The Mitsui Fudosan Group has established the Mitsui Fudosan Group Compliance Policies, and the entire Group has been committed to the promotion of compliance. In these Policies, compliance is not limited to compliance with laws, regulations and corporate ethics. Instead, the purpose of compliance is defined as proactively responding to expectations held by society based on a strong awareness of social norms and principles and the Group's responsibilities as a corporate citizen.

In an effort to maintain the trust and brand strengths that the Mitsui Fudosan Group has accumulated to date, it is essential that the respective employees exercise proper judgment and take appropriate actions in their daily activities, conforming to a high level of corporate ethics. To accomplish this, we regard the practice of compliance as one of our highest priorities for Group management and implement fair and highly transparent corporate activities in accordance with corporate ethics, in addition to observing laws and regulations as well as social norms.

With the enforcement of the Companies Act on May 1, 2006 requiring the establishment of internal control as well as the Financial Instruments and Exchange Law on September 30, 2007, we have established a new risk management framework as of January 1, 2008 in consideration of registration as a financial instruments firm.
We have set up the Strategy Planning Special Committee and the Risk Management Special Committee under the Executive Management Committee as a company-wide risk management framework. The Risk Management Special Committee divided administrative risks into the following four risks to be managed, and decided to submit regular reports as necessary to the Executive Management Committee and the Board of Directors.

Further, with regard to compliance, the following items are reported at the monthly Risk Management Special Committee.

1. Report on progress and status concerning matters such as Mitsui Fudosan's lawsuits.
2. Report on Group-wide compliance
3. Report on compliance with laws, regulations, etc.
4. Report on status of training (plans/results)
5. Report on transactions of financial instruments

In addition, the Risk Management Special Committee gains approval for important matters concerning compliance and indicates the policies of the Mitsui Fudosan Group to be announced to the entire Group.

In response to the enforcement of the Financial Instruments and Exchange Law, we have improved our compliance-related rules.

1. As of September 30, 2007, the rules concerning financial instrument transactions were improved.
2. As of October 1, 2007, the Compliance Rules were established.
3. As of April 1, 2008, the Compliance Rules were revised and the system for compliance-related rules was rearranged.

April 1999	Criteria for Employee Behavior instituted.
April 2001	Compliance Special Committee established.
December 2003	Internal Consultation System and Sexual Harassment Consultation System established at Mitsui Fudosan.
October 2004	Compliance Group established in Audit Department as body to supervise and manage compliance activities for entire Mitsui Fudosan Group.
April 2005	Mitsui Fudosan Group Compliance Policies established.
March 2006	Internal Consultation Service also established within each Mitsui Fudosan Group company.
April 2006	Compliance PDCA Cycle for entire Group established
April 2007	Audit Department Compliance Group reorganized as General Affairs Department Legal Compliance Group. Operations Management Department newly established to manage compliance related to financial instrument transactions.
May 2007	Shared Mitsui Fudosan Group External Consultation Service established.
September 2007	Company regulations and other rules related to financial instruments business improved.
October 2007	Compliance Rules established.
January 2008	Framework for Risk Management Special Committee launched.
April 2008	Compliance Rules revised. Subsidiaries and Affiliates Administration Rules revised.

In order to spread awareness of compliance with laws and regulations, company rules, social norms and ethics and such among all employees working at the Mitsui Fudosan Group, various efforts have been made to improve compliance awareness and thoroughly familiarize employees with the rules.

Compliance Training

Mitsui Fudosan continues to work to cultivate awareness and knowledge of compliance through the implementation of broad-ranging training programs for its employees, including training for each job grade, knowledge-based training, departmental training and training for each Group company.

Penetration Activities

Helpline

An Internal Consultation System and Sexual Harassment Consultation System have been set up within Mitsui Fudosan, and an Internal Consultation System has been established at each Group company. Furthermore, an External Consultation System shared by the entire Mitsui Fudosan Group has also been established.
At the same time, we have been taking steps to ensure that a helpline thoroughly familiarizes the employees of the Mitsui Fudosan Group with such knowledge.

As of April 1, 2008, we revised the Subsidiaries and Affiliates Administration Rules and formulated Mitsui Fudosan's basic policies concerning each Group company's compliance framework (Group Compliance Guidelines). Based on this, each Group company will develop its compliance framework and implement the compliance program created by each company.

Introduction of initiatives conducted by the Mitsui Fudosan Group for actual projects