Basic Compliance Policy
The Asset Management Company understands the importance of managing One REIT's assets as managing unitholders' funds. In order to build an appropriate management system, it positions thorough compliance as a fundamental management principle to protect investors by ensuring the appropriateness of asset management and the soundness of operations. Therefore, the Asset Management Company has established the following compliance structure.
Compliance Structure
Compliance Office and Compliance Officer
The Compliance Office has been established as the department in charge of compliance-related matters, and the compliance officer is appointed as the person in charge of overseeing compliance-related matters to ensure the effectiveness of the internal check-and-balance function over other departments. Appointment and dismissal of the compliance officer is by resolution of the board of directors.
The compliance officer, as the person in charge of compliance at the Asset Management Company, endeavors to establish an internal compliance system and foster awareness of internal norms to comply with laws, regulations and other rules. To this end, the officer constantly monitors the Asset Management Company's execution of asset management for One REIT for legal compliance and also monitors/supervises compliance in everyday operations.
In light of the seriousness of the compliance officer's responsibilities as described above, the Asset Management Company appoints compliance officers who have sufficient examination and supervisory capabilities to ensure compliance with laws, regulations, and codes.
Compliance Committee
The Compliance Committee consists of the compliance officer, the Chief Executive Officer, the head of the Finance & Administration Division, outside committee members and other persons appointed as necessary by the board of directors and is chaired by the compliance officer. The outside members are knowledgeable third parties (lawyers, in principle) outside the Asset Management Company.
In principle, the Compliance Committee is convened by the chair once a month, but other meetings are held as necessary. Resolutions at Compliance Committee meetings require the attendance of at least two-thirds of the members (outside members must also attend) and the approval of at least two-thirds of the members in attendance, including approval by the outside members.
Creation of Compliance Manual, Etc.
In order to establish and operate a compliance system, the Asset Management Company has created a Compliance Manual as a code of conduct, and as a practical plan to more thoroughly implement the code of conduct set forth in the Compliance Manual, it has formed a compliance program, based on revisions to laws, regulations, and other rules concerning One REIT and the Asset Management Company and social trends and changes, which it reviews yearly. It has also a developed a compliance training program, which is likewise reviewed on an annual basis, to effectively increase the awareness and knowledge of the Asset Management Company’s employees, which is essential to establishing and maintaining the compliance activities set out in the compliance program.
Conducting Compliance Training
To establish and operate the compliance system planned in the compliance program, the Asset Management Company conducts compliance training for all officers and employees multiple times each year, which is essential to improving their awareness and acquisition of knowledge and performing them more efficiently.
The training has been implemented as follows.
The actual record will be posted after the aggregation of data.
This table can be scrolled sideways.
| Year | Attendance rate | Main themes |
|---|---|---|
| FY2023 | 100.0% |
|
| 100.0% |
|
Whistleblower System (Compliance Hotline)
The Asset Management Company has established a whistleblower system in order to ensure early detection and correction of compliance-related problems, to embed a self-correcting mechanism and to make the compliance system effective through creation of a framework for appropriate handling of inquiries and reports from officers and employees concerning compliance such as organizational or individual violations of laws, regulations or service disciplines.
The actual number of cases of inquiries with or reporting to the internal whistleblowing system were 0 cases in FY2023.
Response to Compliance Violations
The Asset Management Company views rigorous compliance as a basic management principle and deals strictly with compliance violators, including taking disciplinary action based on the nature of the offence.
Measures Against Antisocial Forces
Handling of Anti-Social Forces
We sever any ties with anti-social forces that pose a threat to the order and safety of civil society, and with future social changes in mind, we ensure the soundness and safety of financial infrastructure functions.
1. We sever all ties with anti-social forces.
The Asset Management Company does not provide any products or services to any form of antisocial forces. We conduct thorough screening and investigation to prevent such transactions from the start. In the event that a company is subsequently identified as an antisocial force, we will promptly terminate the transaction.
2. The entire organization works together to handle anti-social forces.
In the event that a tie to antisocial forces is discovered, the Asset Management Company will promptly report the matter to top management, and under their direction, the entire organization will work together to deal with the matter in the most appropriate manner.
3. We collaborate with specialized external organizations.
The Asset Management Company will work closely with law enforcement authorities, relevant external organizations, and lawyers to deal with the incident, giving due consideration to the safety of our officers and employees.
4. We take a firm stand without hesitating to take legal action.
The Asset Management Company will take resolute action against antisocial forces, both criminal and civil, and will not engage in backroom deals in response to unjustified demands, threats, or other attacks.
5. We protect financial infrastructure that supports society and customers’ daily lives.
The Asset Management Company will protect the safety and soundness of the financial infrastructure by constantly monitoring the latest developments of antisocial forces and promptly implementing various measures to ensure the safety of our products and services.
Efforts to Prevent Bribery and Corruption
The Asset Management Company has stipulated Detailed Procedures Concerning the Provision and Receipt of Hospitality/Gifts for the purpose of ensuring the appropriateness of hospitality and gifts, including preventing collusion with customers through expenses being paid to provide hospitality or gifts to external parties, such as customers, or employees or officers of the various companies receiving hospitality and gifts at the expense of external parties, such as customers. Furthermore, the Asset Management Company has stipulated Operational Guidelines for Dealing with Public Officials, etc., which provide specific operational guidelines for complying with the code of conduct and specific guidelines relating to the legal granting of favors to public officials, persons equivalent to public officials, etc., and strives to implement thorough compliance by following these regulations in an appropriate manner.
Initiatives to Counter Money Laundering and Terrorism Financing
With financial crimes becoming more varied and sophisticated and terrorism continuing to occur in places around the world, money-laundering and terrorist financing countermeasures ("anti-money-laundering measures") are increasing in importance, and the strengthening of anti-money-laundering measures is an issue. In carrying out its asset management business for One REIT, the Asset Management Company takes steps to comply with laws, regulations, and other rules, including the formulation of a Customer Acceptance Policy, the creation and updating of Documents Created by Specified Business Operators that identify and assess money-laundering-related risks, and the implementation of money-laundering-related risk assessment, while also continuously working to further strengthen its anti-money-laundering measures.