G1-4 – Incidents of Corruption and Bribery

To assess the effectiveness and performance of our anti-bribery and anti-corruption policies, Vonovia tracks the number of legal convictions related to bribery and corruption. In the fiscal year, the number of court convictions for bribery and corruption offenses was zero (2024: 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 target of achieving zero corruption and bribery incidents resulting in court convictions. This applies to both our own operations 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. Since no convictions for bribery and corruption occurred during the fiscal year, we have achieved our objective in this regard.

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.

Since there were no bribery or corruption convictions during the fiscal year, no individual case-specific measures were taken to address breaches of procedure and standards to combat anti-corruption and anti-bribery.

The number of confirmed incidents of bribery and corruption, both among our employees and business partners, was 7 in the fiscal year (2024: 2). The number of confirmed bribery and corruption cases takes into account the Care segment that was sold during the fiscal year up until the date of the business area’s discontinuation. The cases that materialized in 2025 concerned the rental of apartments in exchange for commission payments. One case involved potential fraudulent actions related to collaboration with subcontractors. The investigations that Vonovia launched without delay resulted in appropriate action being taken. Overall, the number of confirmed cases in this fiscal year is attributable to the further development of the compliance management system and process improvements. In line with our objective of maintaining the 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 target directly aligns with our policy objectives for maintaining a corruption-free organization. Since seven 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, or business partners of Vonovia are convicted of corruption or bribery, the Compliance and Data Protection department informs the Management Board. The department also receives monthly reports from subsidiaries in Sweden and Austria. In cases of confirmed corruption involving business partners, the business relationship is terminated or not renewed.

All of the compliance-related concerns reported during the fiscal year, where these were confirmed, were minor. This does not include two cases from 2023 and 2024 as well as one case of bribery and corruption from the current reporting year. In the fiscal year, own employees were dismissed or disciplined in two cases due to corruption or bribery allegations.

There were two confirmed cases in the reporting year related to contracts with business partners that resulted in these contracts being terminated or not renewed.

No public legal proceedings were initiated against the company or its employees during the reporting period. As regards a matter dating back to 2023, criminal proceedings commenced in the reporting year, culminating in the conviction of two former Vonovia employees in January 2026. Vonovia itself was involved in the proceedings as the injured party and joint plaintiff.