NIPPON REIT Investment Corporation

Securities code:3296

JAPANESE

Privacy Policy

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1.Basic Policy

NIPPON REIT Investment Corporation (“NIPPON REIT”) shall comply with the Act on the Protection of Personal Information (Act No. 57 of 2003, as amended), the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (Act No. 27 of 2013, as amended; the “Number Act”) and other relevant laws and regulations as well as guidelines (the “laws and regulations, etc.”), and endeavor to properly handle, protect and manage personal information.

2.Purposes of Use of Personal Information

2-1. Purposes of Use of Personal Information

NIPPON REIT will use the personal information it has obtained only within the scope of the following purposes. Unless otherwise authorized by laws and regulations, etc., NIPPON REIT will not use the personal information beyond the scope of the following purposes without obtaining consent from the relevant individuals in advance.

(a) Implementation of tasks related to the exercise of rights by the unitholders and fulfilment of obligations of NIPPON REIT, pursuant to the Act on Investment Trusts and Investment Corporations and other relevant laws and regulations
(b) Administration on information of NIPPON REIT unitholders, including preparation of the unitholders registry and other data, and provision of information to the unitholders
(c) Borrowing of funds, issuance of investment corporation bonds and offering of investment units by NIPPON REIT
(d) Confirmation and responses with regard to such matters as inquiries to NIPPON REIT, requests for its materials and visitation of NIPPON REIT
(e) Implementation of such tasks as surveys, analyses and investigations for the management of assets of NIPPON REIT
(f) Implementation of tasks related to acquisition and transfer of assets by NIPPON REIT as well as leases, administration and operation of real properties (including verification at the time of transaction, credit research and surveys on right holders)
(g) Proper and smooth implementation of IR activities for NIPPON REIT and other operations of NIPPON REIT
(h) Implementation of other operations or clerical works that are incidental or related to the items above and deemed necessary

2-2. Purposes of Use of Specific Personal Information

Notwithstanding 2-1. above, NIPPON REIT’s purposes of use of specific personal information shall be as follows:

(1) Affairs related to Individual Numbers for officers (including dependent relatives of the officers) (including affairs related to the following)
(a) Affairs related to withholding tax to be performed by the employer
(b) Affairs related to inhabitants tax on individuals to be performed by the employer
(c) Affairs related to employment insurance to be performed by the employer
(d) Affairs related to health insurance (coverage / benefits payment) to be performed by the employer
(e) Affairs related to employees’ pension insurance (coverage) to be performed by the employer
(2) Affairs related to Individual Numbers other than for officers (including dependent relatives of the officers) (including affairs related to the following)
(a) Affairs of preparing records of payment of remuneration, fees, etc
(b) Affairs of preparing records of payment of distributions and interest on funds
(c) Affairs of preparing records of payment of real estate usage fees, etc.
(d) Affairs of preparing records of payment of compensation for acquisition of real estate, etc.
(e) Affairs of preparing records for financial instruments transactions, etc.
(f) Other affairs of preparing statutory records, etc. on which the provisions of laws and regulations require Individual Numbers to be stated

3.Collection of Personal Information

3-1.Collection of Personal Information

When NIPPON REIT collects personal information, it shall do so through legitimate and fair methods. In this regard, NIPPON REIT shall not employ fraudulent or unjust means to collect personal information, and shall not obtain personal information from any third party that conducts unjust activities such as illegal collection of personal information when NIPPON REIT knows that it is leaked personal information, etc.
When NIPPON REIT directly obtains personal information from individuals in writing or through the website, etc., it shall clearly indicate the purposes of use to them in advance. However, indication of the purposes of use may be omitted when they are evidently understood from the circumstances in which such collection is made, or when such collection is based on laws and regulations, etc.
In terms of sensitive information, NIPPON REIT shall not obtain, use or provide it to third perties without obtaining consent from the relevant individuals in advance, unless otherwise authorized by laws and regulations, etc..

3-2. Collection of Individual Numbers

Notwithstanding 3-1. above, NIPPON REIT’s right to request that the person or another person in charge of affairs related to Individual Numbers provide Individual Numbers shall be limited to cases where necessary for processing the affairs set forth in 2-2. In addition, the request for provision of Individual Numbers shall be made at the point in time when the need arises for processing the concerned affairs or at the point in time when it becomes foreseeable that the concerned affairs will take place.

3-3. Identity Verification

In receiving provision of Individual Numbers, identity verification shall be performed by the methods provided in Article 16 of the Number Act. In addition, in the case of an agent, confirmation of the agent’s identity, confirmation of the authority of representation and confirmation of the person’s Individual Number shall be performed by the methods provided in said Article.

4.Restrictions on Provision of Personal Information to Third Parties

4-1. Restrictions on Provision of Personal Data to Third Parties

Except for the following cases, NIPPON REIT shall not disclose or provide personal information it owns to any third party.

(a) When consent has been obtained from the relevant individuals
(b) When disclosure or provision is based on laws and regulations
(c) When it is necessary to do so for protecting people’s lives, bodies or estates, in cases when it is difficult to obtain consent from the relevant individuals
(d) When it is necessary to do so particularly for improvement in public health or sound development of children, in cases when it is difficult to obtain consent from the relevant individuals
(e) When it is necessary to cooperate with national administrative organs, local governments or parties entrusted by them in conducting administrative operations designated by laws and regulations, in cases when obtaining consent from relevant individuals may cause problems in conducting such operations
(f) When NIPPON REIT provides personal information to subcontractors which it supervises appropriately, within the scope necessary for achieving the purposes of use
(g) When disclosure or provision is otherwise approved by laws and regulations, etc.

4-2. Restrictions on Provision of Specific Personal Information to Third Parties

Notwithstanding 4-1. above, NIPPON REIT shall not provide specific personal information to any third party except in the cases listed in the items of Article 19 of the Number Act.

4-3. Restrictions on Provision of Personal Data to Third Parties in Foreign Countries

NIPPON REIT shall not provide personal data to third parties in foreign countries without obtaining consent from the relevant individuals in advance, unless otherwise authorized by laws and reglations, etc..

5.Security Management of Personal Data

In managing personal data it handles, NIPPON REIT shall take necessary and appropriate security management measures pursuant to laws and regulations, etc. in order to prevent leakage, losses or damages of the personal data and ensure its safety in other aspects.

6.Outsourcing of Handling of Personal Data

NIPPON REIT may totally or partially outsource handling of personal data it has obtained within the scope necessary for achieving the purposes of its use. When it does so, necessary and appropriate supervision of the consigned parties, such as requiring strict safety management measures, so that they should securely manage the personal data.

7.Disclosure, Corrections, Deletions and Suspension of Use, Etc. of Holding Personal Data

When relevant individuals request for disclosure, corrections, deletions, suspension of use, etc. of their personal data NIPPON REIT owns, NIPPON REIT shall respond to their requests pursuant to laws and regulations, etc. after confirming their identities through predetermined procedures. For the reguests, please contact the following and you will be informed of necessary procedures and other matters. Furthermore, you may be reguested to bear predetermined fees for the reguests.

8.Inquiries Relating to Handling of Personal Information

Please contact the following for inguiries relating to handling of personal information.

<Contact for Inquiries>

Asset Management Company of NIPPON REIT
Address Koku Kaikan 3F
18-1, Shimbashi 1-chome, Minato-ku, Tokyo 105-0004
Name Corporate Planning Department, Finance & Planning Division Sojitz REIT Advisors K.K.
Phone +81-3-5501-0080
URL http://www.sojitz-sra.com/en/
Hours of operation 9:00 a.m. - 5:30 p.m. (Japan standard time; Monday through Friday excluding public holidays)

As for references and other inquiries of matters recorded in the register of unitholders, etc., please contact the transfer agent indicated below.

Transfer Agent for NIPPON REIT
Address 1-1, Nikkouchou, Fuchu-shi, Tokyo
(Mail to) Shin-Tokyo Post Office P.O.B. No.29, 137-8081
Name Corporate Agency Division Mitsubishi UFJ Trust and Banking Corporation
Phone 0120-232-711 (toll-free) (within Japan)
URL http://www.tr.mufg.jp/daikou/ (Japanese)
Hours of operation 9:00 a.m. - 5:00 p.m. (Japan standard time; Monday through Friday excluding public holidays)

9.Continuous Improvement of the Personal Information Protection System

This privacy policy may be revised due to revisions to laws and regulations, etc. and other reasons. Furthermore, NIPPON REIT shall work to reinforce and improve its initiatives on protecting personal information by reviewing this privacy policy as needed in addition to its changes pursuant to revisions and abolitions of laws and regulations, etc.

Established on 15 April, 2014
Latest revised on 14 August, 2017

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