EGW Asset Management Inc. (hereinafter referred to as “EGW Asset Management”) conducts our business by applying a first priority policy on the security and satisfaction of all of our clients (hereinafter referred to as “Clients”) and that we genuinely provide our services using market standard pricing and policies.

EGW Asset Management has accepted “Basic principles on Client-Oriented Business Conduct” which the Financial Services Agency announced on March 30th, 2017, having established these policies, and we will continue to conduct our business for the security and satisfaction of all of Clients.

We will review all such policies on a periodic basis and announce periodic disclosures to clients when required regarding the status of our compliance with such policies and make an effort to realize better client-oriented business conduct.

(1)   Pursuit of Clients’ best services 

We provide commercial real estate investment management and advisory services in Japan for off-shore Clients and those services overseas for Japanese Clients.

There are many executives and employees who have various backgrounds in real estate industry, financial industry, hotel business, or construction industry and have been involved in real estate transactions for many years both in Japan and overseas in EGW Asset Management. We will continue to use the collective deep knowledge accumulated through these such experiences and high integrity that can be accepted globally, increase our asset management of overseas and domestic Clients steadily and securely, and lead them to Clients’ security and satisfaction.

(2)   Proper Management of Conflict of Interest

With the aim to prevent Clients’ interests from unjustifiable infringement, we will comply with the internal rules which stipulate essential points when a Client and our interested party (Ourselves, our executives and employees, our shareholders, affiliated companies, SPC etc. which we have concluded Discretionary Investment Contract etc. with and can have significant influences on) enter into a transaction (hereinafter referred to as “Interested Party Transaction”) and manage Interested Party Transaction in an appropriate manner.

Also, we will sufficiently acknowledge there exists possible Conflict of Interests between a client and another client for both of which we manage their assets based on Discretionary Investment Contract etc., and establish necessary internal system in order not to impair the interest of each client.

At EGW Asset Management, when we conduct a transaction, our Compliance Department acts independently from the investment sales division and will review the transaction in advance from the viewpoint of corresponding to Interested Party Transaction or Conflict of Interests or not. When a transaction is showing a potential conflict or related Party Transaction or Conflict of Interests, it will be deliberated by the compliance committee which includes an outside member who is a qualified attorney and familiar with Financial Instruments and Exchange Law and verified and managed in an appropriate manner in order not to impair the interest of each Client.

(3)   Clarification of Pricing

We have a sufficient level of communication with each Client from the planning stage of our service and we decide an amount of fees etc. objectively and adequately after both the Client and us with good faith agreeing to such fee.

We clearly indicate the amount of fees etc., including which service corresponds to each fee item or under what conditions each fee item will be paid, on Discretionary Investment Contract etc. and explain it verbally to each Client.

(4)   Provision of Important Information in an Understandable Manner

Our executives and employees are familiar with real estate markets of Japan and other countries including European and US countries by long-term experience of real estate investment in Japan and other countries.

When we enter into a transaction, we clearly explain all risks and return assumptions on the proposing financial product and details of its structure, and business practices unique to Japanese real estate market for foreign Clients, and those unique to the real estate market of invested country for domestic Clients. In addition, during continuous transactions, we have close communication with a Client and we report investment status or contingencies, and provide important information to all clients regarding investment opportunities at our either MD or CEO level in Japan.

(5)   Our Clients are in a wide variety of entities such as foreign investment funds including European and American, domestic business companies, and institutional investors. We will have a sufficient level of communication with each Client from the planning stage of our service, properly understand the Client’s characteristics, asset status, view about investment, experience and needs, propose suitable financial product for the Client, and provide most appropriate service.

(6)   We have placed our Compliance Manual which primarily stipulates our conduct and transparent business practice for all Clients on our basic principle and established the system by which every executive or employee in Japan or overseas branch office can always find its latest version.

Also, we have Compliance Training for all of our executives and employees both in Japan and overseas branch every year and make them aware of actions for seeking Clients’ best profits, fair services, and appropriate management Conflict of Interests.

At EGW Asset Management, as our mission, each division is dealing with their members’ performance of these actions on one’s own responsibility.

Moreover when we evaluate the performance of each executive or employee, whether he or she performs these actions is included in the performance in order to motivate each executive or employee to perform these actions.