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 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 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)

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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

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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.

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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

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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.

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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.

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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.

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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

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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 configurations.

Conflicts such as these can have a detrimental impact on SIGNA. So, it is crucial to recognize a conflict of interest early and to take the appropriate measures to neutralize the conflict as much as possible.

For further details, please see the Policy on Managing Conflicts of Interest.

Giving back — donations and sponsorships

We provide support particularly to charitable projects that we consider worthy of promoting as part of our operating policy.

We have established a framework for this purpose which is intended to ensure that the funds used to support these projects are actually used for such an especially charitable purpose.

Donations and sponsorships are only permitted under the conditions we have defined and in compliance with the processes established for this purpose. Donations can not be made or sponsorship agreements entered into for SIGNA outside of this framework.

For additional details, please see the Donation and Sponsorship Policy.

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Our image

We recognize the pivotal role of media in our society. Therefore, we support it in its objective reporting on SIGNA.

External appearances which could affect the public image of SIGNA or of people employed by SIGNA are particularly also possible on social media. SIGNA issued a separate Social Media Policy for this area to address what should be considered for activities on social media where you could be associated with SIGNA.

For additional details, please see the Public Relations and Social Media Policy.

Discretion in handling confidential information

In our day-to-day work, we often become aware of confidential information. One thing that all of this information has in common is that the owner of the information is bound to secrecy. The level of secrecy required may vary in individual cases.

For further details on how to handle this information, please see the Policy on Handling Inside and Other Confidential Information.

Business partner review

For SIGNA, a business partner laundering money, engaging in illegal financial activities, or involved in them in any way is an undesirable business partner and forbidden. Entering into or maintaining business relationships with such undesired and forbidden business partners can have severe consequences for SIGNA. SIGNA only uses funds from legal activities and sources for its own operations and is not involved in the illegal activities of others.

For additional details, please see the Policy on KYC Audits and AML Precautions.

We practice equal treatment

We know that the quality of the collaboration between supervisors, colleagues, and employees is essential to the success of our Company. For that reason, we practice exemplary conduct in working with each other, respect different opinions, and support an environment of tolerance. We welcome a diversity of opinions. We categorically reject any type of discrimination; it has no place in our Company. Our employees, managers, and board members are prohibited from engaging in any type of discrimination or harassing behavior.

For further details, please see the Anti-Corruption Policy.

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Sustainability out of conviction

We are committed to responsible corporate governance aimed at creating long-term value. For us, pursuing profitability is inseparably linked to a responsibility to society according to our basic values — a sense of responsibility, fairness, compliance, transparency, and integrity. We also consider the alignment of our business activities with sustainable value creation to be part of our social responsibility: We value your health and safety, we pay attention to compliance with inalienable human rights, and we treat the environment with care.

Together, we follow a model of sustainable development that will safeguard our future viability. Each one of us plays a role in ensuring that environmental, social, and societal aspects are systematically integrated into entrepreneurial action along with commercial interests. As a matter of conviction, we support sustainability, initiate improvement processes, and continually grow and develop.

Further information on sustainability at SIGNA can be found on our intranet and in the sustainability reports of SIGNA Prime Selection AG and SIGNA Development Selection AG.

Health and safety

Your health and safety are of the utmost importance to us. Each of us has the right to work in a healthy and safe work environment. We achieve this through a number of different measures. We are continually expanding our range of ergonomic workstations, offer an array of services to promote health, and place great value in the occupational safety of our processes. Our sites measure up to the most stringent requirements of modern working conditions. We support each other in upholding the health and safety standards in our day-to-day work.

The health, safety, and comfort of our customers, business partners, and contractors is a top priority for us. We comply with all relevant legal regulations and reliably perform our duties of care towards our stakeholders. For our existing properties, warehouses, and development projects, for instance, we ensure strict compliance with safety and fire prevention concepts.

Human rights

We set high standards of ethical behavior for ourselves and are committed to respecting human rights in accordance with the United Nations Charter and the European Convention on Human Rights. We always avoid detrimental impacts on human rights which could be caused by our business activities. We work in an environment free of discrimination, we respect the right to collective bargaining and freedom of association, and we absolutely reject any type of modern slavery — child labor, compulsory labor, and forced labor.

Without exception, we expect the same behavior from each other and from our customers and business partners. Further information on this topic can be found in our Code of Conduct for Business Partners.

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Environmental and climate protection

We are committed to environmental and climate protection and use natural resources with care. We minimize the negative impacts on the environment which could arise from our business activities. We comply or exceed all environmental laws applicable to us and orient ourselves by standards of sustainable construction and operation. By observing high standards of sustainability and energy efficiency at our existing properties, warehouses, and development properties, we create long-term value and quality for us and for our customers. These include our numerous green building certifications in the German-speaking region according to the most stringent standards such as LEED Platinum.

We are confident that sustainable growth can only be achieved when environmental and climate protection is systematically integrated into our everyday business. Therefore, when engaged in our day-to-day work, we use natural resources sparingly, minimize waste, water, and energy use, and continually reduce the carbon footprint.

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IV. If a compliance violation occurs

All employees, managers, and board members shall comply with this Code of Conduct. A violation may result in disciplinary repercussions or consequences under employment law.

Furthermore, everyone is required to report possible violations of laws and other regulations under the scope of the Compliance Management System and violations of this Code of Conduct. Compliance will follow up on the report. You should always consider making such a report if you notice something or if you have concerns that a colleague, a supplier, or anyone with whom you are in contact at work may be behaving illegally or unethically to the possible detriment of SIGNA.

At SIGNA we do not tolerate any retaliatory measures against people who have reported compliance violations in good faith. The same applies for accusations made in the knowledge that they are false (in bad faith). This behavior represents a violation against this Code of Conduct and will result in corresponding consequences.

Please note: Compliance only works when we all do our part to ensure that the rules are upheld. Participating in activities that are not in accordance with our basic values or looking the other way are not options in our Company.

For further details, please see the Whistleblowing Policy.

V. Let’s talk about it

Something you don’t understand? Something you feel has not been covered clearly or sufficiently? Suggestions for improvement?

Contact the compliance officer responsible for your division at any time with questions, suggestions, or other concerns. The door of Chief Compliance Officer Dr. Marcus Mühlberger is also always open to you.

The HR department in Austria is your contact for matters concerning any discrimination or conflict of interest.

The attachment to this document includes an overview of the individuals tasked with compliance functions and their contact information for the respective divisions.

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Attachment

Your contacts for all compliance matters:

SIGNA company Point of contact

SIGNA Holding GmbH Dr. Marcus Mühlberger (Chief Compliance Officer)

SIGNA Prime Selection AG Markus Wurzer (Compliance Officer)

SIGNA Prime Luxemburg Timo Jäger S.à r.l. (Compliance Officer)

SIGNA Real Estate Management GmbH Robert Kubalek (Compliance Officer)

SIGNA Development Robert Kubalek Selection AG (Compliance Officer)

SIGNA Funds GmbH & Co. KG Jörg Schwengel (Compliance Officer)

SIGNA Innovations Jürgen Fenk Selection AG (Compliance Officer)

SIGNA Financial Services AG Remo Koller (Compliance Officer)

B A I Bauträger Austria Immobilien GmbH Harald Butter (Compliance Officer)

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For questions concerning discrimination and in the event of conflicts of interest:

HR department (Austria) Karina Robinig

For questions concerning public officials, public relations, and social media:

PR department Robert Leingruber

External ombudsman:

VIVACIS Consulting GmbH Michael Kispert Horexstraße 1 Tel: +49 (6172) 6875502 61352 Bad Homburg Email: [email protected]

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Editorial details

Publisher:

SIGNA Holding GmbH Maria-Theresien-Straße 31 6020

Vienna branch office Freyung 3 1010

Tel: +43 1 532 98 48 – 0 Fax: +43 1 532 98 48 – 2023 [email protected] www.signa.at

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