Deutsche Industrie REIT : Declaration of conformity dated 22 October 2021

Declaration of Compliance of Deutsche Industrie REIT-AG with the German Corporate

Governance Code (GCGC)

The Management Board and the Supervisory Board of Deutsche Industrie REIT-AG welcome and support the German Corporate Governance Code (GCGC) and its objectives.

In accordance with § 161 (1) German Stock Corporation Act (AktG), the Boards declare that Deutsche Industrie REIT-AG has complied and will in future comply with the recommendations of the Government Commission on the German Corporate Governance Code in the version dated 16 December 2019, published in the official section of the Federal Gazette (Bundesanzeiger) on 20 March 2020, with the following exceptions since the last Declaration of Compliance which was issued on 23 October 2020 (updated on 24 March 2021):

• Recommendation A.1 GCGC - Consideration of diversity in the filling of management positions: The Management Board does not currently follow the recommendation to take diversity into account when filling management positions in the company. The employees of the company currently do not have any management functions. Apart from the Management Board, there are no management positions to be filled in the company, which is why the company cannot follow this recommendation.
• Recommendation A.2 GCGC - Compliance Management System: The company currently employs only ten staff. The Management Board therefore sees no need to develop and publish a formalised system for compliance management or so-called"whistleblowing". In view of the size of the company, the cost of setting up, implementing, and maintaining formalised systems has not been and is not in any reasonable proportion to the potential benefits.
• Recommendation B.1 GCGC - Observance of diversity in the composition of the Management Board: The Supervisory Board does not currently follow the recommendation to observe diversity when appointing Management Board members in the company. The company is of the opinion that professional qualifications and knowledge of the company are decisive as prerequisites for appointment, so that the above-mentionedrequirements are not conducive to achieving the objective.
• Recommendation B.2 GCGC - Long-term Succession planning by the Supervisory Board and Management Board: In view of the current age of the members of the Management Board (38 to 51 years), the company does not consider long-termsuccession planning to be necessary at present.
• Recommendations C.1 and C.2 GCGC - Specification of objectives for the composition of the Supervisory Board, in particular consideration of diversity and the development of a competence profile:
  The Supervisory Board has not set any concrete objectives for its composition or developed a competence profile for the entire committee and does not intend to set such objectives or develop a competence profile in the future. Nor have any rules on diversity in the objectives for the composition of the Supervisory Board except as set out below, been set or will to be set in the future. The company is of the opinion that the technical qualifications and knowledge of the company are sufficient as prerequisites for the appointment of members to the Supervisory Board, such that the above-mentioned objectives are not conducive to achieving the objective. By resolution of 10 September 2020, the Supervisory Board set 20% as the target for female participation for the period until 30 September 2025.

• Recommendation C.5 GCGC - Supervisory Board mandates in non-group listed

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companies: While the company assumes that Recommendation C.5 of the GCGC contains guidelines for the members of the company's Supervisory Board (and not for its Management Board), in view of the ambiguous wording, please note that a member of the Management Board , Mr. Rolf Elgeti holds more than two Supervisory Board mandates in non-group listed companies or in comparable supervisory bodies (including as Chairman of the Supervisory Board).

• Recommendation on section D.2 to D.5 GCGC - Supervisory Board committees: In the view of its small number of members, the Supervisory Board has so far refrained from forming committees and therefore does not follow recommendations D.2, D.3, D.4 and D.5 GCGC. However, Deutsche Industrie REIT-AGwill elect an audit committee by the end of the year, which will start its work at the beginning of the next calendar year (2022). The company will therefore follow recommendations D.3 and D.4 in the future. In view of the continued low level of complexity and the transparent business model of Deutsche Industrie REIT-AG,the Supervisory Board does not consider it necessary to form further committees in the future and the entire Board will continue to devote its full attention to the issues at hand.
• Recommendations on Section G.I. of the GCGC - Remuneration of the Management Board: In the past, the remuneration model for the management board, which had developed over time and was implemented before the current German Corporate Governance Code was announced, did not yet comply with recommendations G.1, G.3, G.4, G.6, G.7, G.8 and G.10 to G.13. As already communicated in the update of the Declaration of Compliance of 24 March 2021, the company has now established a remuneration system for the management board that complies with the GCGC except for the points mentioned below.
• Recommendation G.10 GCGC - Remuneration of the management board: The remuneration system of the Management Board approved during by the Annual General Meeting of the company on 12 March 2021 and confirmed by the Supervisory Board, does not provide for the variable remuneration components granted to a member of the Management Board to be predominantly invested in shares of the company or to be granted on a share-basedbasis, in deviation from item G.10 of the GCGC. The company is of the opinion that the creation of an incentive by linking the value of the variable remuneration to the long-termdevelopment of the share price of the company is already sufficiently taken into account within the framework of the calculation of the variable remuneration and the conditions for payment. Thus, the development of the share price (in addition to the operating results and the net asset value of the company) represents an essential basis for the assessment of the variable remuneration. Moreover, most of the variable remuneration is only paid out if a minimum target is also achieved in the three financial years following a financial year. The company is therefore of the opinion that an additional variable remuneration in shares is not necessary to set corresponding incentives. Service contracts already concluded in the past (which in part do not yet fully correspond to the remuneration system now established) shall continue to apply for the time being in accordance with §26j EGAktG.
• Recommendation G.16 GCGC - Crediting of compensation when accepting non-group supervisory board roles:
  The Supervisory Board does not follow the recommendation that, when members of the Management Board take on non-group supervisory board mandates, it should decide whether and to what extent remuneration from the respective supervisory board mandate should be taken into account. Based on the experience with the members of the Management Board and

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their dealings with non-group Supervisory Board mandates, it is not expected that non-group Supervisory Board mandates will have a negative impact on the future activities of the members of the Management Board for the company. Given the Supervisory Board's ability to exercise control on remuneration, which also exists independent of the recommendation, seen to be a decision on the crediting of remuneration from non-group Supervisory Board mandates is not necessary.

Rostock, 22 October 2021

For the Supervisory Board

For the Management Board

Hans-Ulrich Sutter	Rolf Elgeti
Chairman of the Supervisory Board	Chairman of the Management Board

The current Declarations of Compliance are published on our website https://www.deutsche-industrie- reit.de/en/, in the "Investor Relations" section under the menu items "Corporate Governance" and "Declaration of Compliance".

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