Touchstone Capital Management | Action Policy on Fiduciary duty
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Action Policy on Fiduciary duty

All members of Touchstone Capital Management (“TSCM”) uphold the following core ethical values in the performance of their professional services:
• Complying with social norms, laws and regulations;
• Managing conflicts of interest proactively;
• Acting for the benefit of clients; and
• Acting with integrity.

Aside from fulfilling the ongoing fiduciary duties for disclosure, care, and royalty, TSCM, as an asset management company that primarily engages in the management of real estate investments, reaffirms its commitment to broadening its accountability to its clients. To that effect, TSCM has developed the following Action Policy for Execution of Customer-Oriented Business Operations code of conduct:

1. Customer-oriented service
TSCM will assist to maximize profits for its clients through thorough understanding of each client’s specific requirements and through sound and unbiased consulting services and communication of all necessary information.

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TSCM will act in the best interest of its clients by providing timely and essential information necessary to make important investment decisions in accordance to each client’s specific investment and risk profile.

2. Conflicts of interest management
TSCM will not utilize any information it obtains through its transactions and day to day business that would unjustly benefit itself or other clients.

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TSCM will comply with internal procedures and restrictions contained in its voluntary rules set for each type of transactions to manage conflicts of interests.

3. Transparent commission system
TSCM aims to build a clear and transparent commission system that would provide confidence to its clients in its services.

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Fees and expenses charged to its clients for services TSCM provides shall be presented in writing and approved prior to the start of an engagement.

4. Fostering corporate culture
TSCM will strive to constantly fulfil its fiduciary duty to its clients.

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TSCM regularly conducts educational and training sessions to all its directors and employees to improve and raise their consciousness in fulfilling their fiduciary duties to the clients.