Mitsui Fudosan｜Sustainability

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.

Policy Prohibiting Discrimination
We will eliminate all discrimination on the grounds of race, nationality, religion, sex, age, disability, or sexual orientation.
Policy Prohibiting Harassment
We will not tolerate any form of harassment, including sexual harassment or abuse of power.
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.
Policy to Support Freedom of Association and the Right to Collective Bargaining
We respect freedom of association and the right to collective bargaining.
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.
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.

Mitsui Fudosan Group Human Rights Policy

Symbolized by our Group DNA, the meaning of "&" which represents the idea that "to generate new value through cooperation, coexistence and co-creation, we forge ahead, innovating", the Mitsui Fudosan Group strives a society where both humanity and the Earth can progress in harmony, we believe that it is of the utmost importance to ensure that our business always gives due consideration to human rights, so we have established the Mitsui Fudosan Group Human Rights Policy (hereinafter this Policy).

This Policy is based on the Guiding Principles for Business and Human Rights advocated by the United Nations.

1. Respect for international human rights standards

The Mitsui Fudosan Group supports and respects international human rights norms including the Universal Declaration of Human Rights, the International Covenants on Human Rights, and the core labor standards established by the International Labour Organization (ILO) in the ILO Declaration on Fundamental Principles and Rights at Work, which are: freedom of association and the effective recognition of the right to collective bargaining; the elimination of all forms of forced or compulsory labor; the effective abolition of child labor; and the elimination of discrimination in respect of employment and occupation.

2. Position of this policy

This policy details initiatives based on the conviction that we must be thorough about ensuring that our business always gives due consideration to human rights in order to achieve our GROUP DNA, the meaning of "&", "to generate new value through cooperation, coexistence and co-creation, we forge ahead, innovating".

3. Scope

This policy applies to all of the Mitsui Fudosan Group's officers and employees (all employees directly employed, including temporary employees, part-time workers, etc.). In addition, we ask our business partners to take human rights into consideration in their corporate activities based on this policy and the Mitsui Fudosan Group Sustainable Procurement Standards.

4. Education and training

The Mitsui Fudosan Group provides appropriate education and training to ensure that this policy is taken into account and effectively executed in all its business activities.

5. Human rights due diligence

The Mitsui Fudosan Group assesses in advance any negative impacts on human rights that could affect the various people with a relationship to its business activities (stakeholders) and takes both preventive and improvement initiatives. In addition, we appraise the performance and effectiveness of these initiatives and disclose relevant information.

6. Corrections and remedies

If it becomes clear that the Mitsui Fudosan Group has had a negative impact on human rights due to its business activities, or that it has been complicit in such impact, it works to correct and remedy the situation using appropriate internal procedures. In addition, the Mitsui Fudosan Group maintains a system for reporting and consulting about any acts that have a negative impact on human rights.

7. Dialogue with stakeholders

The Mitsui Fudosan Group continues to improve its human rights initiatives based on this policy, by engaging in dialogue with various stakeholders.

8. Salient issues related to human rights initiatives

Salient issues related to human rights initiatives are listed in an appendix to this policy. As these salient issues may change in response to evolving business and social conditions, we revise them as needed.

Established December, 2020; Revised April, 2024
Takashi Ueda
President & Chief Executive Officer
Mitsui Fudosan Co., Ltd.

Appendix

Salient issues related to human rights initiatives

Prohibition of discrimination, harassment, or other unfair treatment in the workplace

We prohibit discrimination and unfair treatment on grounds not related to business performance, including race, nationality, origin, religion, beliefs, sex, age, disability, sexual orientation, gender identity, educational background, marital status, and employment type. We also do not allow any harassment in the workplace, such as sexual harassment or power harassment.

Ensuring a safe and healthy working environment

In addition to complying with laws and regulations related to working hours and occupational health and safety, we create a working environment in which all employees can work enthusiastically without feeling health or safety concerns when working.

Consideration for safety, security, and health in urban development

We conduct thorough quality control to ensure that the safety and health of our clients and the other people who use our facilities and services are not impaired. We also consider the safety and health of the people near the areas where we conduct business.

Consideration of minorities and prohibition of unfair discrimination toward them in business activities

In our business activities, we provide facilities and services that take minorities (social minorities; e.g., people with disabilities or foreigners, etc.) into consideration. In addition, we prohibit unfair discrimination or the promotion of discrimination when providing facilities and services.

Sufficient communication with clients and other stakeholders in business activities

In conducting our business activities, we strive to ensure that information provision and communication are sufficient to gain the understanding of our clients and other stakeholders.

Framework

ESG Governance Structure

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 our human rights due diligence efforts, we are working to establish a grievance mechanism, including in collaboration with our internal consultation service.

Establishment of an Internal Consultation Service

The Company has established internal contact points for consultation for individuals engaged in work for the Company. Two contact points, one internal and one external, have been established, and anyone engaged in work for the Company may use either.

The external contact point is provided at a law office, where consultations are accepted from a neutral standpoint.*1 The law office notifies the Company of the consultation content and encourages the Company to take appropriate action.

*1. The law office cannot provide legal opinions as lawyers, or take a stance protecting the consulting person.

Awareness and Training

As part of our annual companywide sustainability training (e-learning), we provide internal training on our Human Rights Policy and Sustainable Procurement Standards, including an overview of our Human Rights Policy.

Major Initiatives (Human rights due diligence)

Identification of Important Human Rights Issues

The Mitsui Fudosan Group identifies important human rights issues based on the UN Guiding Principles on Business and Human Rights. In doing so, we examined potential negative human rights impacts that our business activities and transactions may have on stakeholders, including issues related to labor, occupational health and safety, supply chains, and local communities.

When formulating our human rights policy in fiscal year 2020, we identified and assessed human rights risks for each business segment, extracting a total of 202 human rights risk items. These were then evaluated from the perspectives of severity and likelihood of occurrence as outlined in the UN Guiding Principles, and 42 items were designated as important human rights issues for the Group. Furthermore, considering factors such as the ease of engagement*1 and the scope of relevant organizations, we organized the priority level of initiatives into four tiers and incorporated this into our ongoing human rights due diligence.

In fiscal year 2025, we reviewed human rights risk items in light of changes in the social and business environment and reassessed our human rights issues. As a result, the number of important human rights risks was revised from 42 to 40. We will continue to manage and improve human rights risks through regular evaluation and monitoring.

*1. Ease of engagement refers to considerations such as the business relationship dynamics and the importance of transactions with our Group from the counterpart’s perspective.

Refining by severity and probability

Probability		Medium (more than once a decade, less than once every three years)
Severity: High	Direct	We selected issues in this area as important human rights issues (human rights impacts)
Severity: High	Indirect
Severity: Medium	Direct
Severity: Medium	Indirect
Severity: Low	Direct
Severity: Low	Indirect

Human Rights Risk Management within the Company and Group Companies

As part of our human rights due diligence in business operations, we conducted surveys in fiscal years 2022 and 2025 on four business divisions and ten group companies to assess the status of initiatives related to human rights compliance. These surveys focused on human rights issues identified during the formulation of our human rights policy, particularly items highly relevant to each business. We reviewed the establishment of internal systems, dissemination of manuals and procedures, and the implementation of training programs. In addition, we conducted interviews with some business divisions and group companies to confirm their responses to human rights issues and their understanding of related challenges. Based on the survey results, we identified high‑risk items and provided feedback to business divisions and group companies that require improvement. For the issues identified, we engage in dialogue and encourage improvements as necessary.

Furthermore, in March 2023, we conducted interviews with foreign technical intern trainees engaged in cleaning operations at a group company (Mitsui Fudosan Facilities). Through these interviews, we recognized the importance of having a system that allows trainees to consult about everyday concerns, including language-related issues. Going forward, we will work to strengthen support systems, including the use of external consultation services such as JP-MIRAI. We will continue to carry out ongoing monitoring, education, and awareness‑raising to prevent and mitigate human rights risks in our business activities.

Human Rights Risk Management in the Supply Chain

Based on the results of our human rights risk assessments, we conduct surveys and dialogue aligned with our Sustainable Procurement Standards for suppliers and business partners that are closely connected to our business activities and are considered to have significant potential human rights impacts.
For major contractors and business partners with whom we have ongoing relationships, we confirm their responses to sustainability issues—including human rights—through questionnaires, interviews, and on‑site inspections. When necessary, we also encourage improvements. Going forward, we will continue to promote ongoing dialogue and engagement to identify, prevent, and mitigate human rights risks within our supply chain.

For detailed survey results, identified issues, and improvement initiatives, please refer to Supply Chain Management.
⇒ https://www.mitsuifudosan.co.jp//english/esg_csr/society/04.html

Establishing Remedy Mechanisms

In line with the UN Guiding Principles on Business and Human Rights, our company is advancing initiatives aimed at addressing and remedying negative human rights impacts. As part of these efforts, we are working to establish remedy mechanisms for foreign workers within our supply chain.
In April 2022, we joined Japan Platform for Migrant Workers towards Responsible and Inclusive Society (JP-MIRAI)*, an organization dedicated to supporting foreign workers in Japan. Through participation in the Corporate Collaborative Program to realize responsible acceptance of foreign workers, we make use of resources such as information services for foreign workers, multilingual consultation hotlines, and dispute‑resolution mechanisms designed with independence and neutrality in mind. We also utilize human rights risk information related to foreign workers provided by JP‑MIRAI to strengthen our supply chain management and human rights due diligence. Currently, we apply these mechanisms to foreign technical intern trainees at major group companies, and we will consider expanding the scope through discussions with supply chain partners.

* JP‑MIRAI is a platform established in November 2020 to address issues faced by foreign workers in Japan, and it became a general incorporated association in June 2023. (For details, https://jp-mirai.org/?lang=en)

Platform for Responsible Recruitment of Foreign Workers

Industry Collaboration / Stakeholder Engagement

Participation in the Construction and Real Estate Human Rights Due Diligence Promotion Council

To ensure that companies collectively fulfill their responsibility to respect human rights in addressing common challenges within the construction and real estate industries, our company joined the Construction and Real Estate Human Rights Due Diligence Promotion Council in December 2023. In collaboration with peer companies and construction firms, we will share member initiatives related to human rights due diligence, conduct research on leading practices, and engage in outreach activities with stakeholders.

Stakeholder Engagement with Experts

Regarding our initiatives on human rights due diligence, we have received the following comments from Ms. Ayumi Fukuhara, an attorney and member of the Ministry of Economy, Trade and Industry’s Guideline Review Committee on Respecting Human Rights in Supply Chains. We will incorporate her feedback into our future efforts wherever possible.

Ms. Ayumi Fukuhara

Partner Attorney at a law firm Nagashima Ohno & Tsunematsu. Her primary areas of expertise are corporate crisis management and compliance. In the field of Business and Human Rights, she provides extensive advice on human rights due diligence, human rights issues in supply chains, and global compliance. She has served as a member of the Ministry of Economy, Trade and Industry’s Guideline Review Committee on Respecting Human Rights in Supply Chains, among other roles.

Regarding Mitsui Fudosan Group’s human rights due diligence, it can be positively evaluated that in fiscal year 2025 you reviewed your priority human rights issues, conducted questionnaire surveys for internal departments and group companies, and encouraged improvements through dialogue based on the issues identified. These efforts align with the UN Guiding Principles on Business and Human Rights (UNGP).

Your Group is primarily engaged in leasing, property sales, management, and facility operations businesses. Generally, these types of businesses involve relatively long supply chains across the stages of development, construction, and management, and they also have the characteristic of supporting the foundations of life—including local communities—over long periods of time. For these reasons, it is necessary to consider human rights risks in relation to a wide range of stakeholders. Going forward, it is expected that you will conduct human rights due diligence in overseas regions where you operate, prioritizing efforts based on regional and national risk levels. It is also anticipated that you will deepen your initiatives by establishing standards for conducting human rights due diligence at the stages of new contracts and development projects.

Additionally, with respect to the questionnaire surveys conducted as part of human rights due diligence, it is generally understood that responses tend to be self‑evaluations by the respondents, meaning accuracy and truthfulness are not always guaranteed. As a result, there is a risk that actual practices may differ from what is reported. As you have done this fiscal year with internal departments and group companies, it is advisable to continue verifying responses critically—such as by using questionnaires as an entry point for dialogue—and to prioritize follow‑up based on the content of the responses.