The Mission of the Mitsubishi Estate Group

contribute to society through urban development.
By building attractive, environmentally sound communities where people can live, work and relax with contentment, contribute to the creation of a truly meaningful society.

The Mitsubishi Estate Group Code of Conduct

In order to carry out the Group Mission, pledge to observe the following Code of Conduct.

1. will act with integrity
will base our conduct on laws and ethics and always reflect with humility upon our behavior, valuing our communication with society and placing priority in our corporate activities on earning trust through fairness and transparency.
2. will strive to earn the trust of our clients
will approach all objectives from our clients' point of view, providing safe and reliable products and services, and make information available as appropriate.
3. will strive to create a vibrant workplace
While aiming at personal growth, will respect the human rights and the diversity of opinions of others and increase our creativity and professionalism, while displaying our collective strengths as a team.

Mitsubishi Estate Group Guidelines for Conduct

Article I. Responsibilities of Management

(1) Taking the initiative and setting the example in following the Code of Conduct
All executives, from top management down, must recognize that compliance is an absolute condition for building relations of trust beten our companies and society as a whole. Fulfilling the Code is an important personal responsibility, and each executive is expected to lead by example. Moreover, in addition to their usual role in managing and maintaining the company's internal organization, they must always have the structures in place to deal with any problems or violations of the Code that might arise.
(2) Responding personally and promptly when problems arise
In the unlikely event that problems or violations of the Code arise, all executives, from top management down, must be prepared to respond personally, promptly, and appropriately with the following measures:
  • Identification of the source of the problem
  • Disclosure of the truth of the matter, both within Group companies and publicly
  • Manifestation of a corporate stance of responsibility and honesty towards society
  • Timely and strict disciplining of the parties involved and their supervisors, including oneself, and the public announcement thereof
  • Rigorous measures to prevent any reoccurrence of the problem

Article II. Guidelines for Integrity in the Conduct of Corporate Affairs

(1) Making work a vehicle for personal growth
should always strive to behave with integrity, kindness, and humility, take pride in being a member of society, and aim at achieving personal growth through our work.
(2) Practice of compliance
define compliance as obedience to laws and regulations, including Group companies' internal rules, as ll as actions in accordance with ethics and the social conscience, and by faithfully practicing all of this, constantly working to earn the trust of society.
(3) Discussing it, if have doubts about something
must constantly ask ourselves in the course of our business activities if are really acting in compliance with the laws and regulations, ethics, and the social conscience, and in cases in which are having difficulty judging this, should consult with our superiors. When necessary, should also be prepared to discuss problems with the responsible departments or Help Line. Our goal is "corporate integrity," and rather than ignoring potential violations of the spirit of our Code of Conduct. Such potential violations should be reported to the responsible departments, Help Line, or other means.
(4) Valuing communication with society
In order to respond to the expectations and demands of the market and develop along with society, must actively work to communicate with our clients, shareholders, the companies with which do business, and local communities. Management should then make use of this communication to conduct corporate activities in a manner that is fair, transparent, and places a priority on trust. In addition, must honor our accountability to society by actively and fairly disclosing information about Group companies--including information that may not be advantageous to us.
(5) Respect for human rights
must contribute to building a society in which people of all races and ethnic groups, adults, children, seniors, and the disabled can coexist and men and women can cooperate and participate equally. There should be no discrimination on the basis of nationality, race, religion, thought, gender, age, or physical disabilities; will eliminate all prejudices and stereotypes that give rise to discrimination, and honor a diversity of values and cultures.
(6) Renouncing any relationship with antisocial forces
will not engage in illegal or antisocial activities for any reason whatsoever. If should somehow find ourselves in a situation in which there is the potential for association with illegal activities or antisocial forces, must resolutely reject this and report to our supervisor and responsible department. , as the entire Mitsubishi Estate Group, will take appropriate countermeasures.

Article III: Guidelines for Building a Sound Relationship with Society

1. Relations with Clients

(1) Acting from the clients' perspective
By communicating with our clients, work to understand the expectations and needs of the market and provide socially useful, safe, dependable, and satisfying products and services at a fair price. In order to promote fair business dealings, will view our objectives from our clients' perspective and provide information on the products and services (including information that goes against us) in a timely, appropriate, and easily understandable manner.
(2) Protecting client information
With a full understanding of the importance of properly handling personal information, will collect, store, manage, use, and dispose all the client's personal information in a responsible manner. will exert ourselves to prevent any loss, alteration, or disclosure of personal information.
(3) Responding with integrity
will take appropriate and prompt action, and respond with integrity to client requests or complaints regarding our products and services, as ll as any accidents or problems that may have arisen with them.

2. Relations with Business Partners and Competitors

(1) Fair business dealings
will conduct fair business dealings based on the principle of free, fair, and transparent market competition. will give the greatest priority to the trust of society. will also abolish meaningless formalities and keep ceremonies and congratulatory and condolence occasions simple and reasonable in scale. will provide business entertainment and gifts only when deemed necessary for corporate activities, and will keep them within the bounds of social convention. Moreover, will avoid participating in such activities as prohibited by law or the company regulations of our business partners.
(2) Building mutual trust
Keeping in mind that stand on an equal footing with our business partners, will build a relationship of mutual trust and aim at mutual prosperity through fair and transparent dealings based upon economic rationality.
(3) Respect for the intellectual property of others
will respect copyright and all the other intellectual property rights, and treat them appropriately.
(4) Appropriate acquisition and management of information
All confidential information acquired in the course of our operations will be strictly managed in accordance with the relevant laws, and will exert ourselves to prevent any leakage to outside parties.
(5) Conducting dealings among Group companies in a similar manner as those with other business partners
will conduct business among Group companies with fairness and transparency, under the fundamental principle of equality based on fair market value. If Group companies' interests conflict with one another, will act with mutual understanding in accordance with our Code of Conduct.

3. Relations with Shareholders and Investors

(1) Commitment to sound business practices
conduct our business using valuable financial resources entrusted to us by shareholders and investors. Accordingly, are aware of the responsibility to engage in sound business practices and to provide accurate descriptions of our business activities.
(2) Commitment to communications
Through appropriate and timely disclosure of information and active engagement in investor relations, will work to gain the understanding of shareholders and investors with regard to Mitsubishi Estate's business practices.

4. Relations with Politicians and Government Officials

(1) Building healthy and transparent relations
will avoid any activities, which might be construed as collusion with government officials. When have requests for politicians or government employees, will pursue them through fair and equitable procedures.
(2) No inappropriate business entertainment and gift-giving activities
will refrain from entertainment and gift-giving to politicians and government employees, not just in cases in which it is questionable legally, but also when it might be construed as ethically inappropriate as beyond the bounds of social convention.

5. Relationship with the global environment

(1) Reduction of environmental burdens
will work to prevent global warming with efficient use of energy and resources. Also, will contribute to creation of a recycle-oriented society through the reduction, reuse, and recycling of waste.
(2) Active commitment to disclosure of environmental information
will actively disclose the information on environmental practice.

6. Relationship with Society

(1) Contribution to society as good corporate citizens
With the goal of creating a more humane society, will make social contributions as good corporate citizens. By providing humanitarian and economic assistance and working with non-profit organizations, aim for the resolution of social problems and mutual growth with the society.
(2) Aiming for sustainable development and harmony with local communities
At our business locations, both at home and overseas, aim for harmony with local communities and sustainable mutual development, working to resolve local issues and bring vitality to communities, while at the same time showing respect for local history, culture, and customs.

Article IV. Guidelines for the Workplace

(1) Creation of a vibrant workplace
Maintaining respect for each other's humanity and individuality, will devote ourselves to acquiring the knowledge and skills need as professionals. will act with a voluntary and creative attitude to build an open-minded corporate culture where people are free to speak out and display collective strengths.
(2) Global perspective
As a member of international society, will maintain a global perspective in all our activities.
(3) A workplace free of discrimination and harassment
With respect for fundamental human rights, will promote the creation of a safe and pleasant working environment. will not engage in discrimination on the basis of nationality, race, religion, thought, gender, age, or physical disabilities, renounce all prejudices and stereotypes that give rise to discrimination, and will not tolerate bullying and other unfair infringements on human rights, and will not tolerate child labor or forced labor. reject sexual harassment and all other forms of harassment in the form of words or actions that give offense to others, and will strive to create a workplace environment in which such actions will not be tolerated.
(4) Information sharing
As appropriate, will share and transfer knowledge and information essential to our business among our various group companies so that this information may be put to timely use when needed.
(5) Smooth Communication
Executives are expected to precisely define the policies and procedures of the MEC Group to each employee in a quick, clear and accurate manner in order to achieve the company's objectives and principles. In addition, will actively adopt employees' constructive opinions and proposals as a contribution to management.
(6) Respect for Privacy
will respect the privacy of individuals in the workplace, and deal responsibly with the collection, storage, management, use, and disposal of personal information regarding our directors and employees. will also work to prevent the inadvertent loss, alteration, or leakage of such personal information.
(7) Appropriate management of corporate assets and confidential information
will not make improper use of Group companies' computer networks and other information systems, or any of their other tangible assets or intellectual property. will also undertake appropriate information management, so as to prevent leakage or disclosure of confidential information held by Group companies that might be disadvantageous to our clients or business partners.
(8) Avoiding conflicts of interest
will not utilize our official position or authority for our own private gain or that of any other individuals. If our duties and private interests come into conflict, will not engage in actions that conflict with our responsibilities as members of Mitsubishi Estate Group.
(9) No insider trading
will not engage in insider trading, i.e., the sale or purchase of stocks, etc. of Mitsubishi Estate, Group companies, or our business partners, on the basis of significant undisclosed information regarding these companies that have become privy to in the course of our duties. Moreover, will take adequate precautions to ensure that such information is not inadvertently leaked prior to its formal, public announcement.
(10) Abolition of meaningless formalities
will abolish meaningless formalities and will neither give nor receive money or goods as congratulations or condolences beyond the bounds of social convention.
(11) Appropriate business expense vouchering and approval procedures
will follow appropriate procedures to properly conduct investments and expenditures. Moreover, will carry out accounting and tax procedures in accordance with all the relevant laws, accounting standards, and internal company regulations. will employ similarly appropriate procedures for other approval processes.
(12) Refraining from political and religious activities in the workplace
will not engage in any political or religious activity in the workplace except when deemed necessary for the conduct of business and approved by Group companies.

Article V: Punitive Provisions

Violations of these guidelines are subject to punishment based on the Group company regulations.