Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
System

Improving Management System
Corporate Governance
Policy and Concept
Corporate Governance Reporthttps://tatemono.com/ir/library/governance.html

To enhance the corporate value of Tokyo Tatemono,
we strive to build optimal corporate governance while
securing soundness and transparency of management andincreasing its effectiveness.

SystemTokyo Tatemono has adopted a corporate governancesystem as the structure for corporate governance and wehave established a board of directors and an audit andsupervisory board. In addition, we clarified the division offunctions for management and the execution of operations
to strengthening the auditing functions and businessexecution functions. We are also strengthening the auditing

functions and transparency of management by appointing
external directors and auditors. We believe that we havebuilt a system able to sufficiently execute the supervisingand auditing functions of management and directors.
Furthermore, we established the Group Management
Meeting in an effort toward efficient and sound Groupmanagement.

Corporate Governance Structure
General Meeting of Shareholders
Appointment/Dismissal

Advisory Committee
Advisory

Appointment/Dismissal

Account Auditor

ReportReportCooperation

Board of Directors (Directors)

Appointment/Dismissal

Dismissal Account Audit

Audit and Supervisory Board (Auditors)

Audit

Appointment/Audit
Cooperation

President & Chief Executive Officer
Group Management Meeting

Internal Control Committee
Internal Audit Division

Each Headquarters/Division

Audit Tokyo Tatemono

Each Group Company
Tokyo Tatemono Group●Directors (Board)
There are 12 directors and four are external directors.
As a general rule, Tokyo Tatemono holds a regular Boardof Directors meeting once a month and an extraordinary
meeting when a need arises to decide on important mattersrelated to execution of operations and auditing of theoperations of the directors.
Auditors also attend Board of Directors meetings and share
their opinion when necessary. (Number of members as ofJanuary 2019)60

Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
System●Internal Control Committee
Internal Control Committee discusses and monitors
management of internal control (promoting compliancemanagement and internal management risks), etc. andreports to the Board of Directors, Audit & Supervisory
Board, and other bodies when necessary.

●Auditors (Audit & Supervisory Board)
Audit & Supervisory Board consists from four auditors(two full-time auditors) and two external auditors.
●Executive Officers
Executive Officer System is implemented to stimulate
the Board of Directors by separating management andexecution of operations and to accelerate decision
making process related to operations.

→ Risk management P.63
●Advisory Committee
An advisory committee was put in place as a body toadvise the Board of Directors when deliberating matterssuch as the selection of director candidates and the chief
executive officer as well as the remuneration for directors(excluding external directors). Committee members areappointed from the directors, but we appoint more thanhalf of the total of five directors as external directors toguarantee objectivity and transparency of procedures
while leveraging the knowledge and advice of theseexternal directors.

●Group Management MeetingGroup Management Meeting consisting of executive
officers assigned roles is implemented to deliberate on
important matters related to the management of theGroup.
In addition, fill-time auditors participate in the GroupManagement Meeting to grasp the situation of thedeliberations and share opinions when necessary.

Indicators and Results●Collection Scope• Tokyo Tatemono Co., Ltd.

●Collection Period• January to December each year. Data is as of Decemberof each year unless stated otherwise.
Unit

2014

2015

2016

2017

2018

Number of Board Meetings

Item

Meetings

13

13

13

12

13

Number of Directors

People

7

9

9

11

12

Number of Executive Officers on Board

People

5

6

6

7

7

Number of Non-executive Officers on the
Board (Excluding External Directors)

People

1

0

0

1

1

Number of External Directors

People

1

3

3

3

4

%

97.9%

94.6%

100%

100%

100%

Year

9.3
(March)6.7(March)5.3(March)5.0(March)5.8(March)Board Meeting attendance
Average Tenure of Directors(Including External Directors)

Supporting System for External Directors and Auditors
Furthermore, full-time auditors participate in important
meetings including the Group Management Meeting in
addition to the Board of Directors meeting while receiving
relevant reports from the accounting auditor, directors,
and the employees of each division to build a system thatenables the exchange of opinions with individual bodies at
any time.

The Planning Division, which acts as a Board of Directors
Secretariat, provides explanations and information asnecessary to support the external directors and auditors at
Tokyo Tatemono.
In addition, personnel are assigned as a staff of the auditors
upon request from the Audit & Supervisory Board tosmoothly execute the auditing duties.

61Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
System

Evaluation for the Effectiveness of the Board of Directors
Evaluation Items

Tokyo Tatemono conducts a questionnaire about theconstitution, proposals and management of the Board of
Directors for all directors and corporate auditors once ayear. The Board of Directors analyzes and deliberates theresults of this questionnaire.
We have been able to sufficiently ensure and verify theeffectiveness as a Board of Directors.

Field

Description

Structure

Ratio, number, and diversity of external directors

Proposals

Number, content, and financial criteria of proposals

Operation

Number and length of meetings, ideal form ofadvanced explanations, materials and time for
explanations, time for debate, and content ofmatters to report

Other

Support systems and ideal form of training

Policy on Remuneration and Calculation Method
contribution to growth in the medium to long term corporate
value. By adopting this policy, remuneration, such as thatfor directors, is composed of three types of payments; fixed
remuneration, performance based remuneration, and sharebased remuneration. We limit payment of share based
remuneration (excluding external directors) to a maximum of
40,000 points (equivalent to 40,000 shares) per each fiscal
year.
Remuneration for auditors is limited to basic remuneration
based on the role of the full-time and temporary auditors
and it set to be less than ¥8 million a month (equivalent to¥96 million a year).

The remuneration for directors is set to less than ¥35
million a month (equivalent to ¥420 million a year)*1 as fixedcompensation and 1% of consolidated recurring income andless than 2% of the income*2 of the previous fiscal year isset as performance based remuneration as decided during
the Board of Directors meeting.
Today, we have further clarified the link between
remuneration, such as that for directors, and the shareprice of the company, and we have adopted a stock
remuneration system via a stock bond trust at the 200th
General Meeting of Shareholders held March 28, 2018
for the purpose of heightening awareness about the
Status of Director and Auditor Remuneration (December 2018)

Total Amount by Type of Remuneration
Executive Class

Employee Salary(People)Fixed Compensation(Million Yen)

Performance BasedRemuneration(Million Yen)

Share BasedRemuneration(Million Yen)

Total Salary(Million Yen)

Directors

12

314

155

35

505

(External Directors)

-4

-27

（–）

（–）

-27

Auditors

4

64

–

–

64

(External Auditors)

-2

-12

（–）

（–）

-12

Total

16

379

155

35

570

(External Executives)

-6

-39

（–）

（–）

-39

*1 Based on resolutions at the 190th General Meeting of Shareholders held on March 28, 2008
*2 Based on resolutions at the 195th General Meeting of Shareholders held on March 28, 201362

Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemRisk Management
Policy and Concept
Furthermore, in the preparation of the risk management
structure, we referred to the ISO-31000 international risk
management standards and the JIS-Q-31010 Japanesestandards.

The Tokyo Tatemono Group strives to manage risks thathave the potential to impact the businesses of the Group toheighten the stability of corporate value. We put in place arisk management system to continually monitor and control
risk and provide comprehensive risk management. We haveestablished risk management regulations and put in place arisk management structure to monitor and control ongoingrisks as well as fully manage risk.

Internal Control Reporthttps://tatemono.com/ir/library/control.html

System
We categorize and manage investment risks, financial risks,
operational risks, internal control risks and general risks
that are aggregate risks as vital risks that have a potential
to greatly impact the management of the Tokyo TatemonoGroup.
General risks are stored in the Corporate Planning Division,
which is the department in charge of managing risk, andthe Internal Control Committee debates and manages theinternal control risks (internal control risks and compliancerisks) among those general risks with the President as chair.

We also review policies to respond to general business risks
through the Group Management Meeting and other means.
Furthermore, important matters related to these risks arereported to the Board of Directors as necessary and auditedby the Audit & Supervisory Board.
We are thoroughly managing risk through a series ofprocesses that include monitoring and improving theoperational status of this risk management.

Risk Management Structure

Audit &
Supervisory Board

Board of Directors

Audit

Report of Important Matters

Debate and Report ofImportant Matters

Report of Important Matters

Corporate Planning Division
RiskManagement
Division

Person Responsible for Overseeing Risk Management:
General Manager of Corporate Planning Division
Person Who Assists in Overseeing Risk Management*:
General Manager of the General Affairs Division*Only for internal risk management

Internal Control Committee
Committee Chair: President
Secretariat: General Affairs Division
Assistance: Corporate Planning
Division/Internal Audit Division

Group Management Meeting, etc.
Chairman: President
Secretariat: Corporate
Planning Division

Integrated Risks

Risk
Category(Aggregate of Investment Risk, Financial Risk, Internal Control Risk, Business Risk)

Investment Risk

ReportFinancial Risk
Monitoring/
Improvement

Internal Control Risk

Business Risk

(Aggregate of Internal Management
Risk and Compliance Risk)

ReportMonitoring/
Improvement

ReportMonitoring/
Improvement

Each Division Office
Person Responsible for Risk Management: General Manager of Each Divisional Office
Management/Promotion of Operational Execution: Person Responsible for Operational Management

63Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemJoint Training in Earthquake Measures with Group Companies
In October every year, we conduct collective training inearthquake measures unified with each Group company
and confirm procedures such as the chain of command, thedivision of roles, informational collection and distribution andsafety confirmation.

The Tokyo Tatemono Group defined basic policies when
an earthquake strikes in the Basic Plan of Earthquake
Measures and prepared a manual that includes the initial
response, stockpiling and safety confirmation.

Comprehensive Informational Management
responsible for supervising the management of information
at the core. We are also strengthening management suchas that of personal information and confidential information
through informational management audits through theInternal Audit Division.

The Tokyo Tatemono Group has defined informational
management rules, rules for the handling of personal
information, and rules for handling personally identifiable
information in order to properly handle the information
handled in our operations. Furthermore, we have put inplace an informational management system with the person

64Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemCompliance
Policy and Concept
Tokyo Tatemono Group defines compliance as complying
not only with laws but also social standards and corporate
ethics to gain everlasting trust from society, and it continues
engaging in sound corporate activities. Corporations needto respond to the expectations of customers, business
partners, shareholders, investors, local society, employees,
and other stakeholders, and responding to the needs ofthese stakeholders with integrity is important.
Tokyo Tatemono Group has established the Compliance
Charter to promote corporate activities that observecompliance in June 2009, and it is advancing those efforts.

Tokyo Tatemono Group
Compliance Charter
As we engage in corporate activities, we observe
the Compliance Charter below:• We adhere to laws, regulations, and otherrules and engage in fair, sound corporate
activities.
• We act faithfully by thinking from thecustomers' standpoint.
• We contribute to making society better throughcorporate activities.
• We respect the personalities and valuesof each other and maintain a comfortableworking environment.
Established June 2009

SystemCompliance Promotion System

We established the Tokyo Tatemono Group Internal Control
Committee that discusses Group compliance as well as
general internal control risks, including the preventionof fraud and corruption, and as a framework to promotecompliance and to supervise Group compliance activities.
In addition, the General Affairs Division of Tokyo Tatemono
supports and instructs Group companies on their operations
related to compliance while coordinating with Group
companies to improve the compliance function of the entire
Group.

Board of Directors

ReportAudit & Supervisory Board

Internal Control Committee
Committee Chair:
President & Chief
Executive Officer

ReportSecretariat
General Affairs DivisionCorporate Planning DivisionInternal Audit Division

Compliance Education
Activities Report

Receive Report

Internal
Audit

Each Business Division
Each Group Company
Person in Charge ofCompliance65

Cooperation

Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemIndicators and Results●Collection Scope• Tokyo Tatemono (Number of reports and consultations to
Helpline for the Tokyo Tatemono Group)●Collection Period• January to December each year. Data is as of Decemberof each year unless stated otherwise.
Item

Unit

2014

2015

2016

2017

2018

People

646

657

814

847

860

Completion Rate of Compliance Training

%

99.7

99.4

98.8

98.5

99.3

Return Rate of Compliance Surveys

%

80.9

77.0

71.2

80.5

80.2

Incidents

23

28

15

44

59

Number of Students and Completion Rate ofCompliance (e-Learning) Training

Number of Reports and Consultations to Helpline

Compliance ManualLGBT and actual bribery that has occurred in an effort toprevent corruption, bribery and discrimination.

We formulated the Tokyo Tatemono Group Compliance
Manual to ensure the practice of the Compliance Charter
throughout the Tokyo Tatemono Group.
The Compliance Manual stipulates 16 compliance items asa code of conduct for all people engaged in operations ofoffices of Group companies regardless of their employee
classification, office organization or the employment system.
All employees who work in operations at offices in Group
companies are given the Compliance Manual as a booklet
or it is posted at each office to fully raise awareness.
Tokyo Tatemono also posts case examples on the intranet
divided into 16 compliance items as reference for theCompliance Manual, introduces case studies about theCompliance
Manual<Compliance Items>
1. Observance of Laws and Regulations
2. Proper Relationships with Partners
3. Moderate Gifts and Entertainment
4. Sincere Response to Customers
5. Environmental Considerations
6. Proper Relationships with Politics
and Government

7. Ban on Relationships with Antisocial
Forces8. Timely/Proper Informational Disclosureand Appropriate Tax Reporting
9. Restriction of Insider Trading
10. Respect for Human Rights/Restriction ofDiscrimination and Harassment

11. Guarantee of a Comfortable
Working Environment
12. Proper Management of Information
13. Restriction of Conflicts of Interest
14. Co-existing with Local Communities
15. Management of Information System
16. Respect for Corporate Assets

Preventing Corruption and Bribery<Relevant Items in the Compliance Manual>
1. Observance of Laws and Regulations
2. Proper Relationships with Partners
3. Moderate Gifts and Entertainment
6. Proper Relationships with Politics and Government
13. Restriction of Conflicts of Interest

The Tokyo Tatemono Group has declared to adhere tolaws, regulations, and other rules and engage in fair,sound corporate activities in its Compliance Charter. We
work to raise awareness and thorough compliance withthe compliance items defined in the Compliance Manual
through training and other education to prevent corruption
such as bribery or fraud.
In 2018, there were no incidents of corruption that resulted
in penalties such as fines.

66Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemPreventing Anti-competitive Practices<Relevant Items in the Compliance Manual>
1. Observance of Laws
2. Regulations and Proper Relationships with Partners

The Tokyo Tatemono Group has declared to adhere tolaws, regulations, and other rules and engage in fair,sound corporate activities in its Compliance Charter. We
work to raise awareness and thorough compliance withthe compliance items defined in the Compliance Manual
through training and other education to prevent anticompetitive practices such as prohibiting monopolistic
conduct.
In 2018, there were no incidents of anti-competitive
practices that resulted in penalties such as fines.

Compliance Training
general managers and managers, training for new Tokyo
Tatemono employees, and training for newly appointed
supervisors as well as training to prevent insider trading.
We also design corruption and bribery prevention, use thecorporate intranet, and include spotlight articles about theprevention of insider trading, drinking in moderation andproper relationships with public officials to raise awarenessthroughout the Group.
Furthermore, we hold seminars by inviting outside
experts as lecturers around themes regarding the law andregulation field as well as taxes that have great importancein operations and share the latest judicial examples,tax amendments and other information related to ourbusinesses throughout the entire Group.

The Tokyo Tatemono Group conducts joint Group e-learning
training every year. In 2018, we gained knowledge about
overall compliance, harassment prevention, informational
management such as the prevention of insider training in
addition to the prevention of corruption, the Building Lots
and Buildings Transaction Business Law and the Act on
Prevention of Transfer of Criminal Proceeds such as theprevention of money laundering, as well as brushed up
our knowledge following amendments to the laws andregulations for roughly 2,800 executives and employees
in 13 Group companies, in addition to our foundationin compliance that includes the Compliance Charterand compliance items. In addition, we have introduced
stratified training, such as collective training for new Group
employees, harassment prevention training for executives,

Implementation of Compliance Surveys
of each Group company, and then report that information to
the Internal Control Committee while providing feedback toeach Group company. These results play a role in resolving
issues before they happen and in compliance education
activities as well as being reflected in the compliancesystem.

The Tokyo Tatemono Group conducts compliance surveys
to periodically understand and review the awareness andpenetration about compliance of Group employees every
year since 2009.
This survey was held for 7,162 employees from 13 Group
companies in 2018 with a collection rate of 80.2%.
We analyze the survey results for overall trends and traits

Setup of a Helpline(organization under the direct control of the President) andthe facts are reviewed and verified in accordance with thecontent from an objective standpoint.
We appropriately respond to actions that violate compliance,such as immediate corrective measures as well as steps
to prevent recurrence. The Internal Control Committee
is convened for more important matters to consider the
response.
Furthermore, in accordance with the Whistleblower
Protection Act, we properly protect whistleblowers.

The Tokyo Tatemono Group setup the Tokyo TatemonoGroup Helpline that can be used throughout the Group asa consultation and reporting window to prevent violations
to the laws and illegal acts. Furthermore, the helpline
establishes a contact window with an external law officeto create a system for easy consultation and reporting. All
employees who engage in the businesses of any of theGroup companies can use this helpline.
Consultations and reports received at each contact window
are reported to the Tokyo Tatemono Internal Audit Division

67Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemSupply Chain Initiatives
occupational health and safety. We have also definedproper relationships with business partners, moderate gifts
and entertainment, and environmental considerations as
items related to procurement and orders. These measures
strive to build a suitable supply chain that considers anenvironment free from corruption and bribery.
We actively incorporate environmentally-friendly technology
and ideas into our products and services in every stage ofour business activities even in terms of the environmental
considerations related to procurement in accordance with
the Group Environmental Policy, and it strives to saveresources and use materials that reduce the environmental
impact.

The main flow of business at a real estate developer
moves from the acquisition of a lot to the development
and then lease or sale of the property. We directly procure
the materials and purchased goods according to theland acquisition and leasing or sales activities during thisprocess. However, the development operations involve not
only Tokyo Tatemono but also a bulk order to a construction
company for procuring a large amount of materials as well
as for staffing to accommodate the construction.
Understanding the traits of the business, the Tokyo
Tatemono Group defines the respect of human rights,
restriction of acts of discrimination and harassment, and theguarantee of a work-friendly environment in the Compliance
Manual as items related to human rights in addition to

Responding to Anti-social Forces
Furthermore, we cooperate with external experts suchas the police and attorneys at law to respond with a firm
attitude to anti-social forces.

Our ban on any relationship with anti-social forces has beenclarified in the Exclusion of Anti-social Forces Rules of theTokyo Tatemono Group and we have stipulated specificprocedures for checks in the Anti-social Forces Check
Manual.

68

Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemRespect of Human Rights
Policy and Concept
than minimum wage to our employees.
Information about the freedom of association and the rights
to collective bargaining are included in Work-Life Balance →( P.56 ).

The Tokyo Tatemono Group respects the basic humanrights as outlined in the Constitution of Japan andthe Universal Declaration of Human Rights, upholds
international labor standards advocated by the International
Labor Organization (ILO), and affirms its respect for theindividuality and beliefs of each person in the Compliance
Charter.
We formulated the Tokyo Tatemono Group Compliance
Manual to ensure the Compliance Charter is put into
practice, which defines compliance as a code of conduct
related to the respect of human rights, the restriction ofacts of discrimination and harassment based on race,
creed, gender, sexual orientation, age, appearance, ability
or disability, educational background or social status,or origins, and the guarantee of a work-friendly work
environment. In addition to the Minimum Wage Act, we will
adhere to various labor laws and vow to pay a wage higher

From the Compliance Charter ( P.65 )• We
 respect the personalities and values ofeach other and maintain a comfortable working
environment.

From the Compliance Manual ( P.66 )<Compliance Item> 10. Respect for Human Rights/
Restriction of Discrimination and Harassment

SystemHuman Rights Education and Promotion System

We established the Internal Control Committee to discuss
general internal control risk, including compliance of theTokyo Tatemono Group, to promote human rights andother compliance issues. The Internal Control Committee
supervises the Group compliance activities.
→ Compliance System ( P.65 )Human Rights Education
and Promotion Committee

President andExecutive Officer

We also understand the flow to promote solutions to social
human rights issues, including SGDs. Therefore, weestablished the human Rights Education and Promotion
Committee by fundamentally restructuring the conventional
Anti-Discrimination Promotion Committee in January 2019.
To establish a corporate body for the respect of humanrights, the committee made up of committee members eachappointed by the President plans, executes and verifies theeducational programs and training workshops related tohuman rights issues.

Appointment

Chairperson(Corporate Officer in Chargeof Human Resources)

Vice Chairperson(Secretary Executives: 2)

Committee Members(General Manager of Corporate Planning,
General Manger of Human Resources,
General Manager of Overall Compliance,and Each Branch Manager)

Human Rights Initiatives
and other issues through the Tokyo Tatemono Group
Helpline, which is a common consultation and reporting
window throughout the Group, and Compliance Surveys
while also taking the appropriate response to theconsultations and reports we receive on the helpline and thesurvey results.
Please see the pages below for specific initiatives.

The Tokyo Tatemono Group defines the restriction of actsof discrimination and harassment as well as the guaranteeof a work-friendly environment as part of the Compliance
Manual, which is a code of conduct to put into practice
the Compliance Charter. We fully raise awareness aboutcompliance by distributing the Compliance Manual toemployees and posting it at offices. Furthermore, we areconducting the proper compliance training for employees
and management every year that encompasses humanrights.
We are also preventing and quickly resolving harassment→ Compliance Training ( P.67 )→ Compliance Surveys ( P.67 )→ Setup of a Helpline ( P.67 )69

Index

Message from the President

FeatureCorporate Philosophy
and CSR

Environmental Initiatives

Safety & Security Initiatives

Responding to Social Change

Community Involvement

Utilization of Human
Resource Assets

Improving Management
SystemResponding to Human Rights and Discrimination Issues
Furthermore, we appointed the general manager of humanresources as the person who promotes honest recruitment
and human rights enlightenment to prevent any humanrights issues, including discrimination, in its recruitment
activities.

Developers are susceptible to discrimination due to thenature of the real estate business. The Tokyo TatemonoGroup correctly understands issues related to humanrights and discrimination, and continually holds training
to handle these problems in its business activities. In
2018, 50 primarily first and second-year Group employees
participated in training led by an instructor from the Tokyo
Metropolitan Human Rights Promotion Center.

TOPICS

Participating in the Construction and Real Estate Human Rights Due Diligence Study GroupIn September 2018, Tokyo Tatemono participated in the Human Rights Due Diligence Study Group launched by eight
construction and real estate firms (Mitsubishi Estate, NTT Urban Development, Tokyu Fudosan Holdings, Tokyo
Tatemono, Nomura Real Estate Holdings, Obayashi Corporation, Shimizu Corporation, and Taisei Corporation) at therequest of Mitsubishi Estate.
This study group identifies the impact on human rights and conducts surveys and research on subjects such ascountermeasures to fulfill the responsibility of companies to "avoid infringing on the human rights of others and address
adverse human rights impacts with which they are involved" required by the United Nations Guiding Principles ofBusiness and Human Rights.
We learn from experts on human rights, such as international human rights standards and human rights initiatives
expected of corporations, exchange information with NGOs and other outside experts and conduct research on
methods to identify and specifically address actual human rights risks.

70