Status of Commitment to Basic Policies

1. Establishment, Announcement, etc of Basic Policy for Customer-Oriented Business Conduct We hereby establish and announce the policies for realization of the “Customer-Oriented Business Conduct”. We will regularly review these policies for the purpose of better business operation and publish the result of such review on our website, together with the status of commitment to that purpose. The status of the commitment in the business year ending in March 2023 is as follows:
2. Pursuit of Customers’ Best Interest

We have internally assigned officers and employees with high level of expertise under the concept that it is important for officers and employees to keep high level of professional ethics and engage in business conduct with high professionalism. From this point of view, we have recommended our officers and employees to acquire relevant qualifications and have introduced the system for our partially bearing the expenses for those activities. Especially, with respect to the ARES (Association for Real Estate Securitization) Certified Master, we encourage all our officers and employees other than the office workers to acquire the qualification.

<Recommended qualifications and number of their holders>
ARES (Association for Real Estate Securitization) Certified Master: 32
Real Estate Transaction Agent: 37
Licensed Real Estate Appraiser (including its Assistant): 6
Class-1 Architect: 5
Certified Building Administrator: 2
Certified Member Analyst of the Securities Analysts Association of Japan: 2
Certified Internal Auditor: 1

We consider it necessary to continue the provision of sustainable services relied on by the customers and placing emphasis on the customer satisfaction, in order to establish a stable customer base and ensure profitability. As part of such practice, we have endeavored to include the factors of ESG (Environment, Social and Governance) in our process of investment analysis and decision-making and signed the PRI (Principles for Responsible Investment) in April, 2022.

3. Appropriate Management of Conflicts of Interest

With respect to any transactions with an interested party subject to deliberation by the Compliance Committee, we obtain said committee’s approval thereof through the process that the prior explanation thereof enabling the outside committee members to perform in-depth verification is given and that the unanimous approval by all committee members including the outside members is required.

<Status of holding meetings of the Compliance Committee for deliberation>
Number of meetings of the Compliance Committee held with respect to transactions with an interested party: 5

4. Clarification of Fees, etc. In our business model, our remuneration is determined on an individual basis through the consultation with a customer. Accordingly, with respect to commissions and expenses borne by customers, we have stipulated the requirements of “Giving customers sufficient explanation”, “Setting commissions, etc. taking account of customers’ requests” and “Sufficiently consulting with customers” in the relevant business manual and, when presenting proposals to or entering into agreements with customers, we keep it in mind to specify the rates and amounts in the written proposals and agreements concerned and to give careful explanation.
With respect to the policies concerning solicitations, etc. to customers such as submission of proposals and explanations, please refer to “
5. Provision of Important Information in an Easy-to-Understand Manner

Before transactions with customers, we prepare materials concerning important information using appropriate charts, expressions, etc. in consideration of the knowledge, investment experience, etc. of customers concerned, give easy-to-understand explanation and endeavor to obtain their adequate understanding of such transactions.
During the transactions in progress, we will notify customers of the status of the transactions, incidents and other material information as appropriate in a manner easy-to-understand and satisfying customers’ need.
With respect to the policies concerning solicitations, etc. to customers such as submission of proposals and explanations, please refer to “

6. Provision of Services Suitable to Customers

With respect to provision of services to customers, we will confirm customers’ experience in investment, investment purposes, needs, etc. and grasp their attributes such as classification of general investor or professional investor, and based on such knowledge, endeavor to provide products and services suitable to customers.
With respect to the policies concerning solicitations, etc. to customers such as submission of proposals and explanations, please refer to “

7. Framework for Motivation of Executives and Employees, etc.

We have implemented the initial training covering persons having just been appointed as a director or having just become an employee of our company, and year-around, the training for the purpose of cultivating the compliance sprit or promoting the sustainability-oriented management, the familiarization training at an occasion of amendment of a law or in-house bylaw, etc. in order to instill awareness of the importance of pursuing the best benefit of customers. In addition, we have recommended our officers and employees to attend outside seminars and introduced the system that we partially bear the expenses thereof.
Furthermore, we consider the thorough compliance, internal control and fiduciary duties as our corporate missions, under which each officer and employee has included the factors of thorough compliance, internal control and fiduciary duties in the objectives of personnel evaluation, and the personnel evaluation of achievements and promotion will be conducted incorporating such factors.

<Status of implementation of in-house training>
Number of implementations: 14