Principles for Customer-Oriented Business Conduct

Principles for Customer-Oriented Business Conduct

HEIWA REAL ESTATE Asset Management CO., LTD. (the "Company") has adopted the "Principles for Customer - Oriented Business Conduct" announced by the Financial Services Agency on March 30, 2017. The Company's policies have been established as follows.

1. Establishment and publication of policy on Customer-Oriented Business Conduct

As an asset management company entrusted to the management of assets from HEIWA REAL ESTATE REIT, Inc. ("the Investment Corporation"), we have set forth our management philosophy with the primary goal of increasing value for our investors. Based on this management philosophy, we announce the establishment of our policies towards the Investment Corporation and investors (our "Customers") in realization of customer-oriented conduct. Periodic revisions will be made following the announcement of the status of these initiatives.

▶ Please see here for our Management Philosophy.

2. Pursuit of our customer's best interests

As a financial services provider, the Company shall maintain the highest level of professional ethics and specialized expertise, conducting our asset management business in good faith and fairness in the pursuit of our customer's best interests. Furthermore, the Company shall endeavor to keep the establishment of these practices firm in our corporate culture.

3. Managing conflicts of interest

The Company fully realizes the possibility of conflicts of interest in transactions, and should the possibility of a conflict of interest arise, we shall properly manage such conflicts of interest in accordance with the law and internal rules.

4. Fee transparency

The Company shall provide information so that our Customers are able to understand the details of the management remuneration paid by the Investment Corporation to the Company, including the consideration for service type.

5. Providing accessible, essential information

The Company and the Investment Corporation shall disclose information to our Customers based on regulations prescribed by the law, the Tokyo Stock Exchange, Investment Management Association of Japan and other sources, along with providing information pertaining to the Investment Corporation that is important for our Customers in a prompt and easily understood manner.
Please note that the Company does not sell or recommend multiple financial instruments and services in a package format.

6. Providing customer tailored services

The Company shall endeavor to meet our Customers' needs, conducting our asset management activities and information disclosures with those needs in mind.
The Company is not involved in the composition of financial instruments and does not sell or recommend multiple financial instruments and services in a package format.

7. Framework for employee motivation

We shall establish an appropriate motivational framework and governance system for employees so they are able to pursue our Customers' best interests, deal with Customers fairly, and properly manage conflicts of interest.

Initiatives Status

1. Pursuit of our customer's best interests

The Company will maximize the experience and expertise of the Heiwa Real Estate Group, steadily implementing external and internal growth strategies along with a financial strategy to effectuate long-term and stable dividends for our Customers.

▶ Please see here for additional resources.

Dividend per unit trends

Strategy portfolio

Sponsor support

2. Managing conflicts of interest

The Company has enacted our "Regulations for the Prevention of Conflicts of Interest" in regards to conflict of interest transactions beyond the scope of interested parties as defined by the law to identify interested parties in advance. Further, concerning transactions, conflicts of interest will be properly managed through prior assessment by the Board of Directors and the Compliance Committee which will include external specialists to identify possible conflicts of interest before the transaction is conducted.

▶ Please see here for more information on our efforts in preventing conflicts of interest.

Annual Securities Report: "Section 2 [Investment Corporation Detail], Part 3 [Management and Operations], 2. [Interested Party Transaction Restrictions], (2) HEIWA REAL ESTATE REIT Voluntary Regulations"

Real Estate Investment Trust Securities Issuers Business Practices Report: "2. Operational Framework for HEIWA REAL ESTATE REIT and HEIWA REAL ESTATE Asset Management, (3) Conflict of Interest Transactions Initiatives, ① Conflict of Interest Transactions Policy and Operational Framework"

3. Fee transparency

Remuneration for asset management services entrusted to the Company from the Investment Corporation consists of Management Fee 1, Management Fee 2, Management Fee 3, Acquisition Fee, Transfer Fee, and Merger Fee, with the calculation method and payment timing for each remuneration disclosed.

▶ Please see here for our fee structure.

HEIWA REAL ESTATE REIT Bylaws, Article 38: Asset Management Remuneration Amounts to the Asset Management Company and Payment Standards

4. Providing accessible, essential information

The Company and the Investment Corporation disclose important information on investment decision-making for our Customers from their point of view in an accurate, timely and easy-to-understand manner. While proactively conducting our IR activities, we maintain a close relationship with our Customers and communicate our financial presentation materials simply and effectively.

▶ Please see here for further information.

Financial Information

Press Releases

ESG Initiatives

5. Providing customer tailored services

We strive to continually better understand our Customers and listen to their feedback through our IR activities and customer surveys. In conducting our asset management activities with the goal of securing stable, long-term earnings, we make it a priority to disclose information from the customer's point of view.

6. Framework for employee motivation

So our employees are able to carry out their duties faithfully and provide high quality services to our Customers, we work to instill an awareness of compliance and have made it part of our employee evaluation process. We also support a number of work-related certifications to further improve our employees' technical knowledge and abilities.

Please see here for further information.