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37

• Cofinimmo will continue to comply

rigorously with transparency and ethics

rules.

• Through entrusted missions, the internal

auditor will continue to work to detect

possible cases of fraud.

• Formal adoption of the code of conduct

drafted by the Royal Institution of

Chartered Surveyors (RICS)

***

for all real

estate activities.

Cofinimmo’s Corporate Governance Charter* describes a

series of rules, procedures, and practices that define how

the company is managed and controlled. The Company

has adopted the 2009 Belgian Corporate Governance

Code (“2009 Code”) as its code of reference.

This Charter advocates for transparency in decisions taken

at all levels of the company. On a daily basis, employees

comply with a Code of Conduct and corporate values.

Cofinimmo emphasises the principles of honesty, integrity,

and fairness in all areas and expects a similar attitude

from third parties with which it maintains business

relationships.

Attempted corruption is the subject of a specific article in

the general purchasing terms and conditions, appended

to any order, and its occurrence would be severely

punished. Any form of fraud or misappropriation is

prohibited and very strict rules govern calls for tenders, by:

the application of the double signature method for any

commitment;

the approval of financial statements by an outside

auditor;

the consultation of a relevant number of suppliers or

service providers and a rotation among those invited

to submit offers;

the presence of an internal auditor;

a whistleblowing policy

**

.

Since 2000, Cofinimmo has periodically provided an

up-to-date vademecum to real estate agents. It specifies

in detail the rules of collaboration and remuneration

applied for the marketing of Cofinimmo’s buildings.

* The Corporate Governance rules are described in detail in the 2015 Annual Financial Report starting on page 108 and can be found on the company’s website

(http://www.cofinimmo.com/about-us/governance/

).

** All employees must be able to report ethical misconduct without feeling threatened in their relationship with the company.

***

www.rics.org.

“NO EXAMPLES OF

MISAPPROPRIATION WERE

DETECTED IN 2015.”

2016 Objectives