Compliance | Mitsubishi Estate Logistics REIT Investment Corporation

Promotion System for Compliance

MJIA have achieved compliance through the following system.

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Body	Main Duty
Board of Directors	Establish and modify the Asset Manager's compliance program and compliance manual.
Compliance and Risk Management Committee	Promote Compliance and Risk Management, and discuss and approve these monitoring issues. As a general rule, this committee should be held once a month, but It should be held as necessary.
President & Chief Executive Officer	President & CEO is responsible for establishing and implementing a compliance system as the ultimate responsibility for compliance. President ＆CEO is responsible for working sincerely and taking the lead in promoting compliance awareness among officers and employees.
General Manager of Compliance Department(Compliance Officer)	The General Manager of the Compliance Department is responsible for planning, drafting, coordinating and promotion of the Asset Management Company's compliance and risk management initiatives. If it is determined that problem has occurred or is deemed likely to occur from the viewpoint of compliance, the Company shall promptly report it to the President & CEO, who shall obtain approval for a policy for dealing with compliance violations and measures to prevent recurrence, and report the matter to the Compliance and Risk Management Committee. As an independent organ of separate from other internal organs of MJIA, General Manager of Compliance Department independently verifies the details of transactions or decisions related to the Asset Management Business of Investment Corporation.
Compliance Department	Under the supervision of the General Manager of Compliance Department, the Compliance Department coordinates the planning, planning, coordination, and promotion of compliance activities, and verifies the compliance status of each department. The Compliance Department checks the progress of the compliance program to the Compliance Manager of each department on a quarterly basis, and reports the results to the Board of Managers after deliberation through the approval by the Compliance and Risk Management Committee.

Initiatives for Compliance

Appropriate motivational framework for employees

To promote individual abilities and career development, MJIA have introduced Management by Objective System (MBO) for all employees. Compliance is included in the evaluation items in this evaluation.
MJIA regularly conduct compliance and risk management training to raise awareness of compliance among officers and employees.

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Total no. of compliance and risk management training sessions	FY2018	FY2019	FY2020	FY2021
compliance and risk training sessions	9	11	7	9

※FY2018:　April 2018- March 2019
　FY2019:　April 2019- March 2020
　FY2020:　April 2020- March 2021
　FY2021:　April 2021- March 2022

In order to improve the specialized skills of officers and employees, MJIA support officers and employees in obtaining and maintaining various qualifications (real estate securitization association certified masters, real estate dealers, etc.), as well as in providing outside training to acquire a wide range of knowledge. Relevant information and the number of qualified personnel are available on the website.

http://www.mecinvest.com/en/sustainability/employee.html

Employee Hotlines & Grievance Reporting (Confidential)

MJIA has established a consultation service for grievances, violations of laws and regulations, violations of internal rules, harassment, and other matters that are contrary to broad ethical and social standards of decency for employees (including directors, full-time employees, contract employees, part-time employees, temporary employees, and retired employees (Hereinafter referred to as "employees, etc." in this section) and all persons engaged in the business of MJIA and all of employees, etc. can declare or submit anonymously.
The President &CEO has the ultimate responsibility for the operation of the whistle-blowing system, and regularly disseminate the significance and importance of the system to employees, etc., and thoroughly inform them of the purpose.
The privacy of whistleblowers and consultants is strictly protected, and appropriate action is taken after confirming and investigating the facts of the matter. If necessary, the Mitsubishi Estate Group Helpline may also be used.
If the results of the investigation reveal any misconduct, etc., the General Manager of the Compliance Department shall immediately report it to the President & CEO, who, in the name of the President & CEO, shall immediately order the department or employee, etc. that is committing the misconduct to cease the misconduct and promptly take corrective and recurrence-prevention measures.
In addition, whistleblowers are legally protected by the Whistleblower Protection Act, which prohibits any disadvantageous treatment or harassment of whistleblowers on the basis of their reporting, and we take appropriate measures to prevent the deterioration of the working environment for whistleblowers and others, thereby striving to protect whistleblowers and create an environment for the proper functioning of the internal reporting system.

Bribery and Anti-Corruption Policy

The Compliance Department provides consultation to employees on a daily basis, and the Compliance Risk Management Committee monitors the status of the anti-bribery system annually, in addition to preventing misconduct through the establishment and operation of an internal whistle-blowing system. The Compliance and Risk Management Committee also reports the status of monitoring to the Board of Directors.
In addition, the Internal Audit Department confirms during on-site inspections that these monitoring and supervision systems are being properly operated in accordance with company rules and regulations.
In 2017, an assessment of the overall anti-bribery system of the Mitsubishi Estate Group was conducted by an external organization. By addressing the issues identified in this assessment, we are working to further enhance our anti-bribery system.