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Governance

Compliance

Compliance Approach and Policies

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.

After Mitsubishi Estate was found to have violated some stipulations of the Commercial Code of Japan in 1997, the Mitsubishi Estate Group Basic Mission and Mitsubishi Estate Group Code of Corporate Conduct were formulated to reflect the company's resolve to never repeat the same mistakes. The Code of Conduct and Basic Mission were revised in 2006 as part of a serious and humble response to the discovery of soil and groundwater contamination problems at Osaka Amenity Park (OAP) in 2005.

The company regards compliance as one of its most pressing issues to address. Moreover, as the company continues to expand its businesses domestically and internationally, its social responsibilities increase in sophistication and global scale. This has led to a greater need for the whole Group to share a sense of values and a standard of conduct. This is why the Mitsubishi Estate Group Guidelines for Conduct were revised in April 2018 with the hope that they will increase true corporate value by being applied to the daily actions of individual employees and executive officers.

The Mitsubishi Estate Group aspires to build trusting relationships with its stakeholders through a highly transparent management system and reinforced compliance. Not only does the Group comply with laws and regulations but it also works hard to meet all the expectations of clients and society as it strives to achieve its basic mission of contributing to society through urban development. The Group also identifies and responds appropriately to various business risks.

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System for Promoting Compliance

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 president of Mitsubishi Estate and comprises the executives from respective functional and business groups as well as 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 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.

Besides the normal reporting lines provided through the help line and other systems for consultation and reporting on compliance violations by Group employees, temporary employees, and part-time employee, and various other part-time staff, the Group has established procedures for direct consultation and reporting to the Legal & Compliance Department. Depending on the substance of the inquiries, they are studied and the situation is confirmed with the aim of improving the working environment. When a compliance violation is suspected, a meeting of the Disciplinary Committee is held as needed to take the appropriate action. In an unlikely event of a serious compliance violation, action is taken in accordance with the Emergency Response Manual.

In accordance with the Mitsubishi Estate Group Management Rules, systems for consultation and reporting have been established for any compliance violations that occur at Group companies.

A compliance survey is implemented for all Group officers and employees, including Group employees, temporary employees, part-time employees, and various other part-time staff, every two years to conduct a regular internal review of the status of adherence to the Mitsubishi Estate Group's Basic Mission, the Code of Conduct, and Guidelines for Conduct. In addition, in order to promote understanding of the Code of Conduct, the Group obtains a pledge from employees as an expression of adherence to the guidelines.

Compliance Advisory Committee

Mitsubishi Estate Group Risk Management and Compliance System (as of April 2020)

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Compliance Advisory Committee

In October 2004, the company premises were searched as a result of its violation of the Real Estate Brokerage Act by selling the OAP Residence Tower, a condominium in Osaka with known soil contamination issues, without informing clients. This was known as the OAP Incident.

Although the OAP Incident was legally dismissed in June 2005, the company reflected deeply on its actions and set up the Compliance Advisory Committee in response, under the direct supervision of the company president. The Committee was chaired by Professor Taka of the School of Economics and Business Administration of Reitaku University and was tasked with offering recommendations concerning the checking, strengthening and improving of the compliance system to prevent a recurrence of such an incident. It was also asked to give suggestions on how to improve the corporate culture.

In December of the same year, after seven rounds of deliberation, "Recommendations for Improving the Character of the Mitsubishi Estate Group - Lessons from the OAP Incident" were compiled and issued as a report in January the following year.

Recommendations for Improving the Character of the Mitsubishi Estate Group - Lessons from the OAP Incident (PDF 48KB) (Japanese only)PDF

An overview of the committee is provided below. Titles and departments stated are as they were at the time.

Advisory Committee Overview

1. The objective for establishing the Advisory Committee

To obtain recommendations on checking, improving and strengthening the compliance system and advice on improving corporate culture from the objective viewpoints of external experts to prevent a recurrence of the OAP Incident and other incidents.

2. The position of the Committee within the organization

An advisory committee under the direct supervision of the company president.

  • The president received the findings and recommendations of the Compliance Advisory Committee and deliberated on them and decided on concrete plans along with the CSR Committee, an existing company decision-making body.

3. Members

Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Kakutaro Kitashiro [Chairman of the Board, IBM Japan, Ltd. Chairman, Japan Association of Corporate Executives]
Kenji Koroyasu [Lawyer, Tokyo Eiwa Attorneys at Law. Former superintending prosecutor, Osaka High Public Prosecutors" Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
* Also attended by personnel who were not officers in charge of departments as necessary

4. Period of activity

July–December 2005 (6 months) Met on average once a month

5. Executive Committee

CSR Department, Planning Division

History of Compliance Advisory Committee Meetings

1st Meeting: Compliance Advisory Committee
1. Date and time

July 15, 2005 (Fri) 15:00 - 16:40

2. Location

Main Office Conference Room, Mitsubishi Estate

3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)

The Committee deliberated on how the Compliance Advisory Committee should proceed and finalized the following items as deliverables.

  • (1) Revising the Mitsubishi Estate Group Code of Conduct
  • (2) Formulating guidelines for the sale of residential buildings
  • (3) Creating a report on the findings of the Compliance Advisory Committee

They also decided to publicize the details of discussions held by the Committee in summary form.

2nd Meeting: Compliance Advisory Committee
1. Date and time
August 11, 2005 (Thu) 13:30 - 15:35
2. Location
Main Office Conference Room, Mitsubishi Estate
3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)
The Executive Committee explained the following issues to committee members and an exchange of ideas was held.
  • (1) The history of Mitsubishi Estate's compliance structure
    • They explained the history and status of existing initiatives such as the Mitsubishi Estate Group Code of Conduct, the regulations and organization of the Compliance Committee and the kinds of training provided.
  • (2) The OAP Incident
    • They provided an overview and history of the OAP project.
  • (3) The Investigative Committee for the Explanation of Important Matters
    • They introduced the newly-formed Investigative Committee for the Explanation of Important Matters which is responsible for revising the key points and ensuring the thoroughness of the material created when drawing up contracts and explanatory documents about important matters during the sale of residential buildings.
    • They also pointed out differences in knowledge of residential buildings between business operators and purchasers and the need for the persons responsible for marketing to pay attention to their speech and conduct.
  • (4) Compliance policies for ordering construction work
  • (5) The State of Emergency Guidelines
  • (6) Exposing potential risks
  • (7) Meeting to exchange ideas between mid-level employees
    • In early August, Committee Chairman Professor Taka met with 30 mid-level employees from Mitsubishi Estate and the Mitsubishi Estate Group to exchange ideas. The ideas received on the occasion were explained and then discussed among the committee members and the decision was made to reflect the ideas in future training sessions.
â– Problems with the company noted during the idea exchange meeting
  • The negative effects of the company's headquarters system
  • The lack of a generational balance in the personnel structure
  • The need for greater clarity in the decision-making process
  • The lack of leadership provided by superiors
5. Other opinions
It was pointed out that training is of vital importance since it not only spreads awareness of compliance but also encourages self-reliance and a reformed mindset among individual employees.
3rd Meeting: Compliance Advisory Committee
1. Date and time

August 24, 2005 (Thu) 16:00 - 18:10

2. Location

Main Office Conference Room, Mitsubishi Estate

3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Kakutaro Kitashiro [Chairman of the Board, IBM Japan, Ltd. Chairman, Japan Association of Corporate Executives]
Kenji Koroyasu [Lawyer, Tokyo Eiwa Attorneys at Law. Former superintending prosecutor, Osaka High Public Prosecutors" Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)

The Executive Committee explained the following issues to committee members and an exchange of ideas was held.

  • (1) Conflict of Interest manuals and their application in the Fund Business and other businesses
    • Plans to add information about conflicts of interest in the Fund Business and other businesses to a compliance handbook were explained.
  • (2) Exposing problems through in-house consultations and group questionnaires
    • The Mitsubishi Estate Group's system for eliminating ties to organized crime was explained.
    • Examples of inquiries received through the internal company helpline (internal reporting) system were provided and it was agreed that the responses given were generally conscientious. However, it was noted that the penalties for compliance violations set out in regulations needed further explanation.
    • The need to adopt a no-tolerance approach to sexual harassment and abuses of power in particular was noted.
    • It was suggested that a questionnaire be administered to measure employee satisfaction levels.
    • Proposals were made concerning a revision of the contents of the compliance handbook.
    • Concerning the implementation and importance of compliance, the point was made that there might be a difference in real intentions as opposed to public attitudes. Thus, it was suggested that creating a detailed manual would be effective at spreading awareness of compliance among employees and officers.
4th Meeting: Compliance Advisory Committee
1. Date and time

September 27, 2005 (Tue) 13:00 - 16:00

2. Location

Main Office Conference Room, Mitsubishi Estate

3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Kakutaro Kitashiro [Chairman of the Board, IBM Japan, Ltd. Chairman, Japan Association of Corporate Executives]
Kenji Koroyasu [Lawyer, Tokyo Eiwa Attorneys at Law. Former superintending prosecutor, Osaka High Public Prosecutors" Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)

The Executive Committee explained the following issues to committee members and an exchange of ideas was held.

  • (1) The OAP Incident
    • It was explained that the company was conducting an internal investigation into the OAP Incident and that a report would be provided once it was ready.
  • (2) The formulation of guidelines for the sale of residential buildings
    • An explanation was given about the Investigative Committee for the Explanation of Important Matters which was started by the head office of the Residential Business. The approach of widely communicating even information that clients might consider negative was also explained.
    • Committee members expressed a certain level of approval for this initiative.
    • Committee members then pointed out the following and made the following recommendations.
      • Actively disclosing information that clients may consider negative is important for the sustainable development of the company.
      • Explanations should be given to clients in a way they can understand, which means a system to facilitate the provision of such explanations is essential. Consideration should be given to concrete plans that take the viewpoint of clients into account such as checks by parties outside the company.
      • Along with the preparation of a manual, the company's sense of values based on viewing matters in the client's position should be reflected in the structure instead of being left solely to the individual's mindset. This is necessary in order for those in charge of development and individuals responsible for marketing to share that sense of values.
      • It is important to share information between parent companies and subsidiaries, as well as to reform the mindsets of subsidiaries and parent companies which may inhibit that process.
  • (3) Revising the Code of Conduct
    • The course of action for the revision of the Basic Mission and the principles for action were explained.
    • The reform proposal was positively evaluated for its easy-to-disseminate ideas.
    • It was explained that more detailed Guidelines for Conduct would be considered in the future.
5th Meeting: Compliance Advisory Committee
1. Date and time

October 21, 2005 (Fri) 14:00 - 17:00

2. Location

Main Office Conference Room, Mitsubishi Estate

3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Kakutaro Kitashiro [Chairman of the Board, IBM Japan, Ltd. Chairman, Japan Association of Corporate Executives]
Kenji Koroyasu [Lawyer, Tokyo Eiwa Attorneys at Law. Former superintending prosecutor, Osaka High Public Prosecutors" Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)

The Executive Committee explained the following issues to committee members and an exchange of ideas was held.

  • (1) The formulation of guidelines for the sale of residential buildings
    • A report was given on the decisions made by the Investigative Committee for the Explanation of Important Matters and the overhaul of the sales manual.
    • The Compliance Advisory Committee evaluated these measures as effective for the formulation of guidelines for the sale of residential housing. It was decided that improvements would be made to the details continuously to meet changing social attitudes.
  • (2) The OAP Incident
    • A report was made on the status of the internal company investigation into the OAP Incident.
    • A request was made for a report on selected problems from the investigation to be compiled and provided by the next committee meeting.
  • (3) Revising the Code of Conduct
    • The Executive Committee reported on reform proposals and decided to review them before the next meeting of the Compliance Advisory Committee based on recommendations made by committee members.
6th Meeting: Compliance Advisory Committee
1. Date and time

November 18, 2005 (Fri) 14:00 - 17:00

2. Location

Main Office Conference Room, Mitsubishi Estate

3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Kakutaro Kitashiro [Chairman of the Board, IBM Japan, Ltd. Chairman, Japan Association of Corporate Executives]
Kenji Koroyasu [Lawyer, Tokyo Eiwa Attorneys at Law. Former superintending prosecutor, Osaka High Public Prosecutors" Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)

The Executive Committee explained the following issues to committee members and an exchange of ideas was held.

  • (1) Revising the Code of Conduct
    • The final draft was put together based on recommendations from the company and the Compliance Advisory Committee. It was decided that a report would be made on the topic at the 7th Compliance Advisory Committee meeting following a formal decision by the CSR Committee, the company's decision-making body.
  • (2) Report on Findings
    • Committee members also pointed out the following and made the following recommendations regarding the contents of the report on their findings.
      • Create a timeline of the OAP Incident, point out problems and confirm strategies to prevent a recurrence.
      • For the explanation of important matters, introduce initiatives that are already under way as examples of concrete strategies that take client viewpoints into account.
      • Specify how the department responsible for compliance will be involved.
      • Create a system for the proper communication of items to be handed over in long-term projects.
    • It was decided that the details of the courses of action listed above would be determined by the Compliance Advisory Committee at their 7th meeting and that Professor Taka, the Committee Chairman, would put together the report of findings. It was also determined that a final report on findings would be compiled once the draft had been discussed with each committee member.
7th Meeting: Compliance Advisory Committee
1. Date and time

December 22, 2005 (Thu) 15:00 - 18:00

2. Location

Main Office Conference Room, Mitsubishi Estate

3. Attendees (titles omitted)
Committee Chairman Iwao Taka [Professor, School of Economics and Business Administration, Reitaku University]
Committee Members (in Japanese alphabetical order) One Akiyama [President, IntegreX Inc.]
Toshiko Katayama [Lawyer, Katayama, Kuroki and Hiraizumi Law Office]
Kakutaro Kitashiro [Chairman of the Board, IBM Japan, Ltd. Chairman, Japan Association of Corporate Executives]
Kenji Koroyasu [Lawyer, Tokyo Eiwa Attorneys at Law. Former superintending prosecutor, Osaka High Public Prosecutors" Office]
Attendees from the company Keiji Kimura [President & CEO]
Nobuyuki Iizuka [Executive vice-president/corporate officer in charge of Compliance]
Seiichiro Suzuki [Senior executive officer/officer in charge of CSR Promotion]
4. Deliberations (summary)
  • 1. Mitsubishi Estate's internal audit structure was explained.
  • 2. The Executive Committee explained the following issues to committee members and an exchange of ideas was held.
  • (1) Revising the Code of Conduct
    • A report was made on the formal decision taken by the CSR Committee, the company's decision-making body, and an explanation was given of how the information would be communicated throughout the company going forward.
  • (2) Report on Findings
    • Committee members discussed the contents of the report on findings prepared by Professor Taka, the Committee Chairman.
    • Based on the opinions offered in this session, it was determined that the Committee Chairman would recompile the report, receive feedback from individual committee members and create a final report on findings.

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Reinforcing Compliance

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 Guidelines for Conduct forbid not just actions that could be construed as collusion with government officials or other actions considered illegal, but also entertainment and gift-giving that goes beyond the bounds of social convention.

When providing support related to the activities of political groups, the Group ensures it is appropriate in accordance with relevant laws and regulations such as the Political Funds Control Act and the Public Offices Election Act, as well as internal regulations such at the Mitsubishi Estate Group Guidelines for Conduct.

Moreover, in 2013, the Group established the Mitsubishi Estate Group Basic Regulations on the Prevention of Corruption to put in place a system to prevent corruption across the organization. In 2018, the Group established and published the Mitsubishi Estate Group Anti-Corruption Guidelines. The Guidelines document expectations of business partners with the aim of ensuring compliance throughout the supply chain based on the cooperation of all of the Group's business partners. The Group provides training on corruption prevention to officers and employees and obtains pledges on the Guidelines on the Prevention of Corruption from officers and employees. The Group also holds annual lectures on corruption prevention, particularly for departments and Group companies engaged in international business.

The Risk Management & Compliance Committee monitors the operational status of the corruption prevention system each year, and the status of monitoring by the Risk Management & Compliance Committee is also reported to the Board of Directors.

In 2017, an external organization assessed the Mitsubishi Estate Group's corruption prevention system as a whole. The Group has been working to further strengthen the corruption prevention system by responding to the issues identified through the assessment.

Mitsubishi Estate Group Guidelines for ConductOpen new window

Notice of the establishment of Mitsubishi Estate Group Anti-Corruption Guideline (PDF 246KB)PDF

Consultation and Reporting

In addition to establishing a help line as a point of contact for consultation on matters relating to compliance, including corruption prevention, the Mitsubishi Estate Group has set up a help line exclusively for business partners to receive consultations and reports from business partners of Group companies.

Risk Assessment

The Group has established and operate the Rules on Corruption Risk Assessment and Corruption Due Diligence, which require that the risk of corruption be assessed for each contract and mandate due diligence in the case of counterparties with which transactions are deemed high risk.

In 2017, an external organization assessed the Mitsubishi Estate Group's corruption prevention system as a whole. The Group has been working to further strengthen the corruption prevention system by responding to the issues identified through the assessment.

Monitoring

The Risk Management & Compliance Committee monitors the operational status of the corruption prevention system each year, and the status of monitoring by the Risk Management & Compliance Committee is also reported to the Board of Directors.

Also, in order to maintain and continue the effectiveness of the corruption prevention system, the Group implements internal audits periodically to assess and review the corruption prevention management system.

Education

The Mitsubishi Estate Group strives to make the rules on corruption prevention widely known through training for Group officers and employees engaged in overseas business.

Violation of Laws and Regulations on Corruption

The Group was not subject to any fines or penalties for corruption in fiscal 2019.

Mitsubishi Estate Group Guidelines for Conduct (Extract)

1. Compliance

We comply with all laws and regulations, and respect the social norms in the areas in which we conduct business. We establish and abide by corporate ethics, and respond to the expectations of a changing society. In addition:

1. We engage fairly in all business dealings
2. We manage and safeguard information appropriately
3. We engage in efforts to prevent corruption in any form
4. We refuse any and all criminal activities in our business dealings, and
5. We are highly sensitive and responsive to societal changes.

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.

Augmenting the Help Line

The Mitsubishi Estate Group has established a compliance help line to receive inquiries and consultations on compliance issues. Officers and employees can consult the help line about suspected compliance violations or other issues of concern that have to be addressed, such as harassment, human relationships in the workplace, labor relations, and corruption. Group company employees, temporary employees, part-time employees, and various other part-time staff can also use the help line. 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. To ensure that employees know about the help line, information is provided in the Compliance Newsletter and on posters.

There were 75 reports via the Mitsubishi Estate Group help line in fiscal 2019. About half of the 75 reports were anonymous, and about half were made under the caller's name. Depending on the substance of the consultations received, they are studied and the situation is confirmed to respond appropriately and improve the workplace environment. Of the consultations for which the response was completed in fiscal 2019, 21 cases were identified as problems in need of improvement as a result of a study and confirmation of the situation. Depending on the results, the Group took the appropriate actions such as providing guidance for the person involved.

The Mitsubishi Estate Group has also established help lines at individual Group companies and regularly collates data to confirm trends. In 2019, there were 119 consultations.

In addition, a help line exclusively for business partners has been set up to receive consultations and reports on compliance from the business partners of Group companies.

Occurrences of Serious Compliance Violations

In the event of compliance violations, the Mitsubishi Estate Group takes disciplinary action against the offender in accordance with the nature of the violation.

See the following for occurrences of serious compliance violations.

ESG Data > G: Governance-related data > (2) Other > 2. Risk Management and Compliance

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 Risk Management and Compliance Training

The Mitsubishi Estate Group uses opportunities such as training sessions for new hires and new managers to provide training to ensure risk management and 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.

Moreover, Mitsubishi Estate provides compliance education during training for newly appointed managers and level 2 professional career hires, and also provides all employees and officers, including outside directors, with training in risk management and compliance via e-learning.

See the following for the risk and compliance e-learning attendance rate.

ESG Data > G: Governance-related data > (2) Other > 2. Risk Management and Compliance

Holding Risk Management and Compliance Lectures

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 December 2019, Yoshiaki Honpo, Chief of the UN World Tourism Organization (UNWTO) Regional Support Office for Asia and the Pacific, spoke on the topic of "Mitsubishi Estate Group Risk Management Associated with the Rapid Rise in Inbound Visitors."

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 analyzes the survey results to identify overall trends and characteristics of each business group and company, and provide feedback to each workplace to help maintain and strengthen the compliance system as well as reporting the results to management.

Including Compliance and Risk management Criteria in Personal Evaluations

In order to ensure that each and every employee has aware of compliance and risk management and acts with integrity as a member of the Mitsubishi Estate Group, we have included evaluation criteria related to compliance and risk management in our personnel evaluations. Specifically, in accordance with the The Spirit of Mitsubishi: The Three Principles and The Mitsubishi Estate Group Code of Conduct , the achievement levels are defined for each position and grade, including whether the employee is acting with an awareness of compliance, identifying and avoiding risks, and preventing recurrence. All employees are evaluated once a year on the status of achievement, and the results are taken into consideration for salary increases.

Through these personnel evaluations, each and every employee will strengthen their awareness and consciousness as a member of the Mitsubishi Estate Group, and by acting in a fair and transparent manner, we will strive to earn the trust of our many stakeholders.

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