TLC REIT Management Inc. (hereinafter the "Company") that, with respect to the solicitation policy, required to be set out in accordance with the Law on Sales of Financial Products (2000, Law No. 101, including subsequent revisions), has established the following rules and promises to comply with them to sell financial instruments properly so that we can provide better financial products and services to our clients and react to our clients responsibly.

1. Matters to be considered in light of our clients' knowledge, experience, financial conditions and purposes of making contracts related to the sales of financial instruments
   1. (1)In solicitation or entering into a contract for the sales, etc., the Company makes efforts to provide advice and explanations appropriately taking the followings into consideration; the clients' knowledge level, experience, financial conditions and the purposes of making contract regarding the sales of financial instruments.
   2. (2)In order for our clients to enter into the transaction at their own judgment and risk, the Company will make efforts to obtain our client's understanding on important matters such as the product contents and risk of it by delivery of relevant documents and/or other appropriate means.
2. Matters to be considered for clients regarding solicitation means and its time slots
   1. (1)The Company will carry out proper solicitation in accordance with the Financial Instruments and Exchange Law, and other relevant laws and guidelines.
   2. (2)The Company makes efforts not to carry out solicitation during times or at places inconvenient to our clients.
3. Matters for securing proper solicitation
   1. (1)The Company makes efforts to maintain internal organization structure in order to carry out proper solicitation.
   2. (2)The Company makes efforts to improve our services and deal with any clients' complaints or request sincerely.

1. Presentation of Financial Instruments Business Operators
   TLC REIT Management Inc. Kanto Regional Finance Bureau (Financial Instruments) Registration No.2370
2. The Company carries out Investment Management Business.
3. The Company is a member of The Investment Trusts Association, Japan.
4. The fees payable by the clients for a contract for a financial instrument transaction is determined and based on mutual agreements considering the type of product and contract.
5. Securities dealt with by the Company (such as real estate trust beneficiary interests, interests in collective investment scheme, etc.) may ultimately experience a principal deficit or a loss more than the initial principal amount depending on the fluctuations in the value of the targeted investment real property and its leasing situations. The Company does not guarantee the return of the principal sum and generation of interests. As such, clients shall bear the risk of their investment value of securities becoming lower than the principal amount of securities invested.
   

The Company will make every effort to respond to customers' complaints, etc. sincerely and promptly to obtain customers' understanding in accordance with the Company's "Complaints Handling Rule". The Company's standard procedures for settling complaints are as follows:

1. Receipt of the customer's complaint
2. Hearing to the Company's person-in-charge, and renew of settlement proposal
3. Presentation of settlement proposal, and settlement

The contact information for filing a complaint with the Company is as follows:
Complaints Office:
Strategic Planning Department, TLC Comforia Investment Management INC.
Address: 16-3, Dogenzaka 1-Chome, Shibuya-ku, Tokyo, 150-0043
Tel: 03-6415-6200
(Mon-Fri 9:30am to 6:00pm excluding weekends, holidays)

In addition to the procedures mentioned above, the Company also handles customers' complaints for their settlements through the following organization. This organization undertakes the task of settling complaints from The Investment Trusts Association, Japan, of which the Company is a member, and handles customer's complaints. To file a complaint through this association, please contact the following:

NPO Financial Instruments Mediation Assistance Center
Address: 1-13 Kayabacho 2-Chome, Chuo-ku, Tokyo, 103-0025
Tel: 0120-64-5005(From Japan only: toll free)
(Mon-Fri 9:30am to 5:00pm excluding weekends, holidays)

The standard process of settlement through the center is as follows:

1. Complaint from the customer
2. Communication of the complaint to the Company.
3. Negociation and settlement between customer and the Company

Please contact the center for further information.
Moreover, the Company will solve conflicts between customer and the Company through mediation held by above-mentioned NPO Finance Instrument Mediation Assistance Center.
This center is contracted by the Investment Trusts Association, Japan, with whom the Company is registered as a member, to mediate conflicts. The mediation procedure will take place at the mediation committee.
Please contact the above for resolving conflict with the Company.
The standard process of mediation through the center is as follows:

1. Request for mediation from the customer
2. Acceptance of the mediation and the selection of mediation committee
3. Payment of the filing fee from the customer
4. Hearing to both the customer and the Company by the mediation committee
5. Proposal and acceptance of mediation

Please contact the center for further information.

TLC REIT Management Inc.