Policies on Customer-Oriented Business Conduct (6)

6.Providing Suitable Service to Customers

TSCM will provide and recommend products and services that we judge to be suitable for customers, after understanding the customer’s trading experience, knowledge, financial situation, investment policy, transaction purpose, etc. In addition, TSCM will continue to conduct appropriate follow-ups based on the customer’s wishes, with consideration for long-term perspectives.

Specific Policy Content and Implementation Status

● Providing Suitable Service: TSCM has established the solicitation policy and strives to ensure appropriate solicitation activities in order to provide proposals and services suitable for the customer’s transaction purpose and financial situation.
TSCM will consider the customer’s trading experience, knowledge, and other relevant information provided in advance, and will provide and recommend products and services based on the customer’s transaction purpose and the characteristics of each transaction/target asset.
In order to ensure that customers can continue transactions safely, TSCM will appropriately report the situation and propose countermeasures and improvement measures as necessary in response to changes in the market environment and target assets.
Note: TSCM does not sell or recommend multiple financial products or services as a combined package.

● Close communication with customers: In order to provide and recommend products and services suitable for customers, TSCM believes that it is essential to hear in detail the customer’s transaction purpose and financial situation.
In addition, given the nature of the products and services we provide, TSCM is entrusted with asset management services primarily by corporate clients who are professional investors or by real estate-related funds invested solely by such investors.
Customers who are professional investors often have knowledge and experience in investing in real estate-related funds, and TSCM considers it essential that the information necessary for customers to make investment decisions is provided in a timely manner.
To this end, TSCM maintains close communication with clients and continues to discuss important matters such as investment policies at the time of forming a fund, entrusting asset management services,　or during the investment period. Based on a deep understanding of the customer’s needs, situation, and other circumstances and background, TSCM strives to conduct appropriate business operations that lead to the provision of products and services suitable for each customer according to the customer’s transaction purpose and financial situation, etc.

● Integrated Product Governance through Coordination: To ensure the best interests of clients, TSCM is committed to the continuous improvement of product design and business operations through information sharing and close coordination between personnel involved in the design and structuring of real estate-related funds and other products (hereinafter referred to as “Structuring Personnel”) and client-facing sales personnel (hereinafter referred to as “Sales Personnel”). For example, for each fund product, Structuring Personnel and Sales Personnel share and coordinate acquired, analyzed, and verified information and data throughout the entire product lifecycle. This includes data verified during the product design and structuring phase, such as the complexity of investment schemes, their risk characteristics, and the underlying assumptions and hypotheses, as well as customer attribute information derived from actual investment and sales records. This information sharing and coordination enables us to ensure the effectiveness of product governance.
Currently, both our Structuring Personnel and Sales Personnel consist of internal officers and employees. However, should we engage external third parties as sales representatives (hereafter, “Entrusted Sales Agents”), the same policy and approach of integrated coordination and information sharing will apply. Maintaining the same level of communication and coordination with Entrusted Sales Agents as with internal personnel, we strive to ensure effective product governance and to act in our clients' best interests.

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