Policy

The Group respects basic human rights and complies with the laws and regulations concerning worker's rights in each country where we conduct business. We also support and respect the basic rights for workers set out in the ILO Declaration on Fundamental Principles and Rights at Work. The Group complies with applicable laws and regulations in each country and region where we conduct business.

1. Policy Prohibiting Discrimination
   We will eliminate all discrimination on the grounds of race, nationality, religion, sex, age, disability, or sexual orientation.
2. Policy Prohibiting Harassment
   We will not tolerate any form of harassment, including sexual harassment or abuse of power.
3. Policy to Prevent Child Labor or Forced Labor
   We will not permit child labor or forced labor. The Group has never used child or forced labor. To ensure that none is used in the future, we ensure that each business location complies thoroughly with the laws and regulations of its host country and conduct regular monitoring. In the unlikely event that such a violation is suspected to have occurred, we have also established a whistle-blower contact point that employees can report to.
4. Policy to Support Freedom of Association and the Right to Collective Bargaining
   We respect freedom of association and the right to collective bargaining.
5. Policy Supporting Rights to a Minimum Wage and Living Wage
   The Group conducts labor management while abiding by the labor laws and regulations of each country. In terms of wages, we have adopted a basic policy of not only following rules on minimum wages in each country, but also paying wages that exceed those requirements.
6. Principles and Procedures for Community Investment
   The Group carries out business activities that do not infringe on human rights, either inside or outside Japan, by ensuring respect for the human rights of all stakeholders, including local residents and children. Through neighborhood creation, we are striving to form communities and create opportunities for interaction between diverse human resources, ultimately leading to new markets and employment. In this way, we offer various forms of value to the communities where we conduct business. By participating in and funding area management organizations, we invest in local communities, and work to increase the value of real estate.

Furthermore, we pursue methods to ensure that basic human rights are respected in countries and regions that do not adhere to internationally-recognized basic human rights.

The Group has established the Mitsui Fudosan Group Human Rights Policy as detailed below, and is promoting human rights-related initiatives. The policy can also be found via our internal portal and as well as raising awareness within the Group through training and other measures, we have established our Sustainable Procurement Standards based on this policy. We are also promoting human rights due diligence for the supply chain in accordance with the UN's Guiding Principles on Business and Human Rights.

Framework

Under the Executive Management Committee, which supervises overall risk management for the Group, the Strategy Planning Special Committee and the Risk Management Special Committee manage business risk and administrative risk respectively.

The Managing Director acts as the person in charge of legal affairs and compliance, the Chief Risk Officer, the Chief Legal Affairs Officer, and the Chief Officer for Compliance, and he or she belongs to the Board of Directors and Risk Management Special Committee, is assigned oversight responsibility, and periodically reports on risk management, including for human rights risks, to the Board of Directors.

To promote measures aimed at addressing sustainability issues, and in accordance with company rules, we have established the ESG Promotion Committee (headed by the President and Chief Executive Officer) and under it the ESG Management Committee (headed by the Director of the Sustainability Promotion Division). In each department, we have appointed a group leader responsible for ESG issues, and their role is to actively promote awareness of, and share information about, human rights and other sustainability issues within their departments, and relevant businesses and Group companies. At present, alongside expanding human rights due diligence, we are investigating how to put in place mechanisms to deal with complaints, including through cooperation with our internal consultation service.

Establishment of an Internal Consultation Service

The Company has established internal contact points for consultation. These can be used by regular employees, and anyone engaged in work for our company based on an individual labor contract (contract employee), temporary transfer agreement, worker dispatch contract, part-time contract, or other agreement. Two contact points, internal and external, have been established, and workers can consult with either. The external contact point is provided at a law office, and it accepts consultations from a neutral standpoint,*1 notifies the Company of the consultation content, and encourages a response.

Topics for consultation include: wrongful conduct violating laws, regulations, internal rules, general social norms, or corporate ethics, sexual harassment, abuse of power, other forms of harassment, employment problems, and issues with the workplace environment.*2 The privacy of those who engage in consultation is protected, and there is never any retaliatory action or disadvantageous treatment due to such consultations in terms of personnel decisions. Consultations can be conducted under a real name, or anonymously.*3

Major Initiatives (Human rights due diligence)

When formulating our Human Rights Policy, in order to narrow down major issues related to human rights, we designated and evaluated human rights risks. In each business segment, we select issues related to our activities or business dealings that would infringe human rights of any of the stakeholders. We refine issues down to major human rights issues (human rights risks) specific to our Group, based on their severity according to the UN Guiding Principles and the likelihood of their occurrence. We also determined four levels of priority for initiatives informed by the scope of the relevant organization and the ease *1 with which we could minimize human rights risks. In the future, too, we will assess risks related to human rights issues (human rights risks) on an on-going basis, and review their priority levels, among other methods of continuous risk management.

Human rights impact evaluation

Human Rights Due Diligence

In 2020, we started human rights due diligence in accordance with the UN Guiding Principles on Business and Human Rights. As a supplement to the Human Rights Policy, we designated major issues related to human rights.

For more detailed information about the Salient issues related to human rights initiatives, please refer to the following link.
⇒ https://www.mitsuifudosan.co.jp/esg_csr/society/03.html

We are continuously evaluating their impact on human rights, and putting in place initiatives to prevent or minimize their impact, and will continue monitoring.

Human rights impact evaluation

Human rights impact evaluation is carried out for new and existing groupwide business (predominantly in Japan) in the manner detailed below. This evaluation also covers human rights issues that relate to labor problems or health and safety. When evaluating impact, we also took advice from Akiko Sato, an attorney who is a deputy secretary general at Human Rights Now, an international human rights NGO. We will ensure that in the future, too, we will continue to have such opportunities to gather feedback periodically.

To select major human rights impacts, we investigated the impact of issues related to our activities or business dealings that would infringe human rights of any of our stakeholders in each business segment (from a total of 202 issues). In line with their severity according to the UN Guiding Principles, and other factors, we narrowed the list down to a total of 42 important human rights issues (human rights impacts) unique to our business.

Sample of impact on stakeholders and human rights

Refining by severity and probability

Survey into the status of initiatives to address human rights issues in our business

As part of the Mitsui Fudosan Group's human rights due diligence, in FY2022, we carried out a questionnaire survey into initiatives to respect human rights at four divisions and ten group companies (as well as interviews at a group company).

The questionnaire looked into 15 issues-those strongly relevant to the work of the divisions and group companies taken from 42 human rights issues identified during the formulation of the Mitsui Fudosan Group Human Rights Policy-and surveyed internal systems to prevent human rights violations, awareness of manuals and procedures, status of training, etc.

Human rights risks and future issues in business operations

Based on the results of the survey, we identified risks we anticipate in each business segment, and we referred to the status of actual initiatives to designate high-risk items.

Each related department or group company will investigate future issues for each item, and will work to address these.

Interviews with foreign technical intern trainees

In March 2023, we interviewed technical intern trainees from the Philippines working as cleaners at a group company (Mitsui Fudosan Facilities) about the following topics to investigate human rights issues as they relate to foreign trainees.

• Normal lifestyles
• Work
• Details of their lives up to coming to Japan
• Clarity of labor criteria/treatment during recruitment and contract signing
• Consultations when they have encountered issues in their normal work or personal lives
• Other (passport safekeeping, contract penalties, evacuation plans for an earthquake, medical checkups, etc.)

We did not discover any particular human rights problems, but one thing that became clear was the importance of having someone around them to talk to about concerns in their work and personal lives arising from language issues or similar. Going forward, we will work to create a system that can support trainees by utilizing external consultation services such as JP-MIRAI.

Supply chain engagement

After we identified significant impacts regarding human rights risks that the Group's business poses to communities, we conduct supply chain questionnaire surveys and on-site inspections to properly grasp the impact on suppliers of important issues that relate to human rights and to investigate measures to prevent or minimize this impact.

FY2021: Regarding construction sites that are considered to have the most significant impact on human rights risks, we conducted a questionnaire on overall ESG initiatives, including those related to human rights, with six construction companies, and undertook construction site inspections at two. From next year onward, in order to strive to reduce human rights risks, we continue to implement engagement with stakeholders by expanding the number of target companies and worksites.

FY2022: We conducted a questionnaire with six building operation and management contractors, and undertook on-site inspections at two companies' operation sites. We also conducted a questionnaire with around 200 tenant companies at our commercial facilities.
(See "Supply Chain Management" for more details)
⇒ https://www.mitsuifudosan.co.jp/english/esg_csr/society/04.html

Stakeholder engagement to designate issues that impact on human rights
(Conducted on October 26, 2020, and August 2, 2021)

To designate issues that impact on human rights, we engaged with Akiko Sato, an attorney who acts as a deputy secretary general at Human Rights Now, an international human rights NGO. Her feedback is given below. We have reflected Ms. Sato's opinions as much as possible in the formulation of our Human Rights Policy, amendments to our Sustainable Procurement Standards, and in the implementation of our human rights due diligence. In the future, we hope to have Ms. Sato give feedback on how best to promote initiatives on the theme of business and human rights.

Expectations for the Mitsui Fudosan Group's initiatives for business and human rights

Akiko Sato

Attorney at Kotonoha Law. Deputy Secretary General at Human Rights Now, an international human rights NGO, and Business and Human Rights Liaison Officer, United Nations Development Program (UNDP).

Currently, Ms. Sato works to enhance awareness and understanding of business and human rights by providing advice on topics such as human rights policy and human rights due diligence; coordinating stakeholder engagement; and proposing policy to the government.

Feedback:

• The Group needs to reconsider existing tasks from the framework of human rights, and embed human rights perspectives into decision-making as part of daily work.

• With respect to information disclosure for human rights due diligence, when relaying information on the priority ranking process externally, the Group should make it clear that its investigations are based on the perspective of rights holders, and explain that to external stakeholders in line with ideas contained within the UN Guiding Principles.

• Many companies comply with human-rights-related laws and regulations, or enact initiatives to that end, but the Group must investigate whether merely complying with domestic law is sufficient in addressing the theme of business and human rights. Actually, many measures show some of Japan's laws including the law on eliminating discrimination against persons with disabilities are not up to international human rights standards. In the future, I would like the Group to recognize the gap between those international standards and Japanese domestic law, and respond to those international standards in line with the UN Guiding Principles.

• For issues related to supply chain initiatives where it is unclear where to start, one consideration should be first whether the issue has surfaced in the current situation in Japan or overseas, and whether it is a topic of international debate. For example, real estate companies should also focus on and evaluate the use of illegally harvested materials used at construction sites to make frames for concrete, something that is pointed out and debated by NGOs looking to eradicate the practice.

• The Black Lives Matter movement and other questions of racial discrimination are debated as international human rights issues, and so from an international perspective I think the Group would do well to publicize its own commitment to the cause. Japanese companies tend to do poorly in this regard. In light of corporate social responsibility, this may be evaluated by the international community as a lack of commitment to human rights and social issues.

• The level of demand to respond to human rights problems internationally can be considered from the perspective of the UN Guiding Principles on Business and Human Rights and its concept of eliminating adverse impacts. I feel it is also vital that the Group also focus on whatever positive impact their initiatives can make.

• Japanese businesses, when promoting diversity and inclusion, present the positive side-increased participation-but must also be earnest in efforts to tackle the root of the issue as a human rights risk, i.e., by banning discrimination. This will allow them to clarify policy and gain the understanding of stakeholders.

• Japanese companies don't feel comfortable to announce it when their initiatives don't make progress, but even making it clear that the company is aware of problems even if they are unable to effectively deal with it is itself important. If this kind of information is not disclosed externally, the transparency and accountability for stakeholders must be considered lacking. In such cases, there is a risk that a business may be shut out of the capital market.

Relief Mechanism Initiatives

We are also working to establish a redress mechanism for supply chain workers as part of our consideration of remedying "negative impacts" as stipulated in the UN Guiding Principles on Business and Human Rights.

JP-MIRAI (Platform for Responsible Recruitment of Foreign Workers) to handle foreign worker relief

In April 2022, we joined JP-MIRAI (Platform for Responsible Recruitment of Foreign Workers)* which addresses relief for foreign workers.

* JP-MIRAI is a voluntary organization established in January 2020, which brings together a diverse group of stakeholders including private companies, local governments, NPOs, experts, and lawyers to work together toward a "Japan of choice" by solving issues related to foreign workers in Japan. As of May 2022, there are 443 participating members. Private companies and JICA (Japan International Cooperation Agency) serve as the joint secretariat. Main activities include: 1) providing information and listening to the voices of foreign workers, 2) consultation services and relief mechanisms, 3) multi-stakeholder study groups and workshops, 4) collaborative projects (efforts to secure human resources, emergency support), and 5) dissemination to the domestic and international community.
(For details, see: https://jp-mirai.org/jp/)

Participation in Foreign Workers Consultation and Relief Pilot Project

As part of our initiatives to establish a relief mechanism, we are participating in the "Foreign Worker Consultation and Relief Pilot Project" launched by JP-MIRAI in May 2022. This project is the first of its kind in Japan to package an integrated mechanism from provision of information to foreign workers, a multilingual consultation service, and independent and neutral dispute resolution, as well as feedback of human rights risks to companies. The following are some of the benefits of the program for foreign workers of participating companies and related companies in the supply chain: (1) information through a portal site for foreign workers, (2) a low-hurdle consultation service in nine languages, (3) support for problems that are difficult for foreign workers to solve on their own, and (4) use of an out-of-court Alternative Dispute Resolution (ADR) mechanism in the event of a dispute. This is a project to analyze issues faced by foreign workers based on data collected in the provision of services. Our company is working to strengthen its supply chain management and human rights due diligence by utilizing the human rights violation risk information regarding foreign workers provided by JP-MIRAI. We will begin using the system for foreign technical intern trainees from our main group companies, and plan to expand the scope of use of the system in the future through discussions with each supply chain company.

Other Initiatives

Our Efforts for Children's Rights

The Group supports the abolition of child labor inside and outside Japan, and respects the rights of children, namely: (1) The Right to Live, (2) The Right to Be Protected, (3) The Right to Be Nurtured, (4) The Right to Participate. We believe that ensuring healthy development of the children who will be the next generation-through neighborhood creation and operation of facilities-is essential for an affluent future, and based on that idea, we are making various efforts to support the human rights of children in our business activities and projects.

Business Activities and Projects Relating to Children's Rights

Personnel training

Companywide compliance training (e-learning) twice a year, in addition to human rights training that uses videos once year, includes internal training (explanations of our Human Rights Policy, etc.) related to our Human Rights Policy and our Sustainable Procurement Standards.