The Tokyu Fudosan Holdings Group recognizes that corruption and bribery are serious risks that could considerably damage the trust and credibility of a company.

Policy

The Tokyu Fudosan Holdings Group recognizes that corruption and bribery are serious risks that could considerably damage the trust and credibility of a company. We are committed to maintaining sound relationships with stakeholders and will never engage in business entertainment or gift-giving that elicits suspicion or mistrust from society. Specifically, we will thoroughly implement the following.

1. We will never engage or be complicit in any and all forms of bribery, including money laundering, embezzlement, or obstruction of justice, etc.
2. In fully understanding laws and regulations about relationships with public offices and other similar persons in Japan or other countries, we will never engage in business entertainment or gift-giving that elicits suspicion or mistrust from society and we will never provide monetary or other benefits to gain illicit profits.
3. We will not provide or receive business entertainment or gifts from business partners or other parties that deviates from sound business practices or social norms.
4. We will not use our position or authority to demand personal benefits from our business partners or other parties.

In addition, a code of conduct is stipulated in the code of ethics for executive officers approved by the Board of Directors Meeting to counteract all corruption activities including bribery.

Management Structure

Board audit on corporate ethics (corruption, money laundering, etc.)

Tokyu Fudosan Holdings regularly conducts anti-corruption audits on all businesses. We audit annually on compliance with anti-corruption code of conduct such as corruption and money laundering, and report the results to the Board of Directors.

Goals, Initiatives, and Achievements

Whistleblower System

The Group has established the Compliance Helpline, as an outlet for all employees to report any violation of laws, company rules, and the Code of Conduct directly to Internal Reporting Desk or an outside lawyer.
The Tokyu Fudosan Holdings Group Compliance Manual defines the Group's conduct based on four themes: 1) Fulfilling Our Promises to Society; 2) Creating a Sound Work Environment; 3) Doing Business with Integrity; and 4) Safeguarding Company Assets.
Particularly, number 3, which reads Doing Business with Integrity, further defines specific behavior guidelines, including Moderation in Entertainment and Gifts, Prevention of Corruption and Bribery, Entertainment and Gifts for Politicians and Public Ocials, and Acting as a deemed public officials, in order to counteract all forms of corruption and not just bribery.
More details about the Compliance Helpline can be found in the Tokyu Fudosan Holdings Group Compliance Manual.

Thorough dissemination of information to employees

The Tokyu Fudosan Holdings Group Compliance Manual defines the Group's code of conduct based on four themes: 1) Fulfilling Our Promises to Society; 2) Creating a Sound Work Environment; 3) Doing Business with Integrity; and 4) Safeguarding Company Assets.
More specifically, theme 3. Doing Business with Integrity has further defined behavior guidelines, including Moderation in Entertainment and Gifts, Prevention of Corruption and Bribery, Entertainment and Gifts for Politicians and Public Ocials, and Acting as a deemed public officials, in order to counteract all forms of corruption and not just bribery. Employees can review this code of conduct on the Intranet at anytime.
As part of our compliance training, e-learning on compliance is conducted targeting all employees every year. The learning program features questions related to laws and code of conduct, as well as refreshes employees' understanding of the Tokyu Fudosan Holdings Group Compliance Manual and Whistleblower System. Questions on elements of anti-corruption, including bribery and corruption, are posed to promote well-spread recognition and understanding, as well as to encourage active communication between all employees.
In addition, we regularly hold compliance seminars for our employees. The seminars are held in a timely and appropriate manner, covering themes that are highly demanded by society and inviting outside attorneys as lecturers.