The Compliance Management System is organised and company-wide guidelines are adopted in consultation with and by resolution of the Management Board. The Supervisory Board and the Audit Committee are regularly informed about the compliance management system and any changes to it. We encourage our employees to report concerns and irregularities so that we can take countermeasures at an early stage. This also includes communicating grievances and measures taken transparently within the organisation. [...] Responsibility for measures to prevent and detect corruption and bribery lies centrally with the Corporate Office & Compliance department, which takes a Group-wide holistic approach in this regard. This includes the provision of a code of conduct (primarily via the Code of Ethics & Conduct and the Anti-Corruption Policy) and the associated comprehensive mandatory training for each individual employee. Guidelines and any changes to them are communicated throughout the Group and can be accessed in their current form on the intranet. Mandatory training on the prevention and detection of corruption and bribery as well as dealing with conflicts of interest initially takes place as part of onboarding and must then be completed annually by every employee. In addition, training is focussed on particularly affected business areas (operational business units that are in direct contact with business partners, tenants or service providers)."
"ions to political parties, political exponents and religious communities (donations, benefits in kind, etc.) as well as gifts of money or unauthorised payments to business partners or authorities are strictly prohibited and will be regarded as (attempted) bribery.
Furthermore, employees may not accept or offer any gifts that are inappropriate in social or value terms. Offering, promising or granting money or benefits in kind of any kind to public officials and political exponents is strictly prohibited. As part of the programme to combat bribery and corruption, CA Immo has issued a detailed anti-corruption guideline for its employees that specifies which benefits are permissible and to what extent they are prohibited. Detailed rules on the existence of conflicts of interest and how to deal with them are also set out in detail in the Code of Ethics & Conduct. In addition to basic obligations (recording and authorising secondary employment, board functions and shareholder positions), potential conflicts of interest must be reported immediately to the Corporate Office & Compliance department by the employee concerned.
The anti-corruption guideline also contains comprehensive regulations on sponsoring, dealing with intermediaries and regulating political influence and lobbying activities.
In the event of suspicious circumstances and information received, audits are carried out by the Corporate Office & Compliance department; in the event of a conflict of interest in this regard, audits are carried out by Internal Audit. If necessary, external professionals may also be called in if this appears necessary to clarify a matter.
The Supervisory Board or the Audit Committee is informed at least once a year about measures taken to combat bribery and corruption. Corruption-related matters are audited on the basis of the audit plan approved by the Audit Committee or on the basis of special audit mandates from the Management Board, Audit Committee or full Supervisory Board. All operating Group companies are regularly audited for corruption risks.
12. METRICS AND TARGETS
**Confirmed incidents of corruption or bribery**
There were no cases of corruption or bribery at CA Immo in the 2024 reporting year.
**Political influence and lobbying activities**
Political influence and lobbying activities are strictly regulated at CA Immo. Details in this regard can be found in the anti-corruption guideline, which was newly adopted by the Management Board in the 2024 business year.
Contributions to political parties, politically exposed persons, churches and religious communities (donations in any form, benefits in kind, etc.) are generally prohibited throughout the Group. This does not include charitable organisations with a political or religious background, provided that the focus of the organisation is on promoting the common good, whereby an extensive review process is carried out in advance to ensure the greatest possible transparency.
Special regulations and a comprehensive authorisation procedure are also in place with regard to the commissioning of political intermediaries, which is generally prohibited throughout the Group.
No donations were made to political parties or politically affiliated organisations in the 2024 financial year.
The administrative, Management and Supervisory bodies of CA Immo did not hold any comparable positions in public administration in the two years prior to the current reporting period.