Our Policy for Customer-Oriented Business Conduct

In response to the publication by the Financial Services Agency on March 30, 2017, of the “Principles for Customer-Oriented Business Conduct” (“the Principles”), Mitsui Fudosan Frontier REIT Management Inc. (“MFF”) formulated the following policy.
MFF is involved in management of assets only for Frontier Real Estate Investment Corporation (“FRI”), and so it has not set out policies to address Principle 5 (Notes 1, 2, and 4), Principle 6 (Notes 1, 2, 3, 4, 6, and 7) or Supplementary Principles 1-5 of the Principles, which relate to the sale and recommendation of financial products and services, etc., and the structuring of financial products.

1. Formulating and announcing a policy for
customer-oriented business conduct

In addition to formulating and announcing a clear policy for achieving customer-oriented business conduct, MFF shall confirm and announce the status of initiatives related to this policy at regular intervals. The policy shall also be revised, as necessary.

2. Acting in the best interests of the customer

MFF shall maintain high levels of expertise and business ethics, conduct its operations with fairness, integrity, and act in the best interests of the customer. MFF shall also strive to ensure that such business conduct remains central to its corporate culture.

3. Managing conflicts of interest appropriately

MFF shall maintain a firm grasp on the possibility of conflicts of interest with customers, and in cases where such possibilities exist it shall manage conflicts of interest appropriately in accordance with laws, regulations, and internal rules.

4. Clarifying commissions and other fees

MFF shall provide information to customers to enable them to understand the asset management fees from FRI, including the services to which the consideration relates.

5. Providing important information in easily understood form

MFF shall provide important information related to FRI in a form that can be easily understood by customers.

6. Offering services that are suitable for the customer

MFF shall work to understand the needs of customers, and conduct its business with those needs in mind.

7. Establishing frameworks, etc. that motivate
employees appropriately

One of the metrics used by MFF when evaluating all officers and employees shall be the proper performance of duties, such as acting in the best interest of customers, and a compliance approach that emphasizes managing conflicts of interest appropriately. MFF shall also establish training for all employees, a framework to motivate them appropriately, and a corporate governance system.

Issued March 2018
Last Revised June 2025

Status of initiatives

1. Acting in the best interests of the customer

FRI’s basic policy is to provide stable dividends over the medium to long term.
By leveraging the sponsor pipeline to achieve external growth, making additional investments in properties and upgrading tenants to achieve internal growth, and maintaining a sound financial position, MFF seeks to provide stable dividends as well as maximize unitholder value.

2. Managing conflicts of interest appropriately

In addition to consistently acquiring high quality properties by leveraging Mitsui Fudosan’s sponsor pipeline to the maximum extent possible, we also utilize in our management the extensive know-how that the Group has accumulated in the operation of commercial facilities. However, there is a risk that conflicts of interest could arise between the customer and MFF and related parties. For this reason, in addition to complying with laws and regulations, etc., MFF has put in place organizational structures and internal rules, such as the “ Rules Concerning Conflicts of Interest,” to prevent unfair or inequitable transactions before they occur.
Our policy and management system for dealing with transactions that could arise risk conflicts of interest is as attached here.

Report on the operation system etc. of issuers etc. of real estate investment
　trust securities (Japanese only)

3. Clarifying commissions and other fees

The structure of the remuneration that MFF receives from FRI for managing assets is set out in FRI’s Articles of Association, and is also disclosed in the securities report released every period. The specific amounts of remuneration are also disclosed in the asset management report released by FRI every period.

4. Providing important information in easily understood form

In addition to disclosing information in accordance with laws and regulations, etc., with the aim of ensuring transparency, MFF discloses, on a timely basis and in an easily understood form, the information related to FRI it deems appropriate and necessary to facilitate investment judgments by unitholders.

5. Offering services that are suitable for the customer

MFF manages assets with the aim of generating stable income over the long term by investing mainly in commercial facilities, while maintaining an awareness, developed through its IR activities, of the opinions and needs of unitholders.

  • IR meetings for domestic and overseas institutional investors
  • IR meetings for individual investors
  • Participation in seminars held for individual investors by various organizations

6. Establishing frameworks, etc. that motivate employees appropriately

In order to consistently achieve a high level of asset management operations, MFF focuses on the development of professional human resources. To this end, not only does it support training and examinations aimed at the acquisition and maintenance of specialist qualifications, but it also provides backing for the acquisition of a wide range of skills and knowledge required for the business.
In addition, by implementing ongoing training and initiatives on the theme of compliance and environment, social and governance (ESG), it seeks to instill a thorough awareness of customer-orientated business conduct, and employee evaluations include assessments of matters related to compliance.

Updated September 2025