Sustainable Procurement Policy

1.

Introduction

With a mission of “Always create new values, for people, the community and the world,” KJR Management aims to create
new demands in our society and new values that exceed people’s expectations through real estate investment management.
Based on this mission we have established the Sustainable Procurement Policy (hereinafter, the “Policy”) to contribute to
the realization of a sustainable society. We recognize that, in order to contribute to the realization of a sustainable society,not only is it important for us to implement our own procurement activities based on the Policy, but it is also important tomake efforts along our entire supply chain, which includes our business partners.

2.

Scope of Application

The Policy applies to the suppliers of all products, materials, raw materials, and services that we procure. It applies to ourentire supply chain, including indirect suppliers (such as businesses commissioned or contracted by, or that supply to, ourdirect suppliers).

3.

Procurement Policy

3.1 Compliance with Laws and Regulations, etc.
In addition to complying with applicable domestic and foreign laws and regulations, etc., we respect international codesof conduct 1 and conduct business activities in accordance with appropriate business practices and corporate ethics.

3.2 Respect for Human Rights
We conduct business activities in compliance with international human rights and labor standards 2 and with respect forhuman rights. We also ensure that our business activities do not cause or contribute to human rights violations.

3.3 Establishment of Corporate Ethics(1)

Preventing corruption
We do not engage in any form of bribery, corruption, extortion, embezzlement, or obstruction of justice, etc., nor
are we complicit in such activities.

(2)

Exclusion of antisocial forces
We exclude all relationships with antisocial forces and organizations that threaten the order and safety of civil society.
We firmly refuse any and all improper demands.

(3)

1

Promotion of fair business activities“International codes of conduct” refers to expectations for the behavior of organizations based on principles anddeclarations established by international organizations, such as the United Nations, as well as on intergovernmentalagreements (including treaties and conventions). Relevant examples include the following international human rights
and labor standards and the Sustainable Development Goals (SDGs).
2“International human rights and labor standards” refers to the International Bill of Human Rights (the Universal
Declaration of Human Rights and the International Covenant on Civil and Political Rights), the ILO Declaration on
Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, and the OECD
Guidelines for Multinational Enterprises, etc.

We comply with the Antimonopoly Act, the Unfair Competition Prevention Act, and other relevant laws andregulations, and we promote fair business activities without engaging in any acts that impede free and faircompetition or acts of unfair competition. We also respect intellectual property rights, and the transfer of technology
and know-how is done in a way that protects intellectual property.
(4)

Appropriate disclosure of information
We appropriately disclose in accordance with not only applicable laws and regulations but also social norms andguidelines of industry associations, etc. Falsification of records or disclosure of false information is not tolerated.

3.4 Consideration for the Environment(1)

Addressing climate change
We contribute to the realization of net zero carbon emissions by striving to improve energy efficiency and use
renewable energy, and by engaging in activities to continuously reduce energy consumption and greenhouse gasemissions.

(2)

Conservation of biodiversity
We work to reduce our impact on the surrounding environment, biodiversity, and ecosystems. When procuring raw
materials, we give consideration to the conservation of biodiversity and the sustainable use of resources.

(3)

Prevention of pollution and management of chemical substances
We comply with relevant laws and regulations and implement measures to reduce and prevent the release ofhazardous substances into the air, water, soil, etc.

(4)Effective use of resources, and waste management and reduction
We make effective use of resources and minimize the generation of waste. We also strive to use water and othernatural resources efficiently and to optimize and reduce the amounts we use.

3.5 Improvement of Service and Quality(1)

Ensuring safety
We consider the safety, security, and health of the users of our services, etc. in all aspects of our business activities.

(2)

Quality control, quality assurance, and disclosure of information
In addition to establishing appropriate quality control and quality assurance systems for the services we provide inaccordance with relevant laws and regulations, quality standards, and social demands, we constantly strive toimprove quality. We also provide information on our services that is accurate and not misleading.

(3)

Ensuring convenience and comfort
We consider and examine the convenience and comfort of the users of the products and services we provide, throughsuch means as inclusive design and universal design.

3.6 Information Security(1)

Appropriate management of information
We appropriately manage and protect not only our own confidential information but also the confidential
information received from customers and third parties.

(2)

Protection of personal information
We comply with relevant laws and regulations and appropriately manage and protect the personal information of all
suppliers, customers, employees, and others.

3.7 Establishment of Complaints Handling Mechanisms(1)

Establishment of complaints handling mechanisms

We have complaints handling mechanisms in place for investigating and responding to problems and to enableofficers and employees to make reports. We also protect the confidentiality of information and the anonymity ofinformants, and eliminate any retaliation against informants. We strive to disseminate these mechanisms to ourofficers and employees.
(2)

Dissemination of the KJR Management Compliance Reporting Desk
We strive to inform enterprises involved in our business of the Compliance Reporting Desk for Business Partners
that we have set up.

3.8 Crisis Management
In order to minimize any damage to officers, employees, customers, and other stakeholders, or to assets, due to natural
disasters, accidents and other emergencies, we prepare action procedures for emergency response plans and business
continuity plans, install necessary equipment, etc., and conduct education and training.

4.

Remedial Measures

We have established a Compliance Reporting Desk for Business Partners to receive consultations and reports on violationsof laws and regulations, information management violations, various types of harassment, human rights, and the working
environment in regard to our business operations. If we receive a report or consultation, we take appropriate corrective
and remedial measures, and respond with due consideration to the protection of informants.
Compliance Reporting Desk for Business Partners https://www.kjrm.co.jp/english/contact/index.html

KJR Management
Enacted on November 22, 2023.