Corporate Philosophy, Group Profile, Contents, Editorial Policy

Management

Special Feature

Environment

SocialGovernance

Data

Third-Party Assurance

GovernanceCorporate Philosophy, Group Profile, Contents, Editorial Policy
Management

Compliance

Message from the President and CEO
ESG Management
Materiality of the Tokyo Tatemono Group

Policy and Concept

Special Feature
Environment
Environmental Management
Sustainability Finance
External Evaluation and Certification for Green Building
Responding to Climate Change
Pollution Control and Resource Recycling
Water Resources
Biodiversity
Responding to Natural Disasters

The Tokyo Tatemono Group defines compliance as complying
not only with laws and regulations, but also with social norms
and corporate ethics. This approach builds a long-lasting
relationship of trust with society and allows us to continue
sound corporate activities. We believe companies must
respond sincerely to the needs of people in our surrounding
environment, including our customers, local communities,employees, shareholders and investors, and business partners.
In June 2009, the Group established a shared Compliance
Charter for group companies. This charter is our pledge tosociety to promote corporate activities that are committed tounwavering compliance.

compliance activities.
The Tokyo Tatemono General Affairs Department supports
and guides the compliance-related operations of groupcompanies. This Department also aims to improve compliancefunctions throughout the Group through collaboration between
and among group companies.

Responding to Compliance Violations
In the event that a matter is discovered that may be deemed topose a compliance problem, the matter is reported to theChairman of the Internal Control Committee and other relevant
parties. An investigation team is set up to investigate the facts

Work-Life Balance
Human Resource Investment and Development

Respect for Human Rights
Improving Quality and Customer Satisfaction
Revitalizing and Utilizing Real Estate StockContributing to Our Communities

Compliance Charter
As we engage in corporate activities, we observe theCompliance Charter below:
We adhere to laws, regulations, and other rules and engage
in fair, sound corporate activities.
We act faithfully by thinking from the customers’ standpoint.
We contribute to making society better through corporate
activities.
We respect the personalities and values of each other andmaintain a comfortable working environment.
Established June 2009

ReportBoard of Directors

Risk Management
Compliance
Supply Chain ManagementData

Audit & Supervisory Board

Internal Control Committee
Committee Chair: President
Secretariat
General Affairs Department
Corporate Planning Department
Internal Audit Department

GovernanceCorporate Governance

Provisions for Violations of Laws and Regulations,Lawsuits, etc.

An amount is estimated at the end of the fiscal year for finesand settlements that are likely to arise from events that
occurred prior to the current fiscal year, and provisions aremade accordingly. No significant provisions were made at theend of fiscal 2020.

Compliance Structure

Report

Health Management / Occupational Safety and Health(Data) Compliance Indicators and Results P.73

Formulation of a Compliance ManualSocialDiversity & Inclusionand promptly take the necessary measures to rectify the matterand prevent recurrence.

SystemThe Tokyo Tatemono Group established an Internal Control
Committee as part of our system to promote compliance. Thiscommittee discusses internal management risks, includinggroup compliance, fraud, and anti-corruption, overseeing group

Compliance
Awareness Activities

ReportReceive Reports

Internal Audit

Business Divisions
Group Companies
Person Responsible forCompliance

Coordinate

The Tokyo Tatemono Group created the Compliance Codes ofConduct and the Tokyo Tatemono Group Compliance Manual
to ensure we put our Compliance Charter into practice.
We distribute the Compliance Manual to all employees
engaged in work at group companies. In addition to theCompliance Charter, this document contains 15 standards ofconduct, including the Compliance Action Guidelines, theGroup Environmental Policy, and theGroup Anti-Bribery Policy.
We distribute the Compliance
Manual to all employees engaged inwork at group companies. We may
also post the manual in certain
locations on an office-by-office basis.
Tokyo Tatemono has posted acollection of cases that are useful asreferences for the Compliance ManualCompliance Manual

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Corporate Philosophy, Group Profile, Contents, Editorial Policy

Management

Special Feature

Environment

SocialGovernance

Data

Third-Party Assurance

GovernanceCorporate Philosophy, Group Profile, Contents, Editorial Policy
Management

Compliance

Message from the President and CEO
ESG Management
Materiality of the Tokyo Tatemono GroupSpecial Feature
Environment

on our corporate intranet, categorized by code of conduct.
We strive to prevent corruption, bribery, and to prohibit
discrimination by sharing case studies related to bribery andLGBT issues.

Environmental Management
Sustainability Finance
External Evaluation and Certification for Green Building
Responding to Climate Change
Pollution Control and Resource Recycling
Water Resources
Biodiversity
Responding to Natural Disasters

SocialDiversity & Inclusion
Work-Life Balance
Human Resource Investment and Development
Health Management / Occupational Safety and HealthRespect for Human Rights

Compliance Codes of Conduct
1-1 Comply with laws and regulations
1-2 Maintain proper relationships with partners
1-3 Engage in fair competition
1-4 M aintain proper relationships with governments andadministrations
1-5 Reject relationships with anti-social forces
1-6 Engage in proper management of information
1-7 Prohibit dishonest behavior
1-8 Respect corporate assets
2-1 Respond sincerely to customers
3-1 Exercise consideration for the environment
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 environment

Anti-Bribery Guidelines.
We do not make donations related to political activities toindividual politicians or organizations other than political parties
or political fund organizations. When making donations related
to political activities to political parties and political fundorganizations, we take appropriate measures in accordancewith the Political Funds Control Act, the Public Offices Election
Act, and other related laws and regulations.
The Tokyo Tatemono Group was not assessed any fines orother penalties related to corruption in fiscal 2020. In addition,in fiscal 2020, the Internal Control Committee did not receive
any reports of bribery nor any convictions or administrative
actions for bribery. Accordingly, there were no employeedisciplinary actions or dismissals resulting from violations ofthe Tokyo Tatemono Group Anti-Bribery Guidelines.
Relevant Compliance Codes of Conduct
1-1 Comply with laws and regulations
1-2 Maintain proper relationships with partners
1-3 Engage in fair competition
1-4 Maintain proper relationships with governments and administrations

Improving Quality and Customer Satisfaction
Revitalizing and Utilizing Real Estate Stock

Preventing Corruption and Bribery

Preventing Anti-Competitive Practices

In our Compliance Charter, we declare our commitment tocomply with laws and regulations, engaging in sound, faircorporate activities. We have in place Tokyo Tatemono Group
Anti-Bribery Guidelines and prohibit the provision of economic
benefits to public officials or deemed public officials. In addition,
through training and other means, we are working to ensurethat employees are fully aware of the Compliance Codes ofConduct regarding anti-corruption and Tokyo Tatemono GroupThrough training and other measures, we publicize and teachthe content of our Compliance Manual, working to preventanti-competitive practices (monopolies, etc.).
The Tokyo Tatemono Group was not assessed any fines orother penalties related to corruption in fiscal 2020.

Contributing to Our Communities

GovernanceCorporate GovernanceRisk Management
Compliance
Supply Chain Management

Data

Relevant Compliance Codes of Conduct
1-1 Comply with laws and regulations
1-2 Maintain proper relationships with partners
1-3 Engage in fair competition

Compliance Training
Every year, the Tokyo Tatemono Group conducts training via
e-learning. During 2020, approximately 3,900 managers andemployees across 15 companies participated in the training (aparticipation rate of 98.1%). The training provided employeeswith an opportunity to learn about a range of topics, while
updating their knowledge about various revisions in laws andregulations. Training topics included: general complianceincluding anti-corruption; harassment prevention; information
management including prevention of insider trading; and theReal Estate Brokerage Act and the Criminal Proceeds Transfer
Prevention Act including prevention of money laundering. Other
online training programs were provided that were specific tocertain levels of employees, including anti-harassment training,training for directors and department heads, and training for
newly appointed leaders.
To prevent corruption and bribery, we use the Tokyo
Tatemono intranet to raise awareness about these issues
throughout our organization by publishing a series of monthly
compliance news articles that includes articles on preventing
insider trading, fraud, and harassment.
On the subject of legal and tax matters of high importanceto our business, we invite external experts as lecturers forseminars. These seminars cover the latest examples of trials,

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65

Corporate Philosophy, Group Profile, Contents, Editorial Policy

ManagementSpecial Feature

Environment

SocialDataGovernance

Third-Party Assurance

GovernanceCorporate Philosophy, Group Profile, Contents, Editorial Policy
Management

Compliance

Message from the President and CEO
ESG Management
Materiality of the Tokyo Tatemono GroupSpecial Feature
Environment

Data Related to Compliance Training (E-learning)

Environmental Management

Number of training participants
Training completion rate

Sustainability Finance
External Evaluation and Certification for Green Building(Persons)Water Resources

98.8

1,000814

Responding to Climate Change
Pollution Control and Resource Recycling

Establishment of a Helpline

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

98.5847

Scope of Collection: Tokyo Tatemono Co., Ltd.

99.3

860

99.8

99.9(%)

873884100

80080600

6040040200

20Biodiversity
Responding to Natural Disasters

SocialDiversity & Inclusion

02016201720182019

2020

0Work-Life Balance
Human Resource Investment and Development
Health Management / Occupational Safety and HealthRespect for Human Rights
Improving Quality and Customer Satisfaction
Revitalizing and Utilizing Real Estate StockContributing to Our Communities

GovernanceCorporate GovernanceRisk Management
Compliance
Supply Chain Management

Data
Third-Party Assurance

Compliance Surveys
Since 2009, the Tokyo Tatemono Group has conducted anannual compliance survey to understand and verify the degree ofcompliance awareness and acceptance among group employees.
In 2020, 8,660 employees from 18 group companies weresurveyed—a response rate of 74.8%.
The results of the survey were analyzed to understandresponses by group companies and for the Group as a whole.
This analysis was then reported to the Internal Control
Committee. We also share the survey results on the intranet
and provide feedback to group companies as an aid in solving
problems in advance, reflecting on compliance structure, andengaging in compliance awareness activities.

In the spirit of the Whistleblower Protection Act, we takeappropriate measures to ensure the protection of whistleblowers.

The Tokyo Tatemono Group established the Tokyo TatemonoGroup Helpline, a shared group resource. Using the Helpline,
employees can report to and seek consultation with an external
contact for matters such as harassment, to prevent legal issues
or fraud, or to take early action in addressing such matters. All
workers throughout the Group are entitled to use the helpline.
The privacy of anyone who uses the helpline is protected.
The reports and consultations received through this system
are reported to the Tokyo Tatemono Internal Audit Department(an organization that reports directly to the president).
Depending on the case, the investigation and fact-checking is
conducted by the Internal Audit Department, by the reporting
desk at each Group company, or by the harassment responsedesk of each company. As a result of the investigations, we takeappropriate measures to address actions that constitutecompliance violations, such as promptly taking corrective
measures and measures to prevent recurrence.
The Internal Control Committee convenes to consider
responses to the most serious cases.

Number of Helpline Calls and Consultations (FY2020)
Other: 4Labor Issues: 8Sexual harassment: 2

Other harassment: 27(Data) Reports and Consultations to the Helpline P.74

Response to Anti-Social Forces
The Tokyo Tatemono Group created Exclusion of Anti-Social
Forces Rules, which detail our rules to exclude any and all
relationships with anti-social forces and establishes specificmethods for conducting due diligence on organizations
referencing the Anti-Social Forces Check Manual. We
cooperate with external experts and organizations such as
the police and lawyers as part of our resolute response toanti-social forces.

Tax ComplianceIn accordance with the Compliance Charter, the Tokyo TatemonoGroup pays taxes appropriately, in accordance with international
standards as well as the laws, regulations, and social norms ofeach country and region.
We respond conscientiously to the tax authorities and strive
to maintain good relationships with them. In all of ourresponses to questions from tax authorities, we haveprovided honest and accurate explanations of the facts as
we understand them.

Data Collection Scope: Tokyo Tatemono Group(Data) Compliance Training and Return Rate ofCompliance Surveys P.73
TOKYO TATEMONO GROUPSUSTAINABILITY REPORT 202166