CBRE K.K. ("we," "us," or "our") hereby announces this Basic Policy on Dealing with Anti-Social Elements, in order to win the trust of the business community and to ensure propriety and transparency of our business operations. We will, in a close cooperation with appropriate external experts, organizationally implement the following in order to eliminate anti-social elements from every aspect of our business dealings:
1) Unified Response
In dealing with anti-social elements, we have specific provisions on the subject in our compliance and other internal rules as a basis of our policy in this area. We will present a united front against anti-social elements with involvement of everyone, including and starting with the members of our management, and commit to safeguard the well being of our employees.
2) Coordination with External Experts
In preparation for any unforeseen encounter with anti-social elements, we will enhance our readiness in dealing with them by maintaining a close, functioning relationship with appropriate external experts.
3) Elimination and Termination of Relationships
We will not have or allow to be established any business or other relationship with any of the anti-social elements.
4) Civil and Criminal Response in Appropriate Cases
We will refuse to accept any unlawful demands from anti-social elements, and when appropriate, deal with them in a judicial forum, both civil and criminal.
5) Prohibition of Unrecorded Deals and Provision of Financial Benefits
Even where unlawful demands by anti-social elements are triggered by malfeasance in our business or by our employees, we shall never compromise on our policy of transparency or engage in “side deals” with those who make such demands. We will never provide benefits, financially or otherwise, to anti-social elements.