Easily report compliance violations online

Why should I submit a report?

Compliance with statutory, social and internal company rules is part of a positive and open company culture. Violations of these rules can lead to fines, penalties and, in particular, reputation damage.

Perhaps you are aware of damaging behaviour or risks that endanger the company. Your report could help to reveal possible harm to our company and our reputation at an early stage or prevent it entirely. This protects the long-term success of LEG and secures the jobs of its employees!

What reports can be submitted?

Reports about violations of legal and company-internal policies by LEG employees will be accepted and forwarded. You will receive detailed information on the possible categories of a report during the reporting process.

You can also report any violations by LEG suppliers of our Code of Conduct for Business Partners and grievances along the wider supply chain. This includes, in particular, violations of human rights and environmental standards.

Naturally, employees can still report violations to their supervisors or the Compliance Officer.

This whistleblowing system is not intended for emergency calls. In case of immediate danger to persons, please use the public emergency numbers.

If you have questions or suggestions concerning your lease or billing, please contact the renter service of LEG at https://www.leg-wohnen.de/mieterservice.

What is the process for submitting a report? How do I set up a postbox?

If you wish to submit a report (either by name or anonymously), click the “Submit report” button at the top of our introduction page.

The reporting process consists of 4 steps:

1. First, you will be asked to read some information on the protection of your anonymity and to respond to a security query.
2. On the following page, you will be asked about the category of your report.
3. On the report page, you can elaborate on your report in your own words and answer questions about the case by simply selecting responses. You can enter up to 5,000 characters into the free text field, which corresponds to a full page. You may also submit a file of up to 5 MB to support your report. Please bear in mind that documents can contain information about the author. Following the submission of your report, you will receive a reference number to confirm that you have sent this report.
4. Please subsequently set up your own secured postbox. You will receive feedback from us via this postbox, including answers to questions and information about the progress of your report.

If you already have a secured postbox, you can access it directly via the “Login” button. Here, too, you will have to answer a security query first.

As long as you do not enter any data from which conclusions about your person can be drawn, the technology of the BKMS^® System will protect your anonymity.

Please rest assured that we are interested only in the incident you are reporting. Malpractices should be revealed and financial losses prevented.

Who processes incoming reports?

Reports are received and processed by a small team from the departments of Legal & Compliance and Internal Audit. Employees from other departments are only included if this is necessary to investigate the issue. Every person who processes the report is obligated to maintain confidentiality.

How are my anonymity and the protection of my data ensured?

If you wish to remain anonymous, this whistleblowing system (BKMS^® System) protects your identity by technical means. Your report is kept anonymous through encryption and other specialised security measures. As long as you don’t enter any data which can be traced back to you, neither the system operator nor LEG are able to discover your identity. The data security and the data protection compliance of BKMS^® System with respect to the applicable, publicly viewable criteria in consideration of the requirements of the EU General Data Protection Regulation (GDPR) have been audited and certified by independent experts.

This whistleblowing system is an internet-based application and is operated on independent servers in a high-security data processing centre. In contrast to simple html web portals, neither the employees of EQS Group AG nor other third parties can view the reports of customers.

Communication between your computer and BKMS^® System takes place over an encrypted connection (SSL). Your computer IP address will not be stored during your use of the whistleblowing system. In order to maintain the connection between your computer and BKMS^® System, a cookie is stored on your computer that merely contains the session ID (a so-called session cookie). This cookie is only valid until the end of your session and expires when you close your browser.

Via a secured postbox, an examiner will give you feedback about the further processing of your report or ask you questions if some details are still unclear – you remain anonymous throughout the dialogue. We are interested in reports to avoid damage, not in you as a whistleblower.

To prevent your connection with BKMS^® System from being traced to the devices you use, we recommend that you submit your report from a private PC or mobile device.

What happens if my suspicion turns out to be unjustified?

If a report or a suspicion turns out to be unjustified, you do not have to fear any negative consequences.

Our compliance team will always protect all whistleblowers who submit a report in good faith. It can happen that situations are interpreted incorrectly or that individual actions can be assessed differently within the overall context, which you may not be aware of. However, because an actual compliance violation may never be discovered without your report, it is important for an effective whistleblowing system that any observed malpractices or similar suspicions always be reported. We would like to strongly encourage you to do this.

However, please consider that making accusations against other persons can have serious consequences for these persons. We therefore ask that you use the whistleblowing system responsibly and carefully evaluate whether your suspicions are justified before submitting your report. To protect an accused person, the employees assigned to the case will investigate the suspicion based on your report and only confront the accused person with the report if the suspicion appears justified or a confrontation is unavoidable for further investigation.

Acting in bad faith, in other words knowingly making false and slanderous reports, can result in criminal penalties and employment consequences for the whistleblower.

Rules of Procedure on the Whistleblower System and the Complaints Procedure according to the Act on Corporate Due Diligence Obligations in Supply Chains („Lieferkettensorgfaltspflichtengesetz“)

For LEG, legally compliant behaviour is a matter of course and one of the central prerequisites for the sustainable success of the Company. LEG also works towards sustainable and legally compliant behaviour throughout the entire supply chain with regard to its business partners, and in particular demands compliance with human rights and environmental standards.

If, despite the measures taken, a compliance violation occurs or there is a risk of such a violation, LEG offers both employees and third parties the opportunity to submit information or complaints via its whistleblowing system.

These rules of procedure regulate the procedure for handling information and complaints at LEG.

1. Scope of application

These Rules of Procedure apply to the processing of all indications of possible or actual compliance violations, the processing of which is within LEG's area of responsibility. This includes suspected or actual violations of legal requirements, internal guidelines or LEG's Code of Conduct, as well as suspected or actual violations of human rights-related or environmental laws and due diligence obligations at LEG, its business partners or in their supply chain.

2. Complaint channels

Whistleblowers can use the following channels to submit tips or complaints:

a) Information can be submitted via LEG's digital reporting system:

https: //www.bkms-system.com/LEG

Tips can be submitted via the digital reporting system around the clock. If desired, whistleblowers can remain completely anonymous. Even if whistleblowers disclose their identity, confidentiality and the protection of personal data are guaranteed in any case.

Via the system, persons providing information - even if they are anonymous - can remain in contact with our company even after providing information. The use of the system is of course free of charge for the person providing the information.

b) Information can also be submitted in writing to the Compliance Officer:

Personal / Confidential
LEG Immobilien Gruppe
FAO the Compliance Officer
Flughafenstraße 99
40474 Düsseldorf

LEG employees have further internal reporting options at their disposal. In addition, LEG's "Group Works Agreement on the Introduction of a Whistleblowing System" („Konzernbetriebsvereinbarung über die Einführung eines Hinweisgebersystems“) applies to them. If these rules of procedure and the Group works agreement contradict each other, only the Group works agreement shall apply.

3. Procedural steps and principles

The processing of all incoming tips follows a structured process, which is described below.

LEG has obligated and authorised all employees involved in the processing of reports to process all reports in accordance with the principles of independence, impartiality, independence from instructions, diligence and confidentiality. They are bound to secrecy. Within the framework of a fair procedure, all relevant circumstances of the matter must be taken into account and the principle of proportionality must be observed.

a) Receipt of the message

After receipt of the report, whistleblowers receive an acknowledgement of receipt, usually within seven days after receipt of the report. A confirmation of receipt is not required if there is no possibility of contacting the whistleblower, e.g. in the case of anonymous reports.

b) Incoming inspection

The plausibility of the complaint will then be examined to determine whether there are sufficient indications (so-called initial suspicion) of a compliance violation within the meaning of the scope of application of this Guideline based on the submission.

The aim of the plausibility check is to determine whether there is a suspicious situation that makes it permissible and necessary to take further investigative or clarifying measures as well as possible preventive and remedial measures. If there is any uncertainty regarding the facts described, the whistleblower can be contacted, provided that contact is possible.

If the information is not plausible, no further processing takes place and the procedure ends. In this case, a reasoned response will be sent to the informant no later than three months after confirmation of receipt. No feedback is required if there is no possibility of contacting the person providing the information, e.g. in the case of anonymous information or if internal enquiries or investigations are affected and the rights of the persons who are the subject of a report or who are named in the report are impaired.

c) Investigation of the facts

If there is an initial suspicion of a compliance violation, it is examined which follow-up measures are necessary in the individual case. This includes, for example, the initiation of an internal investigation.

d) Remedial action

If the suspicion is substantiated or a compliance violation can be proven, effective and proportionate preventive and remedial measures are taken to adequately address the violation.

If the suspicion is not substantiated, the procedure is terminated and the person who provided the tip-off is informed accordingly. The feedback is sent no later than three months after confirmation of receipt of the tip-off. It does not apply if there is no possibility of contacting the person providing the tip-off, e.g. in the case of anonymous tips.

4. Duration of the procedure

The duration of the procedure strongly depends on the respective facts and can range from a few days and weeks to several months. In principle, the procedure is conducted by the company as efficiently as possible to a satisfactory solution and the whistleblower is kept informed of the measures taken and the further course of action. If whistleblowers use the digital reporting system, they should log in regularly and check their own case for new messages.

5. Responsibility for the procedure

The Legal & Compliance and Revision departments are responsible for setting up the complaints procedure or the whistleblower system.

Reports via the digital reporting system are received and processed by a small team of employees from these departments. When using the digital reporting system, questions or comments can be addressed directly to the responsible persons.

6. Protection from disadvantage or punishment

Whistleblowers need not fear any disadvantage or punishment as a result of their report. They are particularly protected by the Whistleblower Protection Act („Hinweisgeberschutzgesetz“) and the LEG Code of Conduct.

Among other things, the following measures serve to

Protection of the persons providing the information:

• the information or complaints are only processed by selected and specially trained staff (need-to-know principle),
• the tips or complaints, especially if conclusions can be drawn about the identity of the person making the tip, are treated confidentially.

LEG will not tolerate discrimination, intimidation or hostility of whistleblowers by LEG employees or other reprisals against the whistleblower by employees and will deal with it as a potential compliance violation.

The protection of whistleblowers does not cover situations in which incorrect information is reported intentionally or through gross negligence, the whistleblowing was done with improper intent, or measures that are demonstrably not related to the whistleblowing or were already decided or planned before the whistleblowing.