Social and Environmental Initiatives 2009

Compliance

The Mitsui Fudosan Group regards the practice of compliance as one of its highest priorities for Group management, and develops a compliance framework while working to promote compliance.

Mitsui Fudosan Group Compliance Policies

Group Compliance Policies in an employee handbook

Group Compliance Policies in an employee handbook

The Mitsui Fudosan Group has established the Mitsui Fudosan Group Compliance Policies. Under these Policies, the Group has declared its intention to implement fair and highly transparent corporate activities in accordance with corporate ethics, in addition to observing laws and regulations.

Mitsui Fudosan Group Compliance Policies

Mitsui Fudosan Group Compliance Policies

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.

Definition of Compliance

Definition of Compliance

The Mitsui Fudosan Group defines compliance as “the conducting of corporate activities appropriately and fairly with due consideration given to compliance with laws, regulations and internal regulations as well as general social norms and corporate ethics.”

Mitsui Fudosan's Compliance Framework

Discussions and Reports at Board of Directors' Meetings and Other Meetings

Material compliance matters are either regularly discussed or reported at Board of Directors' meetings and Executive Management Committee meetings or as necessary.
The Company has also established a Risk Management Special Committee to manage administrative risks. Compliance is regarded as part of administrative risks, which is in general managed by the Committee.
In principle, the Risk Management Special Committee convenes once a month. It discusses company regulations, plans, systems, etc. related to compliance, gives reports on their practice and determines policies that are necessary.

Improvement of Company Regulations

We establish the Compliance Policies and develop their frameworks, institute Criteria for Employee Behavior, action plans and other company regulations related to compliance as necessary. The Group practices compliance based on these.

Compliance in Relation to the Financial Instruments Business

With the enforcement of the Financial Instruments and Exchange Law, Mitsui Fudosan completed registration to carry out the financial instruments business. Accordingly, we are establishing a compliance framework necessary as a financial instruments business operator. In particular, we are developing relevant company regulations and an internal control framework. In addition, we comply with the Financial Instruments and Exchange Law and other related laws and regulations, as well as instructions, etc. given by the authorities.

Mitsui Fudosan Group's Compliance Framework

Each company of the Mitsui Fudosan Group is striving to practice compliance by establishing company regulations or a framework in similar fashion to Mitsui Fudosan, and by executing plans.
Furthermore, Mitsui Fudosan and each Group company shares compliance-related information and are striving to address issues together to improve compliance as a Group.
Moreover, Mitsui Real Estate Sales Co., Ltd., Mitsui Fudosan Investment Advisors, Inc., Nippon Building Fund Management Ltd., Mitsui Fudosan Frontier REIT Management Inc., and Mitsui Fudosan Accommodations Fund Management are engaged in the financial instruments business. As such, they comply with the Financial Instruments and Exchange Law and other related laws and regulations, as well as instructions, etc. given by the authorities. They also are establishing a compliance framework by developing company regulations or an internal control framework, among others.

Mitsui Fudosan Group's Compliance Activities

Compliance Program

Each fiscal year, each company of the Mitsui Fudosan Group formulates and implements a “Compliance Program” which stipulates their plan for compliance-related activities.
Specifically, we plan various training seminars to entrench knowledge on compliance, conduct various examinations for ensuring compliance, carry out compliance supervision and tests and create detailed plans for activities to report the contents of the aforementioned activities. Through these activities, the Mitsui Fudosan Group is striving to practice compliance appropriately.
The results of activities of each fiscal year are reported at the Board of Directors' meeting. Furthermore, we discuss new activities or review how we may improve activities based on these results and then reflect them in the plans for the following fiscal year or later.

PDCA Cycle of the Compliance Program

PDCA Cycle of the Compliance Program

Building a Structure for Compliance to Take Root

In order to raise awareness or the level of understanding of compliance and have it take root, the Mitsui Fudosan Group implements training on compliance.
For example, Mitsui Fudosan implemented training concerning compliance in general for all its employees. Furthermore, it implements training to executive officers, new heads of departments and new employees, including training for each job grade, or departmental training. Moreover, Mitsui Fudosan provides training, etc. on specific laws or regulations, or company regulations.
Also, to enable employees to refer to or retrieve company regulations, statements or expertise related to compliance, we have established a portal site on the company's information systems and are striving for the entrenchment of knowledge on compliance.

Beginning of an internal portal site

Beginning of an internal portal site

Internal Consultation System (Internal Reporting System)

Each company of Mitsui Fudosan Group takes steps as a company to address issues that are difficult to resolve under the normal operational system, as well as sexual harassment or power harassment issues. In order to do so, we have set up an internal consultation system for addressing such issues (equivalent to an ordinary helpline).
We have developed a system to promote ease-of-use by establishing a contact point at responsible departments within the company, as well as a common contact point for the Mitsui Fudosan Group at law offices outside the company. When operating the system, we ensure that the privacy of those seeking consultation is protected and prohibit detrimental treatment.

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