S1-1 – Policies Related to Own Workforce

All of the material IROs identified as part of the materiality assessment for the subtopics “Working conditions” and “Equal treatment and opportunities for all” are embedded in our long-term HR strategy, which aims to attract and retain highly skilled and satisfied employees in the long term. The HR strategy supports Vonovia’s business strategy.

Vonovia has identified a material financial opportunity in lower employee turnover and targeted recruitment of skilled workers through working conditions that are tailored to the needs of employees and the company, which will help it combat the prevailing shortage of skilled labor. This opportunity is directly linked to the material impacts on employee satisfaction

• through professional development opportunities,
• through opportunities for participation,
• due to fair remuneration and
• based on work-life balance.

The various subcomponents of our HR strategy address these impacts identified as described above, as well as the opportunity. The strategy was approved at Management Board level and is implemented, managed and developed centrally throughout the Group by the HR department. This also includes the business areas in Austria and Sweden.

The overarching objectives of this strategy are to secure the long-term success of Vonovia’s business and the associated jobs and, as a result, to attract qualified employees to Vonovia and keep them with the company in the long term.

This overarching strategic concept for HR has been integrated into our corporate management, with regard to sustainability aspects, via the Sustainability Performance Index (SPI), which includes two sub-indicators: employee satisfaction and the proportion of women in management positions at the first and second level below the Management Board. For detailed information on the SPI and the tracking of targets, please refer to ESRS 2 GOV-3 and S1-5.

In our quest to achieve our goals, we are using recruitment, targeted HR resource planning and the insourcing of skilled workers in technical areas and the trades to counteract the shortage of skilled workers and demographic change. Part of the concept also involves promoting the development of skilled workers and employees and retaining them at the company (talent management). At the same time, we are working on our organizational development and on establishing an innovative, open and dynamic corporate culture. This includes short, medium and long-term implementation and management phases embedded in a steering cycle at Management Board and Supervisory Board level that is supported by an overarching internal strategy process and is monitored by both this entity and the HR department with regard to the progress made.

Vonovia’s business strategy is bolstered by strategic HR modules, which manifested themselves in three parallel “horizons”: in the short term, the foundation is laid for good staff performance and its immediate requirements are prioritized and addressed, such as remuneration and recruitment issues, as well as the topic of equality and equal opportunities (first horizon). Our aim is to strengthen employer branding, establish talent and performance management processes and provide existing employees with even more targeted training, support and development opportunities as they progress on their individual career paths. In the medium term, strategic recruitment is to be used to attract further qualified specialists for new roles in the company’s core business, for example in procurement, sales, modernization and development, in order to provide HR support to Vonovia’s growth strategy. In addition, we intend to make increasing use of digitalization potential – including AI-supported solutions – to be able to meet the challenges of recruiting, which are brought about by the shortage of skilled workers, even more efficiently in the future (second horizon). In the long term, our HR strategy will focus on further developing and further establishing those aspects that promote leadership and corporate culture, in particular moves to promote gender equality and equality of opportunity within the company, as well as creating links with leadership concepts (third horizon).

The HR strategy is presented and made available as part of the steering cycle and in the corresponding implementation phases at management level. The responsible managers are tasked with implementing the measures derived from the strategic components referred to above in their business areas. Affected employees are also informed of any relevant strategic developments, changes and new features relating to their employment relationships before they are implemented through topic-specific information channels such as the intranet, video calls and (executive) emails. Regular employee surveys and the involvement of employee representatives allow employee interests to be incorporated into the (further) development of the HR strategy.

Vonovia uses the Code of Conduct, as the basis for addressing the material negative impact of a lack of a sense of belonging due to insufficient promotion of diversity and the associated strategy for “Promoting Workforce Diversity,” as a central guideline for behavior that is consistent with Vonovia’s values and regulations. The Code of Conduct sets out provisions governing aspects such as conduct, preventing corruption, conflicts of interest, information and data protection, discrimination, environmental protection and protecting company property. It applies to all Vonovia employees in Germany and has also been adopted in Austria and Sweden, with modifications to take account of country and organization-specific differences. In addition, reports of non-compliance (e.g., in suspected cases of discrimination or violence in the workplace) are submitted using the relevant whistleblowing channels (see S1-3) and, if the facts are confirmed, sanctions are imposed based on formalized processes.

Operational responsibility for the implementation, monitoring and further development of this concept is shared between the HR, Legal, Compliance and Data Protection, Corporate Communications and Internal Audit departments. Ultimate responsibility lies with the Management Board. The Code of Conduct takes the form of a Group works council agreement that was drafted and signed as a collaborative effort between the company and the Group Works Council.

The European legal framework in which Vonovia operates with its business model is strictly regulated and overseen in the markets in Germany, Austria and Sweden. This applies in particular to fundamentally enshrined human rights, to which Vonovia attaches great importance irrespective of the legal framework. Compliance with, and the fostering of, these rights is reflected in our ethos and mission statement. We adapt our guidelines to changing conditions as needed on a case-by-case business.

In our Declaration of Respect for Human Rights, which applies throughout the Group, we communicate our clear conviction for a pluralistic democratic society and zero tolerance of human rights violations and our commitment to respect human rights in all aspects of our business. We adhere to the core labor standards of the International Labour Organization (ILO), the UN Guiding Principles on Business and Human Rights, the principles of the UN Global Compact and the OECD Guidelines for Multinational Enterprises as well as complying with the Universal Declaration of Human Rights (UDHR). Our Code of Conduct also takes account of our stance regarding respect for human rights. We make both documents available on our corporate website.

From a human rights perspective, Vonovia’s business model means that compliance with labor and social standards on construction sites is of particular relevance. Some trade/construction activities in Germany are carried out by the company’s own technical service – and therefore by our employees. This lessens the risk of non-compliance with labor and social standards.

A due diligence process to avoid scenarios in which business activities have negative impacts on people and the environment forms the core of compliance with the minimum safeguards. Taking the OECD Guidelines as a basis, Vonovia has implemented all of the recommended due diligence steps. The analyses conducted in 2023 and 2024 with regard to human rights and environmental risks for our own operations and the supply chain are reviewed annually to ensure they are up to date and adjusted if necessary.

To address risks identified in relation to topics such as fair working conditions (adequate remuneration and social protection), freedom of association or anti-discrimination and equal treatment, we develop measures that we regularly review for appropriateness and effectiveness. Since 2023, for example, we have been offering an e-learning program to raise awareness of our human rights due diligence obligations among our employees. Vonovia has set up various confidential procedures that allow reports on potential abuses (such as human rights violations) by both internal and external parties, including anonymous reports. We conduct in-depth investigations, or have an external reporting office conduct them, into indications of human rights violations within our own operations or in the supply chain that come to our attention via the various formal reporting channels (see S1-3). Whistleblowers are given full protection from retaliation throughout the entire process.

As Vonovia operates in geographical areas (Germany, Austria and Sweden) where child labor, human trafficking and forced labor are prohibited and punishable by law, these issues are considered to entail low risks for the company based on a due diligence analysis. Consequently, these issues are not the main focus of Vonovia’s HR strategy. Vonovia complies stringently with the statutory provisions that apply in its business areas and explicitly rules out these forms of human rights violations by means of corresponding Group policies. As a result, there is no risk of human trafficking, forced labor or child labor. Nevertheless, we carry out regular risk analyses, and ad hoc risk analyses if required, for our own business and for our supply chain. We describe our approach to risk analysis and the risk areas in our Declaration of Respect for Human Rights, which we update on a regular basis.

The company uses its professional health and safety management policy to minimize potential hazards and promote a working atmosphere that effectively protects all employees from health risks in the workplace. We design working processes and structures that are conducive to good health and offer preventive health care programs as part of our corporate approach to health management.

Our Group guideline on occupational safety defines the occupational safety standard that applies throughout the Group. The company undertakes to assess health hazards in the workplace and to implement the necessary safeguards based on this assessment. The guideline thus serves to protect employees from possible risks and hazards as they go about their individual, day-to-day work as well as to prevent potential hazards in advance to the greatest extent possible. It defines the associated responsibilities and duties at Vonovia. The resulting instructions help managers to live up to their occupational safety responsibilities. In line with our Group policies, the Management Board is informed once a year about all occupational health and safety measures and the accident figures for the previous year.

Vonovia’s HR strategy, which explicitly includes preventing discrimination, covers the following grounds for discrimination: ethnic origin, skin color, gender, sexual orientation, gender identity, disability, age, religion, political opinion, national origin or social background, as well as other forms of discrimination covered by EU and national law.

A general ban on discrimination against people with disabilities is enshrined in Article 3 (3) of Germany’s constitution, the Basic Law (Grundgesetz), and in the Federal Participation Act (Bundesteilhabegesetz). This ban is substantiated by the objective of enabling participation and self-determination for people with disabilities, including in areas relevant to the labor market.

The German General Act on Equal Treatment (AGG) provides a framework – in Germany – for access to advertised jobs through the prohibition of discrimination under labor law. As a result, it also influences the management of recruitment and hiring processes, working conditions and the area of continuing professional development at Vonovia by virtue of the ban on discrimination under labor law. The Federal Disability Equality Act (BEinstG) in Austria and the Swedish Anti-discrimination Act (Diskrimineringslag) apply in a comparable framework. In addition to a strict ban on discrimination, Vonovia, as a private-sector company, is obliged to implement appropriate strategies to promote the employment of individuals with disabilities in its own operations. These are set out in a corresponding Group works agreement (the “Inclusion Agreement”) between the Group Works Council and the Group with regard to various areas of application (e.g., integration and employment of people with disabilities, management training, workstation design and professional development). The various Group companies (e.g., the holding company, customer service, engineering, etc.) also have dedicated representatives for severely disabled employees who are on hand to answer formal or work-related questions. If cases of discrimination arise, individuals with disabilities can use our reporting channels (e.g., AGG mailbox, hotline, ombudsperson), which are used to record and investigate suspected cases and take appropriate action if a case of discrimination or harassment is confirmed (see also G1-3).