Compliance

Risk Management by means of Compliance-oriented Management

Tokyu Fudosan Holdings Group has set the establishment of a“Risk Management System by means of Compliance-oriented Management”, as one of the management’s primary responsibilities. Tokyu Fudosan Holdings Group strongly recognizes that fulfilling this responsibility forms the base of our group’s management and cultivates its officers and employees, not only to comply with the laws and regulations required for our group in its corporate activities, but also to make decisions and actions in accordance with the“Code of Conduct”.

Compliance System

In Tokyu Fudosan Holdings Group, each group company has established a compliance system and endeavors to ensure compliance-oriented management by various means, such as the appointment of compliance personnel, the establishment of a compliance department, and the development and promotion of action plans to achieve compliance (compliance programs).
Specifically, the group has established the “Tokyu Fudosan Holdings Group Code of Conduct” to serve as a standard of conduct for all of the officers and employees of Tokyu Fudosan Holdings Group and the “Tokyu Fudosan Holdings Group Compliance Manual” as a detailed manual for understanding the Code of Conduct and putting it to practice. We hold compliance training sessions on a regular basis for all officers and employees to raise their awareness of compliance.

Compliance Council

The “Compliance Council” has been set up to cover the entire group. The“Compliance Council” consists of the compliance personnel at Tokyu Fudosan Holdings and its subsidiaries. It develops and shares group-wide policies and goals to promote “Risk Management by means of Compliance-oriented Management”, and supports and monitors the efforts of each group company.

Efforts to Raise Compliance Awareness

Tokyu Fudosan Holdings and each group company hold seminars, training, and other educational sessions on a regular basis, with the aim of raising the compliance awareness of officers and regular employees, as well as the awareness of the contract employees and temporary employees.
Specifically, various seminars (including those regarding insider trading regulations, labor management, and harassment) are provided by Tokyu Fudosan Holdings, and e-learning programs are made available to employees of Tokyu Fudosan Holdings Group. In addition, group companies are conducting various enlightenment activities to address the issues of each group company.
We also call employees’ attention to compliance matters by posting information about compliance incidents and accidents of other companies on a monthly basis.

Establishment of Compliance Helpline

The “Compliance Helpline” (internal whistleblowing contact point) has been established at Tokyu Fudosan Holdings to receive reports and queries from employees of Tokyu Fudosan Holdings Group (reports from anonymous sources are also accepted) concerning possible violations of laws and regulations, the Tokyu Fudosan Holdings Group Code of Conduct and internal rules, etc. The purpose of this helpline is to quickly discover acts of non-compliance and to prevent them in advance. We have also established a contact point for whistleblowers to report to outside counsel.
Apart from the Compliance Helpline mentioned above, we have established a point of contact to receive comments and suggestions from customers and stakeholders.

Implementation of Compliance Surveys

“Compliance surveys” are conducted on a regular basis at each group company in order to ascertain the degrees of employees’ awareness and understanding regarding compliance, and to identify the inherent individual compliance issues of each group company.

Survey and response mechanism for things judged as compliance violation

When officers and employees find actions that are highly likely to correspond to compliance violations, we will deal with the following:
① Report immediately to Group Legal Department Compliance Officer.
② The Group Legal Department handles and resolves, as well as nominate those who should be treated according to the case (Accident / violation action processing person) and can aid them.
③The accident / violation action processing person shall report to The Group Legal Department as appropriate.
④The Group Legal Department or the accident / violation action processing person reports to the president as appropriate and receive instructions. In case of serious accident / violation, report to the auditors too.

※ The Group Legal Department reports on the number of internal reports, status of disciplinary actions, individual incidents etc. by the Risk Management Committee.

Review code compliance and identify compliance violations

In the event of a violation of laws and internal regulations, in accordance with the regulations of compliance, investigate and respond to stakeholders, backgrounds of facts, the nature and details of the violation, damage amount, the influence on interested persons, etc., Formulate measures to prevent recurrence, implement disciplinary measures, etc.

Regular review of the effectiveness of the Code of Conduct

When a violation or accident occurred, we implement employee training as a measure to prevent recurrence and we regularly review compliance regulations and manuals.

Responses to Antisocial Forces

Tokyu Fudosan Holdings Group hereby clearly states in the “Tokyu Fudosan Holdings Group Code of Conduct” its firm intention to have no relationship of any form with antisocial forces. The Group makes it a point to build close relationships with external parties, such as police and lawyers, even under normal circumstances and adopts a resolute attitude when it comes to dealing with unreasonable demands.
In addition, the Group has set down actual procedures, such as those for taking preventive measures, in the Guidelines for Responding to Antisocial Forces and the Manual for Responding to Antisocial Forces. The Group is working to convey these procedures and make them known to all Group employees as part of its compliance training.

Tokyu Fudosan Holdings Group Code of Conduct

1. Compliance with Laws and Regulations and Fair Trading	2. Ensuring Customer oriented Awareness	3. Suitable Execution of Duties	4. Proper Management of Information	5. Ensuring Good Faith in Business Conduct
● Ensure compliance with applicable laws and regulations. ● Ensure best practice in material procurement and fair trade. ● Ensure compliance with fiduciary responsibility in the execution of duties. ● Never connect with antisocial forces.	● Identify customer needs and develop products to meet their needs. ● Prompt and dedicated response to customers' comments and requests. ● Customers' safety and security comes first when providing products and services. ● Provide a suitable and appropriate explanation and marketing of our products and services.	● Responsible execution of duties, keeping concepts of "speed" and "evolution" in mind. ● Nurture organization culture of placing emphasis on "Collective wisdom". ● Take advantage of combined strength of the corporate group. ● Ensure proper decision making process. ● Proper management of rules. ● Proper negotiations with business associates.	● Operate appropriate document and information management systems. ● Proper management of confidential information and compliance with confidentiality obligation. ● Prohibit insider trading. ● Timely and appropriate information disclosure and PR activities. ● Internal control to ensure proper accounting and financial reporting.	● Preserve corporate assets. ● Ensure a robust, safe, and comfortable working environment. ● Respect human rights. ● Contribution to society and consideration of the environment. ● Reasonable business entertaining and gift-giving. ● Clear distinction between business and personal matters.

1. Compliance with Laws and Regulations and Fair Trading	● Ensure compliance with applicable laws and regulations. ● Ensure best practice in material procurement and fair trade. ● Ensure compliance with fiduciary responsibility in the execution of duties. ● Never connect with antisocial forces.
2. Ensuring Customer oriented Awareness	● Identify customer needs and develop products to meet their needs. ● Prompt and dedicated response to customers' comments and requests. ● Customers' safety and security comes first when providing products and services. ● Provide a suitable and appropriate explanation and marketing of our products and services.
3. Suitable Execution of Duties	● Responsible execution of duties, keeping concepts of "speed" and "evolution" in mind. ● Nurture organization culture of placing emphasis on "Collective wisdom". ● Take advantage of combined strength of the corporate group. ● Ensure proper decision making process. ● Proper management of rules. ● Proper negotiations with business associates.
4. Proper Management of Information	● Operate appropriate document and information management systems. ● Proper management of confidential information and compliance with confidentiality obligation. ● Prohibit insider trading. ● Timely and appropriate information disclosure and PR activities. ● Internal control to ensure proper accounting and financial reporting.
5. Ensuring Good Faith in Business Conduct	● Preserve corporate assets. ● Ensure a robust, safe, and comfortable working environment. ● Respect human rights. ● Contribution to society and consideration of the environment. ● Reasonable business entertaining and gift-giving. ● Clear distinction between business and personal matters.