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
The reporting organization shall report the following information:
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.