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.

The Group has established the Compliance Helpline, as an outlet for all employees to report any violation of laws,

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 the General Manager of the Group Legal Affairs Department or an outside lawyer. The Tokyu Fudosan Holdings Group Compliance Manual defines the Group's conduct based on five themes: 1) Compliance with Laws and Regulations and Fair Trading; 2) Ensuring Customer-oriented Awareness; 3) Suitable Execution of Duties; 4) Proper Management of Information; and 5) Ensuring Good Faith in Business Conduct. Particularly, number 5, which reads ensuring good faith in business conduct, further defines specific behavior guidelines, including 1) reasonable business entertaining and gift-giving, 2) prevention of corruption and bribery, 3) entertaining and gift-giving involving politicians and civil servants, and 4) code of behavior for deemed civil servants, 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 five themes: 1) Compliance with Laws and Regulations and Fair Trading; 2) Ensuring Customer-oriented Awareness; 3) Suitable Execution of Duties; 4) Proper Management of Information, and 5) Ensuring Good Faith in Business Conduct. More specifically, theme 5. Ensuring Good Faith in Business Conduct has further defined behavior guidelines, including 1) reasonable business entertaining and gift-giving, 2) prevention of corruption and bribery, 3) entertaining and gift-giving involving politicians and civil servants, 4) code of behavior for deemed civil servants, in order to counteract all forms of corruption and not just bribery. Employees can review this code of conduct on the Intranet at anytime.

Every year, e-learning on compliance is conducted targeting all employees. 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, are posed to promote well-spread recognition and understanding, as well as to encourage active communication between all employees.

The Group conducts various compliance seminars targeting employees on a regular basis. Until now,

Compliance training

The Group regularly holds compliance seminars for employees. We have taken up themes that are highly demanded by society, such as "insider trading regulations," "measures to prevent power harassment and sexual harassment," and "prevention of accounting irregularities," and have made efforts to hold these seminars in a timely and appropriate manner by inviting outside lawyers as lecturers.

In addition, e-learning training sessions are held annually for approximately 20,000 employees, with the goal of achieving a 100% participation rate. In addition to the same themes as the seminars mentioned above, training was held twice on topics such as "labor affairs" and "internal reporting system. Furthermore, Tokyu Land Corporation regularly holds e-learning sessions for all employees, including temporary and contract employees, regardless of their employment status.