Policy on Customer-Oriented Business Conduct

Correspondence Table Showing Comparison with the Financial Services Agency’s “Principles for Customer-Oriented Business Conduct”
Correspondence Diagram Showing Comparison with the Financial Services Agency’s “Principles for Customer-Oriented Business Conduct”
(Note) To zoom in on the diagram, click again when the diagram has been displayed.

Policy on Customer-Oriented Business Conduct

Since its establishment in 2007, Mitsui & Co., Realty Management Ltd. (“the Company”) has worked to promote customer-oriented* business conduct, based on the following three items of our Management Policy.
(Note) Under the Policy on Customer-Oriented Business Conduct, we refer to parties directly involved in transactions with the Company as well as all investors and shareholders who carry out investment activities via such parties as “customers”, individually or collectively.

We will always try to be "fair" and "modest", and earnestly engage in business operations, keeping investor protection in mind at all times.
Being involved in the management of real estate and other assets as a financial instruments business operator, we will pursue best practices from the perspective of investors. No efforts shall be spared to enhance investment returns through the implementation of appropriate management measures.
We position comprehensive compliance as a fundamental principle of our management, with a strong recognition that compliance is the keystone of the Company’s management base.

The Financial Service Agency (FSA) has cited seven “Principles for Customer-Oriented Business Conduct”, and all of them are compatible with the Company’s above Management Policy. We will continue working to conduct customer-oriented business in the following ways:

（1）Formulation and Announcement of Policies regarding Customer-Oriented Business Conduct

In order to further strengthen our customer-oriented business conduct, which we have pursued under the above “Management Policy”, we have formulated and hereby announce the “Policy on Customer-Oriented Business Conduct” (hereinafter “the Policy”). We will continue working to improve our customer-oriented business conduct, carry out regular checks on the implementation of the Policy, and review the Policy as necessary.

（2）Pursuit of the Customers' Best Interest

As a real estate asset management company with a strong sense of ethics, we utilize the knowledge and track records built up across the Mitsui & Co. group to contribute to the healthy development of the real estate market. We pursue work that is useful to all stakeholders, based on lofty aspirations to cement our social significance. With a strong awareness of the fact that compliance is the keystone of our management base, we uphold laws and regulations, and pursue the best interests for our customers. We will continue working to ensure that this customer-oriented business conduct becomes firmly established as part of our corporate culture.

（3）Appropriate Management of Conflicts of Interest

（4）Clarification of Various Fees and Commissions

（5）Providing Important Information in an Easy-to-understand Manner

（6）Providing Suitable Services to Customers

We recommend appropriate financial products to match customers’ knowledge, experience, asset situation, purpose of concluding contracts, etc.
The products we provide are mostly “private REITs” and “private real estate funds”.
“Private REITs” are investment products offered only to qualified institutional investors. They aim to maximize value for investors by securing stable income and achieving steady growth in the managed assets.
“Private real estate funds” are investment products offered mostly to professional investors. Product characteristics differ from fund to fund, so sufficient information is provided to allow customers to make informed investment decisions.
We do not currently sell or recommend multiple financial products or services as packages.

（7）Framework for Adequate Motivation of Its Employees

We strive to enhance our internal education, training, and other such opportunities in relation to compliance so that our employees can act responsibly with an awareness of the Company’s social responsibilities and public mission. Moreover, in order to maintain the highest standards of specialist knowledge and professional ethics, we encourage the acquisition of specialist qualifications.

Achievements of Customer-Oriented Business Conduct

（1）Formulation and Announcement of Policies regarding Customer-Oriented Business Conduct

In order to further strengthen our customer-oriented business conduct, which we have pursued under the above “Management Policy”, we will announce the achievements relating to the “Policy on Customer-Oriented Business Conduct” (hereinafter “the Policy”). We will continue working to improve our customer-oriented business conduct, carry out regular checks on the implementation of the Policy, and review the Policy as necessary.

（2）Pursuit of the Customers' Best Interest

As a real estate asset management company with a strong sense of ethics, we utilize the knowledge and track records built up across Mitsui & Co. group to contribute to the healthy development of the real estate market. We pursue work that is useful to all stakeholders, based on lofty aspirations to cement the Company’s social significance. With a strong awareness of the fact that compliance is the keystone of the Company’s management base, we uphold laws and regulations, and pursue the best interests for our customers. We will continue working to ensure that this customer-oriented business conduct becomes firmly established as part of our corporate culture. As stated above, with a strong awareness of the fact that compliance is the keystone of the Company’s management base , we strive to achieve stable growth while adhering to laws and other ordinances.

As a result of these efforts, the size of the assets at “Mitsui & Co., Private REIT Inc.”, which the Company manages under commission, reached approximately 103 billion yen as of February 2022. The goal of reaching “100 billion yen in assets within five years of starting management” targeted when Mitsui & Co., Private REIT Inc. was launched (February 2018) was achieved one year early. We have continued to make good progress. For example, new investment units were issued and additional rights were acquired in February 2023, increasing the total size of assets to 117.3 billion yen.
･ Press release (Notice Concerning the Issuance of New Investment Units and the Acquisition of Real Estate Trust Beneficiary Rights in Japan by the Private REIT Mitsui & Co., Private REIT Inc.)

Regarding private real estate funds, as a specific initiative carried out under the capital and business alliance between Mitsui & Co., Ltd. and Japan Post Insurance Co., Ltd., we formed the “MBRM Fund”. Just six months after the fund was formed, it passed 40 billion yen in total managed assets. We have further expanded the size of managed assets by accumulating a steady track record in projects such as a hyperscale data center and a logistics facility development.
･ Press release (Flagship Fund –MBRM Fund– Exceeds Total Assets of ¥40 Billion in Six Months)
･ Press release (Opening of Hyperscale Data Center in Keihanna)
･ Press release (Notice Concerning Completion of the Kazo LC Logistics Facility)

Moreover, based on the recognition that efforts and initiatives relating to the Environment, Society, and Governance (ESG) in our asset management operations contribute to increasing the value of managed assets and bolster our competitive edge in the medium to long term, we have set forth the Sustainability Policy, pursued specific initiatives, including acquisition of external evaluations and certifications for managed properties, obtained GRESB value, declared our support for the Recommendations of the TCFD (Task Force on Climate-related Financial Disclosures), and identified our Materiality (Material issues).
Details can be found on the following pages of the Company website.
Policies, Frameworks, and Initiatives
Environmental Initiatives
Social Initiatives
Employee Initiatives
External Evaluation / Obtainment of Certification
Governance

（3）Appropriate Management of Conflicts of Interest

We have set out “Rules on Preventing Conflicts of Interest” as a set of internal rules to prevent customers’ interests being negatively affected by transactions with stakeholders with a certain relationship with the Company, such as its group companies. Based on these rules, we verify the potential for conflicts of interests with customers arising through such transactions. At the same time when there appears to be a potential conflict of interests, we strictly adhere to the Rules on Preventing Conflicts of Interests, for example by verifying the reasonableness of transaction prices or gaining the approval of the Investment Committee or Internal Control Committee, and thereby strive to carry out appropriate management of conflicts of interests.
The number of meetings of the Investment Committee and Internal Control Committee are shown below. The approval of the Investment Committee or Internal Control Committee is needed for transactions with stakeholders with a certain relationship with the Company, including group companies as described above, the acquisition or sale of managed assets, and the entrustment of asset management, etc.

Item	Unit	FYE March 2023	FYE March 2024	FYE March 2025
Number of Investment Committee meetings	Meetings	14	12	12
Number of Internal Control Committee meetings	Meetings	17	15	15

（4）Clarification of Various Fees and Commissions

We clarify information about the fees, commissions, etc. the Company receives (hereinafter “Commissions, etc.”) in documents such as contracts and product outlines, and remain mindful of giving careful explanation to customers in order to assist customers’ understanding.
The Commissions, etc. received by the Company are mostly composed of management fees during the fiscal year, asset acquisition fees, asset sale fees, etc. We give advance explanations of our approach to these fees and the standards for deciding commissions in the product outlines. We also give clear information about past records of Commissions, etc. by listing them in asset management reports, etc. and giving direct explanations to customers.

（5）Providing Important Information in an Easy-to-understand Manner

We give careful explanations of important matters, including product details, risks, etc., to ensure sufficient understanding by customers, and strive to provide information with clarity, including regular reports about funds currently under management.
The basic schemes, risks, and trading terms for financial products, etc., offered by the Company, as well as important information about details and management conditions, if there are any potential conflicts of interest, are provided on a timely basis using clear language and diagrams, and other means to facilitate communication with the customer.
We have also launched a dedicated website for those who invest in products offered by Mitsui & Co., Private REIT Inc., from which we undertake asset management consignments. Mitsui & Co., Private REIT Inc.’s investors can carry out timely confirmation about the assets it manages by accessing the below website using their dedicated password.
We do not currently sell or recommend multiple financial products or services as packages.

（6）Providing Suitable Service to Customers

（7）Framework for Adequate Motivation of Its Employees

We strive to enhance our internal education, training, and other such opportunities in relation to compliance so that our employees can act responsibly with an awareness of the Company’s social responsibilities and public mission.
Our record of carrying out compliance-related training is as follows (including joint training with group companies). In addition, we also work to provide e-learning, real estate market training, etc.

Item	Unit	FYE March 2023	FYE March 2024	FYE March 2025
Compliance training sessions	Sessions	13	12	12

In order to maintain the highest standards of specialist knowledge and professional ethics, we encourage the acquisition of specialist qualifications. The status of qualification acquisitions is as follows.

Item	Unit	FYE March 2023	FYE March 2024	FYE March 2025
Real estate transaction agent (including those who have passed the test)	People	26	35	42
	％	81.3	81.4	89.4
ARES Certified Master	People	16	20	27
ARES Certified Master	％	50.0	46.5	57.4

... and upwards