LEG Immobilien

Reference: page 125

LEG Immobilien SE has a three-member Management Board responsible for managing the company and a six-member Supervisory Board acting as a controlling body. There is no employee representative on the Supervisory Board, but elected co-determination bodies (Group, company, regional and division works' councils and an economic committee) exist. The Supervisory Board members meet GCGC 2022 requirements in full, and 100% are independent as defined by the GCGC. Both boards are split 67% male / 33% female; the 33% women's quota for each board was extended to 31 December 2029. Sustainability oversight was handled by a dedicated ESG Committee (established 2022), whose members held relevant ESG expertise; from 2025 it was merged into a joint Risk, Audit and ESG Committee. Sustainability-related risks are recorded in the quarterly risk inventory; responsibility for monitoring sustainability impacts and opportunities lies with the Management Board, particularly the CFO. The committee reports to the Supervisory Board.

Reference: page 126

The Management Board is actively involved in sustainability matters, regularly participating in internal meetings and being intensively involved in the revision of the sustainability strategy. It kept the Supervisory Board transparently informed about all strategic developments and actively sought its involvement. The ESG Committee was the point of contact for updating the sustainability strategy, meeting four times in 2024, and the ESG Committee report is an integral part of every Supervisory Board meeting. At regular meetings of the Supervisory Board and its committees, both boards discussed current challenges in the residential real estate sector on an event-related basis, and extraordinary meetings and calls were held when necessary. The Supervisory Board was involved in the development of corporate strategy. Both boards address all material impacts, risks and opportunities (listed in the SBM-3 chapter) and are provided with relevant documents on a quarterly basis and for each meeting.

Reference: page 127

The Management Board remuneration system includes short-term (STI) and long-term (LTI) ESG criteria tied to financial incentives and defined annually by the Supervisory Board. For 2024, environmental, social and governance targets were set; for 2025 only environmental STI and LTI targets were defined, reflecting the sustainability strategy's stronger focus on environment and climate change mitigation. ESG objectives carry a 20% weighting in both STI and LTI target values; in the 2024 STI each E, S and G target accounts for 6.66 percentage points and in the LTI each accounts for 10 percentage points (no long-term G target was agreed). Targets are assigned quantitative or qualitative criteria with minimum and maximum values. For 2024 STI, the environmental target (4,000 t CO2 reduction) was exceeded at 6,639 t; social and governance targets were also exceeded. The LTI 2021-2024 environmental (29% vs 10%) and social (Trust Index 73.5%) targets were exceeded. Details appear in the remuneration report.

Reference: page 129

LEG provides a due diligence statement in the form of a mapping table that links the core elements of due diligence to the relevant references in the Sustainability Report. The five core elements are: (a) integrating due diligence into governance, strategy and business model (referencing ESRS 2 GOV-2, GOV-3 and SBM-3); (b) engaging affected stakeholders in all key stages of due diligence (referencing ESRS 2 SBM-2, IRO-1, and topical standards E1-2, S1-1, S1-2, S4-1, S4-2); (c) identifying and assessing adverse impacts (referencing ESRS 2 BP-2, SBM-3, IRO-1 and E1 IRO-1); (d) taking action to address those adverse impacts (referencing ESRS 2 BP-2, E1-1, E1-3, multiple S1 and S4 disclosures); and (e) tracking the effectiveness of these efforts and communicating (referencing ESRS 2 GOV-2, E1-4, and several S1 and S4 disclosures). The statement maps each element to specific paragraph references within the report.

Reference: page 129

General internal monitoring safeguards the sustainability reporting, coordinated by and under the responsibility of the ESG unit, with responsible departments consulted to provide data and qualitative disclosures. The ESG unit checks information for plausibility using a multi-control approach, an iterative process aiming to ensure completeness and accuracy, supported by a timeline and implementation plan; a review by the Management Board is a further monitoring entity. A method for assessing and prioritising risks within estimated values does not yet exist and is limited by the multi-control principle. For the 2024 reporting year, LEG had not yet implemented an internal control system for sustainability reporting, but intends during 2025 to increasingly integrate sustainability reporting into the internal control system. Identified risks include data risks from incomplete data or low data quality (reduced via remotely readable heating-data devices) and resource risks (minimised through automation and digitalisation). In future, results of the risk assessment and internal controls will be reported at least twice a year to the Management and Supervisory Boards.

Reference: page 130

LEG is the second-largest residential property company in Germany with a portfolio of 164,067 rental units (excluding commercial units) at around 240 locations, with 80% of the portfolio in North Rhine-Westphalia. Its activities are assigned to the ESRS "Real Estate and Services" (RRS) sector and the "Energy Production & Utilities" (EEU) sector via subsidiary EnergieServicePlus and the Siegerland biomass heating power plant. Customers are primarily people with low to medium incomes in the "affordable housing" segment. In 2024 revenue was EUR 1,557.5 million in RRS and EUR 16.5 million in EEU; LEG is not active in other ESRS sectors, including fossil fuels. As at 31 December 2024 LEG had 2,087 employees. The sustainability strategy targets a 47% reduction in Scope 1 and 2 emissions by 2030 (validated by SBTi on 5 December 2024) and near GHG neutrality by 2045, pursued via three measure clusters: emission-efficient heat supply (50-55%), reduced energy requirements (30-35%) and energetic refurbishment (10-15%). Key input factors include the property portfolio, energy sources, qualified employees, IT infrastructure and capital.

Reference: page 132

When developing the materiality analysis, key stakeholders were identified using a scoring model evaluating "influence" and "interest", and those identified as particularly important were integrated into the process, which was overseen by an external consultancy. The most important stakeholders include tenants and customers, shareholders, employees, the Management Board, the Supervisory Board, debt investors, banks, insurance companies, politicians and suppliers. A panel of experts with internal stakeholder representatives was established to cover employee, customer, investor, service-provider and business-partner perspectives; employees were also consulted via survey to validate topics. External stakeholders (investors, banks, insurance companies, suppliers and tenants) were included by survey, and results of the VdW industry survey fed in political perspectives. Stakeholder perspectives on strategy and business model were obtained via survey responses and analysed and validated in the materiality analysis, with the Management and Supervisory Boards informed at an ESG Committee meeting. The survey results broadly confirmed the existing strategy. Further stakeholder exchange is planned every two years.

Reference: page 133

LEG presents its material impacts, risks and opportunities (IROs) in a register table classified by ESRS standard, value chain (own activities EG, upstream VW, downstream NW), description, influence on the business model/strategy, actions, and impact on people/environment. Only four topical standards are material: E1 (Climate Change), S1 (Own Workforce), S4 (Consumers and End-users), and G1 (Business Conduct); E2, E3, E4, E5, S2 and S3 are deemed immaterial. Material E1 IROs cover the building portfolio's high carbon footprint, transformation to a GHG-neutral portfolio, lower tenant incidental costs, and industry role-model effects, with risks such as investment backlog, refurbishment costs, raw-material/energy price rises and regulatory change. S1 covers employee health, satisfaction, job security, diversity and data protection; S4 covers affordable housing, integration of immigrants/refugees, anti-discrimination and tenant data protection; G1 covers compliance, lobbying, corporate culture and whistleblower protection. Material IROs relate to the German rental portfolio. The financial effects of material risks and opportunities amounted to around EUR 85 million for 2024; no business-model-critical social or governance risks were identified.

Reference: page 137

To identify material IROs, LEG first compiled a longlist of potentially relevant sustainability topics, drawing on the previous materiality analysis, the ESRS 1 (AR16) topic list, and other sources (general and sectoral compliance standards, peer reports and ratings). This was narrowed to a shortlist that formed the basis of the stakeholder survey, which evaluated topics by actual/potential relevance and proposed IROs; the existing risk inventory and industry materials also informed IRO identification. LEG's three value chains were defined first to capture key activities and business relationships. Impacts were assessed over short, medium and long-term horizons using time factors of 0.9 (medium) and 0.8 (long), distinguishing actual and potential impacts (probability of occurrence scaled 10-100%), with severity assessed by extent and scope (and irreversibility for negative impacts). The materiality threshold for impacts was set at >=3 on a 0-5 scale (per the EFRAG draft guidelines, using an average figure), and >=2 for risks and opportunities. Materiality was assessed at IRO level; if any IRO for a standard is material, the standard is material. LEG also reviewed environmental pollution, water, biodiversity and resource topics, owning no sites near vulnerable biodiversity areas.

Reference: page 139

LEG presents a content index of the disclosure requirements in ESRS covered by its sustainability statement, including a table cross-referencing datapoints derived from EU climate legislation (e.g. ESRS E1-1 Transition plan, linked to Regulation (EU) 2021/1119, to Chapter 2.2.2.1). Based on the materiality analysis, information on policies, actions, metrics and targets for material sustainability aspects is provided in the chapters on the topic-specific standards ESRS E1, S1, S4 and G1. Correspondingly, ESRS E2, E3, E4, E5, S2 and S3 are deemed immaterial and are not subject to reporting. A full table of disclosure requirements and related datapoints stemming from other EU legislation is provided in the annex. The preceding IRO-1 section lists the 15 material ESRS sub-topics underlying these standards, spanning Climate Change (energy, mitigation, adaptation), Own Workforce (working conditions, equal treatment, other work-related rights), Consumers and End-users, Business Conduct and Responsible Business Practices.

Reference: page 154

LEG's transition plan is derived from its sustainability strategy 2030 with climate-related criteria embedded in ESG objectives. The long-term aim is to reduce GHG emissions to 0-<5 kg CO2e/m2 by 2045, contributing to Germany's climate target. By 2030, LEG targets reducing around 47% of Scope 1 and 2 emissions versus the 2019 base year, validated by SBTi (reconfirmed December 2024) and aligned with the Paris 1.5-degree goal. The decarbonisation pathway starts at 39.5 kg CO2e/m2 (2019), reached 29.1 kg CO2e/m2 in 2024 (26% reduction), and targets 20.9 kg CO2e/m2 by 2030. Scope 3.3 and 3.13 emissions are to fall 27.5% by 2030. The strategy spans three clusters: emission-efficient heat supply (50-55% of reductions), reduced energy requirements (30-35%) and energetic refurbishment (10-15%). Around EUR 1 billion is planned for investment from 2019. Around 53% of locked-in GHG emissions versus 2019 will remain in 2030. The plan is approved by the Management and Supervisory Boards.

Reference: page 159

LEG's sustainability strategy addresses management of material impacts, risks and opportunities connected with climate change mitigation and adaptation, with the Management Board responsible for implementation. Beyond the strategy document, LEG has published several guidelines on climate change mitigation that provide the framework for its business activities, available on the LEG website. Material impacts, risks and opportunities are analysed and measured, and mitigation actions planned. Key climate risks include downgrading of properties (stranded assets) due to investment backlogs from rising regulatory requirements, falling property values from location/construction type, and price increases for raw materials, energy and services. These are countered through prioritised modernisation, climate risk analysis to identify at-risk buildings, construction measures against flooding and sea level rise, insurance, targeted supplier selection and framework agreements. Reducing the high carbon footprint of buildings through emission-efficient optimisations and switching from fossil fuels to renewable energy creates positive environmental impacts and new business opportunities via dekarbo, termios and RENOWATE.

Reference: page 160

Within its three clusters (emission-efficient heat supply, reduced energy requirements and energetic refurbishment), LEG has developed actions and resources to significantly cut GHG emissions. For climate change adaptation, the entire property portfolio is currently insured against extreme weather events to minimise building damage from acute or chronic climate risks. Compared with base year 2019, LEG saved 10.4 kg CO2e/m2 (Scope 1 and 2, market-based) in 2024, a 26% reduction. LEG targets 20.9 kg CO2e/m2 by 2030 and 0 to below 5 kg CO2e/m2 by 2045, an absolute reduction of 374,400 tonnes CO2e (87.5%). Main reduction levers contribute up to 55% (heat supply), 35% (reduced energy requirements) and 15% (energy-efficient renovation) by 2030. The investment volume was reduced from EUR 1.4-1.6 billion to approximately EUR 1.0 billion through technical innovations such as air-to-air heat pumps. LEG also depends on external resources such as construction materials, qualified staff, and equity and debt capital.

Reference: page 161

LEG aims to reduce around 47% of Scope 1 and Scope 2 emissions (market-based) by 2030 versus 2019, and to reduce GHG emissions to 0 to below 5 kg CO2e/m2 by 2045 (an 87.5% to 100% reduction). Scope 3 emissions in the upstream and downstream value chain are targeted to fall around 28% by 2030 versus the 2019 base year. The short-term targets have been validated by the SBTi as science-based and consistent with the Paris 1.5-degree target. The GHG reduction targets relate only to the company's own business activities. Per the E1-4 table, direct (Scope 1+2) GHG emissions are 427,777 tonnes CO2e in 2019, falling to 226,589 by 2030 and 0 by 2050, with reductions split across emission-efficient heat supply, reduced energy requirements and energetic refurbishment. Gross Scope 3 (3.3 and 3.13) emissions are 290,086 tonnes (2019), 210,312 (2030) and 0 (2050). The 2019 base year was adjusted using DWD climate factors and for the late-2021 Adler portfolio acquisition. Targets were validated by SBTi to 2030 and continue to 2045.

Reference: page 162

Total energy consumption was 2,222,692 MWh in 2019, 2,278,196 MWh in 2023 and 2,223,598 MWh in 2024. Total fossil energy consumption fell from 1,874,364 MWh (2019) to 1,609,970 MWh (2024), with the fossil share dropping from 84.7% (2019) to 72.4% (2024). Fossil sources in 2024 included natural gas (836,944 MWh), purchased electricity/heat/steam/cooling from fossil sources (726,988 MWh), crude oil and petroleum products (20,896 MWh), other fossil sources (20,393 MWh) and coal/coal products (4,749 MWh). Total renewable energy consumption rose from 348,328 MWh (2019) to 613,628 MWh (2024), a 27.6% share, comprising fuel from renewable sources including biomass (491,657 MWh), purchased renewable electricity/heat/steam/cooling (120,084 MWh) and self-generated non-fuel renewable energy (1,887 MWh). Nuclear consumption was zero. Renewable energy generation was 105,999 MWh in 2024. As LEG operates only in high climate-impact sectors (Real Estate & Services and Energy Production & Utilities), all disclosures and energy intensity refer to these sectors.

Reference: page 163

For climate-adjusted emissions in 2024: Scope 1 gross emissions were 234,416 t CO2e (down 21% from 295,830 in 2019); location-based Scope 2 was 134,592 t CO2e and market-based Scope 2 was 78,805 t CO2e (down 40% from 131,947 in 2019). Total indirect Scope 3 gross emissions were 245,001 t CO2e (down 16% from 290,086 in 2019), comprising category 3.3 fuel and energy-related activities (85,064 t) and 3.13 downstream leased assets (159,938 t). Total GHG emissions were 614,010 t CO2e (location-based) and 558,223 t CO2e (market-based) in 2024. By 2030 totals are targeted at 369,469 (location-based) and 125,171 (market-based) t CO2e, reaching 0 by 2050. GHG intensity per net revenue (market-based) was 631.3 tCO2e/million euros and per m2 was 29.1 tCO2e/m2 in 2024. GHG accounting follows the GHG Protocol covering the consolidated group, excluding green ventures dekarbo, termios and RENOWATE not under operational control. Only Scope 3.3 and 3.13 are reported, covering over 90% of total Scope 3; 0% of Scope 3 used primary data. The 2019 base year reflects the Adler acquisition and methodology changes.

Reference: page 167

LEG maintains a suite of internal policies governing its own workforce, for which the Management Board is responsible: Declaration of fundamental values, Sustainability model, Code of Conduct, Policy on Human Rights and Environment (including the declaration on respect for human rights and the environment), group works agreements on professional conduct and the whistleblower system, agreements on personnel development, regulations on equal pay according to requirements profile and work remit, agreements on flexible working hours and work location, partial retirement, internal integration management, an Anti-corruption policy, and money laundering policies. LEG has appointed a Disabilities Officer, Bullying Officer and Human Rights Officer. Its commitment to respecting human rights is based on the UN Guiding Principles on Business and Human Rights, the ILO core labour standards, the OECD Guidelines, the UN Global Compact (member since 2021) and the German General Act on Equal Treatment (AGG). The Employees and Diversity Policy commits LEG to non-discrimination regardless of ethnic background, religion, gender, disability, age or sexual orientation. Specific policies address human trafficking, forced/compulsory labour and child labour. An internal Health and Safety Office monitors statutory and internal health and safety regulations.

Reference: page 169

LEG engages with its workforce and workers' representatives through regular meetings (monthly, quarterly or twice-yearly depending on the committee) with the works councils, where topics including discrimination can be raised. A due diligence committee made up of representatives from Legal and Compliance, Procurement, ESG, HR and risk management meets quarterly; HR contributes employee impacts and work orders can result. Employee perspectives are contributed via co-determination bodies and collective bargaining with the trade union ver.di, and via the disabilities representative (SBV) under Section 178 (1) SGB IX. Direct contributions include the diversity day (annually in May), diversity dinner, a yearly mentoring programme pairing employees with management-level mentors, a Female Empowerment programme, the FRED annual review, and an always-available digital whistleblower system that can be used anonymously. The Head of Legal and Compliance, Internal Audit, HR, Committees and IBM hold operational responsibility, with the CEO holding overall responsibility. The efficacy of these actions is not measured, but feedback is possible via the works council, the whistleblower system and employee satisfaction surveys.

Reference: page 169

LEG employees can raise concerns with their supervisors, the works council, the Compliance Officer, the HR department or Internal Audit, and via a digital whistleblower system that permits anonymous reports of discrimination and (sexual) harassment under the Group works agreement. Reports are investigated by the Compliance Officer and Internal Audit, with principles agreed with the Group works council designed to protect both whistleblowers and those wrongly accused and to ensure quick feedback. Employees can also raise complaints or improvement proposals during the FRED annual review (or similar TSP process) and at staff meetings governed under Sections 81 IV, 82 II, 83 I and 84 I BetrVG, where they may invite a works council member. The Legal department maintains a list of all compliance-related cases and reports to the Management Board (CEO) and the Supervisory Board's Audit Committee. The criteria of the Whistleblower Protection Act were used as the basis for these measures, and their effectiveness is regularly audited and certified by the ICG. Compliance training is held at onboarding and annually.

Reference: page 170

LEG implements measures to minimise negative impacts and risks and promote positive effects for employees working in Germany, with hazards determined through risk assessments by location and employment group. Numerous works agreements were concluded, including a company health management system to prevent work-related stress absences, offering road safety training, mental-health seminars and stab-proof vests. To address conflict situations in a tense tenant market, LEG offers conflict seminars, self-defence courses and a supervision programme. Manual-activity employees receive annual occupational safety training and protective clothing. Most employees benefit from in-house collective agreements and statutory co-determination. Flexitime and mobile/home working support work-life balance, and company accident insurance supplements statutory cover. Diversity is promoted through mentoring programmes, diversity dinners and days, and a 2024 Female Empowerment programme. Partial retirement is offered to older employees (except TSP). Employee data protection is managed via authorisation and deletion concepts. Effectiveness is measured via the mental-stress risk assessment (every 3 years) and the "Great Place to Work" employee survey (every 2 years). A project addresses the Hazardous Substances Ordinance cost risk.

Reference: page 172

The Supervisory Board set a target for the Management Board's variable remuneration (STI 2024) to use 100 LEG employee hours for the design, organisation or implementation of intercultural projects by 31 December 2024; a total of 665 employee hours were used, exceeding the target. The selected variable is the improvement in the Trust Index determined by an external research and consultancy institute via the "Great Place to Work" employee survey, reflecting the development and interaction between company and employees on corporate culture. The 2024 attainment factor was based on the development of average survey responses between 2022 and 2024. Results were discussed with management teams, and workshops were planned with employees with specific steps to improve working conditions. The target for 100% attainment was set at 66% (also the baseline value); a result of 73.5% was achieved, so the target was exceeded. The workforce and workforce representatives are not directly involved in target agreement, deriving lessons or improvements as a result of company performance. The target is described in Chapter 1.1.3.3.

Reference: page 173

As of 31 December 2024, LEG had 2,087 employees (heads), comprising 1,345 male and 742 female, with 0 diverse and 0 with no information provided. Employee fluctuation was 229 (a ratio of 11.0%). By contract type, 1,946 employees had open-ended contracts (677 female, 1,269 male) and 141 had temporary contracts (65 female, 76 male); there were 0 on-call employees. The data include all LEG employees and also include 100 employees of LEG Nord FM, which was sold on 31 December 2024. Fixed-term contracts are based on legal requirements and are usually related to factual reasons, in particular parental leave replacements, with other reasons being case-specific such as time limits for one-off projects. Further employee key figures are available in the "Employees" chapter of the management report.

Reference: page 173

At the highest level of management, which LEG defines as the Management Board, there were 3 members: 2 male (67%) and 1 female (33%), with 0 diverse (0%). By age structure, the workforce of 2,087 comprised 334 employees under 30 years, 1,058 employees aged 30-50 years, and 695 employees over 50 years.

Reference: page 173

All LEG employees receive adequate wages in compliance with the relevant reference values. These wages are guaranteed through collective agreements as well as via the statutory minimum wage.

Reference: page 174

100% of LEG employees are covered by occupational health and safety measures. LEG sets out its understanding of reportable workplace accidents: minor injuries such as paper cuts or bruises not requiring initial treatment do not count, whereas injuries causing severe headache or other physical pain that limit ability to work do count; a single instance of psychological stress is not counted, but multiple entries by one employee within 10 working days lead to a limited ability to work. Work-related accidents are only those occurring after crossing the threshold of the office building (first workplace) and related to the person's original work; commuting accidents count only if work-related, while accidents from home to first work, during breaks, or at team events and celebrations are excluded. There were 0 deaths in the company workforce due to workplace-related injuries and work-related illness, and 0 deaths for other employees working at company sites. There were 51 notifiable workplace accidents among permanent employees, with a proportion of 17.1.

Reference: page 174

100% of LEG employees (male, female and diverse) are entitled to family-related leave, including maternity leave, parental leave/paternity leave and leave for family caregivers. Regarding the proportion taking family-related leave: mandatory maternity leave was taken by 0% of male, 3% of female and 0% of diverse employees (1% total); parental leave by 3% of male, 6% of female and 0% of diverse employees (4% total); and care leave by 0% of male, 0% of female and 0% of diverse employees (0% total).

Reference: page 174

The majority of LEG employees are covered by the LEG collective agreement, which ensures that the same work is paid equally; this is reflected in the gender pay gap. In 2024, the average gross hourly salary of female employees at LEG was 6.57% higher than that of men. The gender pay gap was determined by setting the gross average earnings per hour of male employees in relation to that of female employees, taking into account all actual remuneration components settled in the financial year, including non-cash benefits such as company cars or other subsidies. Productive hours were analysed for all employees subject to working time recording; for others (including TSP or LEG managers) the productive hours were mathematically determined. The total annual compensation ratio of the highest-paid individual to the median annual total compensation of all employees (excluding the highest-paid individual) is 57.4.

Reference: page 176

LEG has established a Code of Conduct setting out ethical and compliance standards for all persons associated with the company, including tenants, aiming to promote a culture of integrity and strengthen customer trust. LEG commits to respecting internationally recognised human rights, based on the UN Guiding Principles on Business and Human Rights, and the equal treatment of all customers; discrimination based on ethnic background, gender, religion, disability, age or sexual orientation is not tolerated. These strategies are the responsibility of the Management Board. Because processing customers' personal data is integral to operations, LEG has established a data protection management system whose regulatory heart is the Group-binding data protection policy, setting consistent standards for collecting, processing and using tenants' personal data under statutory law. It is supplemented by procedural guidelines and employee training (in-person onboarding plus annual digital courses with test questions). LEG references Article 3 of the German constitution and the General Act on Equal Treatment (AGG), the UN Universal Declaration of Human Rights, the Diversity Charter (joined 2019), the GDPR and the BDSG. A Customer Advisory Council promotes direct dialogue with tenants. There were no cases of non-compliance with the UN Guiding Principles, the ILO Declaration or the OECD Guidelines affecting consumers or end-users.

Reference: page 178

LEG attaches great importance to involving its customers, including vulnerable groups such as people with a migration background, in important decisions, and has established several engagement mechanisms. A central element is the Customer Advisory Board, founded at the end of 2019 as a permanent institution for regular direct exchange; it meets once a quarter and is currently made up of 13 tenant representatives from all branches who are actively involved in decision-making for district development and the development and improvement of services. In the "customer talk" format, LEG's CEO meets existing and new tenants and residents on site three to four times a year to present projects and address concerns. LEG also conducts quarterly customer satisfaction surveys via an online questionnaire, plus direct contact-point surveys in departments such as Central Customer Service, Rent Management and Operating Costs. Surveys are carried out jointly with AktivBo GmbH, which sends invitations, collects and evaluates data and provides results only in anonymised form. Operational responsibility for surveys lies with the Quality Management team (indirectly subordinate to the COO); overarching responsibility lies with the Management Board, with the CEO responsible for the department and the Supervisory Board's Risk, Audit and ESG Committee responsible for data protection.

Reference: page 179

Breaches of data protection regarding tenant or customer-related data due to errors or misuse were identified as a negative impact, and LEG has implemented various measures to handle and prevent such occurrences. LEG operates a compliance management system (CMS) bundling measures for legal and internal compliance, including data protection, based on the criteria of the Whistleblower Protection Act and regularly audited and certified by the ICG. The data protection management team and the Data Protection Officer serve as central contact points. Defined communication channels exist for employees, tenants, business partners and supervisory authorities via the Privacy address (privacy@leg-wohnen.de) or the Data Protection Officer, with contact details on the homepage and intranet. Technical and organisational measures safeguard data security. Employees must report data protection violations immediately within statutory deadlines. LEG has implemented an electronic whistleblower system available around the clock to both employees and external third parties, allowing anonymous reports and guaranteeing no negative consequences for those reporting. The team continually monitors the Privacy address, and the system's efficacy is reviewed in regular weekly meetings with the external Data Protection Officer, Compliance Officer and other relevant positions, supported by regular audits and training.

Reference: page 180

LEG adopted measures relating to material impacts on consumers and end-users in the 2024 reporting year; these are integral to LEG, are understood as ongoing and are continuously adapted in the business model, so a description of expected results is not feasible. No new measures were established in the 2024 financial year. The measures relate to the customer and thus the downstream value chain; all LEG customers live in Germany. LEG is guided by the "honourable merchant" role model, with values summarised in the Code of Conduct. To address the negative impact of data protection breaches, LEG uses its CMS, the data protection management team and Data Protection Officer, and defined communication channels. To promote positive impacts, LEG provides affordable housing, helping avoid the fear of losing a home, contributes to integrating immigrants and refugees, avoids discrimination in housing allocation, and reduces operating costs through energy-efficiency measures. Customer satisfaction surveys (jointly with LEG Management GmbH, LEG Wohnen NRW GmbH and AktivBo GmbH, anonymised) help record and improve satisfaction. Data protection effectiveness is pursued via preliminary reviews, data protection impact assessments and technical and organisational measures. LEG has a Human Rights Officer and a due diligence committee handling supply chain obligations.

Reference: page 181

In order to avoid negative effects and promote positive ones, LEG has set a target in the area of data protection. This target is also in line with the STI 2024 (short-term incentive), as the IT security training also covers the topic of data protection, among other things. A description of the goal and its reference to the sustainability strategy is explained in chapter 1.1.3.3. Through this, LEG employees are sensitised to data protection issues, including in connection with customer data and especially in the IT context. There was no involvement of stakeholders in setting the target. The target is thus intended to ensure that customers and their data are protected accordingly.

Reference: page 183

LEG's corporate policy and culture, the responsibility of the Management Board, emphasise compliance with legal and internal requirements, supported by the Code of Conduct, the Anti-Corruption Directive, standardised rental processes and contracts, and clear purchasing guidelines. The corporate culture is based on principles set out in a declaration of fundamental values, including fair interactions with customers, employees, investors, business partners and society, and is evaluated through regular employee surveys and feedback mechanisms. LEG provides internal and external whistleblowers with an electronic system enabling around-the-clock, anonymous reports of compliance breaches; external whistleblowers may also write directly to the Compliance Officer. Upon receiving a notification, the complaint is checked for plausibility, and if plausible the Management Board (or the Chair of the Risk, Audit and ESG Committee where a Board member is concerned) is informed and consults the Compliance Officer to commission an investigation. Confirmed breaches are punished appropriately regardless of position (zero tolerance), with equal treatment of equal breaches. Whistleblowers are protected under the Whistleblower Protection Act and Code of Conduct; reports are handled confidentially on a need-to-know basis and reprisals are not tolerated. Anti-corruption measures include an anti-corruption directive and regular employee training. LEG never uses intermediaries, as rental employees are particularly at risk of corruption and bribery.

Reference: page 185

Prevention measures against corruption and bribery include training sessions, intranet information, information sheets and advice from the Compliance Officer. Detection measures include the electronic whistleblower system and routine audits by Internal Audit. All reports are investigated through structured processing set out in the rules of procedure for the compliance whistleblower system and the complaints procedure under the German Supply Chain Due Diligence Act; if a breach is identified, proportionate preventive and remediation measures (such as special training) are taken. Where a breach is suspected, investigation is carried out by Internal Audit or an external third party, ensuring separation between the roles of management/Compliance Officer and the senior management involved in prevention and detection. The Management Board informs the Supervisory Board and Risk, Audit and ESG Committee of compliance breaches through "Governance, Risk and Compliance" reporting per Section 107 III AktG. LEG's compliance management system (CMS) underpins this, with the Code of Conduct, anti-corruption policy and Business Partner Code of Conduct defining standards on conflicts of interest, gifts and bribery. All employees and senior management receive regular corruption-risk training; new employees train quarterly and all complete annual online refresher courses, with ad-hoc training for high-risk rental positions. 100% of risky functions are covered by appropriate training.

Reference: page 186

Measures implemented to minimise compliance risks relating to tenants include the Code of Conduct setting out clear standards of behaviour, regular employee training on preventing corruption and on data protection, and the anonymous whistleblower system enabling early identification and remediation of violations; these are integral to LEG, understood as ongoing and continuously adapted. At LEG, there were no convictions or fines for violations of corruption and bribery regulations in the 2024 reporting year. The total number and type of confirmed cases of corruption or bribery was 0, and the number of confirmed cases in which own workers were dismissed or disciplined for corruption or bribery was 0. The number of confirmed cases relating to contracts with business partners terminated or not renewed due to breaches related to corruption or bribery was 2. No court proceedings were opened.

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The type, scope and content of LEG's political positioning are determined by the full Management Board, if necessary in consultation with the Supervisory Board, which decides on memberships and sponsorship of interest groups and campaigns. National and EU-level positioning is the CEO's responsibility, regional and communal contacts the COO's, and financial market regulation the CFO's; political communication is coordinated by Corporate Communication and Public Affairs. In 2024, LEG was a member of GdW/VdW and the ZIA industry associations; the CEO chairs the Bundesfachkommission Bauen, Immobilien, Smart Cities in the Wirtschaftsrat der CDU. LEG was also a member of Initiativkreis Ruhr, the IW 2050 climate initiative, the ICG and the BDEW. The internal Politics and Social Engagement guideline (effective 2021, reviewed annually) prohibits direct or indirect monetary and in-kind donations to political parties, politicians, candidates or political action groups, so a table of donations to parties would make no sense. LEG publishes its expenses in the German Bundestag lobby register (number R002757); financial expenses and indirect contributions for interest representation amounted to EUR 140,000 to 150,000 in 2024. No Management or Supervisory Board members held a position in public administration in the past two years.