Compliance and Risk Management

Basic compliance policy

Basic policy

Industrial & Infrastructure Fund Investment Corporation (hereinafter referred to as "the Investment Corporation") and Mitsubishi Corp.-UBS Realty Inc. (hereinafter referred to as "the Asset Manager"), a company charged with the responsibility of managing the assets of the Investment Corporation, are striving to ensure the appropriateness of asset management and soundness and adequateness of operations, as well as protection of investors at the discretion and on the responsibility of each entity, by strengthening and facilitating functioning of the internal control system based on the highest quality standards of laws and regulations under the real estate investment fund system. In addition, the Investment Corporation and the Asset Manager are of highly public nature and also assume the social responsibility of extensively making contributions to the economy and society.
 
Given such a business environment and in view of the fact that the Asset Manager is a joint venture company between a Japanese company and a foreign financial institution and characteristically has an international corporate culture, it has developed the following compliance system with the aim of achieving a high-level compliance system in the industry.
  • In order to ensure that the performance of duties by directors and employees of the Asset Manager complies with laws and regulations and the articles of incorporation, the Asset Manager establish the Compliance Office, which shall seek to develop the system for directors and employees to act in compliance with laws and regulations, the articles of incorporation and social norms, and identify problems thereof.
  • The Risk Management Committee shall identify administrative risks, system risks and any other risks relating to the business operations of the Asset Manager and investment corporations on a regular basis.
  • Based on the "Whistle Blowing Rules", the Asset Manager shall avoid any disadvantageous treatment on a whistle blower. Any whistle blower is entitled to appropriate protection and may contact the internal inquiry counter. If he or she wishes to contact external counsel, he or she may use the "MC Group Lawyers' Opinion Box" which is designated as the external inquiry counter for consultation and reporting. By such means, the Asset Manager shall prevent violations of laws and regulations or the articles of incorporation and, if any such violation has occurred, shall seek to quickly gather information and address it.
  • If any violation of laws and regulations or the articles of incorporation has been discovered, the Compliance Office shall, pursuant to the "Administrative Incident Handling Rules", investigate the cause of such violation and handle and settle it, and then establish measures to prevent recurrence.

Establishment of a system to eliminate antisocial forces

To preempt violence from antisocial forces, clarify how the Asset Manager will respond as an organization and ensure that the Asset Manager will never have any relations or dealings with antisocial forces and use them, the Asset Manager provide the "Basic Rules around How to Deal with Antisocial Forces" which stipulates that the Asset Manager will take a resolute attitude as an organization to antisocial forces, including coordinating with external specialized institutions, as our basic principle. Each division of the Asset Manager is expected to confirm in advance that counterparts to transactions, etc. are not considered as antisocial forces, to report any questionable acts or behaviors when they are expected directly or indirectly to the Head of the Compliance Office and the President, and review social risks thoroughly to make a decision of whether the transaction can go ahead or not, in accordance with the Basic Rules as per their respective operations manuals for the Divisions that are provided separately.