Policies for Customer-Oriented Business Conduct

The Kenedix Group is guided by a mission statement and a corporate mission). These guidelines
are consistent with the fundamental concept behind the Principles for Customer-Oriented
Business Conduct announced on March 30, 2017 by the Financial Services Agency. As a memberof the Kenedix Group, we support all of these principles based on the missions, and we haveestablished our own Policies for Customer-Oriented Business Conduct.

I. The Kenedix Group Missions(1) Mission Statement
Kenedix is dedicated to realizing the full potential of real estate
Looking beyond short-term profits alone, the Kenedix Group has a resolute commitment to asset
management that “realizes the full potential of real estate.” This is accomplished by carefully
assessing real estate locations and property characteristics, and then using the best possiblecombination of asset management strategies, timing, and financing schemes to meet the needsof investors.
The mission statement “Kenedix is dedicated to realizing the full potential of real estate” clearly
expresses our determination to continue creating value from real estate. By pursuing this mission,
we intend to remain at the forefront of the real estate fund market.

(2) Corporate Mission-Business Objective “For What?”
We contribute to society by making the best use of investment capital and creating value
from real estate.
-Business Field “For Whom?”
We offer the best investment opportunities to our clients by committing to multiple roles
globally as a real estate asset manager.

-Business Principle “How?”
We confront new business challenges through our management speed and flexibility,
while emphasizing stability and fairness.

II. Policies for Customer-Oriented Business Conduct(1) Pursuit of the customers’ best interest 【Principle 2】
Based on our strong dedication to asset management that “realizes the full potential of realestate,” we act sincerely and fairly, adhering to high standards of business ethics and a consistentcommitment to providing high-grade investment opportunities to client investors. Through theseactions, we aim to foster a corporate culture defined by transparency, expertise, innovation, andflexibility and creativity.

(2) Appropriate management of conflicts of interest 【Principle 3】
Based on a dedication to sound and fair business practices, we accurately identify transactions
between client investors and our related parties, and always do our utmost to conduct
appropriate management in accordance with our Related-party Transaction Rules so as not toharm the interests of client investors. The objective is to ensure that business activities are done
properly and transactions are performed fairly.
< Specific explanation > - For customers of private funds When a customer intends to conduct a related-party transaction, such as the acquisitionor sale of assets under management, with our related parties, etc. based on ourinvestment decision or investment advice, each Fund Management Department examines
the content of the transaction and the Compliance Officer further reviews it. TheCompliance Officer examines the applicability of the related-party transaction and theappropriateness of the actions, etc. taken by each Fund Management Department, and if
the Compliance Officer determines that such actions are insufficient, the Compliance
Officer requests each Fund Management Department to take necessary actions. The
Compliance Committee deliberates on the related-party transactions. 【Principle 3 (Note)】(3) Provisionofimportantinformation,including

feesandotherexpenses,

inaneasy-to-understand manner 【Principle 4, Principle 5】
Based on a dedication to providing information with a high degree of transparency, we are careful
to provide important information about investment products and services, including associatedfees and other expenses to be borne by client investors, in an easy-to-understand manner.
< Specific explanation > - For customers of private funds ①

The private funds that we are involved in establishing basically target client investors
who fall under the category of Professional Investors (including customers who are to
be treated as Professional Investors in accordance with Article 34-3, Paragraph 4 of
the Financial Instruments and Exchange Act), and we explain to that effect in advanceand provide information to sales companies to that effect. When a customer who does
not fall under the category of Professional Investors wishes to invest, we strive toprovide investment products and services after thoroughly consulting with the sales
company and provide sufficient information to the customer. 【Principle 5 (Note 1)】②We strive to prepare and provide materials that are easy to understand with respect toimportant information concerning investment products and services (i.e., assumed
returns, risk of loss, etc., reason for selection, transaction terms, commission, outlinesof related-party transactions, etc.) according to the experience, financial knowledge ofeach client investor and the importance of information, and to prepare and provide
materials that meet client investors’ requests. 【Principle 5 (Note 1) (Note 3) (Note 5)】③

We basically do not expect to sell multiple investment products (or services) as a
package to client investors, except in cases where the seller requests the bulk
purchase of multiple properties (including trust beneficiary rights) (however, weprovide a series of asset management operations to the extent necessary for theestablishment of private real estate funds and real estate management.). When
packaging is required, we strive to explain the reason and content to client investors inan easy-to-understand manner. 【Principle 5 (Note 2)】④

The assets that we handle are mainly real estate or assets backed by real estate, andwe basically do not expect to offer investment products using complex structures.
However, since real estate is highly individualized and not necessarily easily
comparable to other real estate investment projects, and risks and returns are not thesame, we are dedicated to providing easy-to-understand information according to thedegree of complexity of each investment project. 【Principle 5 (Note 4)】

(4) Provision of services that match customers’ needs 【Principle 6】
We are dedicated to providing investment products and services that match the goals,requirements, financial position, experience, knowledge, and other characteristics of each client
investor.
< Specific explanation > - For customers of private funds ①

With respect to private funds that we are involved in establishing, we strive tounderstand the client investors’ needs such as investment goals, periods, and target
returns, through dialogue with them, etc., and to propose investment products orservices that match such needs. In addition, not only at the time of sales ofinvestment products and services, but also during the subsequent investment period,
we strive to communicate with client investors in a timely manner and reflect any
changes in their needs in fund management to the greatest extent possible.
【Principle 6 (Note 1)】②

The real estate or assets backed by real estate that we mainly handle are highly
individualistic and not necessarily easy to compare. However, we strive to propose
better investment products or services, sufficiently considering the results ofinvestment products or services provided in the past. 【Principle 6 (Note 1)】③

We basically do not expect to sell multiple investment products (or services) as a
package, except in cases where the seller requests the bulk purchase of multiple
properties (including trust beneficiary rights) (however, we provide a series of asset
management operations to the extent necessary for the establishment of private realestate funds and real estate management.). When packaging is required, we strive togive consideration to whether the entire package is appropriate for the client.
【Principle 6 (Note 2)】④

The private funds that we are involved in establishing basically target client investors
who fall under the category of Professional Investors (including customers who are tobe treated as Professional Investors in accordance with Article 34-3, Paragraph 4 of
the Financial Instruments and Exchange Act), and we explain to sales companies tothat effect in advance. Due to the nature of private funds that are not expected to be
sold to an unspecified number of customers, we do not plan to disclose the above
customer attributes. 【Principle 6 (Note 3)】

⑤The assets that we handle are mainly real estate or assets backed by real estate, andwe basically do not expect to offer investment products using complex structures.
However, since real estate is highly individualized and risks and returns are not thesame, we are dedicated to providing easy-to-understand information according to
the degree of complexity of each investment project, and providing investment
products or services that match the client investors’ goals and requirements as muchas possible. We basically target client investors who fall under the category ofProfessional Investors, and do not expect to sell or recommend products to any
customer groups with attributes that make them vulnerable to financial transaction
damage. 【Principle 6 (Note 4)】⑥We strive to prepare and provide materials that are easy to understand with respect
to the information necessary for understanding the investment products and services
that we intend to provide according to the experience and knowledge of client
investors, and to prepare and provide materials in response to meet client investors’requests. We also encourage and strive to further develop the professional
knowledge of our employees regarding investment products and services throughinternal and external training programs. 【Principle 6 (Note 5)】(5) Framework for adequately motivating employees 【Principle 7】
We aim to increase clients’ interest and our corporate value by constantly providing outstanding
services to client investors. One step in increasing the motivation of our employees to achieve theaim is to include not only performance but also compliance perspectives in the standard
performance parameters used for their evaluations. Furthermore, we work to disseminate theKenedix Group missions to our employees at the Kenedix Group through our daily operations,training programs, and other activities.
*The principles and (Notes) in 【 】 above indicate the correspondence with the "Principles for
Customer-Oriented Business Conduct" and its notes published by the Financial Services Agency.

Kenedix Investment Partners, Inc.