Privacy Policy

Recognizing that the protection and proper management of personal information is a social responsibility,
Kenedix Investment Partners, Inc. (hereinafter referred to as “KIP”) hereby establish and implement thefollowing privacy policy (hereinafter referred to as the “Policy”) and will strive to maintain and improve it.

1. Basic Policy

Recognizing the importance of personal information, KIP respects and complies with the Act on theProtection of Personal Information (hereinafter referred to as the “APPI”) and the Act on the Use ofNumbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as the “MyNumber Act”), relevant laws, related guidelines, including the guidelines for the APPI, and the social order,and strive to achieve proper handling and protection of personal information. In addition, we strive toimprove our personal information protection system continuously, by reviewing it from time to time.

2. Collection and Use of Personal Information

KIP collects personal information by appropriate means, publicizes or provides notice of the purpose(s) ofuse (including publication in the Policy), and does not handle personal information beyond the scope of thepurpose of use without the consent of data subjects.

3. Purpose of Using Personal Information

KIP uses the personal information we collect (excluding personal information that is an Individual Number orincludes an Individual Number in its contents [hereinafter, collectively referred to as “Specific PersonalInformation”]; hereinafter the same shall apply in this article) for the following purposes.

3-1

Personal information concerning customers and others (in the case of a corporation, its officers
and employees)(1) Performance of contracts, and provision of information and services in connection withacquisition, management, and disposal of real estate and others (including trust beneficiaryrights; the same shall apply hereinafter)(2) Performance of contracts, and provision of information and services in connection withtransactions relating to sales, brokerage, leasing, and management of real estate(3) Performance of contracts, and provision of information and services in connection withtransactions relating to sales, brokerage, and management of credit(4) Performance of contracts, and provision of information and services in connection with

advisory services relating to real estate and credit(5) Performance of contracts, and provision of information and services in connection with due
diligence services (e.g., valuation services concerning the value of real estate and credit)(6) Managing KIP’s business partners(7) In addition to the foregoing, uses that accompany the execution of services related orincidental to the business of KIP
3-2

Personal information concerning stockholders (in the case of a corporation, its officers andemployees)(1) Shareholder management for KIP, including the preparation of records in accordance withvarious laws and regulations(2) Exercise of rights and performance of obligations under the Companies Act

3-3

Personal Information concerning applicants for recruitment and recruitment activities(1) Recruitment and selection of officers, employees, contract employees, and others(hereinafter referred to as “officers and employees”) of KIP(2) Communications and provision of information to achieve the purposes above, and other uses
necessary for recruitment and recruitment activities

3-4

Personal Information concerning officers and employees(1) Management of officers and employees of KIP(2) Business communications with officers and employees(3) Payment of remuneration (wages, bonuses, allowances, etc.), performance of personnel andlabor management, and provision of benefits to officers and employees(4) Health management for officers and employees

3-5Other
Provision of personal information to a third party to the extent necessary for the achievement ofthe purposes of use set forth in 3-1 through 3-4 above

4. Purpose of Using Specific Personal Information

When collecting Specific Personal Information, KIP publicizes or provides notice of the purpose of use(including publication in the Policy), and does not use Specific Personal Information other than as permitted
by the My Number Act.

4-1

The purposes for which KIP uses Specific Personal Information are as follows.

Processes related to an Individual Number (including processes related to the following) relating to
officers and employees (including their dependents)(1)

Work related to tax withholding, work to prepare salary payment reports, and work to
prepare notifications of transfers of salary income earners relating to special collection of asalary payment report, and similar matters

Application forms for (changes in) exemptions for dependents, work to prepare application(2)forms for exemptions from insurance premiums and for special exemptions for spouses ofsalary income earners, work to prepare application forms for switching to special collection,and similar matters
Work to prepare payment records for each recipient of a retirement allowance, or related(3)

matters, and work to prepare applications related to retirement income, and related matters
Work to file health insurance, employees’ pensions, and corporate pensions, work to apply for(4)and make claims under health insurance, employees’ pensions, corporate pensions, work to
file national pension No. 3, and similar matters
Work to file a notification of employment insurance, and work to apply for and claim(5)

employment insurance, and related matters
Work to prepare and provide statutory documents related to financial instruments(6)transactions relating to stock option plans, and related matters
4-2

Processes related to an Individual Number (including process related to the following) relating toindividuals other than officers and employees(1)Work to prepare records of payment of remuneration, fees, and the like

(2)

Work to prepare records of payment of dividends, distributions of surplus, and fund interest(3)Work to prepare records of payment of royalties and similar payments for real estate and thelike
Work to prepare records of payment of consideration for the purchase of real estate, and the(4)like

5. Provision of Personal Data to Third Parties

KIP does not provide personal data (excluding Specific Personal Information) collected by KIP to any third
party without obtaining the prior consent of data subjects, except as permitted by the provisions of thisPolicy and laws and regulations.

In addition, KIP does not provide Specific Personal Information, except aspermitted by laws and regulations.

6. Joint Use of Personal Data

KIP jointly uses personal data (excluding Specific Personal Information; hereinafter the same shall apply inthis article) as follows.

(1)

Items of personal data to be used jointly

Items of personal information about data subjects and their families, such as names andaddresses, collected when recruiting officers and employees of Our Group（The corporate

group to which the KIP belongs. The same shall apply hereinafter.）(2)

Scope of joint users

(3)

Each company within Our Group

Purpose of usersPersonal Data is used jointly within the scope of the purpose of uses described in “3-3Personal Information concerning applicants for recruitment and recruitment activities”
and “3-4 Personal Information concerning officers and employees” above.

(4)

Person responsible for management


The following company is responsible for the personal data that is jointly used.
[Person responsible for management] Kenedix, Inc.
2-1-6, Uchisaiwaicho, Chiyoda-ku, Tokyo, 100-0011
Taisuke Miyajima, President & CEO

7. Security Control Measures of Personal DataKIP shall take necessary and appropriate security control measures to manage the personal data held by KIP
properly and carefully in accordance with KIP’s internal rules and to prevent unauthorized access, loss,falsification, leakage, etc., of personal data.

8. Outsourcing of Handling of Personal Data

We may outsource the handling of personal data held by KIP.

In such cases, we will select a person who hastaken sufficient measures to protect personal information, and will supervise the outsourced company asnecessary and appropriate.

9. Procedures for Disclosure, Correction, etc., of Retained Personal Data

We will respond to data subjects’ requests for disclosure, correction, or suspension of use of retained
personal data and other information held by KIP without delay in accordance with procedures separately
established by KIP.

10. Contact Desk for Inquiries about Personal Information

Please contact the following address if you have any requests regarding the disclosure, correction,suspension of use, etc., of retained personal data, as well as any opinions or questions regarding thehandling of personal information by KIP, including this Policy and security control measures relating topersonal data.

Contact Desk: Compliance Department, Kenedix Investment Partners, Inc.
Address: 2-1-6, Uchisaiwaicho, Chiyoda-ku, Tokyo, 100-0011
Tel: 03-5157-6085 (Hours on weekdays: 10:00-17:00)

KIP is a member of the Japan Investment Advisers Association, which is an authorized personal information
protection organization. The Association receives complaints and provides consultations concerning thehandling of personal information by its members.

Contact Desk: Complaint and Consultation Office of The Japan Investment
Advisers Association (responsible for personal information)
Address: Tokyo Shoken Kaikan 7th Floor, 1-5-8, Nihombashi-Kayabacho, Chuo-Ku, Tokyo, 103-0025
Tel: 03-3663-0505 (9:00-17:00), Monday through Friday (excluding national holidays)

11. Revision of the Policy

The Policy will be reviewed and revised from time to time in order to meet the requirements of laws andregulations and further improve the protection of personal information.