Compliance

Basic Approach

In order for the Heiwa Real Estate Group to earn the trust of society and achieve sustainable development, we will consistently maintain an awareness of compliance and conduct business in keeping with our Code of Conduct and the Standards for Behavior for Heiwa Real Estate Group.
To stamp out misconduct and further strengthen compliance, we also enacted the Announcement on Stamping Out Misconduct and Strengthening Compliance in December 2019, and are taking initiatives in keeping with this.

Compliance System

The Group has established a Risk Management Committee, a body for sharing, discussing, and controlling compliance and business risks in the Group. Serious violations of compliance or material emerging risks are reported to the Company's Board of Directors and handled accordingly.
The Corporate Planning and General Affairs Department, which serves as the secretariat for the committee, is responsible for coordinating with Group companies, and promotes improved compliance and risk management function across the entire Group.

Establishment and Implementation of a Compliance Manual

The officers and employees of the Asset Management Company must fully recognize the importance of the publicness of their business activities and their social mission, comply with the Financial Instruments and Exchange Act, the Investment Trust Act, other related laws and regulations, the rules of the Investment Trusts Association, Japan and other groups of which the Company is a member, the rules of the financial instruments exchanges on which the Investment Corporation, which has concluded an asset management agreement with the Asset Management Company, lists investment units, and internal rules and regulations, and perform their duties faithfully. The compliance manual established by the Investment Management Company lays out the basic principles that all officers and employees must observe without exception. The goal of all officers and employees is to achieve fair and appropriate management and to fulfill the social responsibilities imposed upon the Company in the conduct of its business activities.
Corporate compliance is put into practice by having all officers and employees fully understand the significance of compliance, embrace a high sense of corporate ethics, and engage in activities that observe compliance not only in corporate activities but in their daily social lives.

Compliance Hotline

Based on our Internal Reporting Regulations, the Group has established an internal compliance hotline in order for us to rapidly be aware of organizational or individual misconduct or violations of laws and regulations and to take necessary measures in response. This system also promotes ethics and compliance with laws and regulations at Group companies.
Reports may be made to internal or external desks. We protect those who provide us with reports, like ensuring that they are not penalized for their use of our compliance hotline.
To promote fair transactions with business partners such as corporations, we have also set up an external reporting desk to receive reports on compliance violations and suspected violations by officers and employees of the Group.

Responding to Compliance Violations

1. If any of the following matters arise during the performance of their duties, an officer or employee of the Asset Management Company shall promptly report the matter to the Compliance & Risk Management Office and ask for instructions.
   (1) When conduct that violates laws, regulations, rules or other requirements has occurred for any reason
   (2) When there are doubts regarding laws, regulations, rules or other requirements and a determination needs to be made on how to respond
2. Of the reports described in the preceding paragraph, for those matters the Compliance & Risk Management Office deems to constitute a case of serious misconduct, such as a violation of business law or criminal law, the Chief Compliance Officer shall promptly report to the Representative Director and convene a meeting of the Compliance Committee to deliberate over the matter.
3. The results of deliberations by the Compliance Committee must be reported to the Board of Directors meeting convened immediately afterward.
4. The Compliance & Risk Management Office must report to the Compliance Committee and Board of Directors regarding the status of response measures concerning a matter deliberated over by the Compliance Committee in accordance with Paragraph 2.

Combating Anti-Social Forces

1.Basic concept for excluding anti-social forces

We are strongly resolved to combat anti-social forces that threaten the order and security of civil society.

2.Status of measures to exclude anti-social forces

The Company has clearly established a number of policies showing its strong resolve to combat anti-social forces. These can be found in the Code of Conduct, the Standards for Behavior for Heiwa Real Estate Group, the Basic Policy for Building Internal Control Systems, and the Regulations for Exclusion of Anti-Social Forces. We thoroughly disseminate these policies to directors, executive officers, and employees.
The Corporate Planning and General Affairs Department serves as the controlling department for our internal systems in this area. In the event of unreasonable demands and other instances with anti-social forces, this department takes action in coordination with attorneys and related institutions, such as the police department with jurisdiction.
By joining the Tokubouren, a police-run association for the prevention of organized crime, we participate in activities to exclude anti-social forces and gather information, providing details to various departments as necessary.

Prevention of Corruption

The Group has enacted the Code of Conduct and the Standards for Behavior for Heiwa Real Estate Group, and drafted a summary of matters to be complied with in order to act with fairness and honesty without violation of social norms. In keeping with these we maintain an awareness of the gravity of our social responsibility, strictly comply with all laws, regulations, and rules, and seek to be a company that has a strong sense of ethics and can keep the trust of society.
The Standards for Behavior for Heiwa Real Estate Group calls on us to strictly refrain from behavior that may seem like collusion from society's standpoint in our relationships with government and administrative bodies, prohibits entertainment, gifts, and other benefits deviating from social conventions, and concretely defines measures to prevent not only bribery, but corrupt behavior in general. These details are published to our intranet, and are available for employee viewing at any time.
We are also taking a number of actions to improve compliance awareness, such as holding at least five compliance training sessions each year for all officers and employees and thoroughly disseminating the contents of various compliance regulations, including those for the prevention of corruption and bribery.
Furthermore, based on our Internal Reporting Regulations, we have established a compliance hotline at the Company in order for us to rapidly be aware of organizational or individual misconduct or violations of laws and regulations and to take necessary measures in response. This system also promotes ethics and compliance with laws and regulations at Group companies.
To promote fair transactions with business partners such as corporations, we have also set up an external reporting desk to receive reports on compliance violations and suspected violations by officers and employees of the Group.

Corporate Ethics Training for Employees

The Asset Management Company conducts corporate ethics training for all officers and employees. In addition to quarterly in-house training, we have introduced lectures delivered by attorneys and e-learning conduct, with the aim of having officers and employees acquire specialized and practical knowledge that is more wide-ranging and applicable to their duties.