Basic policy on customer-oriented business operations

1. Establishment and publication of policy

The Company, will establish and announce our “Basic Policy on Customer-Oriented Business Operations”. This policy will be reviewed regularly and the status of efforts related to the policy will be announced.

2. Efforts to improve asset value

The Company aims to realize the best interests of our customers by improving the medium- to long-term asset value of our assets under management through accurate judgments, professional advice, and high-value-added services that we could provide to suit our customers’ investment criteria.

Action plan

As a professional group, we will make the best use of our exclusive real estate management experience and management resources.
We will aim for a balanced risk and return based on our customers management criteria by implementing an investment policy based on the assets characteristics and risk analysis on investment.
We will endeavor to reflect the valuable opinions obtained from discussions with customers in our operational policy.

3. Efforts to manage conflicts of interest

The Company will establish strict internal rules and practice compliance with internal rules and procedures as well as laws and regulations, in order to ensure the effectiveness of the conflicts of interest management system that prioritizes the interests of our customers.
We maintain an independence determined for each business content in decision-making, and have an internal wall established between departments to enable and maintain a strict information management system.

Action plan

Regarding transactions related to conflicts of interest, the Compliance Committee will be held based on internal rules, and after fair and impartial debate, decisions will be made subject to the approval of external members (lawyers) who have no interest in the Company or the Group, that can then be approved by the Investment Committee.

4. Enforcing to provide easy-to-understand information

The Company will aim to disclose information in a fair, impartial and easy-to-understand manner to our customers when creating and explaining materials related to product content and status of operations.

Action plan

We will always disclose the information necessary for investment decisions in a timely and appropriate manner as in the customer’s point of view.
When explaining fees and other commissions to customers, we will provide detailed information and easy-to-understand verbal explanations.

5. Providing products according to customer criteria and risk tolerance

The Company, fully understands the customer’s knowledge of financial products, investment experience, the status of owned assets, investment purpose, etc., and will strive for the appropriate solicitation and to provide advice that is in alignment with the customer’s intentions and circumstances.

Action plan

We will aim to understand customers criteria and risk tolerance, and provide sufficient explanations on the content and risks involved with the products we offer so that they can make appropriate investment decisions.
This is also to be said with customers (specified investors) who have abundant knowledge and transaction experience regarding real estate and financial products, that we will provide sufficient explanations on the content and risks involved with the products we offer in order to make appropriate investment decisions.

6. Establishing a corporate culture with customer-oriented business operations

The Company, in order to establish a corporate culture based on customer-oriented business operations, we provide education training courses and guidance in daily work to raise the awareness to officers and employees, and maintain to improve an appropriate compliance and governance system.

Action plan

We will create a compliance program each business year, and implement planned measures to establish the above corporate culture.
We will prepare a compliance manual and regularly conduct compliance trainings using the manual as teaching material in order to improve knowledge and understanding of related laws and regulations, to maintain and further establish the above corporate culture.

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