Principles for Customer-Oriented Business Conduct

Principles for Customer-Oriented Business Conduct

AEON Reit Management Co., Ltd. (the “Company”) has adopted the Principles for Customer-Oriented Business Conduct announced by the Financial Services Agency on March 30, 2017（the”Principles”）and has established the following policy to carry out business conduct oriented to AEON Reit investment corporation from which the Company is entrusted with business pertaining to asset management (the “Investment Corporation”) and its investors (the “Investors”) (the Investment Corporation and the Investors are collectively referred to as the “Customers”) based on the Company’s corporate philosophy and action guidelines. Since the company is solely involved in asset management for the Investment Corporation, the Company does not set out policies regarding the sale or recommendation of financial products and services, or the structuring of financial products, requiring clarification in Principle 3 (Note), Principle 5 (Notes 1, 2, and 4), Principle 6 (Notes 1, 2, 3, 4, 6, and 7), and Supplementary Principles 1 to 5.

Established on Jun 27,2018
Revised on Oct 26,2021
Revised on Jun 30,2023
Revised on Jun 27,2024
Revised on Jun 27,2025
Revised on Sep 26,2025

• The company formulates and discloses clear policy for achieving Customer-Oriented Business Conduct Based on the corporate philosophy*「We contribute to local communities and maximize unitholder value through acquiring, and raising the value of, retail properties operated by Aeon Group.」, and announces the progress of implementing the policy after going through the PDCA cycle. In addition, the Company will periodically review the policy to improve its business conduct.

• Our retail business background makes us an asset management company with unique strengths. Taking full advantage of these strengths, we acquire, and raise the value of, retail properties operated by Aeon Group. By providing support for the operation of more attractive retail properties, we aim to maximize unitholder value. Moreover, the stores that we own are an integral part of the communities in which they are located, and so that we may continue to be a company that receives the support and loyalty of customers, we partake in community contribution activities as an active community member.

• The Company maintains a high level of expertise and professional ethics, performs business sincerely and fairly to the Customers and optimizes the profit of the Customers as described below. Additionally, the Company endeavor to establish such business operation as its corporate culture.

• The Company utilizes the collective strengths of the Aeon Group* and aims to achieve external growth by expanding the investment assets of the Investment Corporation, maintenance and improvement of asset values and internal growth through investment in revitalization projects. At the same time, the Company controls expenses appropriately and strives to provide a stable increase in profit distributions.
  

• The Aeon Group refers to the group consisting of AEON Co., Ltd., which is a pure holding company, and its consolidated subsidiaries and equity-method affiliates.

• The Company takes into account the environmental, social and governance (ESG) criteria in its overall operations and cooperates with stakeholders to meet such criteria.

• The Company recognizes the importance of the appropriate management of conflicts of interest between the Investment Corporation and AEON Co., Ltd., which is the sponsor of the Company, and other related parties of the Company in connection with asset management business that the Company carries out for the Investment Corporation and establishes internal rules* to manage such conflicts of interest. The company strictly follows the rules for transparent decision-making under such internal rules and appropriately ensures the interest of the Investment Corporation and discloses the status of related-party transactions in the press releases, disclosure documents, etc. of the Investment Corporation appropriately and in a timely manner.

• The Company obtains prior consent of the Investment Corporation based on the approval of the Board of Directors of the Investment Corporation for transactions with related parties, etc. specified in the Act on Investment Trusts and Investment Corporations (the “Investment Trust Act”) pursuant to the provisions of the Investment Trust Act. In addition, the Company has adopted a set of rules for related-party transactions as its internal rule and implements such rules as described below;
  When the Company carries out certain transactions (purchase, sale and lease of real estate, etc.; property management outsourcing; placing orders for construction, etc.; financing, etc.) between a related party specified in the rules regarding related-party transactions and the Investment Corporation, prior approval of the Compliance Officer shall be obtained. Furthermore, the Investment Committee and the Compliance Committee, in which third parties having no relationship with the Aeon Group participate as external members, shall review and approve such related-party transaction. The basic rule is that the approval of the Investment Committee and the Compliance Committee may not be obtained without the participation and consent of such external members.

• The Company periodically announces in a comprehensible manner, fees and commissions for the asset management business conducted by the Company and other expenses to be incurred by the Investment Corporation including the description of the services, for which such fees, etc. are incurred, in statutory disclosure documents, etc. of the Investment Corporation.

• The Company performs appropriate statutory and timely disclosure, from the perspective of the Investors, of important information including descriptions of risks associated with investment in the Investment Corporation.
  In the preparation of information materials for the Investors, the Company respects the feedback obtained from the recipients of the information through investor surveys, etc., prepares documents that are comprehensible and endeavor to provide information in good faith including timely and appropriate updates of the website of the Investment Corporation.

• The Company performs fair information disclosure in compliance with the fair disclosure rules.
  The Company regularly carries out IR activities for both individual and institutional Investors and provides information in a timely manner in English for international Investors, in an effort to provide information appropriately in view of the Investors’ asset management experience and knowledge and investment purposes and needs.

• The Company has adopted customer-oriented business conduct as the code of conduct of its officers and employees.
  The Company will establish the practice of customer-oriented business conduct by performing goal management in accordance with such code of conduct on an individual basis and through having officers and employees engage in self-learning such as participation in trainings* in and outside the Company and the acquisition of technical qualifications.

• The internal and external trainings of the Company include operational training, code of conduct training, compliance and other types of training. Compliance training is generally provided on a monthly basis based on the Company’s annual compliance program with the aim of raising employees’ compliance awareness including conflict-of-interest management.