Compliance

Compliance is essential for the continuous growth of JPR. Through sound management and operation of JPR based on laws, regulations and other requirements, Tokyo Realty Investment Management, Inc. (TRIM) will endeavor to merit the trust of JPR, its unitholders, tenants and a variety of other stakeholders.

Basic Policy on Compliance by TRIM

In an effort to rightly recognize social and public duties within asset management for investment corporations, and maintain and enhance the trust of investors and society, Tokyo Realty Investment Management, Inc. (TRIM) shall follow the following basic policy as a code of conduct for its officers and employees in order to ensure that every member of the company adheres to the utmost professional ethics, abides by laws and regulations, and implements sound business operations with integrity.

  1. In conducting operations of asset management for investment corporations, our officers and employees shall abide by public and voluntary regulations set forth in laws and regulations related to the relevant operations, government and ministerial ordinances, voluntary rules of the industry and internal rules on its own, etc. (hereinafter, the laws and regulations, etc.).
  2. Our officers and employees shall fully understand the purposes and substance of the laws and regulations stated in the above item and, when their actions, though seemingly compliant with the provisions of laws and regulations, etc., have deviated from the purposes and substance of the provisions, they shall strictly refrain from taking such actions.
  3. Our officers and employees shall recognize that progress in financial liberalization and greater relaxation of restrictions on asset management, etc. would increase and diversify risks as well as require business management to observe more tightly the principle of self-responsibility. With such recognition, they shall endeavor to thoroughly implement risk management.
  4. Our officers and employees shall endeavor to enhance their asset management and risk management capabilities for implementing operations of asset management for investment corporations so as to maintain and enhance the trust imparted by investors and society. Each division and group of TRIM shall work to establish a system that helps reinforce the capabilities of its members in order to achieve the purposes of such operations.
  5. Our officers and employees shall recognize that securing fair and free competition is indispensable for the continuity and sound development of TRIM, and shall avoid any behavior that hampers fair competition, such as industry meetings to restrict competition, consent with other companies intended for restricting trade, restraint of business activities of suppliers or client companies by taking advantage of a superior position in business, and unjust discrimination in transaction terms and conditions, etc.
  6. Our officers and employees shall fully recognize the importance of protecting personal information and, when handling customer data and other internal information possessed by the company, implement appropriate and stringent control of such information in accordance with the internal rules.
  7. Whether business or personal, we will oppose with firm resolve any demand, including provision of donations and contributions and subscription of information magazines as well as provision of money and other articles, from anti-social forces that threaten the order and safety of civil society.
  8. We will prevent any laundering of monies generated from criminal behavior.
  9. We will work to utilize the company's assets and expenses in a fair and efficient manner, and will not make inappropriate, unjust or inefficient use of them, such as confusing business and private use and spending for unnecessary items or matters.
  10. We will abide by the employment regulations, labor agreements and other rules to secure a sound, efficient and comfortable workplace environment. Moreover, our officers and employees shall not engage, among themselves, in 1) lending money or similar behavior and 2) sending courteous gifts, etc. beyond the extent deemed appropriate under normal social conventions.
  11. We will respect individual human rights and personality. We understand that it is unacceptable, in terms of common sense of society as well, to assume discriminatory behavior by reason of nationality, sex, birthplace, religion, belief, illness or physical features, etc. or behavior that may result in sexual harassment, etc., and will not engage in such behavior.
  12. Fully understanding that we are involved in a business of a highly public nature, we will maintain efforts to enhance our ethical view in our social life as well, and act with a good sense of social being.

Organization to Promote Compliance

TRIM promotes compliance through the following organization.

171030-8d1c970128.png

Consultation Counter on Compliance

In consideration of the purposes of the Whistleblower Protection Act, TRIM has established a consultation counter on compliance in order to appropriately handle information from its employees regarding contravention of laws and other violations. With a reception desk for inside information and a reception desk for outside information, the consultation counter allows for effective utilization by informants when they learn of contravention of laws and other violations.

Provision of Compliance Training

TRIM periodically provides training for all of its officers and employees to inform themselves on matters of compliance. The training sessions are held approximately ten times a year and, with the participation rate of almost 100%, function to disseminate compliance among the entire officers and employees. Questionnaires and confirmation tests might be conducted at any time after the sessions, and the results are utilized for future training.

Prevention of Transactions with Anti-Social Forces

TRIM nor its officers and employees shall have any relations whatsoever with anti-social activities and anti-social forces that threaten the order and safety of civil society and hamper economic activities. Any unjust demand from anti-social forces, including provision of donations and contributions as well as provision of money and other articles will be opposed with firm resolve

Moreover, TRIM has established "rules for facing anti-social forces" with an aim to prevent the company from being damaged by anti-social forces and to help it perform its social responsibilities. Under the rules, TRIM endeavors to eliminate anti-social forces through constant, close coordination with such external specialized institutions as the police and lawyers.