Code of conduct, Terms of services and conditions and Privacy Statement

CODE OF CONDUCT

DOMICILIUM is a boutique advisory firm driven by an experienced management team with a large pan-European network and unique industry insights. We source alternative investment opportunities with a specific focus on commercial real estate that will help maximize investors’ portfolio value. Furthermore, we concentrate on sustainable, experienced based real estate assets that reflect the changes in demographics and technology.

DOMICILIUM is conscious about legal requirements and compliance rules. It was a real will from its Partners to introduce this Code of Conduct as a sign of commitment to reassure his employees, clients and all the stakeholders of the integrity of the company and his people to strictly follow these terms.

We commit in maintaining good practice in our business activities, by adhering to the standards of quality management. We do not derogate from our selection criteria and we take this as an essential principle that all transactions that are offered to our company, or any transaction that we offer should be transparent, clear, fully under control, comprehensible and complete.

This is to enhance any collaboration experience and to ensure the delivery of consistent and trusted services, for the interests of all the people and guarantee continuous improvement:

I - Integrity: we commit to legal requirements and compliance rules
M - Maximise: maximise positive impact by promoting a safe and healthy work environment
P - Performance: we engage to provide the highest standards at all times
R - Respect: we consider others idea’s and share openly information for a stronger confidence and collaboration
O - Opportunities: we don’t wait for opportunities, we create them
V - Value: we value equality and diversity
E - Excellence: we always focus in creating value and strive for continuous growth and improvement
M - Misconduct: we encourage our collaborators, staff and stakeholder to report concerns or suspicions of misconduct
E - Expectations: deliver services beyond expectations
N - Nonconformity: we take all corrective actions to eliminate and detect failure to comply with all legal requirements
T - Team: we believe in teamwork and common goals with our employees and encourage continuous personal development

FUNDAMENTALS

The Partners and staff of DOMICILIUM will, in the execution of their profession, behave correctly, honestly and with the utmost integrity, both when dealing with the general public or with other professionals.

DOMICILIUM Partners, team and accredited professionals collaborating with our company:

shall not deny equal professional services to any person for reasons of race, colour, religion, sex, handicap, familial status, or national origin.
shall not be parties to any plan or agreement to discriminate against a person or persons on the basis of race, colour, religion, sex, handicap, familial status, or national origin.
shall conform to the standards of practice and competence which are reasonably expected
shall refrain from misleading statements and exaggerated claims in all of their professional dealings
shall adopt a free and independent position in the execution of their professional activities
must not give advice or make recommendations on matters or in areas beyond their competence
shall not accept instructions which conflict with the laws and regulations of the country in which they are established / operate or with this Code of conduct.
shall make clear to all parties their position and whose interests they represent
shall within the framework of the law and to the best of their ability have the duty to protect the interest of all intervening parties
shall not accept instructions that adversely affects the professional standard of their work.

CONFIDENTIALITY

DOMICILIUM Partners, team and accredited professionals collaborating with our company:

must at all times preserve confidential information provided
must not use confidential information to the disadvantage of any party
must not use client’s confidential information for their own, or third-party advantage, unless:
there is a consent after full disclosure
these are required by court order
the intention of a party is to commit a crime and the information is necessary to prevent the crime
it is necessary to defend someone against an accusation of wrongful conduct

LEGAL

DOMICILIUM Partners, team and accredited professionals collaborating with our company:

must comply with the laws and regulations in force within the country in which they are established or operate at any given time shall not engage in activities that constitute the unauthorised practice of law and shall recommend that independent legal advice be obtained when the interest of any party requires it

will be directly responsible for the actions of their employees

CONTACT

DOMICILIUM SARL

72, Route d'Arlon

L-1150 Luxembourg

Email: domicilium@domicilium-re.com

TERMS OF SERVICES AND CONDITIONS

PLEASE READ THE FOLLOWING TERMS OF USE AND DISCLAIMERS CAREFULLY BEFORE USING THIS WEB SITE

Art. 1 – Acceptance of terms

DOMICILIUM SARL (“DOMICILIUM”) maintains this Website (the “Site”) for your personal use. Your access to and use of this Site is subject to the following Terms of Use. DOMICILIUM reserves the right to update these Terms of Use at any time without notice to you. The most current version of the Terms of Use may be accessed by clicking on the “Terms and Conditions” hypertext link located at the bottom of the Site. By using this Site, you accept, without limitation or qualification, these Terms of Use. If you do NOT agree to these Terms of Use, please do NOT use this Site.

Art.2 – Accuracy and completeness of information

While DOMICILIUM strives to ensure that the information contained in this Site is accurate and reliable, DOMICILIUM makes no warranties or representations as to the accuracy, correctness, reliability or otherwise with respect to such information, and assumes no liability or responsibility for any omissions or errors in the content of this Site.

Art.3 – Modification of Site

DOMICILIUM will periodically revise the information, services and resources contained in this Site and reserves the right to make such changes without any obligation to notify past, current or prospective visitors.

Art.4 – Your use of the Site

You may download content for non-commercial, personal use only, provided copyright, trademark or other proprietary notices remain unchanged and visible. No right, title or interest in any downloaded materials is transferred to you as a result of any such downloading or copying. You agree that you will not otherwise copy, modify, alter, display, distribute, sell, broadcast or transmit any material on the Site in any manner without the written permission of DOMICILIUM.

Art.5 – No unlawful or prohibited use

As a condition of your use of the Site, you will not use the Site for any purpose that is unlawful or prohibited by these Terms of Use or any applicable laws.

Art.6 – Unsolicited submissions

DOMICILIUM does not accept or consider any creative ideas, suggestions or materials from the public (“Submissions”), therefore, you should not make any Submissions to DOMICILIUM. If you do send us a Submission, despite our request not to do so, then such Submission will be considered non-confidential and non-proprietary and shall immediately become the property of DOMICILIUM. DOMICILIUM shall exclusively now and hereinafter own all rights, title and interest therein. DOMICILIUM will be free to use any Submissions for any purpose whatsoever.

Art.7 – Privacy policy

DOMICILIUM use of any personal data you submit to the Site is governed by the PRIVACY STATEMENT (following after Jurisdiction article).

Art.8 – Disclaimers

THE WEBSITE IS PROVIDED ON AN “AS IS” BASIS. DOMICILIUM EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING THE WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NONINFRINGEMENT. DOMICILIUM DISCLAIMS ALL RESPONSIBILITY FOR ANY LOSS, INJURY, CLAIM, LIABILITY OR DAMAGE OF ANY KIND RESULTING FROM, ARISING OUT OF OR ANY WAY RELATED TO (A) ANY ERRORS IN OR OMISSIONS FROM THIS WEBSITE AND THE CONTENT, INCLUDING BUT NOT LIMITED TO TECHNICAL INACCURACIES AND TYPOGRAPHICAL ERRORS, (B) ANY THIRD PARTY WEB SITES OR CONTENT THEREIN DIRECTLY OR INDIRECTLY ACCESSED THROUGH LINKS IN THIS WEBSITE, INCLUDING BUT NOT LIMITED TO ANY ERRORS IN OR OMISSIONS THEREFROM, (C) THE UNAVAILABILITY OF THE WEBSITE OR ANY PORTION THEREOF, (D) YOUR USE OF THIS WEBSITE OR (E) YOUR USE OF ANY EQUIPMENT OR SOFTWARE IN CONNECTION WITH THE WEBSITE.

Art.9 – Limitation of liability

In no event and under no legal or equitable theory, whether in tort, contract, strict liability or otherwise, shall DOMICILIUM be liable for any direct, indirect, special, incidental or consequential damages arising out of any use of the information contained herein, including, without limitation, damages for lost profits, loss of goodwill, loss of data, work stoppage, accuracy of results, or computer failure or malfunction.

Art.10 – Indemnification

You agree to defend, indemnify and hold DOMICILIUM harmless from and against any and all claims, damages, costs and expenses, including attorney’s fees, arising from and related to your use of the Site.

Art.11 – Copyright notice

Unless otherwise noted, the graphic images, buttons and text contained in this Site are the exclusive property of DOMICILIUM and its subsidiaries. Except for personal use, these items may not be copied, distributed, displayed, reproduced, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise without prior written permission of DOMICILIUM.

Art.12 – Trademarks

This Site features logos, brand identities and other trademarks and service marks (collectively, the “Marks”) that are the property of or are licensed to DOMICILIUM and its subsidiaries. Nothing contained on this Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Mark displayed on this Site without written permission of DOMICILIUM or any such third party that may own a Mark displayed on the Site.

Art.13 – Links to third-party sites

As a convenience to users, this Site may link to other sites owned and operated by third parties and not maintained by DOMICILIUM. However, even if such third parties are affiliated with DOMICILIUM, DOMICILIUM has no control over these linked sites, all of which have separate privacy and data collection practices and legal policies independent of DOMICILIUM. DOMICILIUM is not responsible for the contents of any linked sites and does not make any representations regarding the content or accuracy of material on such sites. Viewing such third-party sites is entirely at your own risk.

Art.14 – Jurisdiction

DOMICILIUM maintains and operates this Site from its offices in Luxembourg. These Terms of Use are governed and interpreted under the laws of the Grand Duchy of Luxembourg. By using this site, you consent to the jurisdiction of the courts located in Luxembourg for any action arising from these Terms of Use. Any cause of action or claim you may have with respect to the Site must be commenced within one (1) year after the claim or cause of action arises. If any portion of these Terms of Use is deemed unlawful, void or unenforceable, then that part shall be deemed severable and shall be construed in accordance with applicable law. Such a term will not affect the validity and enforceability of any remaining provisions. DOMICILIUM failure to act with respect to a breach of these Terms of Use by you or others does not constitute a waiver and shall not limit DOMICILIUM rights with respect to such breach or any subsequent breaches.

PRIVACY STATEMENT

Art.15 – Who we are

DOMICILIUM, together with its subsidiaries and affiliates, is a boutique advisory firm sourcing alternative investment opportunities with a specific focus on commercial real estate.

Art.16 – Our commitment to privacy

We take our responsibility to protect the personal information provided to us seriously. This statement explains how we do that. It sets out what we do with the personal information we hold, how we protect it, and it explains your privacy rights (if applicable).

Art.17 – If we change this Privacy Statement:

DOMICILIUM might update this Privacy Statement from time to time. When we have to do this the revised statement will be posted on this page, and where appropriate, by notification on our homepage. You should check this page from time to time to review any changes we have made.

Art.18 – The personal information we collect:

When we collect personal information, we are open about how we will use it.

Art.19 – We collect information:

• through our website or the website of our affiliates – for example names, addresses or email details.

• from meetings with staff or business contacts, such as exchanging business cards, or collecting information at conferences or business events.

• that you provide to us in connection with the services we provide, for example in connection with tenancy or a lease agreement.

• that we use to validate your identity, such as a passport or proof of residency document.

Art.20 – Our legal basis for processing your information

We rely upon a number of different legal bases for processing personal information and special category personal information – these include processing personal information where it is in our legitimate interests to do so, where this is necessary for the fulfilment of a contract or where the processing is necessary to carry out our obligations under employment law. Where we rely on our legitimate interests, this means that we use personal information to run our business and to provide the services we have been asked to provide. We only collect information that has been supplied voluntarily, you do not have to provide us with personal information. However, if you do not provide us with information we need by law or require doing work, we may not be able to offer certain products and services.

Art.21 – How we use your information

• We use your personal information in compliance with all the relevant laws and may use it in one or more of the following ways:

• We may use the personal information of tenants or other natural persons you have supplied us with to carry out work such as lease management on your behalf.

• We may use the contact information you supply to respond to your requests.

• We may use identification verification documents to meet with regulatory and legal requirements to verify who you are as a condition of providing DOMICILIUM services and products.

• We may use personal financial information to assess your eligibility for DOMICILIUM products and services.

• Where you give us consent, we use personal information to provide you with marketing and advertising about DOMICILIUM services, you can opt out of this at any time from our marketing department info@domicilium.lu

• Personal information may be used to inform you of services that may be of interest to you from DOMICILIUM.

• Personal information is used to make your online experience as smooth as possible – for example by setting cookies and tailoring what you see on the website.

• Personal information may be used to safeguard the security of our premises and those we maintain for third parties.

Art.22 – Whom we share personal information with

We may share your personal information with:

• DOMICILIUM employees who require it to perform their jobs.

• Organizations that support the products or services we provide to you.

• Anyone you give us permission to share it with.

• Official bodies to detect and prevent criminal activity e.g. money laundering, theft, fraud, terrorism, cybercrime.

We will never sell your personal information and we take steps to keep your details safe and secure.

Art.23 – Stopping us contacting you

If you have provided us with consent to supply you with marketing and information, you can withdraw your consent at any time by email to info@domicilium.lu

Art.24 – Where we keep and process your information

We might transfer and store the information we collect from you outside the European Economic Area (EEA). It may be processed by staff or our suppliers outside the EEA. When we do this, we aim to make sure the information is secure and properly protected.

Art.25 – Keeping your information safe

We commit to maintaining the deployment of appropriate security to protect personal information wherever it is located, and whether it is in electronic or manual form. To do this we may use a variety of mechanisms depending on where the information is stored and the relationship between DOMICILIUM and any recipient organizations.

Art.26 – Your Rights

Where applicable you may have the following rights over your personal information:

Art.26.1 – Request a copy of the information we hold

You can access the personal information we hold about you. To do so please contact us by email at info@domicilium.luThere is no charge for us providing this information to you. You can also ask for information that you have provided to us in a machine-readable format, so you can transfer it to another organization if you want to.

Art.26.2 – Ask us to not use your information

If for any reason you do not want us to hold or use your information please contact us by email at domicilium@domicilium-re.com. We may need to keep some of your information for legal and business reasons, for example to comply with a regulatory requirement.

Art.26.3 – Have your information corrected

If you think the personal information we hold is wrong contact us at info@domicilium.lu and we will check and correct it if necessary. We are committed to holding personal information that is accurate and current.

Art.26.4 – How long we keep your information

We endeavour to keep your information for as long as we need it for legitimate business or legal reasons.

We will then delete it safely and securely. If you would like us to delete your information, please contact us at info@domicilium.lu.

Art.26.5 – How to complain

If you need to make a complaint about our handling of your personal information, please contact us directly at info@domicilium.lu. If you are unhappy with how we deal with your complaint, you can contact your Country Data Protection Authority if applicable. Commission Nationale pour la Protection des Données – Tel. (+352) 2610 60 1, Fax (+352) 2610 60 29.

Art.26.7 – How else to contact us:

If you have any other questions about your personal information, please contact us by email at domicilium@domicilium-re.com.

For all enquiries not relating to your Personal Information please contact us here: domicilium@domicilium-re.com