According to Section 4.1.3 S. 2 GCGC (German Corporate Governance Code), the Managing Board must ensure the establishment of a compliance management system that is aligned to the company’s risk situation, which includes an anonymous whistleblowing system (at least for employees), and disclose the principles of this system. The PATRIZIA Group has a compliance management system that meets these requirements.
The core elements of the compliance management system are:
- a compliance organisation that is overseen by the Head of Compliance for the PATRIZIA Group; each PATRIZIA company has a compliance officer/compliance representative in charge of it
- risk analyses to identify and evaluate compliance risks
- a set of compliance rules for the PATRIZIA Group, which specifically includes policies on “breaches of duty and actionable conduct,” on the topic of “conflicts of interest,”’ on “stock company and capital market law,” on “dealing with business partners,” and on “preventing money laundering and the financing of terrorism.”
- regular compliance training and communications on compliance issues
- a whistleblower system for reporting suspected violations (anonymously, if desired)
- regular reporting by Compliance to the Managing Board and Supervisory Board of PATRIZIA AG.