Mitsui Fudosan Accommodations Fund Management

Policies on Customer-Oriented Business Conduct

Initiative Policy

Mitsui Fudosan Accommodations Fund Management Co., Ltd. (the Company) stipulates the following policies given the Financial Services Agency's announcement of Principles for Customer-Oriented Business Conduct on March 30, 2017.

1．Development and Publication of Policies on Customer-Oriented Business Conduct

The Company shall develop and publish policies for realizing business conduct oriented for Nippon Accommodations Fund (NAF) and unitholders (collectively referred to as Customers) and periodically disclose the implementation status.

Since the Company is engaged only in managing NAF’s assets, it has no policies regarding selling or recommending financial instruments and services or composing financial instruments corresponding to Principle 3 (Note), Principle 5 (Notes 1, 2 and 4) and Principle 6 (Notes 1-4).

2．Pursuit of Customers' Best Interests

The Company shall maintain highly qualified expertise and professional ethics and treat NAF faithfully and fairly in pursuit of Customers' best interests. In addition, the Company shall make efforts to ensure such business conduct becomes established as a corporate culture.

Specifics:
The Company will strive to steadily and continuously acquire accommodation assets owned and developed by the Mitsui Fudosan Group through NAF. By utilizing the Group’s information network and the Company’s own information-gathering channels, it will also acquire highly competitive quality properties from outside the Group, aiming for stable external growth.
The core of NAF’s investment strategy is to solidify its earnings base through continuous acquisition and stable management of rental housing. In addition, as a complementary investment target to rental housing, it will invest a certain amount in “hospitality facilities,” a recently growing and maturing market. Furthermore, by way of sophisticated, specialized asset management, the Company will seek improvement of unitholder value on a mid- to long-term basis, i.e., the stable growth of DPU (distributions per unit) on a mid- to long-term basis as well as an increase of NAV (net asset value) per unit.

3．Appropriate Management of Conflicts of Interest

The Company shall accurately identify the possibility of conflicts of interest arising with Customers and appropriately manage them in the possible event of such, in line with laws, regulations, internal rules and such.

Specifics:
The Company has established the following standards and procedures for transactions with sponsor-related parties in order to contribute to NAF unitholder interests by eliminating conflicts of interest and thereby ensuring appropriate asset management for NAF.

It has established Rules for Transactions with Sponsor-Related Parties, which are defined more broadly than the scope of interested parties under laws and regulations, as its internal rules to prevent transactions that are not fair and impartial between NAF and sponsor-related parties.
If NAF conducts a certain type of transaction with a sponsor-related party, it shall be subject to the approval of the Compliance Committee and the deliberation and decision of the Investment Committee.

4．Clarification of Fees and Expenses

The Company shall provide information in a manner understandable by Customers on the details of management fees that NAF pays to the Company to which asset management is entrusted, as well as what services correspond to each of such fees.

Specifics:
In accordance with the provisions of the Articles of Incorporation, the asset management fees that the Company receives from NAF consist of five items: 1) Management Fee 1, which is based on real estate rental income; 2) Management Fee 2, which is based on pre-tax net income; 3) Management Fee 3, which is upon acquisition; 4) Management Fee 4, which is upon sale; and 5) Management Fee 5, which is for a merger with another investment corporation, whether by consolidation or absorption.

5．Easily Understandable Provision of Important Information

The Company shall disclose information according to laws and regulations from the viewpoint of ensuring transparency. In addition, the Company shall disclose information that the Company deems necessary and appropriate for unitholders' judgment in a timely and easy-to-understand manner.

Specifics:
The Company has established Disclosure Rules to develop a system for prompt, accurate, fair, investor-centric disclosure of information concerning the Company and NAF.
In addition to posting timely disclosure information on NAF's website, the Company strives to update financial and portfolio-related information in a timely manner, for example publishing month-end occupancy rate data within one week, to ensure that the information on NAF is up to date. Furthermore, all disclosed materials, including financial statements, annual reports (in English), analyst meeting materials, asset management reports and securities reports, are available to view.

6．Provision of Services Suited to Customers

The Company shall strive to understand the opinions and needs of unitholders through IR activities. Furthermore, the Company shall implement asset management with an aim to secure stable long-term earnings primarily through investment in high-quality rental apartments while paying attention to needs, etc.

Specifics:

The Company will strive to understand the opinions and needs of unitholders through briefings for individual investors and meetings with institutional investors.
The Company will strive to disclose information proactively and conscientiously so that all Customers can easily understand NAF's strategies and management status.

7．Framework for Motivating Employees Appropriately and Other Measures

The Company shall develop a framework for motivating employees appropriately and an appropriate governance system to thoroughly promote actions for pursuing Customers' best interests and the appropriate management of conflicts of interest.

Specifics:
The Company implements the following initiatives to develop personnel with high levels of expertise, broad knowledge and ethical standards and ensure the health and safety of its employees.

Support in obtaining qualifications
Encouragement/support for participation in internal and external training programs
Ongoing training on compliance, ESG, and other topics
Use of expertise of sponsor and other external personnel
Regular medical checkups
Achievement of work-life balance
Introduction of special leave programs

Initiative Status

1．Pursuit of Customers' Best Interests

By way of sophisticated, specialized asset management, the Company seeks improvement of unitholder value on a mid- to long-term basis, i.e., the stable growth of DPU (distributions per unit) on a mid- to long-term basis as well as an increase of NAV (net asset value) per unit.

≫ Change in DPU and NAV per unit

2．Appropriate Management of Conflicts of Interest

The Company uses the value chain of the Mitsui Fudosan Group for asset management. On the other hand, there is concern that conflicts of interest may arise between customers and the Company and its related parties. Therefore, in addition to complying with laws and regulations, in order to prevent transactions that are not fair and impartial, the Company has established internal rules and an organizational structure.

≫ Report on the operation system etc. of issuers etc. of real estate investment trust securities (Japanese only)

3．Clarification of Fees and Expenses

The Company displays clearly the system of management fees it receives from NAF and discloses the amount of management fees paid each fiscal period.

≫ Management Fee System / Amount of Management Fee Paid

4． Easily Understandable Provision of Important Information

In addition to disclosing information in accordance with laws and regulations from the viewpoint of ensuring transparency, the Company discloses in a timely and easy-to-understand manner the following information deemed necessary and appropriate for unitholder's investment decisions.

≫ Press releases

≫ Disclosure of Financial Results, Securities Reports (Japanese only), Asset Management Reports (Japanese only), etc.

≫ Conduct briefing sessions for analysts and institutional investors

≫ Disclosure on Investor Presentation materials and videos on NAF's website

≫ Content posting for individual unitholders on NAF's website

5．Provision of Services Suited to Customers

While conscious of the opinions and needs of unitholders understood through IR activities such as those listed below, the Company implements asset management with the goal of securing long-term and stable earnings primarily through investment in high-quality rental apartments.

≫ Implementation of IR meetings for institutional investors both in Japan and overseas

≫ Implementation of briefing sessions for individual unitholders

≫ Participation in seminars for individual unitholders organized by industry organizations

6．Framework for Motivating Employees Appropriately and Other Measures

The Company focuses on nurturing its professional personnel to implement high-quality fund management on an ongoing basis. Employees are encouraged to acquire various certifications so that their expertise can be improved as professional personnel. Specifically, employees are given support in their training and examinations for acquiring and maintaining expert qualifications and are assisted in obtaining a wide range of knowledge and skills that are required for their work.
Through the implementation of training on compliance, ESG and such on an ongoing basis, the Company aims to spread awareness of its Customer-oriented business conduct among its employees.
The Company will also evaluate compliance in the performance rating of employees.

≫ Human Resource Development

Privacy Policy

Mitsui Fudosan Accommodations Fund Management Co., Ltd.

Mitsui Fudosan Accommodations Fund Management Co., Ltd. (the "Company") recognizes the importance of protecting personal information and specific personal information, etc. (where "specific personal information, etc." as used herein shall refer collectively to Individual Numbers and specific personal information), and has established and implements the following privacy policy with respect to the handling of personal information and specific personal information, etc. that the Company collects, retains and manages in exercising its asset management duties on behalf of Nippon Accommodations Fund Inc. ("NAF"). The Company has also established and implements rules on how the protection of personal information and specific personal information, etc. is handled. The Company periodically revises the content of the privacy policy and the rules noted above whenever necessary.

1．Compliance with Relevant Laws and Ordinances

The Company strives to protect personal information and specific personal information, etc. by abiding by the "Act on the Protection of Personal Information" (the "Personal Information Protection Act"), the "Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure" (the "My Number Act") and other relevant laws and ordinances, as well as the "Guidelines for Personal Information Protection in the Financial Field" (the "Guidelines in Financial Field") and "Guidelines for proper handling of Specific Personal Information (for private entities)," etc., (referred collectively as "Laws and Ordinances, etc.") in the handling of personal information and specific personal information, etc.

2．Collection of Personal Information and Specific Personal Information, etc.

The Company collects personal information and specific personal information, etc. through legal and appropriate means to the extent necessary to perform its services. Moreover, the Company shall not collect special care-required personal information without consent from the individual except in cases required by laws and ordinances, nor shall the Company collect sensitive information (as defined in the Guidelines in Financial Field) except in cases stipulated in the Guidelines in Financial Field.

3．Purpose of Use of Personal Information and Specific Personal Information, etc.

The Company uses specific personal information, etc., only to the extent provided by laws and ordinances. In addition, other than these, any personal information collected by the Company are used, only for the following purposes. As for sensitive information, it shall not be used except in cases stipulated in the Guidelines in Financial Field.

To enforce the rights of those who own securities issued by NAF, to fulfill the obligations of NAF and to carry out measures to ensure a smooth relationship among NAF and its investors;
To prepare and file various reports and documents of NAF in accordance with the Investment Trust and Investment Corporation Act, the Companies Act and other relevant laws and, to manage the information of NAF's investors;
To respond to inquiries concerning the bonds, additional investment units and securities issued by NAF;
To carry out operations related to the acquisition, transfer and leasing of assets by NAF and the management of real estate;
To carry out general affairs the Company is responsible for or to carry out operations incidental or related to (1) through (4) above; and
To provide personal information to a third party within the scope necessary to fulfill the purpose of use indicated in (1) through (5) above.

4．Provision of Personal Data and Specific Personal Information to Third Parties

Unless otherwise provided by the My Number Act, etc., the Company will not provide specific personal information to a third party, regardless of whether or not the consent of the individual has been obtained. In addition, other than these, the Company may provide personal information to a third party, only in the following cases. As for sensitive information, it shall not be provided to third parties except in cases stipulated in the Guidelines in Financial Field.

In cases of the provision to a third party within the scope of the purpose of use as set forth in the preceding paragraph "3. Purpose of Use of Personal Information and Specific Personal Information, etc."; and
Other cases where the provision is permitted under the Act on the Protection of Personal Information.

5．Disclosure Requests, etc.

The Company strives to respond swiftly and appropriately when a request for notification of purpose of use is made or when asked to disclose, modify, add, delete, suspend using, erase, or discontinue the provision to third parties the retained personal data (including retained personal data pertaining to specific personal information) of an individual after verifying that the request is from the individual himself/herself.

6．Security Measures

The Company has implemented the following measures in accordance with the relevant Laws and Ordinances, etc., to ensure the security of personal data and specific personal information, etc., such as prevention of leakage, loss or damage.

Establishment of rules for the handling of personal information
The Company has established internal rules that specify the methods of handling personal information, responsible persons/persons in charge, their duties, etc.
Organizational security measures
The Company has appointed a Chief Information Officer to be responsible for the handling of personal information, and formulates a personal information protection plan each fiscal year to implement, evaluate and improve security measures.
In addition, it ensures that its employees (including contract employees and temporary employees) comply with its internal rules regarding security measures, and has established a system for reporting to and informing the responsible person if they become aware of any facts or signs of violations of laws or internal rules.
Personnel security measures
The Company provides its employees with education and training on the proper handling of personal information.
Physical and technical security measures
In the areas where personal information is handled, the Company controls employee access and locks all devices containing personal information.
In addition, it has implemented access control measures for personal information and the information systems that handle personal information as well as measures against unauthorized software, monitoring of information systems, etc. (e.g., restricting access to file servers, etc., implementing firewalls in the Internet connection environment and obtaining and analyzing operation history).
Understanding of the external environment
The Company stores the customers’ personal information in its possession in Japan.

7．Inquiries Regarding Personal Information and Specific Personal Information, etc.

The contact information for inquiries related to the Company's handling of personal information and specific personal information, etc., requests for notification of purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, or discontinuation of the provision to third parties concerning the retained personal data (including retained personal data pertaining to specific personal information) and complaints, etc., is provided below. The Company will respond as quickly as possible and in good faith to complaints and consultations regarding personal information and specific personal information, etc.

Mitsui Fudosan Accommodations Fund Management Co., Ltd.
1-4-1, Nihonbashi, Chuo-ku, Tokyo 103-0027
Tel : 03-3246-3677
(9 a.m. - 5 p.m. (excluding weekends, holidays and scheduled non-working days))

The Company is also a member of the Investment Trusts Association, Japan (JITA), which is a personal information protection organization authorized under the Act on the Protection of Personal Information. JITA accepts complaints and provides consultation concerning its members' handling of personal information.

JITA Investor Advisory Office
Tel : 03-5614-8440

8．Revisions

The Company may revise this privacy policy from time to time in order to ensure the protection of personal information and specific personal information, etc., and to conform to changes in laws and ordinances. Please confirm the date of the last revision provided below.

Enacted ： July 31, 2006
Latest revision ： March 31, 2022