Basic Policy on Customer-Oriented Business Conduct

Enacted March 26, 2018

As a member of the NTT Urban Development Group, we share our parent company’s corporate slogan, “Integrity and Innovation,” and, taking a long-term perspective, devote ourselves to sound management, strong ethics and customer-oriented business conduct. We regularly announce the status of our efforts related to this policy and review it regularly to constantly improve our operations.

1. Pursuit of the best interests of our customers

As a financial business, we maintain a high degree of expertise and professional ethics, strive to accurately meet the needs of our customers, conduct fair and sincere business and always give top priority to maximizing the interests of our customers in our operations.

2. Appropriate management of conflicts of interest

In order to prevent conflicts of interest, we have established Stakeholder Transaction Rules and policies for transactions between parties that may have conflicts of interest and, by complying with these, endeavor to eliminate all conflict-of-interest-related adverse effects. In addition to clarifying the scope of stakeholders and transaction rules, the Stakeholder Transaction Rules stipulate that, for example, transactions that may have conflicts of interest may not be decided without the approval of the Compliance Committee, which includes external experts.

3. Clarification of fees, etc.

We provide information for your understanding, including what services are related to the fees you incur directly and indirectly.

4. Clear provision of important information

We provide important information such as schemes, returns, risks and operational status related to the financial products and services we offer in a clear manner that you can understand.

5. Provision of services suitable for customers

We endeavor to understand your asset status, transaction experience, knowledge, transaction purpose and needs, and provide financial products and services that suit you.

6. Appropriate motivational framework for officers and employees

We believe that it is important for all of our officers and employees to have a high degree of expertise and professional ethics in order to fulfill our social responsibilities and public mission as a financial business through sound management, so we proactively implement measures to motivate them and maintain an appropriate governance system by regularly and continuously conducting training and establishing a system for monitoring operations.

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