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

The Tokyo Tatemono Group established the Internal Control Committee that discusses Group compliance as well as general internal control risks 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.

System

Index and Performance

Number of Students and Completion Rate of Compliance (e-Learning) Training

2015 2016 2017
Number of Students and Completion Rate of Compliance (e-Learning) Training 657 people 814 people 847 people
Completion Rate of Compliance Training 99.4% 98.8% 98.5%

Number of Reports and Consultations to Helpline

2015 2016 2017
Number of Reports and Consultations to Helpline 28 15 44

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.

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 Anti-social 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

Compliance Training

The Tokyo Tatemono Group conducts joint Group e-learning training every year. In 2017, we gained knowledge aboutharassment prevention, informational management, the Building Lots and Buildings Transaction Business Law and the Act on Prevention of Transfer of Criminal Proceeds 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, training for executives and general managers, training for new Tokyo Tatemono employees, and training for newly appointed supervisors.
We also 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 approximately 6,800 employees from 16 companies throughout the entire Group in 2017 with a collection rate of roughly 80.5%.
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 nternal Control Committee is convened for more important matters to consider the response.

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.