Approach and Policies

The Nomura Real Estate Group has positioned compliance with laws, regulations, corporate codes of conduct, and so on as a key management issue and formulated the Nomura Real Estate Group Code of Action as a compliance guide. In addition, Nomura Real Estate Holding established a Risk Management Committee and Group Legal/Compliance Department, conducts ongoing education and training for officers and employees throughout the Group, and provides advice, guidance, and support to Group companies.
Furthermore, the Group signed the UN Global Compact in May 2019 to further strengthen its compliance initiatives. In accordance with the principles of the UN Global Compact, we will take measures to avoid extortion, bribery, and other forms of corruption.

The Nomura Real Estate Group Code of Action

The Nomura Real Estate Group has formulated a Code of Action to define fundamental rules that Group officers and employees must adhere to. We review the effectiveness of the content of the Code of Action as appropriate, taking social circumstances and other factors into consideration, and any changes thereto are subject to decision by the Board of Directors.

【Table of Contents of the Code of Action】

Chapter 1 General provisions
Article 1 (Purpose)
Article 2 (Positioning)
Article 3 (Definitions)
Article 4 (Revision or abolition)

Chapter 2 Basic position
Article 5 (Awareness and behavior as a member of society)
Article 6 (Respect for basic human rights)
Article 7 (Observance of compliance)
Article 8 (Consideration for the global environment)
Article 9 (Corporate social responsibility)

Chapter 3 Behavior that gains customer trust
Article 10 (Providing highly safe, high-quality products and services)
Article 11 (Description of and risks relating to goods and services)
Article 12 (Customer consultation, response to complaints)
Article 13 (Appropriate disclosure to customers and provision of information)
Article 14 (Management of customer information)

Chapter 4 Maintaining a fair relationship with business partners
Article 15 (Implementation of fair competition and fair trade)
Article 16 (Implementation of highly transparent transactions)
Article 17 (Offering moderate entertainment or gifts for business partners)
Article 18 (Infringement of intellectual property rights and prohibition of unauthorized use)
Article 19 (Management of information on business partners)

Chapter 5 Relationship with officers and employees
Article 20 (Respect for human rights of officers and employees)
Article 21 (Maintenance and improvement of work environment)
Article 22 (Prohibition of insider trading)
Article 23 (Sincere business activities)
Article 24 (Operational records and reports)
Article 25 (Management of company assets and information)
Article 26 (Reporting illegal or unethical behavior)

Chapter 6 Relationship with society
Article 27 (Disclosure of corporate information)
Article 28 (Offering entertainment or gifts to public officials etc.)
Article 29 (Exclusion of anti-social forces)
Article 30 (Construction, operation, improvement of internal control for proper business execution)

Chapter 7 Miscellaneous provisions
Article 31 (Preparation of guidelines)
Article 32 (Use of guidelines)
Article 33 (Application to overseas subsidiaries and affiliates)


Compliance Promotion Framework

Nomura Real Estate Holdings has established a Risk Management Committee and Group Legal/Compliance Department to develop and implement a framework for compliance. In addition, the position of Compliance Officer has been established at each Group company, and Compliance Leaders and Compliance Promotion Officers have been appointed under the Compliance Officer to ensure compliance throughout the Group.
Serious violations of the Code of Action are reported to the Company’s Board of Directors by the Risk Management Committee Chairman and appropriate responses are being taken.

The Nomura Real Estate Group Risk Helpline

The Nomura Real Estate Group has set up the Nomura Real Estate Group Risk Helpline based on the Whistle-blowing System Operation Rules in order to secure a system for appropriately responding both to day-to-day general consultations from officers and employees, and official reporting on legal violations and misconduct committed at organizational or individual levels. We have established internal points of contact (The Risk Management Committee Chairman and the Group Legal/Compliance Department) and external points of contact (the Company's lawyer and outsourcing contractors) to make it easy for informants and users to use the system. We have established a system to protect informants by ensuring that the content of information is kept confidential and allowing for disciplinary action to be taken, in accordance with the work regulations, against persons who have disadvantageously treated or harassed informants.
In addition, we have established the Helplines for Business Partners for reporting on compliance violations or possible misconducts, in order to carry out fair transactions with corporate customers and other business partners.

Policy on Political Participation

In cases where the Group supports the activities of a political organization or makes political contributions, we act in compliance with relevant laws and regulations such as the Political Funds Control Law and the laws and regulations of each country and check our actions under the Group Code of Action.

Policies on the Preventing Bribery and Corruption

The Group prohibits the provision of entertainment or gifts incompatible with common sense to public officials (including foreign public officials) in pursuit of self-interest.
Specifically, the Group Code of Action provides, with regard to receipt or provision of entertainment or gifts from or to business partners, "Nomura Real Estate Group officers and employees shall not request, provide, or receive entertainment or gifts incompatible with sound business practices or common sense" and "No officer or employee shall use their professional position to request or accept benefits or favors from a business partner." The Group strictly implements the Code of Conduct, for instance, detailed reporting and documentation of the details of entertainment or goods provided or received by its officers and employees.
The Group complies with the Guidelines for the Prevention of Bribery of Foreign Public Officials established by the Ministry of Economy, Trade and Industry and formulated its own Policy on the Prevention of Bribery of Foreign Public Officials, which can be found on the Group website. In accordance with this policy, the Group formulated the Regulations on the Prevention of Bribery of Foreign Public Officials and the Anti-Bribery Guidelines and has established specific internal procedures relating to the provision of entertainment, gifts, invitations, and donations to foreign public officials and the use of agencies and so on. The Group also conducts periodic training on the prevention of bribery for officers and employees in overseas business units.

Policy on Anti-Bribery of Foreign Public Officials

Implementation of Fair Competition and Fair Trade

The Nomura Real Estate Group Code of Action sets forth rules on maintaining fair relationships with business partners. The areas covered by the rules include the implementation of fair competition and fair trade and implementation of highly transparent trade, to ensure compliance with the Anti-Monopoly Act, the Act Against Delay in Payment, etc. to Subcontractors and other laws and regulations. Moreover, in the selection of business partners we strive to comprehensively and fairly assess a wide range of factors, including quality, price, performance, and reliability.

Guidelines on Social Media

The Nomura Real Estate Group as Guidelines on the Use of Social Media state that use of social media must exhibit an awareness of the individual as position as a member of society and exemplify a high level of ethics following the norms of society at all times when posting, regardless of whether such posting is for personal or professional reasons.
As a part of our compliance training program, we implement periodic measures intended to raise awareness and provide information on areas of caution and risks relating to the posting information on social media.

Excluding Anti-Social Forces from Business Relationships

The Nomura Real Estate Group has established a provision within its Code of Action that prohibits business transactions with anti-social forces or related organizations. It is our strict policy to exclude anti-social forces from our business relationships.
In line with this policy, we issued a manual that details specific responses and have designated responsible departments and appointed personnel responsible for preventing improper requests to ensure organizational responses by Nomura Real Estate Holdings and each Group company. In addition, we consult and coordinate with legal counsel, the police, and other specialized external organizations to ensure that anti-social forces are excluded from involvement in our business activities and to prevent any harm caused by such anti-social forces.

Complying with Regulatory Requirements and Raising Awareness

The Nomura Real Estate Group has developed a compliance program every year and provides compliance training to officers and employees all year round in a planned manner in order to ensure compliance and the penetration of compliance awareness among officers and employees.


Promotion Measures


Compliance Hour:
Distributed online every other month. In fiscal 2018, the attendance rate for the entire Group was 100%.
Compliance Training:
Group training for different professional ranks. In fiscal 2018, training was conducted 65 times.