Nippon Accommodations Fund Inc. (“NAF”) and have adopted a basic policy whereby they have established an organizational structure for invariably engaging in fair business transactions acting in compliance with laws and regulations and strive to earn the trust of investors by engaging in behavior that reflects high ethical standards.
In addition, the Asset Management Company strives to establish an appropriate management structure given that it recognizes that the management operations it carries out on behalf of NAF are important in that they involve management of unitholder funds.
Thorough Compliance
The Company has established an organizational structure that should secure compliance with laws and regulations and implement fair transactions at any time. At the same time, the Company works to ensure that its officers and employees will act based on high ethical values and win the trust of its stakeholders.
Mitsui Fudosan Group Compliance Policy
Compliance Structure
Organizational components relevant to compliance are as follows.
Board of Directors
The Board of Directors makes decisions on matters of fundamental importance to management including those involving management strategies, and also resolves matters with respect to election and dismissal of the Chief Compliance Officer (CCO) and external members of the Compliance Committee.
Compliance Committee
The Asset Management Company has established the Compliance Committee, which deliberates and makes decisions on business transactions potentially subject to conflicts of interest, legal compliance, and other such important matters related to compliance. The committee is composed of the CCO (chairperson), the President & CEO, and two external professionals.
Chief Compliance Officer (CCO)
To establish an appropriate asset management structure for facilitating asset management operations carried out by the Asset Management Company, we have appointed a CCO, who exclusively handles compliance independent from the organization, and ensure effectiveness of the internal check functions with respect to other business units.
Compliance Manual Formulation and Implementation
The Asset Management Company has prepared a compliance manual, which is to serve as a code of conduct on matters of compliance.
We also establish yearly compliance programs, which are to serve as specific action plans regarding compliance.
Upon having formulated the preliminary draft of a compliance program, we explain such details to all officers and employees and elicit their feedback. We then formulate the final draft incorporating such feedback as necessary. Next, we have the Compliance Committee and Board of Directors furnish their approval before subsequently taking steps toward putting the program into action.
Internal Audits
CCO conducts internal audits across all organizational units and job categories to confirm whether business and operations of each unit is carried out appropriately and efficiently in accordance with laws and regulations as well as other rules and bylaws, based on the internal audit rules set forth in the internal rules of the Asset Management Company. The results of audits are reported to the audited business units, the Compliance Committee and the Board of Directors.
Training
Please refer to “Company-wide Group Training”
Responding to Anti-social Forces
The Asset Management Company has established specific procedures for preventing business dealings with anti-social forces and contending with unreasonable demands from anti-social forces in its compliance manual and its internal rules for policy against anti-social forces. These are to serve as guidelines to which all officers and employees must comply.
As part of our efforts to refuse all ties with anti-social forces, we have appointed a CCO as the person in charge, built a centralized management system and strive to prevent prospective harm caused by anti-social forces.
We have also been taking steps to ensure that we do not engage in business transactions with anti-social forces through efforts that involve collecting, amassing, and using information on anti-social forces, liaising with external professional organizations, and implementing stringent screening.
Whistleblowing System
Those who have become aware of an act that may be deemed problematic in terms of legal compliance are generally to report the matter through the usual corporate channels. However, in cases where there may be grounds to believe that such channels may not function appropriately, those with such concerns may seek support outside the scope of such channels by consulting directly with the CCO or with a consultation service office (law firm) established externally.
Those seeking consultation are subject to protection under the Whistleblower Protection Act, and shall not be treated unfavorably by the company on the grounds of having sought consultation. Moreover, the CCO is to provide notification to officers and employees regarding the whistleblowing system twice per year.
Anti-Corruption Policy
To prevent bribery and corruption, the officers and employees of the Asset Management Company are instructed not to engage in illegal acts including bribery, embezzlement and money-laundering in the “Compliance Manual” and persons who commit wrongdoing are subject to strict punishment.
Issues related to fraud and corruption
Serious violations of laws and regulations and fines, surcharges and financial settlements related to bribery and corruption
There were no serious violations of laws and regulations nor fines, surcharges or financial settlements paid by NAF or the Asset Management Company in relation to non-compliance, etc. with anti-bribery rules during this reporting period(*1).
Officers and employees subjected to disciplinary action or dismissal related to bribery and corruption
No officers or employees of NAF or the Asset Management Company were disciplined or dismissed in relation to bribery or corruption during the reporting period(*1).
Political contributions
No political contributions were made by NAF or the Asset Management Company during the reporting period(*1).
- *1 Reporting period:
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Nippon Accommodations Fund Inc.
From March 1 of the previous year to the end of February of the current year Mitsui Fudosan Accommodations Fund Management Co., Ltd.
From April 1 of the previous year to the end of March of the current year