G1-4 – Incidents of Corruption and Bribery

To assess the effectiveness and performance of our anti-corruption policies, Vonovia tracks the number of legal convictions related to corruption and bribery. In the fiscal year, the number of court convictions for bribery and corruption offenses was zero (2023: zero). During the fiscal year, no convictions were recorded, and consequently there were no fines for violation of anti-corruption and anti-bribery laws.

In line with our objective of maintaining the company free of corruption and bribery, we set an annual quantitative and results-oriented target of achieving zero legal convictions for corruption and bribery offenses, which applies to both our business areas and our business partners. Stakeholders were not involved in setting these targets. This quantified target directly aligns with our policy objectives for maintaining a corruption-free organization, and since no convictions for bribery and corruption occurred during the fiscal year, we have achieved our objective.

Ongoing investigations are not included in this metric. The Compliance and Data Protection department monitors compliance with applicable regulations across the Group and oversees any ongoing legal proceedings and related outcomes to ensure target achievement. In the event that Vonovia is subject to fines for bribery or corruption violations, the Compliance and Data Protection department immediately informs both the Management Board and the Supervisory Board. The department also receives monthly reports from subsidiaries in Sweden and Austria, while subsidiaries within the Care segment and SYNVIA provide ad-hoc or on-request reports.

Since no convictions were recorded during the reporting year, no corrective actions were necessary to address breaches of standards of anti-corruption and anti-bribery.

The number of confirmed incidents of bribery and corruption, both among our employees and business partners, was 2 in the fiscal year (2023: 1). Both incidents involved potential fraudulent actions related to collaboration with subcontractors. The 2023 incident involved certain (mostly former) operational-level employees in the technical area, who were involved in questionable transactions with subcontractors, causing damage to Vonovia. Vonovia immediately launched an extensive internal investigation with the support of the law firm Hengeler Mueller and the auditing firm Deloitte, which was concluded within the fiscal year. Additionally, corresponding further development measures of the ICS were implemented.

In line with our objective of maintaining a company free of corruption and bribery, we set an annual quantitative target of achieving zero confirmed corruption and bribery incidents. This applies to both our business operations and our business partners. Stakeholders were not involved in setting these targets. This quantified goal directly aligns with our policy objectives for maintaining a corruption-free organization; since two confirmed cases of bribery and corruption occurred during the fiscal year, we did not achieve our objective.

The metric refers to confirmed incidents submitted through the compliance mailbox or other whistleblowing channels, which were verified by the Compliance and Data Protection department through an internal investigation or confirmed by a legally binding court ruling.

Just as with the number of convictions, the Compliance and Data Protection department monitors compliance with applicable regulations across the Group and oversees any ongoing legal proceedings and related outcomes to ensure target achievement. In the event that Vonovia employees are convicted of corruption or bribery and subsequently receive a written warning or are dismissed, the Compliance and Data Protection department informs the Management Board. In the event that any of Vonovia’s business partners has been convicted of corruption or bribery, the Compliance and Data Protection department also informs the Management Board. The department also receives monthly reports from subsidiaries in Sweden and Austria, while subsidiaries within the Care segment and SYNVIA provide ad-hoc or on-request reports. In cases of confirmed corruption involving business partners, the business relationship is terminated or not renewed.

The reported compliance-related concerns during the fiscal year were all minor, if confirmed at all. The only two exceptions are the previously confirmed incidents of bribery and corruption. In the fiscal year, own employees were dismissed or disciplined in the two previously reported confirmed incidents of corruption or bribery allegations.

No contracts with business partners were terminated or not renewed due to corruption or bribery-related violations during the reporting year.

No public legal proceedings were initiated against the company or its employees during the reporting period, and there are no cases from previous reporting years. Regarding the incident from 2023, a public prosecutor's investigation is ongoing, in which Vonovia is involved as the aggrieved party. A court proceeding has not yet begun.