Formulation and Announcement of Policies Regarding Customer-Oriented Business Conduct

In order to achieve even better business conduct, MJIA affirms and publishes the status of efforts relating to this Policy on its corporate website at least once a year in addition to reviewing this Policy at least once a year.

Commitment to Customers’ Best Interest

MJIA positions compliance as one of the most important priorities for management with a view to maintaining the impartiality of the financial instruments markets and ensuring the trust of customers. The company complies with Japan's Financial Instruments and Exchange Act, as well as other laws and regulations, and conducts its business sincerely, impartially, and in good faith, executing business operations faithfully with the care and diligence of a prudent manager in order to serve the best interests of its customers.

Appropriate Management of Conflicts of Interest

MJIA implements the following measures in transactions between customers and interested parties* of the company to ensure that customer interests are not harmed due to conflict of interest. *MJIA has designated in advance companies from among the Mitsubishi Estate Group that meet certain criteria, including investment from Mitsubishi Estate Co., Ltd., and parties which entrust business to the company, as interested parties.

• When handling transactions between customers and interested parties that exceed certain criteria, MJIA tasks the Compliance & Risk Management Committee with deliberation and confirms through an outside attorney that there are no issues from the perspective of laws and regulations. This is done in order to carefully consider the advisability of the transaction concerned from the standpoint of conflict of interest prior to the company’s decision.
• MJIA, as a rule, obtains the approval of the general manager of the Compliance Department when handling transactions between customers and interested parties, even for transactions that do not exceed the said criteria.
• When handling buying and selling between parties which entrust business to the company, MJIA takes measures to shield information between the seller and the buyer (system access restrictions and physical shielding measures) to manage the transaction concerned appropriately.

Clarification of Commissions and Fees

• MJIA endeavors to provide customers with information on the fees incurred by the customer and other details of costs, including the services provided by specific fees, in an understandable manner.
• MJIA sets the amount of business remuneration and the method for calculating the amount of business remuneration for each customer in light of the relevant laws and regulations, based on the type and attributes of the transaction target and market transaction practices. When the company engages in two or more businesses, as a general rule it sets the amount of business remuneration and the method for calculating the amount of business remuneration for each business.

Provision of Important Information in an Understandable Manner

• MJIA complies strictly with laws and regulations and discloses information promptly and accurately with a view to maintaining the impartiality of financial instruments markets and ensuring the trust of customers. The company also gives consideration to the transparency and understandability of the information it provides and is committed to sound and appropriate conduct of business and information disclosure.
• MJIA does not currently sell or recommend packages of multiple financial products and services.
• MJIA provides information in accordance with customer and product characteristics, taking into account the transaction experience and financial knowledge of customers.

Provision of Appropriate Services to Customers

• MJIA originates, sells, and recommends financial products and services that are appropriate for customers, taking into account the transaction experience and financial knowledge of customers.
• MJIA does not sell or recommend financial products that are particularly complex or high risk and does not sell or recommend financial products to groups with attributes that are deemed to be vulnerable to damage from financial transactions.
• MJIA strives to provide customers with information that includes basic knowledge relating to financial transactions, taking into account the transaction experience and financial knowledge of customers.
• When selling financial products, MJIA will work with internal and external parties involved in formation in an effort to ensure the effectiveness of product governance such as by confirming product characteristics as well as the management structure of the management company, etc. based on the principle of suitability.

Framework for Motivating Employees Appropriately

MJIA positions compliance as one of the most important priorities for management. The company works to develop a framework for appropriately motivating employees and a structure for appropriate governance as described below in order to ensure compliance with laws and regulations and the sound and appropriate conduct of business.

• MJIA includes compliance in the items to be assessed in personnel evaluations.
• MJIA works to raise the awareness of executives and employees by holding periodic training on compliance.
• In an effort to encourage its executives and employees to increase their expert knowledge, MJIA provides programs to help them acquire and maintain a variety of qualifications (ARES Certified Master, Real Estate Transaction Agent, etc.), as well as external training opportunities to acquire wide-ranging expertise.

Formulation and Announcement of Policies Regarding Customer-Oriented Business Conduct

In order to ensure even better business operations, MJIA posts updates on the status of initiatives related to this policy on its website and via other channels. In addition, the company reviews this policy at least once a year.

For more information on these policies and status of initiatives, see the MJIA website below.

https://www.mecinvest.com/en/company/fiduciary.html

Commitment to Customers’ Best Interest

• At the Nippon Open Ended Real Estate Investment Corporation (JOE) and the Mitsubishi Estate Logistics REIT Investment Corporation (MEL) as well as other funds managed by MJIA, compliance is positioned as one of the most important management issues in the effort to continuously increase investor value by delivering stable medium- to long-term growth.
• MJIA considers the greatest possible incorporation of environmental, social, and corporate governance (ESG) factors into investment decision-making and management processes necessary for maximizing medium- to long-term investor value and has established basic policy on sustainability and set goals to achieve this. MJIA posts information pertaining to these matters on its website.

https://www.mecinvest.com/en/sustainability/index.html

Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/esg/sustainability/policy.html

JOE:

 https://joe-re.com/ (in Japanese only)

• The asset management fee for MEL is structured from three layers, (1) Asset management fee I (AUM-linked), (2) Asset management fee II (real estate profit-linked), and (3) Asset management fee III (unitholder interest-linked). MEL introduced an asset management fee fully linked with investment unit performance in the third layer, that reflects the relative performance between MEL's investment unit price and the TSE REIT Index, which was the first in J-REIT. In doing so, MEL aims to strengthen the alignment between the Asset Management Company and unitholder interest. The relevant information is available on MEL’s website.

https://mel-reit.co.jp/en/esg/governance/corporate.html

• MJIA accepts talented human resources with experience and expertise in real estate investment and real estate management, as well as advanced IT personnel, seconded from other Mitsubishi Estate Group companies. MJIA also accepts attorneys and real estate appraisers with a high degree of specialization in various legal systems and real estate valuation in order to maximize investment performance by fully utilizing these external human resources. MJIA posts information pertaining to these matters on its website.

https://www.mecinvest.com/en/sustainability/employee.html

Appropriate Management of Conflicts of Interest

• MJIA ensures that the company’s Rules Governing Transactions by Related Parties are duly observed at the investment companies and other funds it manages in order to prevent transactions by related parties that are unjust and/or unfair.
  
  Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/features/management.html

JOE:

 https://joe-re.com/ (in Japanese only)

• MJIA has established the Compliance and Risk Management Committee, which deliberates transactions that may cause conflicts of interest and other compliance-related matters.

Clarification of Commissions and Fees

MJIA has systematically determined the management fees it receives from its investment companies and funds. For more information on the management fees charged to the investment companies, check the MEL securities reports and JOE product descriptions.

Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/ir/library.html

JOE:

 https://joe-re.com/ (in Japanese only)

Provision of Important Information in an Understandable Manner

• MJIA conducts IR activities for MEL investors and publishes the content of IR briefings and relevant explanatory materials on the MEL website. MJIA redesigned the MEL website with enhanced content for investors in April 2025. Additionally, MJIA strives to provide information in our Asset Management Report in an easy-to-understand format by responding to our investors’ requests as follows.

• The company also conducts IR activities for JOE investors and releases current financial statements for each fiscal term as well as forecasts for the coming term (currently available only in Japanese).
  
  Note that MEL posts relevant information pertaining to these matters on its website. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/ir/index.html?cate=all&year
 https://mel-reit.co.jp/en/ir/library.html

JOE:

 https://joe-re.com/ (in Japanese only)

• MJIA proactively provides investors with information on its commitment to sustainability and ESG-related initiatives via its investment companies’ websites.
  The MEL website has a section dedicated to ESG initiatives, where the company’s Sustainability Report is available for download. JOE investors are able to check relevant information by accessing the JOE website using a dedicated password.

MEL:

 https://mel-reit.co.jp/en/esg/

JOE:

 https://joe-re.com/ (in Japanese only)

Provision of Appropriate Services to Customers

• In managing its investment corporations and other investment targets, MJIA strives to clearly understand the needs of its investment customers and to appropriately provide these parties with the information believed necessary for investors in its investment corporations and other investment targets.
• In the formation of its financial products, MJIA identifies customer attributions per characteristics of each product and appropriately provides customers with timely information and proposals regarding products that match their investment objectives, experience and knowledge.
• MJIA shares information on the formation, sale, recommendation, etc. of financial products and services both internally and externally in a timely and appropriate manner, and continuously verifies whether it is providing products that are in the best interests of customers.

Framework for Motivating Employees Appropriately

• In order to encourage skill and career development for individual employees, MJIA has introduced a Management by Objectives (MBO) system for all employees and includes compliance as an evaluation item in its relevant assessments.
• MJIA conducts regular compliance and risk management training to raise compliance awareness among executives and employees.

• In an effort to encourage its executives and employees to increase their expert knowledge, MJIA provides programs to help them acquire and maintain a variety of qualifications (ARES Certified Master, Real Estate Transaction Agent, etc.), as well as external training opportunities to acquire wide-ranging expertise. MJIA posts information pertaining to these matters as well as numbers of employees with major qualifications on its website.

https://www.mecinvest.com/en/sustainability/employee.html

• MJIA has introduced a payroll deduction stock program (MEL) available for its executives and employees, where they can own the MEL investment units. In doing so, MJIA aims to raise their awareness of improving MEL investment unit price and the company’s performance, and thereby continuously enhance the value the company delivers to its investors over medium- to long-term.

Basic Philosophy

Close ties between the Mitsubishi Estate Group and Mitsubishi-related industrial and financial institutions enable clients to benefit from investments chosen to yield either a stable cash flow or capital gains. In sourcing high-value properties, MJIA focuses on medium- and long-term investment returns, and buy-in at reasonable prices. This approach yields exceptional asset values, and delivers outstanding investment opportunities to clients.

Establishment of a Product Governance System

MJIA will establish a system to ensure effective quality control in each process from formation to management so as to acquire real estate and other assets at appropriate prices and manage these financial products appropriately based on the basic philosophy outlined above.

Measures when Forming Financial Products

• When forming financial products, MJIA will verify whether the product meets the true needs of its customers by comprehensively considering the reasonableness of risk, return and cost, and verifying whether the investment has been evaluated from a medium- to long-term perspective.
• In addition, MJIA will determine the appropriate target customers for each financial product and strategically collaborate with financial institutions involved in sales in order to realize the best interests of our customers.

Measures after Provision of Financial Products

• MJIA will continuously verify the actual performance of financial products as well as the initial business plans for products at the time they were formed, conduct quantitative and qualitative factor analysis, and flexibly review the plans, etc. to ensure the best interests of its customers.
• MJIA does not currently outsource asset management.

Provision of Understandable Information to Customers

MJIA will provide easy-to-understand information about its management structure and product governance system, etc. to help customers choose better financial products.

Basic Philosophy

The three product lineups of Nippon Open Ended Real Estate Investment Corporation (JOE), the Mitsubishi Estate Logistics REIT Investment Corporation (MEL) and private real estate funds enable clients to benefit from investments chosen to yield either a stable cash flow or capital gains. By sourcing and delivering high-value properties, MJIA strives to realize its clients' best interests.

Establishment of a Product Governance System

• MJIA conducts multiple layers of checks and verifications in accordance with its prescribed decision-making processes in each process from the formation to the management of financial products. This includes the involvement of independent management departments separate from business divisions.
• MJIA has also established multiple conference bodies such as the Executive Committee made up of members such as the management team (outside real estate appraisers also attend meetings for certain matters), the Compliance & Risk Management Committee (outside attorneys also attend meetings for certain matters), and the Fund Management Council for Internal Reporting, in addition to the Board of Directors. For each project, these conference bodies verify whether the formed/managed financial products meet the true needs of customers and whether MJIA is offering products that are in the best interests of customers, etc., in each process from formation to management as necessary.
• MJIA has established various internal rules based on laws and regulations, etc. with the aim of ensuring appropriate quality control in each process from the formation to management of financial products. MJIA reviews these rules in a timely and appropriate manner based on the PDCA cycle to ensure the effectiveness of product governance. In FY 2024, MJIA partially revised the method for selecting real estate appraisal companies.

Measures when Forming Financial Products

• MJIA engages in direct dialogue with customers and exchanges opinions with financial institutions involved in sales in order to understand the true needs of its customers and determine the appropriate target customers for each product.
• When forming financial products, MJIA verifies whether the product meets the true needs of its customers from the perspective of whether the investment has been evaluated from a medium- to long-term perspective. This verification is carried out by the Executive Committee made up of the management team, external experts, etc.
• When engaging in transactions such as sales, business outsourcing, etc. with interested parties in the formation of financial products, MJIA’s Compliance & Risk Management Committee made up of the management team, external attorneys, etc. verifies the reasonableness and appropriateness of transaction amounts, including transaction terms and conditions and transaction details, from the perspective of whether or not the transaction is contrary to the best interests of customers.

Measures after Provision of Financial Products

• MJIA engages in direct dialogue with customers and exchanges opinions with financial institutions involved in sales about the operational status of financial products.
• In addition, the operational status of financial products (including customer complaints and requests) is regularly reported at the Fund Management Council for Internal Reporting made up of the management team and other members, and MJIA continuously verifies the actual performance of the financial products as well as the initial business plans for products at the time they were formed, conducts quantitative and qualitative factor analysis, and flexibly reviews the plans, etc. MJIA is also striving to understand the latest market information through the Fund Investment Council for Internal Reporting and other means, and to share this information internally. In addition, MJIA utilizes the knowledge and expertise it has accumulated to form better products in the future.
• When making important decisions or conducting transactions with interested parties, etc. in connection with products that MJIA is currently managing, MJIA verifies such matters at our Executive Committee and Compliance & Risk Management Committee made up of the management team, external experts, etc. and strive to achieve the best interests of our customers, just as MJIA does at the product formation stage.

Provision of Understandable Information to Customers

• MJIA’s investment philosophy, product lineup, and performance, etc. are published on the MJIA website.
• Information about MJIA's management structure and product governance system as well as the characteristics and performance of MEL products is published on the MEL website and in MEL disclosure materials.
• JOE investors are able to check information about MJIA's management structure and product governance system as well as the characteristics and performance of JOE products by accessing the JOE website using a dedicated password.

MJIA:

https://www.mecinvest.com/en/company/philosophy.html
https://www.mecinvest.com/en/fund/lineup.html

MEL:

https://mel-reit.co.jp/en/esg/governance/corporate.html
https://mel-reit.co.jp/en/ir/library.html

JOE:

https://joe-re.com/(in Japanese only)