Compliance

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 need to respond to the expectations of customers, business partners, shareholders, investors, local society, employees, and other stakeholders, and responding to the needs of these stakeholders with integrity is important.
Tokyo Tatemono Group has established the Compliance Charter to promote corporate activities that observe compliance 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 other rules and engage in fair, sound corporate activities.
  • We act faithfully by thinking from the customers' standpoint.
  • We contribute to making society better through corporate activities.
  • We respect the personalities and values of each other and maintain a comfortable working environment.

Established June 2009

System

We established the Tokyo Tatemono Group Internal Control Committee that discusses Group compliance as well as general internal control risks, including the prevention of fraud and corruption, and as a framework to promote compliance 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.

Compliance Promotion System

System

Indicators and Results

●Collection Period:
  • January to December each year. Data is as of December of each year unless stated otherwise.
●Collection Scope:
  • Tokyo Tatemono (Number of reports and consultations to Helpline for the Tokyo Tatemono Group)
Item Unit 2014 2015 2016 2017 2018
Number of Students and Completion Rate of Compliance (e-Learning) Training People 646 657 814 847 860
Completion Rate of Compliance (e-Learning) 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
Number of Reports and Consultations to Helpline Incidents 23 28 15 44 59

Compliance Manual

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 as a code of conduct for all people engaged in operations of offices 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 the Compliance Manual, introduces case studies about the LGBT and actual bribery that has occurred in an effort to prevent corruption, bribery and discrimination.

Compliance Manual

Compliance 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 Forces
  • 8.
    Timely/Proper Informational Disclosure and Appropriate Tax Reporting
  •   9.
    Restriction of Insider Trading
  • 10.
    Respect for Human Rights/Restriction of Discrimination 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

The Tokyo Tatemono Group has declared to adhere to laws, regulations, and other rules and engage in fair, sound corporate activities in its Compliance Charter. We work to raise awareness and thorough compliance with the 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.

<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

Preventing Anti-competitive Practices

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

<Relevant Items in the Compliance Manual>

  •   1.
    Observance of Laws
  •   2.
    Regulations and Proper Relationships with Partners

Compliance Training

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 the prevention of money laundering, as well as brushed up our knowledge following amendments to the laws and regulations for roughly 2,800 executives and employees in 13 Group companies, in addition to our foundation in compliance that includes the Compliance Charter and compliance items. In addition, we have introduced stratified training, such as collective training for new Group employees, harassment prevention training for executives, 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 the corporate intranet, and include spotlight articles about the prevention of insider trading, drinking in moderation and proper relationships with public officials to raise awareness throughout the Group.
Furthermore, we hold seminars by inviting outside experts as lecturers around themes regarding the law and regulation field as well as taxes that have great importance in operations and share the latest judicial examples, tax amendments and other information related to our businesses throughout the entire Group.

Implementation of Compliance Surveys

The Tokyo Tatemono Group conducts compliance surveys to periodically understand and review the awareness and penetration 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 of each Group company, and then report that information to the Internal Control Committee while providing feedback to each 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 compliance system.

Setup of a Helpline

The Tokyo Tatemono Group setup the Tokyo Tatemono Group Helpline that can be used throughout the Group as a consultation and reporting window to prevent violations to the laws and illegal acts. Furthermore, the helpline establishes a contact window with an external law office to create a system for easy consultation and reporting. All employees who engage in the businesses of any of the Group companies can use this helpline.
Consultations and reports received at each contact window are reported to the Tokyo Tatemono Internal Audit Division (organization under the direct control of the President) and the facts are reviewed and verified in accordance with the content 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.

Supply Chain Initiatives

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 the land acquisition and leasing or sales activities during this process. 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 the guarantee of a work-friendly environment in the Compliance Manual as items related to human rights in addition to occupational health and safety. We have also defined proper 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 an environment free from corruption and bribery.
We actively incorporate environmentally-friendly technology and ideas into our products and services in every stage of our business activities even in terms of the environmental considerations related to procurement in accordance with the Group Environmental Policy, and it strives to save resources and use materials that reduce the environmental impact.

Responding to Anti-social Forces

Our ban on any relationship with anti-social forces has been clarified in the Exclusion of Anti-social Forces Rules of the Tokyo Tatemono Group and we have stipulated specific procedures for checks in the Anti-social Forces Check Manual.
Furthermore, we cooperate with external experts such as the police and attorneys at law to respond with a firm attitude to anti-social forces.