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Compliance Management System SIGNA Holding GmbH Code of Conduct (excerpt) Foreword Dear employees and colleagues, Over the years, SIGNA has grown to become one of the leading real estate companies in Austria and Europe. We have gained a foothold in this crowded market segment and, despite this challenging economic environment, have managed to continually and successfully evolve to a real estate investment company of European stature. In recent years, we have achieved a strong position and expanded further even in the retail sector. Our success story since 2000 has been built on our reputation, which is based on ethical and performance-related basic values. We have the ambition to create high added value for our customers, generate an attractive return for our investors, be a preferred employer to our employees, and a recognized member of society. Achieving this calls for the highest degree of integrity, transparency, confidentiality, and professionality. Beyond the impressions we leave in the landscape in our daily business as real estate developers by making long-lasting changes in real estate and development properties, the slogan “Leave your SIGNAture” serves to remind us all that we also make lasting impressions with those who we interact with through our behavior and our decisions. This is true for every kind of interpersonal relationship, in our personal and in our business lives. Our basic values and rules of conduct define the impressions we want to leave as SIGNA and how we want to be remembered. With this Code of Conduct, we reinforce the foundation in order to keep and further grow the trust that others place in us. Here, you will find our values and principles that create the foundation of the policies and instructions of SIGNA companies and divisions. Besides the employees, all members of the management and board members are also required to comply with these regulations. Please take the time to familiarize yourself with them. They form the foundation for all decisions we make in our day-to-day work. Thank you for your support! Sincerely, René Benko Marcus Mühlberger (CCO) Christoph Stadlhuber (CEO) 1 Contents I. Our Driving Values ........................................................................................................ 3 II. Our basic values ............................................................................................................ 4 Sense of responsibility .................................................................................................................. 5 Fairness .......................................................................................................................................... 5 Compliance .................................................................................................................................... 6 Transparency ................................................................................................................................. 6 III. Our rules of conduct for fair cooperation .................................................................... 8 Zero tolerance for corruption ....................................................................................................... 9 We are committed to fair competition......................................................................................... 9 Handling conflicts of interest ........................................................................................................ 9 Giving back — donations and sponsorships ............................................................................. 9 Our image ..................................................................................................................................... 10 Discretion in handling confidential information ....................................................................... 10 Business partner review ............................................................................................................. 10 We practice equal treatment ...................................................................................................... 10 Sustainability out of conviction .................................................................................................. 11 Health and safety ........................................................................................................................ 11 Human rights ................................................................................................................................ 11 Environmental and climate protection ...................................................................................... 12 IV. If a compliance violation occurs ................................................................................ 13 V. Let’s talk about it ......................................................................................................... 13 Attachment ............................................................................................................................ 14 2 I. Our Driving Values SIGNA stands for outstanding services. We work together as a team to realize visions and, in doing so, we make our individual impression in the landscape. And our Driving Values form our shared SIGNA DNA. Our visions reinvent entire cityscapes. Our creative freedom is as enormous as our responsibility: Our flat hierarchies allow us to quickly reach decision points and to grow our personal impact. We encounter motivated people, who achieve the extraordinary through a strong sense of teamwork. Our commitment is recognized and rewarded — every day represents a new challenge for us, and we are continually pushed onward. We share our strengths rather than excluding each other through singular ambition. We are part of a unique success story when our efforts create outstanding projects. Through the combination of our assertiveness and our resources, visions become plans and plans become properties and entire urban areas. 3 II. Our basic values Our basic values are the ethical foundation of our decisions and actions in our daily business. Sense of responsibility Integrity Fairness Transparency Compliance 4 Sense of responsibility “To us, being responsible means that each individual is aware of his or her own responsibility and also acts accordingly.” (René Benko, SIGNA founder and Chairman of the Advisory Board) Ask yourself what kind of behavior you expect from a responsible person, and use your own expectations as guidance. Fairness “We consider fairness to be ‘proper’ behavior. First and foremost, this is when we avoid differentiating on the basis of subjective criteria. (Christoph Stadlhuber, CEO) Ask yourself how you would like to be treated in a comparable situation, and live up to that expectation. 5 Compliance “We consider compliance to be legally impeccable behavior in accordance with our basic ethical values.” (Marcus Mühlberger, CCO) Ask yourself if you would engage in a behavior if it were to become known to the broader public. If not, you should reconsider your plans or your decision. Transparency To us, transparency means communicating and designing our goals, processes, and decision paths in an open and verifiable manner, while not losing sight of the confidentiality required in individual cases. Ask yourself if a situation calls for open communication and communicate accordingly. Before disclosing information you should also make sure that doing so is not in conflict with any confidentiality requirements or agreements. 6 Integrity We consider integrity to mean incorruptibility of character. Ask yourself if a decision or a behavior is compatible with our basic values. If not, refrain from it. If you are not sure, contact the compliance organization so that any doubts can be dispelled. 7 III. Our rules of conduct for fair cooperation Please consider that the chart is only intended to provide you with an initial overview of our rules of conduct. It is not meant to replace a careful review of the detailed explanations provided below. Our image Anti-corruption Anti-discrimination - public relations and equal treatment - social media Health Environmental and and climate safety protection Sustainability Our operations Donations out of internal and conviction and sponsorships external Fair Conflicts of competition interest Business partner Handling Human rights review confidential information 8 Zero tolerance for corruption Corruption is not a minor offense. It is a white-collar crime and can have serious consequences for both the Company as well as for the individual. These potential consequences range from long- term damage to the Company’s image to termination of employment relationships and legal penalties. For this reason, SIGNA has a zero tolerance corruption policy. Our objective is not only to prevent corrupt behavior per se but even any appearance of such behavior. For further details, please see the Anti-Corruption Policy. We are committed to fair competition Fair competition means that we conduct ourselves transparently and fairly in the market. SIGNA forbids any type of violation of the provisions of antitrust and other competition laws. We also distance ourselves from any other type of unfair business practice. For further details, please see the Antitrust and Competition Law Policy. Handling conflicts of interest Conflicts of interest can arise wherever different spheres of interest meet. Such conflicts of interest can occur in a variety of situations and

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