Nippon Commercial Investment Corporation (hereinafter referred to as "NCI") sets forth a policy on and adopts measures for personal information protection and hereby declares it as NCI's personal information protection policy.

Basic Policy

NCI recognizes the importance of personal information on the holders of securities (investment securities) issued by NCI based on the Investment Trusts and Investment Corporations Law (Law No. 198 of 1951; hereinafter referred to as the "Investment Trust Law") (hereinafter referred to as "unitholders") and tenants (includes applicants) of properties owned by NCI (real estate in kind and also includes those owned by holding beneficiary interests in trust) (tenants and unitholders hereinafter referred collectively as "customers"). As such, NCI strives for proper handling of personal information as well as its safe and secure management and operation by thoroughly ensuring that all directors are well informed on the Law on the Protection of Personal Information and other legislation, internal rules and other regulations pertaining to personal information protection.
Moreover, NCI will be dedicated to continuous improvement of our system for personal information protection by conducting timely reviews.

Business Operations Involving Personal Information Handling and Purposes of Use

NCI shall use personal information on customers in the business operations specified below and within the scope necessary to accomplish the purposes of use. Further, when the purposes of use of specific personal information are restricted by law, NCI shall not use the information beyond the limitations of use.

Business Operations Involving Personal Information Handling

Business operations at NCI that involve the handling of personal information shall be as follows.

1. Asset acquisition business operations
2. Asset management and operation business operations
3. Asset transfer business operations
4. Business operations relating to capital procurement
5. Business operations incidental to each of the abovementioned business operations
6. Other business operations that NCI is licensed to conduct or business operations incidental to such (includes business operations NCI will be licensed to conduct in the future)

Purposes of Use of Personal Information

1. To exercise the rights of and fulfill NCI's obligations to unitholders
2. To establish and implement policies and measures to ensure smooth relations between NCI and its constituent unitholders
3. To prepare and submit various statements, reports and other documents of NCI in accordance with the Investment Trust Law and other related laws and ordinances, and to create data on unitholders of NCI and other operations aimed at managing information on unitholders
4. To introduce, communicate, and address marketing, etc. in regards to securities issued by NCI
5. To facilitate NCI's issuance of investment corporation bonds and subsequent issuance of investment units
6. To grasp the implementation, management and leasing conditions of leasing the portfolio assets of NCI (includes screening of tenants moving in, management of rent income from tenants, follow-up management after contract terminations and building management after tenants move in), and to collect, compile statistics and analyze data on such
7. To facilitate NCI's acquisition, investigations prior to acquisitions and studies on the acquisition of assets (includes real estate, etc.), and to conduct business operations in relation to follow-up management
8. To facilitate NCI's sale, solicitation of buyers and studies on the sale of assets (includes real estate, etc.), and to conduct business operations in relation to follow-up management
9. To perform other business operations incidental or related to the abovementioned 1. through 8. deemed necessary for NCI to adequately and smoothly implement business operations, and to perform administrative work
10. To provide personal information to third parties in order to accomplish the purpose of use specified under 1. and 9. above

Acquisition, Use, Provision and Entrustment of Personal Information

Acquisition and Use of Personal Information

NCI shall acquire personal information through legitimate means and handle personal information within the scope of the purposes of use to which the person in question has consented. NCI shall not handle personal information beyond the scope of the purposes of use without the prior consent of the person in question.

Provision of Personal Information

In principle, NCI shall not provide nor disclose personal information on customers to a third party unless the prior consent of the person in question is obtained. However, NCI reserves the right to use personal information or provide personal information to third parties without the prior consent of the person in question when required by law or when necessary to protect the life, health, property or other material interests of the person in question or the general public.

In addition, NCI may entrust the handling of personal information on customers to external parties upon the entrustment of business operations. In the event of such, NCI shall maintain its standards for personal information protection by entrusting only to parties carefully selected for their adoption of sufficient measures for personal information protection and by implementing necessary and adequate supervision.

Furthermore, NCI may provide personal information in its possession to third parties in writing, as mail, via the internet or in other forms within the scope necessary to accomplish the aforementioned purposes of use in cases not necessarily stipulated by law. NCI shall suspend provision to third parties upon customer request.

Third Parties Provided with Personal Information

1. The licensed asset management company to which NCI entrusts asset management business operations
2. The counterparties to agreements and other concerned parties to the transaction of real estate, etc. (includes prospective parties)
3. Real estate transaction specialist
4. Financial institutions, insurance companies (includes insurance agents), practicing attorneys, judicial scriveners, land and house surveyors, real estate agents, real estate appraisers and other advisors, etc. engaged in business operations associated with transactions of real estate, etc.

Personal Information Items Provided to NCI

Name, address, telephone number, email address and contract information, as well as other information concerning items within the scope necessary to accomplish the aforementioned purposes of use.

Proper Management of Personal Information

1. NCI shall handle personal information on customers appropriately and with caution and take the uttermost care and necessary and adequate steps for safe management in order to prevent unauthorized access to or loss, destruction, alteration, leakage, etc. of personal information.
2. In the event of an accident, NCI shall promptly adopt a system that will minimize damages and also take corrective action to prevent recurrence.
3. NCI shall hold periodic training sessions so that all directors understand the significance and necessity of compliance with applicable laws and ordinances and the steps for personal information protection, and conduct necessary and adequate supervision.
4. The Executive Director shall oversee the protection of personal information at NCI.

Information Desk for Inquiries on Personal Information

NCI shall promptly respond to requests for disclosure, correction or discontinuance of use, claims or other inquiries concerning personal information from customers within a reasonable time frame. Please address requests for disclosure, correction or discontinuance of use, claims or other queries, comments or inquiries concerning personal information on customers to the information desk below.

Information Desk

Financial Planning Division
Pacific Commercial Corporation
(Pacific Commercial Corporation is the licensed asset management company to which NCI entrusts asset management business operations.)

Address: 1-14-1 Kanda-Jimbocho, Chiyoda-ku, Tokyo 101-0051
TEL: 03-3518-0288 (Business hours: 10:00 a.m. - 5:00 p.m. on weekdays)

How to Request for Personal Information Disclosure, etc.

Customers wishing to request the disclosure of their own personal information are kindly asked to complete the required fields on the designated disclosure request form, enclose the prescribed documents verifying your identity and send it to the aforementioned information desk. Please note that you will be charged a set fee for the personal information disclosure.
*Please contact the information desk for details regarding the procedure.

Date of enactment January 1, 2007
Date of revision January 28, 2009
Tomohiro Makino
Executive Director
Nippon Commercial Investment Corporation