Tokyo Tatemono Investment Advisors

In relation to the "Customer-Oriented Business Operation Policy," we have established the following "Policy on Supplementary Principles for Product Governance" with the aim of realizing the best interests of our customers throughout the entire process of creating and selling financial instruments.

1. Basic PhilosophyIn addition to the experience, skills, and industry networks we have cultivated as a financial business operator involved in the creation of financial instruments, we organically utilize the knowledge and various functions of the Tokyo Tatemono Group to provide our customers with financial instruments and related services with higher added value that match their investment needs based on their asset status, trading experience, knowledge, trading objectives, and so on. We will build and implement the governance necessary to achieve this.


2. System DevelopmentWe provide financial instruments to our customers primarily through investment management and investment advisory services. The life cycle of the instruments is mainly divided into the initial fund creation, the fund management period, and the fund investment recoup period. In order to ensure the effectiveness of achieving the above philosophy in each process, we will make appropriate decisions and develop a system, including various other procedures. Through these systems, we will thoroughly implement appropriate quality control in each process.
   
   *In order to ensure the effectiveness of this policy and quality control in each process, we will have them verified by our administrative departments, such as the Compliance Department and the Internal Audit Department. The Board of Directors will also incorporate the opinions of outside directors and various committees will incorporate the opinions of external experts to make appropriate decisions. If we determine that this will be beneficial to our customers' investment decisions, we will also consider obtaining a fund evaluation from an external evaluation agency. Based on these deliberations and verifications, we will establish a PDCA cycle, including reviewing the system to ensure product governance as necessary.


3. Response when Creating Financial InstrumentsWe anticipate the investment needs of our customers, and then consider factors such as the investment eligibility of the real estate, etc. that will be the investment target, the investment period, the investment style, the expected target return and risk tolerance, and work with sales companies to verify whether the financial instrument in question matches the investment needs of potential customers, and the rationality of this. The verification process involves conducting sufficient due diligence on the real estate and other assets targeted for investment, including their past track records, based on the assumed investment period, in order to verify their investment eligibility. In addition, when we identify the expected customer attributes for each financial instrument we create and entrust this to a third-party sales company, we provide sufficient information to the sales company and closely share information with them by exchanging opinions (including prior consultation on information to be disclosed). In order to understand customer needs and identify expected customer attributes, in addition to sharing information, we also conduct surveys such as interviewing potential investors directly.
   
   *When creating financial instruments, we determine the customer's asset status, transaction experience, knowledge, transaction objectives, transaction needs, and so on, according to the characteristics of the instrument, and identify the attributes of potential investors. We take care to select the best sales method for our customers so that they understand the nature of our financial instruments. Please note that we currently do not handle complex financial instruments or financial instruments with special management and distribution methods.


4. Response after Creating Financial InstrumentsAfter a financial instrument is created, it will be managed with the aim of increasing the investment value based on the initial investment management policy. During this process, we continuously monitor the financial instrument, including their risk and return, to ensure that they are maintaining sufficient performance compared to the initial investment plan, based on the business plan period (quarterly, half-yearly, yearly, etc.) agreed upon in advance with the customer. If a significant deviation from the investment plan occurs or is expected to occur in the future, we will take measures to improve the situation, and if we are unable to achieve the added value we intend to provide, we will consider measures such as recovering the investment principal, including selling the underlying assets of the financial instrument, or replacing the assets. Furthermore, if we determine that the overall product governance system, including the product creation, provision, and management processes, needs to be reviewed as a result of these efforts, we will consider improvement measures.
   We will listen to as many customer opinions as possible during the investment period, either directly or in collaboration with sales companies, to verify whether they match the expected customer attributes, and will use this information to improve future investment plans, develop financial instruments, and review the investment product governance system.
   
   *When a sales company sells our financial instruments to a customer, unless we have directly heard from the customer, we will provide an opportunity for information sharing, such as by asking the sales company about the customer's feedback (including complaints) and sales status. In order to realize the best interests of our customers, we will continue to consider diversifying our sales methods as one of our options. We also take seriously customer feedback received from our sales companies, consider improvements, and implement them. We do not outsource operational work to external companies.


5. Providing easy-to-understand information to customersWhen we create financial instruments and sell them to customers either directly or through our sales companies, we will describe the product characteristics, management structure, product governance structure, and so on, in an easy-to-understand manner in product brochures, etc., and will also explain these directly to customers as necessary. Even after the fund is established and during the investment period, we will strive to respond promptly to any questions our customers may have and provide ongoing information.
   
   *With the aim of realizing the best interests of our customers, we organically utilize the functions of each department throughout each product cycle of financial instruments to create, operate, and manage financial instruments. From this perspective, the marketability of our financial instruments cannot necessarily be evaluated based on the performance or investment philosophy of a specific investment manager, or the composition or performance of a specific investment team, therefore we have a policy of not disclosing these.

Established: June 30, 2025