Status of Efforts toward Policies for Customer-Oriented Business Conduct(FY2023)

The status of efforts made in FY2023 toward the Policies for Customer-Oriented BusinessConduct, which were established in December 2018, is as provided below.

(1) Pursuit of the customers’ best interest 【Principle 2】
We believe that efforts to maintain and enhance professional expertise and high standards ofbusiness ethics of executives and employees are important to provide high-grade investment
opportunities to client investors. Based on this, we have facilitated initiatives and such like,including promoting the acquisition of various professional qualifications (see below for the status
of holding of qualifications by executives and employees), implementing periodic internal training(including compliance and business training; see below for the implementation status), andrequiring executives and employees to attend external training according to their position.
Status of holding of professional qualifications(As of December 1 of each year. Excl. part-time executives)

Name of qualification

FY2023

FY2022（For reference）

Number of executives andNumber of executives andemployees: 65employees: 59

Number ofPercentage

holders
Association for Real Estate Securitization

NumberPercentage

of holders
2945%

2542%

Real Estate Transaction Agent

4772%

4271%

Certified Building Administrator

812%

915%

Real Estate Consulting Master

23%

35%

Real estate appraiser

00%

12%

First Class Architect

23%

23%

Certificate-holder Member of the

00%

12%

Lawyer23%

23%

Judicial scrivener

12%

12%

Certified public accountant

23%

23%

Tax accountant

12%

12%

Chief of Money Lending Operations

23%

23%

(ARES) Certified MasterSecurities Analysts Association of Japan

Implementation status of internal training
FY2023: 6 times

FY2022（For reference） : 4 times(2) Appropriate management of conflicts of interest 【Principle 3】
We strive to appropriately identify transactions between client investors and our related parties.
And when transactions are conducted with our related parties, we take action in accordance withour Related-party Transaction Rules, including deliberations at the Compliance Committee, which
consists of external experts, and disclosure to client investors.
< Specific explanation > - For customers of private funds When a customer intends to conduct a related-party transaction, such as the acquisition orsale of assets under management, with our related parties, etc. based on our investment
decision or investment advice, each Fund Management Department examines the content ofthe transaction and the Compliance Officer further reviews it. The Compliance Officer
examines the applicability of the related-party transaction and the appropriateness of theactions, etc. taken by each Fund Management Department, and if the Compliance Officer
determines that such actions are insufficient, the Compliance Officer requests each FundManagement Department to take necessary actions. The Compliance Committee deliberates
on the related-party transactions. 【Principle 3 (Note)】(3)

Provisionof

important

information,including

feesandotherexpenses,

inaneasy-to-understand manner【Principle 4, Principle 5】
Based on a dedication to providing information with a high degree of transparency, we strive toprovide important information on investment products and services in an easy-to-understandmanner, and to appropriately state fees and other expenses that are agreed upon throughdialogue with client investors in agreements. In addition, we report the investment status offunds at a frequency and with a content in accordance with agreements and strive to accurately
grasp the impact of natural disasters, social issues, and other events on investment properties
and are striving to make timely reports on the status of actions being taken and otherinformation.

< 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 advance and provide information to sales companies to that effect. When acustomer who does not fall under the category of Professional Investors wishes toinvest, we are dedicated to providing investment products and services after
thoroughly consulting with the sales company and providing sufficient information
to the customer. 【Principle 5 (Note 1)】②We strive to prepare and provide materials that are easy to understand with respect
to important information concerning investment products and services (i.e.,assumed returns, risk of loss, etc., reason for selection, transaction terms,commission, outlines of related-party transactions, etc.) according to theexperience, financial knowledge of each client investor and the importance ofinformation, 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 bulkpurchase 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.), and when
packaging is required, we strive to explain the reason and content to client investors
in an easy-to-understand manner. 【Principle 5 (Note 2)】④The assets that we handle are mainly real estate or assets backed by real estate,
and we 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 the same, we are dedicated to providing easy-to-understand informationaccording to the degree 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 each client investor.
We do this by appropriately understanding their goals, requirements, financial position,
experience, knowledge, and other characteristics through our activities or via securities firms andother companies that engage in sales, and by holding dialogue.
< 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, andtarget returns, through dialogue with them, etc., and to propose investment
products or services that match such needs. In addition, not only at the time ofsales of investment 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 thegreatest extent possible. 【Principle 6 (Note 1)】②

We strive to propose better investment products or services, sufficiently
considering the results of investment 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 multipleproperties (including trust beneficiary rights) (however, we provide a series ofasset management operations to the extent necessary for the establishment ofprivate real estate funds and real estate management.), and when packaging isrequired, we strive to give consideration to whether the entire package isappropriate 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 (includingcustomers who are to be treated as Professional Investors in accordance withArticle 34-3, Paragraph 4 of the Financial Instruments and Exchange Act), and weexplain to sales companies to that 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 disclose the above customer attributes. 【Principle 6 (Note 3)】⑤The assets that we handle are mainly real estate or assets backed by real estate,
and we do not offer investment products using complex structures. However, weare 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 asmuch as possible. In addition, we do not sell or recommend products to any
customer groups with attributes that make them vulnerable to financialtransaction damage. 【Principle 6 (Note 4)】⑥We strive to prepare and provide materials that are easy to understand withrespect to the information necessary for understanding the investment products
and services that we intend to provide according to the experience and knowledgeof client investors, and to prepare and provide materials in response to meet client
investors’ requests. We also encourage and strive to further develop theprofessional knowledge of our employees regarding investment products andservices through internal and external training programs. 【Principle 6 (Note 5)】(5) Framework for adequately motivating employees【Principle 7】
As stated in (1) above, we are aware of the importance of making efforts to maintain andenhance high standards of business ethics of executives and employees in order to increaseclients’ interest and our corporate value by constantly providing outstanding services to client
investors. Based on this understanding, we are dedicated to increasing the motivation of ouremployees in an appropriate manner by holding periodic internal training and including not only
performance but also compliance perspectives in the standard performance parameters.
*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.