Compliance Statement

Last updated: December 16, 2025

1. Our Commitment

Beherzig Realty is committed to the highest ethical standards and compliance with all applicable laws and regulations. As a trusted partner in the Swiss luxury real estate segment, compliance is not just a legal obligation but an integral part of our corporate culture.

We operate according to the following principles:

• Integrity: Honesty and transparency in all business relationships
• Responsibility: Taking responsibility for our actions
• Professionalism: Highest standards in consulting and service
• Confidentiality: Protection of sensitive client information

2. Anti-Money Laundering Act (AMLA)

As real estate brokers, we are subject to the Swiss Anti-Money Laundering Act (AMLA). We fulfill our due diligence obligations conscientiously and consistently.

2.1 Know-Your-Customer (KYC) Procedures

We conduct thorough KYC checks for all business relationships:

• Identification and verification of the contracting party
• Determination of the beneficial owner
• Clarification of the business purpose and origin of assets
• Continuous monitoring of the business relationship

2.2 Suspicious Activity Reports

We immediately report suspicious transactions to the Money Laundering Reporting Office Switzerland (MROS) according to Art. 9 AMLA. Our employees are trained to recognize signs of money laundering or terrorist financing.

2.3 Record Retention

All relevant documents and records are retained for at least 10 years according to Art. 7 AMLA.

3. Data Protection Compliance (DPA/GDPR)

We comply with the provisions of the Swiss Data Protection Act (DPA) and the EU General Data Protection Regulation (GDPR).

3.1 Data Protection Principles

• Lawfulness: Data processing only on legal basis
• Purpose Limitation: Collection only for specified, explicit purposes
• Data Minimization: Limitation to necessary extent
• Accuracy: Ensuring correct and current data
• Storage Limitation: Retention only as long as necessary
• Integrity and Confidentiality: Appropriate security measures

3.2 Details

For detailed information, please see our Privacy Policy.

4. Conflicts of Interest

We proactively disclose potential conflicts of interest and always act in the best interest of our clients.

4.1 Identification of Conflicts of Interest

We systematically examine whether conflicts of interest may exist:

• Own economic interests vs. client interests
• Representation of multiple parties in a transaction
• Personal relationships with contracting parties
• Competitive situations between clients

4.2 Management of Conflicts of Interest

• Transparent disclosure to all affected parties
• Obtaining written consent for dual representation
• Implementation of appropriate safeguards (Chinese Walls)
• If in doubt: Declining the mandate

5. Anti-Corruption and Bribery

We do not tolerate any form of corruption or bribery. All business is conducted transparently and lawfully.

5.1 Gifts and Hospitality

Our employees may not accept or offer inappropriate gifts or hospitality:

• Permitted: Low-value promotional items (< CHF 100)
• Reportable: Gifts and hospitality > CHF 100
• Prohibited: Cash, gift vouchers, inappropriate benefits

5.2 Payments to Third Parties

All payments are transparent and traceable. Commission payments to third parties are agreed upon in writing and documented.

6. Reporting Channel for Compliance Violations

We promote an open communication culture and encourage reporting of compliance violations.

6.1 Whistleblowing System

Reports of compliance violations can be made confidentially and anonymously:

6.2 Whistleblower Protection

• Protection from retaliation and discrimination
• Confidential treatment of all reports
• Possibility of anonymous reporting
• Independent investigation by Compliance Officer

7. Regular Training

All employees receive regular training on compliance topics:

• Basic Training: For all new employees (mandatory)
• Annual Training: Refresher and updates (mandatory)
• Specialized Training: Specialized training on AMLA, data protection, etc.
• Case Studies: Analysis of real compliance cases

Participation in compliance training is mandatory and documented.

8. Compliance Organization

8.1 Compliance Officer

Our Compliance Officer is responsible for:

• Development and implementation of compliance guidelines
• Monitoring compliance with regulations
• Conducting risk assessments
• Coordinating training measures
• Processing reports of compliance violations

8.2 Compliance Monitoring

We conduct regular compliance audits:

• Quarterly: Review of high-risk transactions
• Annually: Comprehensive compliance audit
• Event-driven: Upon suspicion of violations

9. Continuous Improvement

We continuously review and update our compliance measures:

• Adaptation to new legal requirements
• Integration of best practices
• Consideration of lessons learned
• Incorporation of employee feedback

10. Contact

For questions about compliance, please contact: