Compliance in Practice

System for Promoting Compliance

The Mitsubishi Estate Group believes that compliance does not simply involve legal compliance, but is also defined as adherence to internal rules and corporate ethics. Mitsubishi Estate's compliance system has its roots in the determination of its executives and employees to improve their awareness and reform the organization after the company was found in violation of some stipulations of the Commercial Code of Japan in 1997. The Code of Corporate Conduct was formulated to define the company's basic commitment to reform, and was further refined in 2002. Group-wide reform was implemented, with all employees sharing the sense of urgency. In July 2005, a Compliance Advisory Committee consisting of external experts was formed on a temporary basis to review the compliance system in light of the soil and groundwater contamination problems discovered at Osaka Amenity Park. This committee worked to improve the corporate culture, for example, by revising the Code of Conduct.
In April 2018, the Mitsubishi Estate Group Guidelines for Conduct were revised and the company stepped up its compliance practices to meet changing demands in society and an expansion in business areas.
The current compliance promotion system is administered by the Risk Management & Compliance Committee and the Risk Management & Compliance Subcommittee. The Risk Management & Compliance Committee is chaired by the company president and comprises the executives from respective business fields and the Corporate Group and discusses issues concerning Group compliance and risk management. The Risk Management & Compliance Subcommittee, which comprises general managers, holds discussions before the CSR Committee meets. In addition, an executive director has been appointed by decision of the Board of Directors as the Executive Director of Compliance to take responsibility for overseeing and promoting compliance. All Mitsubishi Estate departments and Group companies are working closely with the Legal & Compliance Department, which serves as the executive committee, to pursue compliance in a coordinated manner.

Mitsubishi Estate Group Risk Management & Compliance System (as of August 2018)

Image:Mitsubishi Estate Group Risk Management & Compliance System (as of August 2018)

Risk Management

The Mitsubishi Estate Group has established the Mitsubishi Estate Group Risk Management Rules and has set up and operates a risk management system to manage risk in all its business activities.
The Group systematically carries out risk management programs, focusing on the following two types of activities.

(1) Individual risk management activities

Individual Group companies and business groups identify risks of focus based on a risk analysis, and carry out activities throughout the year to reduce the risks identified.

(2) Group-wide priority risk management activities

The Group identifies priority risks that require new countermeasures from the entire Group, taking into account the risks of focus identified by individual Group companies as described above and social trends, and carries out activities throughout the year to reduce these risks.

(Note) Please refer to the Integrated Report 2018 (P33-34) (PDF 5,493KB) for information on business and other risks.

Revising and Publishing the Compliance Guidebook

To accompany the revision of the Mitsubishi Estate Group Guidelines for Conduct in April 2018, the Compliance Guidebook was revised and published as a training tool. The Guidebook uses illustrations and a Q&A format to explain the Mitsubishi Estate Group's five most important values in an easy-to-follow format. It was distributed to all Group officers and employees and helps to increase knowledge and understanding of what compliance involves.

Providing Compliance Training

The Mitsubishi Estate Group uses opportunities such as training sessions for new hires and new managers to provide compliance training to raise compliance awareness among all executives and employees.
In particular, new hires from major Group companies participate in joint training together to learn about the Code of Conduct and basic compliance issues (336 participants from 21 companies in April 2018).
Moreover, Mitsubishi Estate provides compliance education during training for newly appointed managers and level 2 professional career hires, and also trains all officers and employees in compliance via e-learning.

Compliance training such as training by level and CSR lectures

Compliance e-learning attendance rate
(Mitsubishi Estate Group*)
*Made up of four companies: Mitsubishi Estate, Mitsubishi Jisho Property Management, Mitsubishi Jisho Residence and Mitsubishi Real Estate Services

99%
(Sustained target
for fiscal 2030: 100%)

Holding Risk Management and Compliance Lectures

The Mitsubishi Estate holds risk management and compliance lectures for managers and executives, including those at Group companies.
The lecture topic is chosen from genres related to risk management and compliance, in light of social conditions in that particular year. In July 2017, Professor Iwao Taka of the School of Economics and Business Administration at Reitaku University (and also a Mitsubishi Estate outside director) spoke on the topic: "Foreign Corrupt Practices as a Global Risk."

Compliance Surveys

The Mitsubishi Estate Group gives compliance surveys every two years to its approximately 16,000 executive officers and employees (including temporary employees) to ascertain the extent to which they are aware of compliance issues. The Group uses the results, after analyzing them to identify overall trends and characteristics of each business group and company, to plan activities to improve compliance.

Compliance survey “Extent to which Code of Conduct is achieved”

88%

Augmenting the Help Line

The Mitsubishi Estate Group has established a compliance help line to receive inquiries and consultations on compliance issues. In January 2018 the Mitsubishi Estate Group help line consultation window was changed and unified with external organizations to make it possible for it to receive calls on weekday evenings and weekends and holidays as well. The help line has both internal and external contact points and can be used by Group employees, temporary employees, part-time employees and various other part-time staff, and even the business partners of Group companies. To ensure that employees know about the help line, information is provided in the Compliance Newsletter and on posters. There were 64 consultations and reports via the Mitsubishi Estate Group help line in fiscal 2017. Depending on the substance of the inquiries, they are studied and the situation is confirmed so that an appropriate response can be made. A help line exclusively for business partners has also been set up.

Rigorous Information Management

The Mitsubishi Estate Group Guidelines for Conduct include stipulations on information management. As such the company is committed to obtaining information appropriately, managing it strictly and protecting personal information to the greatest extent of its capabilities. In April 2018 the Group's internal regulations on information management were completely revised. In addition to appointing an officer with maximum authority over information management for the whole Group, a chief information system management officer was also appointed and the Group strengthened its information security across board. To support this revision in regulations, the Group's employees and executive officers were trained in information management in order to ensure the proper handling of information. Mitsubishi Estate works to improve information handling by conducting Information Management e-learning training for all employees and officers and reexamining the way information is handled in all departments.

Preventing Corruption

The Mitsubishi Estate Group has declared that it will carry out equitable, transparent corporate activities with a primary emphasis on earning trust. The Group's Code of Conduct forbids not just actions that could be construed as collusion with government officials or other actions considered illegal, but also entertainment and gift-giving to politicians and government employees that could be deemed ethically inappropriate for going beyond the bounds of social convention.
Moreover, the Mitsubishi Estate Group Basic Regulations on the Prevention of Corruption were established as a system to prevent corruption throughout the organization. The risk of corruption is assessed for each contract and due diligence is mandated in the case of parties considered high risk. This due diligence is accompanied by monitoring in the course of operations. The Group also drew up and published the Mitsubishi Estate Group Anti-Corruption Guideline in July 2018. It also conducted training for Group officers and employees involved in its international businesses to ensure their full understanding of the company's anti-corruption regulations.
The Group was not subject to any fines or penalties for corruption in fiscal 2018.

Mitsubishi Estate Group Anti-Corruption Guideline (PDF 160KB)

Measures Against Organized Criminal Elements

The Mitsubishi Estate Group clearly stipulates its refusal to countenance any relationship whatsoever with organized criminal elements in its Guidelines for Conduct. Mitsubishi Estate's Legal & Compliance Department serves as a special department to take resolute measures for the Group, in cooperation with the police, in the event of any contact from criminal elements.

Major Compliance Violations

Major Compliance Violations involving the Mitsubishi Estate Group in fiscal 2017 0 cases

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