SANKEI REAL ESTATE Inc. (hereinafter, “SANKEI REAL ESTATE”) sets the following basic policy on proper handling of individual numbers and specific personal information (hereinafter, “specific personal information, etc.”) pursuant to the “Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures” (hereinafter, the “Numbers Act”).

1. Name of Business Operator

SANKEI REAL ESTATE Inc.

2. Basic Policy (Compliance with Relevant Laws, Regulations, Guidelines, Etc.)

SANKEI REAL ESTATE shall conduct proper handling of specific personal information, etc. in compliance with the Numbers Act, the Act on the Protection of Personal Information (hereinafter, the “Personal Information Protection Act”) and other relevant laws and regulations, the “Guidelines for Proper Handling of Specific Personal Information (for private entities),” the “(Supplement) Guidelines for Proper Handling of Specific Personal Information in Financial Operations,” the “Guidelines on the Act on the Protection of Personal Information” and other guidelines, etc.

3. Purposes of Use of Specific Personal Information, Etc.

SANKEI REAL ESTATE shall use the provided specific personal information, etc. for the purpose of handling the following affairs. SANKEI REAL ESTATE shall not use specific personal information, etc. beyond the purposes of use even if the person’s consent has been obtained, except in cases where necessary for protection of the life, body or property of humans.

1. Specific personal information, etc. on unitholders, transaction counterparties, etc. (including affairs relating to below)
   • Affairs of preparing reports of payment of remuneration, fees, etc. pursuant to the Income Tax Act
   • Affairs of preparing reports of payment of distributions, distributions of surplus and interest on funds pursuant to the Income Tax Act
   • Affairs of preparing reports of payment of real estate usage fees, etc. pursuant to the Income Tax Act
   • Affairs of preparing reports of payment of consideration for acquisition of real estate, etc. pursuant to the Income Tax Act
2. Specific personal information, etc. on directors (including dependents of directors) of SANKEI REAL ESTATE (including affairs relating to below)
   • Affairs relating to inhabitant tax on individuals pursuant to the Local Tax Act
   • Affairs relating to employment insurance pursuant to the Employment Insurance Act
   • Affairs relating to health insurance (coverage and benefits) pursuant to the Health Insurance Act
   • Affairs relating to employees’ pension insurance (coverage) pursuant to the Employees’ Pension Insurance Act

4. Restrictions on Collection and Provision to Third Parties of Specific Personal Information, Etc.

SANKEI REAL ESTATE shall not collect specific personal information, etc. beyond the affairs listed above under “3. Purposes of Use of Specific Personal Information, Etc.” In addition, regardless of whether or not the person’s consent has been obtained, SANKEI REAL ESTATE shall not provide specific personal information, etc. to third parties unless otherwise permitted by the Numbers Act.

5. Outsourcing of Operations

In cases where SANKEI REAL ESTATE is to outsource processes relating to individual numbers or processes using individual numbers as defined in the Numbers Act, in whole or in part, necessary and appropriate supervision shall be exercised so as to ensure that the parties so entrusted are appropriately taking security control measures equivalent to those to be taken by SANKEI REAL ESTATE itself.

6. Matters Concerning Security Control Measures

SANKEI REAL ESTATE shall comply with rules that it shall separately establish for prevention of divulgence, loss or damage of specific personal information, etc. and other management of specific personal information, etc.

7. Continual Improvement

SANKEI REAL ESTATE shall strive to continually review the content of the Policy and also revise accordingly as needed, and thereby improve the management system, etc. for specific personal information, etc.

8. Contact for Requests for Disclosure, Etc. of Retained Personal Data Pertaining to Specific Personal Information, Etc. and Other Inquiries Concerning Handling of Specific Personal Information, Etc.

In cases where SANKEI REAL ESTATE is requested to be informed of the purposes of use or receives requests for disclosure, correction, addition, deletion, cessation of use, erasure or cessation of provision to third parties pursuant to the Personal Information Protection Act (hereinafter, collectively referred to as “requests, etc. for disclosure, etc.”) of retained personal data pertaining to specific personal information, etc., SANKEI REAL ESTATE shall respond appropriately without delay pursuant to laws, regulations, etc. once verification can be made that the person or legitimate agent is making the requests, etc. However, requests, etc. for disclosure, etc. may not be met in certain cases, such as cases where there is a possibility of harming the life, body, property or other rights and interests of the person or third parties. In such cases, the person or the person’s agent shall be informed of the reasons for such without delay.

The contact below is available to take requests, etc. for disclosure, etc. of retained personal data pertaining to specific personal information, etc. and other inquiries concerning specific personal information, etc.
Also, the contact below is available to take consultations, complaints, etc. concerning the handling of specific personal information, etc. of SANKEI REAL ESTATE, too, which shall be dealt promptly and appropriately by SANKEI REAL ESTATE.

Name	Corporate Planning and Administration Department, Sankei Building Asset Management Co., Ltd.
Address	S-GATE Otemachi-Kita 4F, 2-3-4 Uchikanda, Chiyoda-ku, Tokyo　101-0047
TEL	03-5542-1316
Hours of operation	9:30 to 17:45 (excluding Saturdays, Sundays, national holidays, year-end through New Year holidays and the company’s designated holidays)

However, the contact for the abovementioned inquiries when concerning unitholders is as follows:

Name	Stock Transfer Agency Department, Mizuho Trust & Banking Co., Ltd.
Address	2-8-4 Izumi, Suginami-ku, Tokyo 168-8507
TEL	0120-288-324
Hours of operation	9:30 to 17:45 (excluding Saturdays, Sundays, national holidays, year-end through New Year holidays and the company’s designated holidays)

End

Established on March 5, 2019
Revised on January 23, 2023
Revised on February 1, 2024