Compliance | LIFULL Co., Ltd.

Fundamental Policy and Guidelines

We have established a Fundamental Policy for the Construction of an Internal Auditing System for the LIFULL Group to ensure sound and efficient management with consideration to all stakeholders. Based on this policy, we have built, maintained and are managing internal auditing systems which meet legal standards, provide for efficient and effective business operations as well as financial reporting.

Additionally, we have established Guidelines for executives and employees to follow in their everyday work. By making sure that all of our executives and employees are aware of and follow these Guidelines, we are working toward realizing our Corporate Philosophy while also ensuring compliance within the Company.
^※LIFULL Co., Ltd. Guidelines

Training

The Legal Department is responsible for compliance and holds company-wide trainings for executives and employees. This department also works to build, maintain and improve systems to ensure compliance within the Company as part of our CSR initiatives.
By regularly providing educational opportunities on topics such as protection of personal data and other compliance-related issues, we are ensuring that we doing business in a fair and honest way.

Internal Reporting Mechanisms

According to the Whistle-Blower Protection Act, the Company has established both internal and external reporting mechanisms to quickly identify and resolve fraud, legal violations and unethical actions.
Full-time, part-time, contract, dispatched and outsourced employees working for the Company and its subsidiaries and affiliates all have access to these mechanisms and internal and external contact points.

Business Partners

Fundamental Policy

For the LIFULL Group, fulfilling our social responsibilities to all stakeholders, including business partners is the top priority of our management. Within the scope of this responsibility, compliance with laws and regulations as well as adherence to ethical norms are, of course, also considered to be of utmost importance.

Due Diligence on Business Partners

We are continuously making improvements to the checks we have in place in the Legal, Supplier Review and buying operations in order to create a more rigorous system to prevent risks such as illegal transactions. One concrete example is our Supplier Review Department. This department run checks on all new suppliers, including any past legal and compliance violations, before entering into business transactions or contracts.
We also strive to ensure appropriate actions from a compliance perspective with our existing business partners. For example, in our core business, LIFULL HOME'S, if any compliance violations are identified with our business partners, we take measures such as suspending or terminating advertisements based on our company regulations.

Elimination of Antisocial Organizations

The LIFULL Group has established the following fundamental policy to take a resolute stance against antisocial forces that threaten social order and safety and have no relationship with such forces or the like.

(I) Basic Concept of the Fundamental Policy on Antisocial Organizations

A) The Group will not conduct any transactions with antisocial organizations
B) For no reason shall the Group engage in any conveniences provided by antisocial organizations such as back-door transactions or funding.
C) The Group will not respond to any unreasonable demands from antisocial organizations and will legally respond to unreasonable civil and criminal demands in a systematic manner.
D) If the Group is suspected or found guilty of transactions with antisocial organizations, we will immediately take measures to terminate the relationship.
E) In addition to maintaining close communications with law enforcement, Tokyo Center for Removal of Criminal Organizations, legal advisors and other external professional organizations, we will take steps to protect our employees from unreasonable demands from antisocial organizations.

(II) Maintenance of Internal Measures to Eliminate Antisocial Organizations

A) Establishment of Response Team against Antisocial Organizations
The Company's General Administration department will respond to antisocial organizations and centrally manage related data. We will also implement internal measures across departments to respond to unreasonable demands by antisocial organizations.
B) Collaboration with External Organizations
As an action against antisocial organizations, we have joined the Tokuboren (the Federation on Special Organized Crimes with the Jurisdiction of the Tokyo Metropolitan Police Department) and collect data related to antisocial organizations as well as maintain close relationships with other specialized organizations such as local law enforcement, the Tokyo Center for Removal of Criminal Organizations and legal advisors.
C) Internal Research
In accordance with Article 14 Item 2 of the Tokyo Center for Removal of Criminal Organizations "Act on Prevention of Unjust Acts by Organized Crime Group Members," in addition to training for the prevention of unreasonable demands for responsible parties, all of our employees receive training on the prevention of unreasonable demands.

Anti-Corruption

Considerations on Anti-Corruption

At LIFULL, under the supervision of the Board of Directors, we have established our Fundamental Policy for Building an Internal Control System. In accordance with this policy, we comply with various laws and regulations, conduct fair business activities in line with sound business practices and social norms and strive to prevent all forms of corruption in order to gain unfair profits, including coercion and bribery.
Also, we strictly screen all potential business partners and intermediaries before starting new business relationships with them in order to ensure that they comply with our business partner management rules and prevent any transactions that could be linked to corrupt practices.

Operations Assessed for Risks Related to Corruption

(1) Operations Assessed for Risks Related to Corruption
The Company has strengthened its system of checks through its Risk Management and Disciplinary Action Committees and has constructed a system to prevent corruption-related risks.
(2) Significant Risks Related to Corruption Identified through Risk Assessments
There are no significant risks related to corruption identified through risk assessments.

Communication and Training about Anti-Corruption Policies and Procedures

(1) Directors

prevention of corruption which is communicated to new officers.

(2) Employees

We have established an anti-corruption policy for employees in our employee employment regulations and disciplinary rules, which are included in training for new hires. In addition, we are working to foster an awareness of compliance issues trough regular activities geared toward instilling our vision in our employees.

Examples of Grounds for Disciplinary Action / Dismissal

－Embezzlement of Company funds or goods
－Theft of Company funds or goods
－Receiving money or goods as a result of unfair gains in the workplace
－Bribing public officials etc.

Internal Reporting Mechanisms

The internal reporting mechanisms cover overall compliance including corruption and bribery, etc.
We have also established internal and external Whistleblower Channels.
Through this program, employees and business partners can anonymously report incidents. People reporting incidents and other individuals involved in the reporting are protected from disadvantageous treatment.

Privacy and Protection of Personal Data

LIFULL Group recognizes the importance of personal information and, in order to achieve its protection, complies with the laws and regulations related to the protection of personal information, including the Personal Information Protection Law and other related guidelines.

For more details on LIFULL Group's privacy policy and handling of personal information, please refer to the LIFULL Group Privacy Policy.