Policy to Prevent Bribery and Corruption

The Group positions compliance as a management issue of the highest priority, and in addition to ensuring compliance with laws, regulations, and social norms, it forbids any kind of corruption, and executes corporate activities that are fair and highly transparent, in line with corporate ethics. To that end, the Group makes concerted efforts to maintain and improve its compliance structure.

The Mitsui Fudosan Group Compliance Policies sets forth the relevant compliance definitions and conduct guidelines, as well as summarizing the structure and procedures needed to achieve its basic policies as its Compliance Rules, with a specific code of ethics codified as the Compliance Procedures.

Moreover, the Group has set conduct guidelines for areas such as eliminating organized crime, preventing money laundering, eliminating unfair transactions, preventing insider trading, prohibiting gifts and entertainment, and forbidding contributions to politicians and political organizations. In this way, it makes consistent efforts to ensure compliance and prevent bribery and corruption of any kind.

Furthermore, the Group formulated the Sustainable Procurement Standards in 2018, and is working to completely eliminate bribery and other forms of corruption throughout the entire supply chain.

⇒ Click here to see the Mitsui Fudosan Group Compliance Policy in their entirety

⇒ Click here to see the Mitsui Fudosan Group Sustainable Procurement Standards in their entirety

Enhanced Compliance

The employee handbook includes a clear description of Group Compliance Policies. We also strengthen compliance and ensure broad dissemination of information by issuing Compliance news to all employees when appropriate. This news covers topics specified in the Compliance Manual (based on the Mitsui Fudosan Group Compliance Policy) such as eliminating organized crime, preventing money laundering, eliminating unfair transactions (abuse of superior bargaining position), preventing insider trading, prohibiting gifts and entertainment, and duty of confidentiality regarding company information.

Group Compliance Policies recorded in an employee handbook

Prohibiting Bribery and Handling of Gifts and Entertainment

Mitsui Fudosan has prohibited the illicit provision of benefits to public officials and other individuals in similar positions. Also, in dealings with business connections and affiliates, etc., a rule has been established preventing the giving or receiving of excessive gifts, entertainment, and the like. Also, the Company has established a structure and rules to be followed to prevent bribery and has formulated and is implementing Regulations for Preventing Bribery with the aim of preventing such conduct before it occurs.

Our Efforts to Assess the Risk of, and Prevent, Corruption

(1) Compliance promotion plans and training

In order to promote compliance, we formulate a compliance promotion plan each fiscal year as a concrete plan of action for compliance. Based on the plan, we carry out training on issues such as eliminating organized crime, preventing money laundering, eliminating unfair transactions (abuse of superior bargaining position), preventing insider trading, and prohibiting gifts and entertainment, as well as preventing any other kind of corruption.

(2) Policy on high-risk fields

We comprehensively assess every kind of corruption risk and endeavor to control it when selecting new domestic and international business partners and entering new regions and business areas. We ask our prospective business partners to fill out a basic check sheet and a compliance check sheet, and also have our legal compliance-related departments confirm the absence of any violations. In this way, we carry out a comprehensive examination in areas designated or assessed to be high risk, such as preventing bribery, eliminating organized crime, preventing money laundering, eliminating unfair transactions, preventing insider trading, and forbidding contribution to politicians and political organizations.
In 2021, to assess the risk of corruption, we began conducting surveys based on the Sustainable Procurement Standards for suppliers and contractors to ascertain the situation at each company, asking about designated high-risk issues such as preventing bribery and other forms of corruption, avoiding interactions with organized criminal groups, and promoting fair business activities.

(3) Internal consultation service

We have established an internal whistle-blower system that allows for consultations to be made anonymously, and in this way, we strive to prevent bribery or any other kind of corruption.

(4) Supervision and improvement processes

Businesses deemed to be at high risk of corruption are monitored closely by the Executive Management Committee and the Strategy Planning Special Committee, and they decide on an appropriate response in each case. The Board of Directors closely monitors the Corruption Prevention Policy. The Risk Management Special Committee has oversight of anti-corruption policy, including such areas as eliminating organized crime, preventing money laundering, eliminating unfair transactions, preventing insider trading, prohibiting gifts and entertainment, and forbidding contribution to politicians and political organizations. It regularly reports to the Board of Directors.

Political Donations

Mitsui Fudosan does not provide donations for political activities to any parties other than official political parties and political fund-raising organizations. Furthermore, support for activities by political organizations is conducted appropriately in accordance with the Political Funds Control Law, laws and regulations connected to the Public Offices Election Law, and other relevant laws and regulations.

Fiscal 2015-2023

• One donation each year, to The People's Political Association. Amount: ¥20 million