Basic Compliance Policy

Basic policy

Mitsubishi Corp.-UBS Realty Inc. (hereinafter referred to as "the Asset Manager"), and each 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 Compliance Rule, which shall seek to, in operation with the Compliance Office, 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 Investment management risks, administrative risks, system risks, reputation 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. The employees may contact the external legal counsel, using 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.
    *Confidentiality Legal counsel will confirm the affiliation of whistleblowers, but will not disclose their name or organizational position to the Compliance Administration Office without their consent.

  • If any violation of laws and regulations or the articles of incorporation has been discovered, the department in which the Administrative Incident occurred shall, pursuant to the "Administrative Incident Handling Rules”, investigate the cause of such violation and handle and settle it, and then establish measures

(January 1, 2019)