts and labour practices. For this reason, Deutsche Wohnen does not subject new suppliers to any specific screening beyond a creditworthiness check during the selection process, unless the individual circumstances warrant such additional measures.

In future, environmental and social checks will not only be run on companies offering their services for the first time for new construction projects but also for refurbishment and modernisation work on existing holdings.

Key Performance Indicator GRI SRS-414-2: Social impacts in the supply chain
The reporting organization shall report the following information:

a. Number of suppliers assessed for social impacts.

b. Number of suppliers identified as having significant actual and potential negative social impacts.

c. Significant actual and potential negative social impacts identified in the supply chain.

d. Percentage of suppliers identified as having significant actual and potential negative social impacts with which improvements were agreed upon as a result of assessment.

e. Percentage of suppliers identified as having significant actual and potential negative social impacts with which relationships were terminated as a result of assessment, and why.

No incidents of non-compliance with statutory or internal social requirements came to light.
 

18. Corporate Citizenship

The company discloses how it contributes to corporate citizenship in the regions in which it conducts its core business activities.

Engagement through core business activities
Deutsche Wohnen is one of Germany’s leading real estate companies. As such, our core line of business alone – providing good-quality housing – has a variety of impacts on the social environment. Our successful performance results not only in happy tenants and investors – the surrounding districts also benefit from well-maintained buildings, attractive outdoor areas and the social projects that we support.

The strategic aims of our sustainability programme in the “Responsibility towards society” area of action are to promote a vibrant district structure and to further our social engagement. We firmly believe that numerous local activities in various locations will have a greater impact than single, larger-scale campaigns. We specifically focus on measures that allow us to use our core areas of expertise effectively.

Focus of Deutsche Wohnen’s social commitment: Leveraging our core area of expertise also enables us to make our social engagement especially effective. We therefore primarily promote measures related to the topic of living in the broader sense. For example, we let commercial space to social facilities at a reduced rate. Furthermore, we help to finance social workers and allocate residential units to socially disadvantaged individuals.

We make approximately 4–5% of the space newly let each year available for social and non-profit purposes. We support initiatives which have a positive impact on the neighbourhoods within our estates and contribute to successful community interaction with donations or affordable housing.

Support for local projects
The Kastanienallee boulevard in Hellersdorf has been under the management of Deutsche Wohnen since 2013. While the majority of the commercial units have since been let again, the green and once bustling shopping street is still suffering from the results of an exodus of retailers which occurred in the 1990s. To initiate the boulevard’s redevelopment, the district management division established a diverse local participation process in 2016.
Deutsche Wohnen made housing available to refugees right from the start of the influx of people seeking refuge. At the end of 2017, approximately 750 residential units from within our portfolio were let to refugees, around 300 of which are in Berlin alone. In addition, Deutsche Wohnen has been a member of the “Wir zusammen” (We Together) network since 2015. This integration initiative on the part of German industry promotes projects that facilitate integration and invigorate interaction and communication between residents and refugees.

Additional concrete examples of our social engagement can be found in our Sustainability Report 2017, p. 62–63.

Key Performance Indicators to criteria 18

Key Performance Indicator GRI SRS-201-1: Direct economic value generated and distributed
The reporting organization shall report the following information:

a. Direct economic value generated and distributed (EVG&D) on an accruals basis, including the basic components for the organization’s global operations as listed below. If data are presented on a cash basis, report the justification for this decision in addition to reporting the following basic components:
i. Direct economic value generated: revenues;
ii. Economic value distributed: operating costs, employee wages and benefits, payments to providers of capital, payments to government by country, and community investments;
iii. Economic value retained: ‘direct economic value generated’ less ‘economic value distributed’.

b. Where significant, report EVG&D separately at country, regional, or market levels, and the criteria used for defining significance.

 
Economy
  Einheit 2016 2017
Rental income EUR m 704.5 744.2
Earnings from Residential Property Management EUR m 586.4 612.8
Earnings from disposals EUR m 54.3 50.3
Earnings from Nursing and Assisted Living EUR m 16.8 48.0
FFO I EUR m 383.9 432.3
EPRA NAV (undiluted) EUR m 10,017.0 12,676.8
Market capitalisation EUR bn 10.1 12.9
 

A detailed presentation of our key economic figures can be found in the Annual Report 2017, p. 96 f.
 

19. Political Influence

All significant input relating to legislative procedures, all entries in lobby lists, all significant payments of membership fees, all contributions to governments as well as all donations to political parties and politicians should be disclosed by country in a differentiated way.

Legislative procedures
Relevant legislative procedures, such as those relating to tenant, construction or to energy law, are those which will impact Deutsche Wohnen in its capacity as an enterprise that operates within the property sector. Furthermore, laws relating to the financial market can also impact Deutsche Wohnen SE in its capacity as a listed company. These include the recent amendments to the German Commercial Code (HGB) as a result of the German Act Implementing the CSR Directive (CSR-Richtlinie-Umsetzungsgesetz – CSR-RUG), which we are complying with through the publication of our non-financial statement. 

Membership

Akademie der Immobilienwirtschaft e. V. (Academy of Real Estate Managment, BBA)
Berlin Building Chamber (BK)
Verband Berlin-Brandenburgischer Wohnungsunternehmen e. V.
 (Association of Residential Property Companies in Berlin-Brandenburg, BBU)
Bundesverband deutscher Wohnungs- und Immobilienunternehmen e. V.
 (Federal Association of German Housing and Real Estate Companies, GdW)
Creditreform e. V. 
Deutsche Public Relations Gesellschaft e. V. (German Public Relations Association, DPRG) 
Deutsche Entwicklungshilfe für soziales Wohnungs- und Siedlungswesen e. V.
 (German Centre for Development Aid with regard to Social Housing and Human Settlements, DESWOS) 
German Financial Reporting Enforcement Panel (FREP) 
Deutsche Schutzvereinigung für Wertpapierbesitz e. V.
(German Association for the Protection of Investors, DSW)
Deutscher Verband für Wohnungswesen, Städtebau und Raumordnung e. V.
(German Association for Housing, Urban and Spatial Development, DV)
DialogGesellschaft e. V. (DialogueSociety) 
European Public Real Estate Association (EPRA) 
Friends’ Association of the Federal Foundation of Baukultur 
Marzahn-Hellersdorfer Wirtschaftskreis e. V.
(Marzahn-Hellersdorf Business Association, MHWK) 
Schutzgemeinschaft der Kapitalanleger e. V.
(German Association for the Protection of Capital Investors, SdK) 
Economic Council 
German Property Federation (ZIA; from 2018) 

Since 2014, Deutsche Wohnen has been a regular member of the Economic Council of the CDU (Wirtschaftsrat der CDU e. V.); we pay an annual membership fee of EUR 10,000 in this connection. In the reporting year, we spent a total of over EUR 300,000 on material memberships, including the Association of Residential Property Enterprises in Berlin-Brandenburg (Verband Berlin-Brandenburgischer Wohnungsunternehmen e. V. – BBU), the German Association for Housing, Urban and Spatial Development (Deutscher Verband für Wohnungswesen, Städtebau und Raumordnung e. V. – DV), the European Public Real Estate Association, and the Federal Association of German Housing and Real Estate Companies (Bundesverband Deutscher Wohnungs- und Immobilienunternehmen e. V. – GdW). We donated EUR 5,000 in 2017 to the summer party of the Parlamentskreis Mittelstand (PKM) of the CDU/CSU faction, the largest parliamentary group (representing the interests of medium-sized companies) in the German Bundestag.

Our sustainability programme includes the implementation of a guideline laying out standards for social and cultural engagement. Additional information on dialogue with political representatives can be found under Criterion 9, Stakeholder Engagement, and in our Sustainability Report 2017, p. 18–20.
 

Key Performance Indicators to criteria 19

Key Performance Indicator GRI SRS-415-1: Political contributions
The reporting organization shall report the following information:

a. Total monetary value of financial and in-kind political contributions made directly and indirectly by the organization by country and recipient/beneficiary.

b. If applicable, how the monetary value of in-kind contributions was estimated.

Deutsche Wohnen does not make any donations to political parties.

20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

Compliance
Deutsche Wohnen places great value on compliance with both legal provisions and the standards of the German Corporate Governance Code.  Observing legal norms is primarily the responsibility of executives and the Compliance Officer. The latter is the central point of contact for all compliance matters. He/she informs the management, employees and business partners about relevant legal requirements and the consequences of breaching the regulations.

Our Code of Conduct, which prescribes and defines dealings which are in compliance with the law, applies to and is binding on all of the company’s employees. Every new employee receives and commits to following the guidelines upon commencing his/her employment with the company. They are also available throughout the company via the Intranet. Whenever the Code of Conduct is updated, employees must explicitly confirm that they have been advised of the change. In addition, the managerial staff ensure that their employees are made aware of material compliance-related risks. Employees receive online training in the fundamentals of compliance. This training includes a final test and is mandatory; staff who successfully complete the course receive a certificate. Processes which may have implications under competition law (such as acquisitions) undergo the relevant checks. The approval of the German competition authority (Bundeskartellamt) is then sought if applicable.

Prevention of corruption risks
Bribery and corruption risks are an important issue for the real estate industry. Like its peers, Deutsche Wohnen sees itself as facing these risks as we primarily operate in regions with a shortage of housing and high demand pressure. This leads to an increased risk of attempts to bribe staff, such as those responsible for letting apartments or awarding construction contracts. Furthermore, third parties – including public officials – can also be affected, for instance when it comes to speeding up modernisation and refurbishment measures or gaining anti-competitive and unfair advantages.

We believe that the above-mentioned scenarios pose a material risk of the company suffering reputational harm and a loss of credibility. That is why we have implemented clear, binding anti-corruption rules which are a central component of our compliance management system. These primarily take the form of our Code of Conduct and anti-corruption guidelines, which expressly prohibit corruption. In particular, our employees are not allowed to accept gifts in return for giving assurances as to the possible conclusion of a business transaction. The guidelines also prohibit employees from attempting to unlawfully influence business partners by according them preferential treatment, giving them gifts or granting them other benefits. Our managers are responsible for ensuring their staff understand the importance of complying with these regulations.

We use a proprietary e-learning programme for the purpose of continuous professional development in this field. We have also put in place a regulation regarding signatories. This is based on the principle of double-checking and imposes a range of requirements, tiered according to contract value. Whenever a contract is awarded, a second signature and a plausibility check are required.

We evaluate any suspected violations and cases of corruption as part of our regular risk reporting. Our processes or guidelines are adjusted if necessary.

Key Performance Indicators to criteria 20

Key Performance Indicator GRI SRS-205-1: Operations assesed for risks related to corruption
The reporting organization shall report the following information:

a. Total number and percentage of operations assessed for risks related to corruption.

b. Significant risks related to corruption identified through the risk assessment.

As part of the risk management system in place at Deutsche Wohnen, all of its business divisions and processes are subject to both regular and event-based review by way of a risk inventory, which addresses not only compliance risks but also corruption-related risk.

Key Performance Indicator GRI SRS-205-3: Incidents of corruption
Die berichtende Organisation muss über folgende Informationen berichten:

a. Total number and nature of confirmed incidents of corruption.

b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.

c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.

d. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.

The company also set up a whistle-blower system in 2017, which enables employees and contractual partners of the Deutsche Wohnen Group to report information on suspected serious violations of either the law or other regulations to a legal counsel. This can be done anonymously on request; whistle-blowers are protected by the legal counsel’s duty of confidentiality. The counsel records suspected violations, evaluates them and, where necessary, forwards them to the Compliance Officer. There were no confirmed cases of corruption in the year under review. 

Our Code of Conduct, which prescribes and defines dealings which are in compliance with the law, applies to and is binding on all of the company’s employees. Every new employee receives and commits to following the guidelines upon commencing his/her employment with the company. They are also available throughout the company via the Intranet. Whenever the Code of Conduct is updated, employees must explicitly confirm that they have been advised of the change. In addition, the managerial staff ensure that their employees are made aware of material compliance-related risks. Employees receive online training in the fundamentals of compliance. This training includes a final test and is mandatory; staff who successfully complete the course receive a certificate. 
Processes which may have implications under competition law (such as acquisitions) undergo the relevant checks. The approval of the German competition authority (Bundeskartellamt) is then sought if applicable.

Key Performance Indicator GRI SRS-419-1: Non-compliance with laws and regulations
The reporting organization shall report the following information:

a. Significant fines and non-monetary sanctions for non-compliance with laws and/or regulations in the social and economic area in terms of:
i. total monetary value of significant fines;
ii. total number of non-monetary sanctions;
iii. cases brought through dispute resolution mechanisms.

b. If the organization has not identified any non-compliance with laws and/or regulations, a brief statement of this fact is sufficient.

c. The context against which significant fines and non-monetary sanctions were incurred.

No significant fines and/or non-monetary sanctions as a result of non-compliance with laws and/or regulations in the social and economic area in the reporting period.