Policies on Product Governance
(Supplementary Policy 3)

(Supplementary Policy 3)
Product Design and Structuring

TSCM prioritizes close communication with our customers to provide and recommend products and services that align with their individual needs. We engage in ongoing discussions regarding important factors such as the type of underlying real estate assets, expected returns and acceptable risk levels, as well as the investment period and policy. Through a thorough understanding of our customers’ needs and financial circumstances, we carefully assess critical aspects of product design and structuring to ensure that the proposed products and services align with their expectations.

Specific Policy Content and Implementation Status

● Actions during Product Design and Structuring

During the product design and structuring stage, Structuring Personnel, who are responsible for structuring real estate-related funds and other products, conduct comprehensive due diligence on the underlying real estate assets from physical, financial, and legal perspectives, in accordance with internal policies and procedural manuals. Following a thorough examination and selection of the appropriate investment structure (which includes financing strategies), we conduct feasibility studies, such as cash flow analysis, to both verify and formulate the investment strategy and business plan.
Should TSCM outsource the solicitation and sales of products to Third-Party Distributors in the future, we will identify and specify appropriate investor segments based on factors such as the complexity and risk characteristics of the investment scheme, as well as customer transaction experience, financial circumstances, and investment objectives. We will work closely with Third-Party Distributors to share all necessary and sufficient information and provide products and services that are appropriate for the targeted customer segments.
When coordinating with Third-Party Distributors, we will confirm the specific sales channels and advertising and promotional tools, and define the investor segments to be excluded from the solicitation (hereinafter referred to as “Excluded Investor Segments”). We will also discuss and establish procedures for handling applications from Excluded Investor Segments. Furthermore, we will undertake ongoing review and analysis of both the differences between the actual attributes of investors and the initially targeted segments, and the discrepancies between the actual investment performance and the initially projected figures. These findings will inform the improvement and revision of future solicitation activities and disclosure content, ensuring more accurate targeting and effective communication with potential investors.
Additionally, in collaboration with Third-Party Distributors, to gain a deeper understanding of the specific needs of each investor segment, we will, if necessary, conduct pre-marketing activities such as interviews and surveys targeting potential investor segments. This will allow us to more accurately identify and specify the attributes of the intended customers and provide more tailored products and services.