Compliance at HAMBORNER REIT AG
HAMBORNER REIT AG takes compliance extremely seriously. The Management Board is fully committed to compliance and has developed a comprehensive compliance management system with the aim of ensuring that HAMBORNER's business activities are consistent with the law and the company's internal policies and regulations at all times and that responsible behaviour is firmly enshrined within the thoughts and actions of its employees.
The compliance management system is built on three pillars: prevention, investigation and response.
In particular, preventive measures include the provision of regular training to all HAMBORNER employees and a detailed compliance policy that applies unconditionally to the Management Board and all employees, irrespective of their hierarchical level. The policy describes the relevant statutory provisions in greater detail, defines internal principles of conduct and serves as a set of guidelines for employees. It is intended to protect employees against breaches of the law and contractual obligations, prevent conflicts between professional and private interests, and protect the company against material loss and reputational damage.
Another key element of all efforts taken to ensure legally compliant activity and protect the company against loss and damage is that information concerning potential misconduct reaches the Management Board and Supervisory Board of HAMBORNER REIT AG. Accordingly, a clearly defined, functional whistleblower system enabling the investigation of compliance breaches is the second pillar of HAMBORNER REIT AG's compliance management system.
The company has appointed the lawyer Dr Thomas Stohlmeier as an external ombudsman to act as a neutral point of contact for employees and business partners for all matters relating to compliance breaches. The ombudsman can be contacted via HAMBORNER REIT AG's whistleblower system. His role is to receive information on potential misconduct or violations of law within the company's sphere of influence. The system ensures that the whistleblower's anonymity is protected throughout the entire process if desired.
Immediate responses and unequivocal consequences in the event of misconduct are the third pillar of HAMBORNER REIT AG's compliance management system. Clearly defined disciplinary measures are implemented once compliance breaches have been thoroughly investigated and clarified by the ombudsman. These measures are described explicitly in the compliance policy. They take into account the respective legal situation and are geared towards the severity of the respective breach and the loss and damage incurred by the company as a result.