Contents

Message fromthe President

Sustainabillity

FeatureEnvironment

SocialGovernanceCompliance

Policy and Concept

SystemThe Tokyo Tatemono Group defines compliance as complying

The Tokyo Tatemono Group established an Internal Control

not only with laws and regulations, but also with social norms

Committee as part of our system to promote compliance. Thisand corporate ethics. This approach builds a long-lastingcommittee discusses internal management risks, including

relationship of trust with society and allows us to continue

group compliance, fraud, and anti-corruption, overseeing groupsound corporate activities. We believe companies mustcompliance activities.

respond sincerely to the needs of people in our surrounding

The Tokyo Tatemono General Affairs Division supports andenvironment, including our customers, business partners,

guides the compliance-related operations of group companies.

shareholders, investors, local communities, and employees.

This division also aims to improve compliance functions

In June 2009, the Tokyo Tatemono Group established athroughout the group through collaboration between andshared Compliance Charter for group companies. This charter

among group companies.

is our pledge to society to promote corporate activities thatare committed to unwavering compliance.

▶ Compliance Structure

Tokyo Tatemono Group
Compliance Charter

ReportBoard of Directors

Audit & Supervisory Board

Internal Control Committee

Chair: President and CEO

As we engage in corporate activities, we observe
the Compliance Charter below:

ReportSecretariat

General Affairs Division◯ We adhere to laws, regulations, and other rules
and engage in fair, sound corporate activities.

Corporate Planning Division◯ We act faithfully by thinking from the customers'
standpoint.

Internal Audit Division
Compliance
AwarenessActivities◯We contribute to making society better throughcorporate activities.
◯We respect the personalities and values ofeach other and maintain a comfortable workingenvironment.

Receive
Reports

ReportInternal Audit
DivisionDivisions
Group Companies

Person Responsible
for Compliance

Established June 2009

Coordinate▶ Compliance Indicators and Results

Item
Number of Employees Taking Compliance Training (E-Learning)
Compliance Training (E-Learning) Completion Rate
Compliance Survey Response Rate

Unit

2015

2016

2017

2018

2019

Employees

657

814

847

860

873

％

99.4

98.8

98.5

99.3

99.8

％

77.0

71.2

80.5

80.2

75.0

Number of Helpline Calls and Consultation Incidents

Cases

2815445956

Number of incidents related to bribery

Cases

00000

Number of incidents related to antitrust or anti-competitive behavior

Cases

00000

Number of incidents related to other compliance violations

Cases

00000

◯ Data Collection Period: January to December of each year. Unles s otherwise specified, figures are as of December each year.
◯ Data Collection Scope: Tokyo Tatemono72

Contents

Message fromthe President

Sustainabillity

FeatureEnvironment

SocialGovernanceCompliance Manual

Preventing Corruption and Bribery

The Tokyo Tatemono Group created the Tokyo Tatemono

In our Compliance Charter, we declare our commitment toGroup Compliance Manual to ensure we put our Compliancecomply with laws and regulations, engaging in sound, fairCharter into practice.

corporate activities. To meet this commitment, we established

The Compliance Manual is for all persons engaged inanti-bribery rules, ensuring we prevent bribery, fraud, orwork at group company workplaces, regardless of employee

corruption in other forms.

classification, system at location employed, or employment

As one specific initiative, we conduct training to publicize andtype. The manual provides 15 codes as standards of conduct.

ensure consistent compliance with the rules defined in theWe distribute the Compliance Manual to all employees

Compliance Manual.

engaged in work at group companies. We may also post theThe Tokyo Tatemono Group was not assessed any finesmanual in certain locations on an office-by-office basis.

related to corruption in fiscal 2019.

Tokyo Tatemono has posted a collection of cases thatare useful as references for the Compliance Manual on our< Relevant Compliance Manual Codes of Conduct >corporate intranet, categorized by code of conduct.

1-1 Comply with laws and regulations

We strive to prevent corruption, bribery, and to prohibit

1-2 Maintain proper relationships with partners

discrimination by sharing case studies related to bribery and1-3 Engage in fair competition

LGBT issues.

1-4 M aintain proper relationships with governments andadministrations< Codes of Conduct >1-1 Comply with laws andCompliance
ManualPreventing Anti-Competitive Practices

regulations
1-2 Maintain proper relationships withIn our Compliance Charter, we declare our commitment topartners

comply with laws and regulations, engaging in sound, fair

1-3 Engage in fair competition

corporate activities. Through training and other measures, we

1-4 Maintain proper relationships withpublicize and teach the content of our Compliance Manual,governments and administrations

working to prevent anti-competitive practices (monopolies, etc.).

1-5 R
 eject relationships with anti-social

The Tokyo Tatemono Group was not assessed any fines

forcesrelated to anti-competitive practices, etc., in fiscal 2019.

1-6 Engage in proper management of information
1-7 Prohibit dishonest behavior< Relevant Compliance Manual Codes of Conduct >1-8 Respect corporate assets

1-1 Comply with laws and regulations

2-1 Respond sincerely to customers

1-2 Maintain proper relationships with partners

3-1 Exercise consideration for the environment

1-3 Engage in fair competition

3-2 E ngage in timely and appropriate disclosure, conduct
appropriate tax reporting
3-3 Practice co-existence with local communities
4-1 Respect human rights and prohibit discrimination
4-2 Prohibit harassment
4-3 Provide a comfortable work environment73

Contents

Message fromthe President

Sustainabillity

FeatureEnvironment

SocialGovernanceCompliance Training

Helpline

Every year, the Tokyo Tatemono Group conducts groupwide

The Tokyo Tatemono Group established the Tokyo Tatemono

joint training via e-learning. During 2019, approximately 4,000Group Helpline, which is a shared group resource formanagers and employees across 15 companies completed

employees to consult and report as a means to prevent legal

training or updated their understanding of revised laws.

issues or fraud.

Training topics included the appropriate use of alcohol,

This resource is available to all group employees. The reports

information management (including anti-corruption initiatives

and consultations received through this system are reported

and prevention of insider trading), and matters related toto the Tokyo Tatemono Internal Audit Division, which reports

the Building Lots and Buildings Transaction Business Law

directly to the president. The Internal Audit Division investigates

and the Act on Prevention of Transfer of Criminal Proceeds

and conducts fact-checking independently.

(prevention of money laundering, etc.). In addition, we

We take appropriate measures, implementing prompt

conducted joint training for new group hires, held seminars forcorrective actions and preventing the recurrence of any acts

harassment prevention training instructors (general manager

in violation of compliance The Internal Control Committeelevel), sponsored seminars on the appropriate use of alcohol,

convenes to consider responses to the most serious cases.

conducted training for new Tokyo Tatemono employees, andIn the spirit of the Whistleblower Protection Act, we

provided leadership trainings for newly promoted individuals.

take appropriate measures to ensure the protection ofTo prevent corruption and bribery, we use the Tokyo

whistleblowers.

Tatemono intranet to publish articles on preventing insider▶ Number of Helpline Calls and Consultations

trading, moderation in the consumption of alcohol andappropriate management of information as needed, publicizing

Reports,
Consultation Category

the availability of these articles throughout our organization.
On the subject of legal and tax matters of high importanceto our business, we invite outside experts as lecturers for2016

2017

2018

2019

Report28

15394948

Consultation

11

5

108

Labor Issues

11313

1116

Sexual harassment

71313

Other harassment

7726

39

34

Other

45283(Breakdown)

seminars. These seminars cover the latest examples of trials,

2015

tax reforms, and other information related to business activities
throughout the group.

Compliance Surveys
Since 2009, the Tokyo Tatemono Group has conducted anResponse to Anti-Social Forces

annual compliance survey to understand and verify complianceawareness and acceptance among group employees.

The Tokyo Tatemono Group created Exclusion of Anti-Social

In 2019, 9,826 employees from 18 group companies wereForces Rules, which detail our rules to exclude any and all

surveyed with a response rate of 75%.

relationships with anti-social forces and establishes specific

The results of the survey were analyzed to understandresponses by group company and for the group as a whole.

methods for conducting due diligence on organizations

This analysis was then reported to the Internal Control

referencing the Anti-Social Forces Check Manual.

Committee.We also provide feedback to group companies as

We cooperate with outside experts and organizations suchan aid in solving problems in advance, reflecting on complianceas the police and lawyers as part of our resolute response tostructure, and engaging in compliance awareness activities.

anti-social forces.

74