Compliance Action Guidelines
Based on the Tokyo Tatemono Group Compliance Charter with emphasis on our relationships withcustomers/business partners, society, shareholders/investors, andcompanies/executives/employees, the Tokyo Tatemono Group has formulated the following 15item Action Guidelines that form our standards of conduct.
1. We will engage in fair and sound corporate activities in compliance with laws and regulations(1) Observance of Laws and Regulations
・ We will engage in fair and sound corporate activities based on social norms and highcorporate ethics, in compliance with laws and regulations.
・ We will understand and respect national and regional laws and regulations, as well as culturesand customs.
(2) Proper Relationships with Partners
・ We will respect the rights, obligations, standpoints, etc. of our business partners and will
engage in sound transactions grounded in economic rationality.
・ We will not engage in gift exchanges, entertaining, or the offer or receipt of other benefits
beyond the extent deemed to fall under proper social norms.
(3) Fair Competition
・ We will not permit anti-competitive practices such as collusion and price cartels.
・ We will not engage in acts of unfair competition such as improper acquisition of confidential
information or dumping.
(4) Proper Relationships with Politics and Government
・ We will maintain transparent and sound relationships with politics and government.
・ Based on the Policy on the Prevention of Bribery at Tokyo Tatemono Group, we will not offer
economic advantage to persons who are or who are deemed to be civil servants.
(5) Ban on Relationships with Antisocial Forces
・ We will take a firm stance against antisocial forces and will never respond to improper
demands, etc.
・ We will take constant care to avoid participation in money laundering (actions to disguise funds
obtained through criminal acts as funds earned through legitimate economic activities), etc.
(6) Proper Management of Information
・ We will protect the privacy of individuals, will properly manage personal information obtained in
the workplace, and will not use information for purposes other than its original purpose. We will
also take due care to avoid externally disclosing personal information in the absence of valid
reason, without the consent of the persons involved.
・ We will not unreasonably infringe on the interests of customers, business partners, othercompanies, etc. by leaking confidential information obtained in the course of work.
・ We will make proper use of the Company's information systems and will enact proper safety
management measures with sufficient care given to information management. We will not
improperly access or obtain information from information systems owned or managed by othercompanies or other persons.
(7) Prohibition of Improper Activities, etc.
・ We will execute the business of the Company in good faith and will not take actions thatdamage the reputation or credibility of the Company or take actions that are contrary to theinterests of the Company.
・ Upon becoming aware of improper activities, etc., we will make use of the Tokyo TatemonoGroup Helpline.
・ In cases of becoming aware of undisclosed important information about a company, until said
information is publicly announced, we will not engage in purchase or sale of shares of the said
company or encourage others to do so, and will not engage in actions that may cause
suspicions.

・ We will properly manage information to ensure that undisclosed important information is notleaked to third parties through carelessness, etc.
(8) Respect for Company Assets
・ We will maintain full awareness that all Company assets are lent or provided for the purpose of
executing the business of the Company, and will not make use of these for private purposes.
・ We will not provide or disclose intellectual property held by the Company to third parties
without the approval of the Company.
・ We will respect intellectual property held by other companies or other persons, and will not
duplicate said property without permission or otherwise use it improperly.
2. We will think from customers' point of view and act in good faith(1) Sincere Response to Customers
・ We will disclose truthful and accurate information about the products and services that weprovide to customers.
・ Putting customers' point of view first, we will respond in good faith to requests and complaints
concerning our products and services.
3. We will contribute to the achievement of a better society through our corporate activities(1) Environmental Considerations
・ We will conduct business activities with consideration of the global environment, on the basisof the Tokyo Tatemono Group Environmental Policy.
・ In the supply chain as well, we will work toward co-existence and joint flourishing with thenatural environment by practicing procurement activities that take the global environment intoconsideration.
(2) Timely and Appropriate Information Disclosure, Financial Reporting and Appropriate Tax
Reporting・ We will disclose Company information that significantly affects investment decisions toshareholders and investors in a timely and appropriate manner.
・ We will engage in reliable financial reporting and proper tax reporting in accordance withaccounting- and taxation-related laws and regulation and with other generally accepted
accounting standards.
(3) Co-existing with Local Communities
・ We will strive to build and maintain good relationships with local communities.
・ We will seek co-existence and co-prosperity with local communities through fully
understanding the communities and engaging in corporate activities grounded in thosecommunities.
4. We will respect each others' personalities and values and will ensure a comfortable workingenvironment.
(1) Respect for Human Rights and Prohibition of Discrimination
・ We will respect human rights and will not engage in discrimination on the basis of race,nationality, creed, gender, sexual orientation, age, social status, origin, etc.
(2) Prohibition of Harassment
・ We will not engage in acts of harassment that cause distress or discomfort to others or thosearound them.
・ We will strive to maintain workplace environments free of harassment.
(3) Guarantee of a Comfortable Working Environment
・ We will assure open workplace environments through the formation of relationships of trustthat enable all persons to speak freely and through fair treatment of personnel.
・ We will seek to maintain harmony between work and private life, such as childrearing, and toengage in efficient work that is healthy in mind and body.
Established on July 1, 2020