Basic Policy concerning Customer-Oriented Business Conduct

1. Development/Publication of policy

Tosei Asset Advisors, Inc. (hereinafter “Our Company”) has developed and published the “Basic Policy concerning Customer-Oriented Business Conduct”. In this policy, the Customers are defined as Tosei Reit Investment Corporation (hereinafter the "Investment Corporation"), investors of the Investment Corporation, Special Purpose Companies, etc. who have entered into entrustment contracts for asset investments, etc. in private placement fund schemes and investors of such Special Purpose Companies, etc, collectively. Our Company will review this policy and publish the status of implementation of our engagements on periodic basis.

2. Engagement for enhancing asset value

  • Our Company will aim to fulfill the best interest of the Customers through enhancing mid-to-long term asset value of assets under management.
  • Our Company will provide the Customers with the best advice that is suitable to their asset management needs and high value-added service.

 ■Action plan

  • As a team of professionals, Our Company will use our individual knowledge and experience as an asset management company,and will make the maximum use of know-how and business resource of Tosei Group regarding real estate management.
  • Our Company will develop the management policy after analyzing and understanding the feature of the assets to be invested in and the risk profile, and will aim to achieve investment performance that is well-balanced between risks and returns through implementing such management policy.
  • Our Company will make efforts to reflect valuable opinions obtained through engagements with the Customers to our management policy.

3. Firm engagement toward conflict of interest management

  • In order to ensure the effectiveness of our conflict of interest management system that puts Customers' interest first,Our Company will comply with our internal rules and procedures, etc. as well as laws and regulations, etc.
  • Our Company will develop and maintain the rigorous information management system through maintaining independence of decision making established with respect to each asset under management and setting up Chinese Wall within Our Company.

 ■Action plan

  • With respect to conflict-of-interest transactions, Our Company will perform fair and equitable procedures on deliberation through holding Risk Compliance Committee meeting and obtaining opinions from the external committee members (lawyers) who do not have any interest in Tosei Group in such meeting pursuant to our internal rules.
  • Our Company will disclose our policy dealing with conflict-of-interest transactions regarding the Investment Corporation in Securities Reports, etc.

4. Rigid enforcement of providing information in an easily understandable manner for Customers

  • When Our Company explains the contents of financial products and asset management status, etc. or prepare documents, etc., Our Company will make efforts to provide information fairly, equitably and in an easily understandable manner for the Customers.
  • When Our Company explains fees, etc., such as commission charges, etc., to the Customers, Our Company will provide the detailed contents of the intended service and explain in an easily understandable manner for the Customers.

 ■Action plan

  • In order to ensure transparency for the Customers, Our Company will put ourselves in the Customers' shoes on a continuous basis and disclose information necessary for investment decisions in a timely and appropriate manner.
  • With respect to the standard concerning the payment of fees that the Investment Corporation pays to Our Company and time of such payment, Our Company specifies them in the Certificate of Incorporation of the Investment Corporation, publish the contents thereof and disclose the amount of the fees in every period in investment management reports and Securities Reports, etc.

5. Providing financial products taken in consideration of the Customers' risk tolerance

  • Our Company will make efforts to understand sufficiently the Customers' knowledge regarding financial products, investment experience, investment purpose, needs and status of their assets, etc., and provide appropriate solicitation and advice based on the Customers' desires and current conditions.

 ■Action plan

  • Our Company will make efforts to have the Customers understand the Important Matters defined in "Act on Sales, etc. of Financial Instruments" accurately, and will sufficiently explain the contents and risks, etc. of the finanical products to be provided to the Customers in order for the Customers to make their own investment decisions appropriately.
  • Our Company will also provide the Customers who have sufficient knowledge and experience regarding transactions on real estates and financial products (i.e. professional investors) with important information relevant to their investment decisions in an easily understandable manner.

6. Establishing Customer-Oriented Corporate Culture

  • For the further implementation of our engagements that meet the needs and interests of the Customers, Our Company will make efforts to provide the officers and employees with education that enhances their awareness through training, etc., consolidate the personnel and performance evaluating system that promotes customer-oriented business conduct, and improve the appropriate compliance structure and governance structure.

 ■Action plan

  • Our Company will make efforts to foster the spritually rich and professional personnel through enhancing their knowledge of transactions on financial products in various scenes relevant to real estates.
  • When Our Company conducts personnel evaluation and performance evaluation, Our Company will conduct these evaluations in the context of their customer-oriented attitudes.