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.

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.

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.

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.

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.

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.

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.

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.

Sustainability Policy

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.

  1. 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;
  2. 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;
  3. To respond to inquiries concerning the bonds, additional investment units and securities issued by NAF;
  4. To carry out operations related to the acquisition, transfer and leasing of assets by NAF and the management of real estate;
  5. To carry out general affairs the Company is responsible for or to carry out operations incidental or related to (1) through (4) above; and
  6. 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.

  1. 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
  2. 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 all necessary and appropriate 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.

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 : May 30, 2017

Terms of Use

1. Intellectual Property Rights

The copyrights and intellectual property rights to all contents (information, trademarks, designs, etc.) on this website shall belong to Mitsui Fudosan Accommodations Fund Management Co., Ltd. ("the Company") or the respective right-holder(s). Therefore, unauthorized reproduction, use, duplication, distribution or alteration of the content contained in this website is prohibited.

2. Disclaimer

The Company accepts no liability for any problems, losses and damages that may arise from actions taken or not taken due to judgments made based on the information contained in this website. Moreover, the Company accepts no liability for any damages that may result from unauthorized alteration of the text, leakage of textual content, fraudulent use by third parties and any other incidents involving the information contained in this website. Note that the operation of this website may be suspended or terminated and the contents contained in this website may be modified at any time without a prior notice. The Company accepts no liability for any problems, losses and damages that may result from such suspension, termination and modification.

3. Links

Some links and banners on this website take users to other websites that are not operated by the Company. The Company accepts no liability or responsibility with respect to the contents contained in those websites.

4. Recommended Browsers

Using Internet Explorer 5.5+ or Netscape Navigator 6.0+ is recommended in viewing this website. Please use the latest Flash plug-ins.

5. Forward-Looking Statements

The information contained in this website may include forward-looking statements regarding the Company's future financial position and business performance. Such forward-looking statements are subject to certain risks and uncertainties, and website users are advised that actual results may differ from such statements due to changes in the business environment and other factors in the future.

6. Applicable Laws and Court of Jurisdiction

The laws of Japan shall apply to the use of this website and the interpretation and the application of the Terms of Use. The Tokyo District Court shall have exclusive jurisdiction over any disputes related to this website.

Inuiries

Inquiries to Mitsui Fudosan Accommodations Fund Management Co., Ltd.
Tel 03-3246-3677 (main line)
Hours 9 a.m. - 5 p.m. (excluding weekends, holidays and scheduled non-working days)