• Basic Policy
• Approach
• Promotion Structure
• Compliance Program
• Consultaton Counter

The Asset Management Company has established the following policies and structures with the purposes of conducting corporate activities in good faith and with fairness, and to secure healthy management.

Basic Policy

The Asset Management Company fully recognizes its social responsibility and mission as an asset management company, and has established thorough compliance as a basic management principle to conduct appropriate and fair management assets of JEI.

Approach

• The Asset Management Company’s Directors and Auditor conduct operations upon understanding that compliance is one of the most important items in management.
• The Asset Management Company’s Directors and Auditors engage in compliance themselves to lead its promotion, and endeavor to communicate its importance to employees.
• The Board of Directors develops the necessary structure for compliance and promotes its execution to realize and secure compliance.
• The Asset Management Company’s employees execute tasks while ensuring compliance.
• The Asset Management Company’s employees strive to obtain sufficient knowledge necessary in executing tasks such as laws and regulations.
• The Asset Management Company’s Directors and employees shall always confirm with the Compliance Officer and lawyers, etc., when there are questions regarding the interpretations, etc., of laws and regulations, etc., and shall not continue operations under individual interpretations, etc.

Promotion Structure

1. Compliance Committee
   The Compliance Committee has the purpose of thoroughly meeting compliance in terms of laws, regulations, and rules for the Asset Management Company, and deliberates and makes decisions on basic matters and important matters regarding the compliance of the Asset Management Company.
2. Compliance Officer
   The Compliance Officer is an independent department that does not belong to any other, and works exclusively on compliance tasks. The Compliance Officer develops plans for all aspects of compliance, promote these, and compile the agenda for the Compliance Committee.
3. Compliance Manager
   The Department Head of each department serves as a Compliance Manager, and improves compliance awareness and strengthen the structure within their departments, provides initial responses to breaching compliance within their department, reports these to the Compliance Officer, investigates the cause, and instructs considerations and measures to prevent recurrence, etc.
4. External Experts
   External Experts are appointed among lawyers, certified public accountants, real estate appraisers, etc. by the Board of Directors. The Compliance Committee’s resolutions are not to be adopted without approval from external experts.

Flow of Decision-Making of the Asset Management Company

Compliance Program

A Compliance Program is established as a specific plan to realize compliance. They are established annually as a rule, and are reviewed as necessary.

Consultation Counter on Compliance

A Consultation Counter has been established for employees to report or discuss matters when they discover problems relating to compliance such as violation of laws and regulations, code of conduct, etc.