Basic Policy on Customer-Oriented Business Conduct

Last modified: January 1, 2026

As a member of the NTT Urban Development Group, we share our parent company’s corporate philosophy, “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 relating to this policy and review it regularly to constantly improve our business conduct.

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.
Furthermore, since we are entrusted with managing multiple investment corporations, private funds, etc., we have formulated Distribution Criteria for Real Estate-Related Assets and stipulated priority rules for determining acquisition priorities, in order to prevent conflicts of interest based on competition to acquire management assets for each fund. When we acquire information about properties, acquisition priorities are decided in accordance with the priority rules at an Acquisition Priority Review Meeting.

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 instruments and services we offer in a clear manner that you can understand.
Note that we don’t sell or recommend multiple financial instruments or services as a package.

5. Provision of services suitable for customers

We endeavor to understand your asset status, transaction experience, knowledge, transaction purpose financial instruments and services that suit you.
Note that we don’t sell or recommend multiple financial instruments or services as a package, and complex or high-risk products.

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.

7. Basic philosophy of product governance

We work to build and implement product governance based on a basic philosophy of engaging in the formation, operation, and management of optimal financial instruments for customers by grasping customer needs in order to deliver added value to customers through the provision of financial instruments and services.

8. Establishment of product governance system

We have a system put in place for performing appropriate quality control in each process from the formation to operation and management of financial instruments based on the basic philosophy. Furthermore, a mechanism is put in place for appropriately incorporating external expert opinion so as to ensure the effectiveness of each process.

9. Measures to be taken at the time of formation of financial instruments

We design financial instruments to newly form based on a comprehensive consideration of the risks, returns, costs, etc. of the products, and verify the sustainability, reasonableness, etc. of the products from a medium- to long-term perspective by anticipating the true needs of our customers.
In addition, we form private funds, etc. as financial instruments aimed primarily at specific investors with product design based on customer needs and appropriate provision of information required for investment decisions by seeking coordination of information with the financial instruments distributors.

10. Measures to be taken after the formation of financial instruments

We continue to verify whether the product characteristics envisioned at the time of formation of financial instruments are being secured and utilize the results in not only improving and reviewing financial instruments but also reviewing each process from the formation to operation and management of financial instruments and the product governance system overall.
In addition, we form private funds, etc. as financial instruments aimed primarily at professional investors that realize the best interests of our customers by seeking coordination of information with the financial instruments distributors, and utilizing such in making operational improvements and improving subsequent formation of financial instruments as needed.
Furthermore, when outsourcing operations, we seek coordination of information with also the outsourcing partners as needed.

11. Provision of easy-to-understand information to customers

We strive to provide easy-to-understand information on our operational structure, product governance system, etc. to customers so that customers can select the better financial instruments.

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