Policies on Customer-Oriented Business Conduct

Touchstone Capital Management Co., Ltd. (hereinafter referred to as “TSCM”) has adopted all seven principles in the Principles for Customer-Oriented Business Conduct announced by the Financial Services Agency on March 30th, 2017 (including subsequent revisions, hereinafter referred to as the “Principles”), and has established the following policies for the purpose of providing better quality services to our customers.

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

TSCM formulates and announces our Policies regarding Customer-Oriented Business Conduct (hereinafter referred to as the “Policy”) in order to pursue the best interests of customers as a real estate investment manager.
In addition, TSCM will regularly verify the status of the Policy implementation and review the Policy as necessary.

Specific Policy Content and Implementation Status

● Formulation and Announcement of the Policy: As an investment manager entrusted with your valuable assets, TSCM has an obligation to act in good faith and to exercise due diligence in the interests of our customers.
In order to live up to such customer’s trust, TSCM intends that the Policy will be observed as the basic code of conduct that underpins our business operations, and will be settled and penetrated within the organization as our shared values.
Through business operations in accordance with the Principles and the Policy, TSCM will pursue the best interests of our customers, thereby expect to contribute to the purpose of the Financial Instruments and Exchange Law, which is “the sound development of the national economy and the protection of investors (Article 1 of this law)”.

● Scope of assumed “customers”: “Customers” in the Policy include investors investing in real estate-related funds that are counterparties to asset management agreements concluded by TSCM.
TSCM provides investment management services mainly to investors with extensive experience in investing in financial instruments, and is entrusted with asset management services by corporate clients who are professional investors (Including professional investors who have been transferred from general investors; the same shall apply hereinafter) or by real estate-related funds invested only by such investors.
Therefore, TSCM will conduct business operations in accordance with the Policy in principle, on the premise that the customer or investor in the real estate-related fund is a corporation that is a professional investor, or has equivalent knowledge and experience.