Basic compliance policy
Japan Retail Fund Investment Corporation (hereinafter referred to as “the Investment Corporation”) and Mitsubishi Corp.-UBS Realty Inc. (hereinafter referred to as “the Asset Management Company”), a company charged with the responsibility of managing the assets of the Investment Corporation, are striving to ensure the appropriateness of asset management and soundness and adequateness of operations, as well as protection of investors at the discretion and on the responsibility of each entity, by strengthening and facilitating functioning of the internal control system based on the highest quality standards of laws and regulations under the real estate investment fund system. In addition, the Investment Corporation and the Asset Management Company are of highly public nature and also assume the social responsibility of extensively making contributions to the economy and society.
Given such a business environment and in view of the fact that the Asset Management Company is a joint venture company between a Japanese company and a foreign financial institution and characteristically has an international corporate culture, it has developed the following compliance system with the aim of achieving a high-level compliance system in the industry.
- The Ethical Rules and the Compliance Handbook shall serve as the code of conduct for compliance with laws and regulations and the articles of incorporation by officers and employees. When officers and employees join the Company, the Compliance Office shall provide guidance on the said Handbook and fully explain the rules contained therein. In addition, the Compliance Office shall continue to remind officers and employees of these rules from time to time so as to ensure their awareness of the fact that the business activities of the Company are premised on compliance and adherence to social ethics.
- Compliance Office has been established. It is headed by the Chief Compliance Officer. The Company will establish a firm-wide compliance system and endeavor to identify problem areas in its compliance systems. The Company will also establish a Compliance Committee, to be chaired by the President, to discuss important matters concerning compliance on a regular basis, and report the results of such discussions to the Board of Directors, if necessary.
- The Compliance Office shall develop an Annual Compliance Program, and set out important compliance issues for each division. The Compliance Committee shall confirm the status of these suggested improvements on a regular basis. The Board of Directors shall approve the Program when it is developed. Around the end of each business year, the President shall report on the implementation of the Program to the Board of Directors.
- Each division shall appoint a person or persons who will conduct self-assessments on a regular basis and increase the awareness of the importance of compliance in the work place, through communication of compliance information or otherwise.
- In the event of a threatened or actual violation of compliance, officers and employees shall inform the Compliance Office either through their immediate supervisors (the executives of their division) or directly in accordance with the Compliance Handbook. Upon receipt of such information, the Compliance Office, together with the head of the relevant division, shall immediately investigate the details of such event, seek opinions or advice from outside legal advisors and/or other experts if necessary, and implement appropriate remedial measures to prevent a recurrence of such an event. In the event that the Compliance Office, directors and statutory auditors discover or are informed of any compliance problems, they shall promptly report the same to the President.
Furthermore, based on the Whistle Blowing Rules, the Company shall avoid any disadvantageous treatment of a whistle blower. Any whistle blower is entitled to appropriate protection and may contact the internal inquiry counter. If he or she wishes to contact external counsel, he or she may use the MC Group lawyers’ opinion box, which should be designated as the external inquiry counter for consultation and reporting.
For more information, please refer to Report on the Management Structure and System of the Issuer of Real Estate Investment Trust Units and Related Parties
