Compliance

 

Code of Values for PATRIZIA Group

Complying with the law and regulations and adhering to moral and ethical standards are an integral part of our corporate culture and essential to our success as a business in the long term.

At PATRIZIA, compliance is about more than just ensuring that all legal and internal regulations are followed. Ethical factors also play a key role.

We have a strong social responsibility as a company and we take this responsibility very seriously. This is why the fundamental corporate principles of PATRIZIA include honesty and integrity. This means acting in the interests of the investor with diligence, candour, fidelity and fairness, and respecting the integrity of the market.

The PATRIZIA Compliance Programme is based on the PATRIZIA Code of Values, which you can download here. This code serves not only to guide our actions, but also provides direction and pointers, reflecting the values we aim to actively live by in our corporate culture.

You can find contact details for getting in touch with the PATRIZIA Group Compliance Office, including for reporting possible compliance violations, here.

Contacting Compliance at the PATRIZIA Group and reporting violations

Prioritizing adherence to legal regulations and internal compliance standards stands as a foremost principle at PATRIZIA. It is imperative to swiftly identify any breaches, enabling us to enact suitable measures to prevent potential harm to investors, employees, business partners, other stakeholders, the environment, and the company as a whole.

To ensure timely awareness of significant breaches within the organization and to facilitate appropriate responses, PATRIZIA has established a range of reporting channels for all PATRIZIA Group companies. These channels are open to both PATRIZIA employees and external individuals, enabling them to disclose violations of external legal statutes and internal directives. The scope of these violations encompasses, but is not restricted to, instances of fraud, theft, bribery, corruption, money laundering, terrorist financing, breaches of data protection regulations, harassment, discrimination, deceptive selling practices, violations of internal PATRIZIA policies, laws, or guidelines.

If you have or suspect concrete, well-founded indications of legal violations or breaches of rules at PATRIZIA, you have the following options for contacting our Group Compliance Office:

  • Via our whistleblowing system Hinweisgeberexperte: PATRIZIA operates a modern tool through which you can send us information - even anonymously. The tool enables a secure and confidential exchange between the whistleblower and Compliance via an anonymised mailbox.
  • Via letter to:

PATRIZIA SE
Compliance
Fuggerstr. 26
D-86150 Augsburg
Germany

Information can also be submitted anonymously to the PATRIZIA Group Compliance Office. In such cases, please include as much detail and evidence (e.g. documents) as possible with your message so that the matter can be investigated properly.

At PATRIZIA, each report undergoes thorough investigation. Throughout the handling process, utmost confidentiality and equitable treatment of the whistleblower are upheld. This principle extends to any employees who may be implicated by an allegation as well.

Kindly note that our whistleblowing system is not designed for addressing customer concerns linked to any PATRIZIA products or services. In these cases, please refer to the designated contacts stated in your investor documents or reach out to your key account manager for assistance.

PATRIZIA places great priority on maintaining confidentiality and safeguarding the identities of individuals who provide information. Should the information fall within the ambit of the Whistleblower Protection Act, the corresponding regulations will be adhered to.

Retaliation against individuals who, in good faith, bring forward information is categorically unacceptable within PATRIZIA. This stance remains unchanged, irrespective of whether subsequent investigations substantiate the claims made.

We employ meticulous measures to handle all received information conscientiously, ensuring the well-being of all parties involved. In specific instances, the contents of your report may need to be shared with bodies responsible for addressing compliance notifications for the purpose of investigation.

Where disclosure becomes necessary — for instance, to uphold the rights of the data subject or due to legal obligations — we strive to restrict the circle of informed parties to the minimum required. Examples of such legal obligations encompass requests from authorities or obligations arising from data protection laws.

All provided data will be processed in accordance with pertinent data protection regulations and aligned with our Privacy Policy.

According to the German Whistleblower Protection Act (HinSchG), you have the alternative of submitting a report to external reporting channels. However, please bear in mind that your concerns can be dealt with more quickly and directly if you report them internally.

Please do not hesitate to contact the Compliance contact persons at the above contact details for further information on reporting channels.

Exemplary overview of external reporting offices:

Germany: More information on the possibilities of an external report can be found at the Federal Office of Justice under "Whistleblowing Office" (bundesjustizamt.de).

Luxembourg: External reporting channels for receiving and processing information are established by the competent authorities, e.g. the banking sector supervisory authority (Commission de Surveillance du secteur financier, CSSF).

Denmark: A national whistleblower system has been established ("Den Nationale Whistleblowerordning").

The Netherlands: A national whistleblower system has been established ("Huis voor Klokkenluiders").

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