Compliance Promotion Initiatives

①Promoting Reform in Compliance Awareness That Reflects Voices of Each Employee

Leopalace21 Group is working to improve the awareness and knowledge acquisition of each officer and employee in order to promote compliance. In addition to understanding the basic concept of compliance, we conduct group training and E-learning on themes that meet the needs of the times, such as harassment prevention and handling of personal information. In addition, we regularly and continuously strive to further improve our compliance and ethics by disseminating information as appropriate in line with revisions to various laws.

■"Change Day 5.29"

Leopalace21 established May 29 every year as "Change Day 5.29"

In order to regain the social trust, we established May 29 every year as "Change Day 5.29" to remind ourselves that each of the officers and employees in Leopalace21 Group should play an integral role in the restoration challenge, and to pledge to make continued emphasis on preventing the recurrence of construction defects.

On May 29, 2018 we released the "Notice Concerning Construction Deficiencies of Apartment Parting Walls (six series)" and made a sincere response by disclosing the other construction defects which we subsequently discovered during the course of all-building investigations. On May 29, 2019 we announced the "Notice Concerning Causes and Measures to Prevent Recurrence of Construction Defects" based on the final report and recommendations by the External Investigation Committee.

The purpose of establishing the "Change Day 5.29" is to have time to look back and remember the regrettable series of the problems so that the memories never fade away with the times. We will continue to conduct employee training and implement a variety of measures under the leadership of the Compliance Promotion Headquarters. We will also announce the state of these initiatives as needed.

Bunya Miyao, President and CEO
Established on May 29, 2020

■Change in Mindset Toward Recurrence Prevention

About Self-Ownership Mindset and Blame-Shifting Mindset

Following the construction defects problem that occurred in 2019, discussions among participants and the results of post-training surveys from the Recurrence Prevention Training conducted for all executives and employees revealed that a mindset of shifting responsibility outward and relying on others was widespread within the organization.

We believe that preventing recurrence requires not only reforming the corporate culture but an attitude in which each executive and employee proactively considers and reflects on their own actions and judgments. Therefore, we defined the concepts of Self-Ownership Mindset and Blame-Shifting Mindset as guidelines for this change in mindset.

Self-Ownership Mindset: A mindset that urges employees to consider their own responsibility

It refers to a way of thinking in which one takes responsibility for one's own actions and choices, views matters as personally relevant, and approaches them proactively.

Blame-Shifting Mindset: A mindset that treats matters as someone else's responsibility

This refers to a way of thinking in which one does not take matters personally, but instead attributes responsibility or blame to external factors such as other departments, superiors,business conditions, or the whole organization.

Through our Recurrence Prevention Survey, we continuously monitor trends in Self-Ownership Mindset and Blame-Shifting Mindset.

  • Q: Which do you think you tend to get into: Self-Ownership Mindset or Blame-Shifting Mindset?

    Survey Results

Survey Results

Over the five-year period from 2020 to 2025, the percentage of employees who demonstrated the Self-Ownership Mindset increased by approximately 16 percentage points. As of 2025, the combined percentage of those who have the Self-Ownership Mindset and those who are inclined to get into Self-Ownership Mindset reached 92.6%, indicating that more than 90% of employees take responsibility for their actions and approach their work proactively.

As the proportion of employees joining the company since the construction defects problem has been rising year by year, we will continue to provide opportunities to deepen understanding of the Self-Ownership Mindset and implement measures aimed at raising the mindset awareness, with the goal of realizing an organization trusted by the customers and society.

■Compliance Awareness and Fact-Finding Survey of the Workplace Environment

Compliance Awareness Survey

  • コンプライアンス意識調査
  • We are working on a drastic reform of our corporate culture as a measure to prevent a recurrence of the construction defects problem. The President and CEO gave a message to all employees stating that compliance first is the management policy in July 2019. Under this circumstance, 83% of executives and employees answered that they were aware of compliance in the 2019 survey, whereas the percentage increased to 98% in the 2022 survey. We were able to confirm that there are many officers and employees who are conscious of compliance in their work and are taking some measures.

Workplace Harassment Survey

  • Workplace Harassment Survey
  • As a result of our continued training and awareness-raising initiatives aimed at enhancing awareness among officers and employees and improving the workplace environment, the percentage of respondents who answered that they had experienced power harassment in our "Workplace Harassment Survey," conducted to assess actual workplace conditions, decreased by 4.4 points from 5.9% in March 2022 to 1.5% in March 2026. Similarly, the percentage of respondents who reported having experienced sexual harassment decreased by 11.6 points, from 14.5% to 2.9%.
    However, a certain number of respondents still report having experienced power harassment and sexual harassment, indicating the need for further strengthened efforts.
    We will continue to position the elimination of harassment as one of our key management priorities and strive to create a workplace environment where all officers and employees can work with peace of mind by promoting effective measures.

②Promotion of Self-propelled Compliance in Each Department and Affiliated Companies

Each department appoints a compliance officer and person in charge as a system to actively implement measures related to compliance at the business execution site, and each person carries out their duties.

Response to Compliance Violations

In the event of a compliance violation, the compliance manager and compliance person in charge will take the lead and promptly take the necessary measures to address the incident.

【Specific measures】

  • Collecting and creating materials that serve as evidence
  • Confirmation with customers, etc.
  • Fact-checking of employees who committed violations
  • Confirmation and reporting to the government, etc.

In addition, the response status is added to the "Report on Compliance Violation Occurrence" as needed, and the response status is reported to the Compliance Promotion Department as a follow-up report.

Flow of Response at The Time of Occurrence

The person in charge of compliance shall familiarize officers and employees in their department with respect to the rules on a daily basis so that compliance violations and the risk of compliance violations do not occur within their departments. In case the unlikely event that an officer or employee within their department discovers a compliance violation or the possibility of such violation, we have established an environment in which they can immediately report it to the person in charge of compliance.
We ensure that officers and employees in their departments are thoroughly informed of the following so that they can report to the compliance manager if something happens in their department.

  • Do not hesitate to report or consult with the person in charge of compliance in the event of a compliance violation or the possibility of such violation.
  • Do not treat unfavorably on the grounds of having made a report or consultation.

③Compliance Consulting Service

Compliance hotline

To handle cases where legal violations or similar acts by officers and employees are discovered, the Group has established compliance hotline services to deal with the associated consultation and reporting in-house (the Compliance Promotion Headquarters), outside of the company (a law firm), and for Audit & Supervisory Board members (the Audit &Supervisory Board).
The Compliance Hotline protects whistleblowers in accordance with the whistleblower protection and our internal whistleblower regulations, and also takes appropriate measures based on the results of investigations to improve problems. In addition, the "business partner hotline" is a contact point for consultation and reporting in the event that officers and employees of business partners who have ongoing business transactions with our company discover legal violations or misconduct at our company.

Whistleblowing Contact

Business Partners Hotline

State of the whistleblowing cases in Leopalace21 Group
Hotline for Business Partners (Japanese only)

④Anti-Bribery Policy

The Leopalace21 Group strives to meet the expectations of customers and all other stakeholders and works with them as a corporate citizen to help create a more sustainable society. To maintain and enhance the social trust, the Leopalace21 Group has adopted this policy and will take steps to counter bribery in the countries and regions where the Leopalace21 Group engages in business activities.

⑤Response to Anti-social Forces

The Leopalace21 Group clearly states in our Corporate Ethics Charter that we shall "resolutely oppose all antisocial forces." We have no relations with anti-social forces or organizations that threaten the social order and safety and stand firmly against them.
The Group has established detailed rules for the exclusion of anti-social forces, and has appointed a person in charge of preventing unreasonable demands at each office to build a system that does not yield to unreasonable demands from antisocial forces.
In addition, with the Human Resources and General Affairs Department and the Risk Management and Compliance Department as the departments in charge of handling incidents, we have established a system to discuss and respond to related departments, including the Compliance Committee and Risk Management Committee, as well as external specialized organizations, depending on the case.

⑥Guidelines on Customer Abuse of Employees

We adopted the Guidelines on Customer Abuse of Employees in order to realize our goal of Customer First and to continue to provide services that satisfy our customers.
We will take action in accordance with the guidelines when any customer speech or behavior is found to have a significant negative impact on the way we treat other customers or on the way our employees perform their duties.

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