Rules of procedure (HinschG and LkSG)

Rules of procedure for dealing with information received under the Whistleblower Protection Act (HinSchG) and Supply Chain Due Diligence Act (LkSG)


I. Objective and area of application

As a large housing company, TAG regards compliance with the relevant laws, internal guidelines and environmental standards as well as respect for human rights as a fundamental principle of its corporate and sustainable conduct. TAG also expects its business partners to act in a legally compliant and sustainable manner in their respective business areas and in their activities with business partners and subcontractors.

Transparency is crucial for TAG in order to detect any violations of legal regulations and its internal guidelines as well as human-rights and environmental risks and violations as early as possible. This knowledge enables effective remedial and preventive measures to be taken and damage or loss to be prevented or minimised.

Internal and external persons, particularly TAG employees, business partners and other stakeholders, are able to report actual or suspected violations of legal regulations and internal guidelines as well as human-rights and environmental risks and violations caused by actions in their own business area or by a direct supplier. To this end, TAG has installed a whistleblower system with various reporting channels for the submission of relevant information and complaints.

These rules of procedure for the whistleblower system under the Whistleblower Protection Act (HinSchG) and for the complaints procedure under the Supply Chain Due Diligence Act (LkSG) define the reporting channels, the procedure, the responsibilities and whistleblower protection requirements.


II. Reporting/complaint channels

The following channels can be used to submit information and complaints:

Digital reporting system:       

E-Mail: compliancetag-agcom

TAG Immobilien AG
Compliance Officer
Steckelhörn 5
20457 Hamburg

Telephone: +49 40 38032-184

Whistleblowers can also submit their report completely anonymously if they wish. TAG employees are also able to make use of a contact form available on the intranet to submit anonymous information to the TAG Compliance Officer.

In addition, whistleblowers also have the option of contacting TAG's compliance lawyer, Dr. Alexander Raif, GreenGate Partners Rechtsanwaltsgesellschaft mbH, as an additional reporting channel:

E-Mail: compliance.tag-aggreengatelegal

GreenGate Partners Rechtsanwaltsgesellschaft mbH
Dr. Alexander Raif
TAG`s Compliance Lawyer
Friedrichstraße 186
10117 Berlin

Telephone: +49 30 509 32 35 10


III. Procedure and process for reports/submission of complaints

Incoming reports are processed according to the procedure defined below. The Compliance department is responsible for processing incoming reports and complaints. The Management Board of TAG Immobilien AG has appointed the Compliance Officer as Human Rights Officer. The employees who handle the reports are obliged and authorised by the Management Board to carry out their activities independently, impartially and in accordance with the principles of confidentiality and due diligence. They are under a duty of confidentiality.

  1. Receipt of the report and confirmation of receipt
    The whistleblower will receive confirmation of receipt of the report within 7 (seven) days, where it is possible to contact him or her.
  1. Initial review
    At the beginning of the procedure, a check is performed to determine whether the facts reported come within the material scope of the Whistleblower Protection Act or the Supply Chain Due Diligence Act. If this is not the case or if the report concerns questions and suggestions about rental contracts, e.g. statements of utility costs, the report is not processed via the whistleblower system and the procedure ends.
  2. Determination and investigation of the facts
    If there are justified and plausible indications of a breach of legal regulations and/or internal guidelines or of violations of human rights and environmental obligations or evidence of human-rights or environmental risks, the necessary follow-up measures are taken.

    An internal investigation is initiated with the aim of determining whether an offence and/or risks have arisen. During the investigation, the facts of the case are investigated in greater detail and, if necessary, the content of the report is discussed with the whistleblower in order to gain a better understanding of the facts. If necessary, the persons concerned are also contacted as part of the internal investigation. Depending on the content of the respective report, it may be necessary to include experts from other departments (e.g. HR, data protection, purchasing or sustainability) in the investigation. The relevant department will take the lead in examining and developing a solution particularly with regard to violations of human rights and environmental obligations under the Supply Chain Due Diligence Act. The investigation is carried out as quickly as possible and without any major interruptions, in compliance with the requirements of confidentiality, data protection and the protection of the whistleblower’s identity.
  3. Communication with the whistleblower
    After confirmation of receipt, contact will be established with the whistleblower, if necessary and as far as possible, in order to obtain further information and discuss the facts of the case. The whistleblower can obtain information on the status of the procedure at any time. They will be given feedback on the follow-up measures within 3 (three) months of confirmation of receipt in accordance with Section 6 below.
  4. Remedial measures
    If and to the extent that the internal investigation reveals a violation of legal regulations and/or internal TAG guidelines or human rights and/or environmental risks or violations in TAG’s own business area or that of its suppliers, effective and appropriate remedial measures will be taken to eliminate or minimise the extent of the violation, risk or violation. Remedial measures may particularly include measures under labour, civil or criminal law. In the event of any violations by business partners, appropriate measures may include additional checks and audits as well as the temporary or permanent termination of the business relationship.

    The findings from the procedure are also used to review existing work and compliance processes and, if necessary, to adapt and optimise them and to implement any further preventive measures that may be necessary.
  5. Conclusion of the procedure
    The investigation into the report can be terminated for various reasons:
    1. The information reported or complaint does not fall within the material scope of the Whistleblower Protection Act or the Supply Chain Due Diligence Act,
    2. Violations of legal regulations and/or internal guidelines as well as human rights or environmental risks and violations of human rights and environmental obligations have
      1. not been confirmed or
      2. have been remedied as a result of the action taken.

The whistleblower will receive substantiated feedback on the status or conclusion of the procedure within 3 (three) months of confirmation of receipt, provided that they can be contacted. The feedback will include the reasons for the termination of the procedure. To the extent permitted by law, information on planned or completed follow-up measures will be provided as far as this communication does not affect internal enquiries or investigations or the rights of the persons who are the subject of the report or who are named in it.


IV. Confidentiality and protection against recrimination

Protecting the whistleblower is of paramount importance for TAG. Whistleblowers who report actual or suspected misconduct in good faith need not fear any recriminations as a result of their report. Among other things, the following measures are taken to protect whistleblowers:

The information and complaints are only processed by a small group of trained TAG employees. The identity of the whistleblower is treated confidentially and their personal data protected in accordance with data privacy requirements.

TAG does not tolerate any discrimination or intimidation of whistleblowers or reprisals against them. Such conduct itself constitutes a potential compliance violation and will be dealt with accordingly.

Information that is deliberately or negligently incorrect or is provided with fraudulent intent is not covered by whistleblower protection.


V. Review of the effectiveness of the complaints procedure and the rules of procedure

The effectiveness of the complaints procedure and of these rules of procedure is reviewed annually as well as on an ad hoc basis. If necessary, the complaints procedure and the rules of procedure will be revised.