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.

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.