Kenedix Advisors recognizes that it has a social responsibility to manage and use personal information appropriately. Therefore, we have established the policies outlined below, and will strive to implement, maintain and improve them.

1. Basic policies

Kenedix Advisors (hereafter, “the Company”) recognizes the importance of personal information. Therefore, the Company resolves to respect and observe all legal regulations and social obligations that arise as part of its collection and use of personal information. The Company will also review its structure for archiving personal information on a periodic basis and continuously seek to make improvements.

2. Policies on the collection, use and provision of personal information

The Company resolves to adopt appropriate methods for collecting personal information, and to disclose, disseminate and clarify the objectives and intended uses of such information. It will not use this information in any way that exceeds the scope of use defined herein without the informed consent of the individual him/herself. The Company resolves to follow strictly the legal standards for disclosing or providing this information to a third party.

3. Intended use of personal information

The Company collects personal information for the following purposes:

1. In order to properly exercise its rights and duties under legal regulations
2. To confirm and provide a record of consultations and visits to the conduct of company business
3. To use the information in general clerical activities and related or appended paperwork as part of the Company’s core business operations
4. In order to carry out the required research and analysis, document collection and various types of notification that are included in the Company’s business activities
5. In order to confirm the identity of the individual submitting applications or concluding contracts, as a part of the Company’s business activities
6. To provide information to third parties within the scope of activities that are necessary to carry out the objectives listed in items 1) - 5), above.

4. Disclosure and provision of personal information to third parties

The company will not disclose or provide personal information to third parties, except under the following circumstances:

1. When the individual consents to release the information
2. In situations where disclosure is required by law
3. In situations where the information is needed to protect the person’s life, personal safety or property, and circumstances make it difficult to obtain the individual’s consent
4. In cases where the Company is required, by law, to provide the information to a national or local government organization or their direct representative, in cooperation with their activities, and where any effort to obtain the consent of the individual involved might compromise those activities.
5. In cases where the Company is providing the information to a contracted service provider, under careful supervision, with the intent of fulfilling the objectives for which the information was collected.
6. In cases where the disclosure or release of the information has been approved, under the terms of the Personal Information Protection Law and related legislation.

5. Supervision of subcontractors

If the Company discloses or provides personal information to outside service providers, it will carefully monitor the contracted service provider to ensure that the information is used safely and properly.

6. Measures to manage personal information safely

In order to manage the personal information that it collects in a proper and secure manner, the Company has established measures to handle the information appropriately, which prevent any unauthorized access, deletion, falsification or disclosure of the information.

7. Process for disclosing and revising personal information

Any questions or requests regarding the disclosure or revision of personal information, or requests to halt this use, should be directed to the contact addresses and phone numbers listed below:

Personal Information Inquiry Center, Kenedix Advisors, Inc.
KDX Shimbashi Building 5F, 2-9 Shimbashi 2-chome, Minato-ku, Tokyo  105-0004
Phone: (81-3) 3519-4056
Hours of operation: 10AM-12 Noon, 1PM-5PM
(excluding Saturdays, Sundays and Holidays)

Kenedix Advisors is a member of the Japan Securities Investment Advisers Association, a certified investor protection organization. This association offers complaint resolution and consultation services regarding the handling of personal information by companies that are members. The Association’s contact address is:
Japan Securities Investment Advisers Association
Complaint and consultation office (Personal Information)
Tokyo Shoken Kaikan 7F, 1-5-8 Kayabacho, Nihombashi, Chuo-ku, Tokyo 103-0025
Phone: (81-3) 3663-0505
Hours of operation: 9AM-5PM
(excluding Saturdays, Sundays and Holidays)

8. Process for disclosure or correction of personal information

The above policies on the collection and use of personal information may be revised or altered as required by changes in legal regulations.

Note:

Any changes or deletions to the above policy must be approved by the Board of Directors.
Resolved: September 26, 2007
Implemented: October 1, 2007