In recognition of the importance of maintaining the security of personal information, ESR REIT Management Ltd. (the "Company") strives to handle personal information appropriately, and complies with the Act on the Protection of Personal Information (the "Personal Information Protection Act") and other related laws and regulations, and rules when protecting such information. Note that the Company has established and observes a separate policy entitled the "Basic Policy on the Handling of Specific Personal Information" in relation to individual numbers and specific personal information (the meanings of each as provided in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures).

1. Basic Policy on the Handling of Personal Information

The Company recognizes personal information it handles as a vital information asset for business, and that the proper handling of personal information in its possession is not only a legal requirement but also a social responsibility. In light of this, the Company strives to protect personal information in accordance with the following basic policy:

1. The Company shall obtain personal information through appropriate and lawful means, and only to the extent necessary for conducting business. Except as provided under laws and regulations, etc., the Company shall not acquire personal information requiring special care without obtaining the prior consent of the relevant person; nor shall the Company acquire sensitive information (as defined in the Guidelines on the Protection of Personal Information in the Financial Sector; hereinafter referred to as the "Financial Sector Guidelines"), except as provided for under the Financial Sector Guidelines.
2. Unless otherwise required by laws and regulations, etc., the Company shall not handle any personal information in its possession beyond the scope necessary to achieve the purpose of use of the personal information. Unless otherwise set forth in the Financial Sector Guidelines, the Company shall not use sensitive information.
3. The Company shall endeavor to manage personal information in its possession accurately and with the most up to date content to the extent necessary to achieve the purpose of use and shall take strict safety management measures for prevention of leakage, loss, and damage in respect of personal data and for other safe management of personal data.

2. Purposes of Use of Personal Information

1. Unless otherwise required by laws, regulations, etc., the Company shall use personal information in its possession to the extent of the purposes of use set forth below:
   1. To allow unitholders of ESR REIT, Ltd (the "Investment Corporation") to exercise their rights, and to carry out the Investment Corporation's obligations to the unitholders in accordance with the Act on Investment Trusts and Investment Corporations (the "Investment Trusts Act") and other laws and regulations, etc.
   2. To prepare each item of data pertaining to unitholders of the Investment Corporation, to manage other information, and to provide information to the unitholders in accordance with the Investment Trusts Act and other laws and regulations, etc.
   3. To perform operations related to the acquisition, transfer and leasing of property, as well as entrustment of property management by the Investment Corporation, as well as the information collection, research, analyses and studies for the performance of such operations.
   4. To perform operations related to IR activities and general administration, etc. on behalf of the Investment Corporation.
   5. To perform work incidental or related to the duties listed above.
   6. To disclose or provide personal information to external experts such as lawyers and certified public accountants to the extent necessary for the purpose of achieving the objectives listed above.
2. Except as provided under laws and regulations, etc., the Company shall notify or announce the purpose of use of personal information as follows:
   1. The Company shall notify the relevant person of or announce the purpose of use of personal information promptly when it acquires personal information, except where the purpose has been announced in advance.
   2. When, upon concluding an agreement with the relevant person, the Company acquires personal information described in the agreement or in other documents (including electronic records), the Company shall clearly state the purpose of use to the relevant person in advance, except as urgently necessary for protecting a person's life, body or property.
   3. When the Company amends the purpose of use, the Company shall notify the relevant person of or announce the amended purpose of use.

3. Provision of Personal Data to Third Parties

1. The Company does not provide personal data to third parties without obtaining the prior consent of the relevant person, except in the following cases:
   1. When the provision of personal data is permitted by laws and regulations.
   2. When it is difficult to obtain the consent of the relevant person where providing the personal data is necessary for protecting a person's life, body or property (including the property of a corporation).
   3. When it is difficult to obtain the consent of the relevant person where providing the personal data is particularly necessary for improving public health or promoting the sound development of children.
   4. When providing personal data is necessary for cooperating in the activities of national or local government authorities, or of a representative entrusted by such authorities in accordance with laws and regulations and obtaining the consent of the relevant person is likely to impede the execution of such activities.
   5. When the Company entrusts the handling of personal data, in whole or in part, to a contractor to the extent necessary for achieving the purpose of use, and ensures appropriate management and supervision.
   6. When disclosure or provision is permitted by the Personal Information Protection Act or other applicable laws, regulations, or guidelines.
2. The Company shall comply with laws and regulations when providing personal data to third parties located in foreign countries, and, when obtaining the consent of the relevant person, shall provide information regarding the country where the third party is located, etc.
3. In the following cases, the Company will provide information about the foreign country, etc., upon request from the relevant person. In such cases, please contact the inquiry desk as described in Section 8 below.
   1. When the foreign country where the third party is located was not identified at the time of obtaining consent but was subsequently identified.
   2. When information about the measures taken by the third party to protect personal data could not be provided at the time of obtaining consent but can be provided subsequently.
   3. When personal data is provided to a party that has established a system that complies with the standards set forth by laws and regulations to continuously implement measures equivalent to those required of personal information handling businesses.

4. Disclosure, Correction, Deletion, and Suspension of Use, Etc., of Retained Personal Data

The Company strives to manage personal data accurately and keep it as up-to-date as possible. Upon receiving a request from the relevant person with regard to retained personal data, the Company will take steps to confirm the identity of the relevant person (or their representative) and, in accordance with applicable laws and regulations, respond to requests for disclosure, correction, deletion, suspension of use, etc. For more information on the procedures, please contact the inquiry desk mentioned in Section 8 below. However, in certain cases (such as where responding to such requests could potentially harm the life, body, property, or other rights and interests of the relevant person or a third party), the Company may not be able to fulfill requests for disclosure, etc. In such instances, the Company will promptly notify the relevant person (or their representative) of the reasons for this decision.

5. Safeguarding Personal Data

The Company shall implement necessary and appropriate safety management measures to prevent leakage, loss, or damage of acquired personal data, and to ensure the secure management of personal information, in compliance with applicable laws, regulations, and guidelines. For details regarding the specific safety management measures implemented by the Company, please contact the inquiry desk mentioned in Section 8 below.

6. Outsourcing and Supervision of Contractors

When the Company consigns third parties to manage all or part of the handling of personal data, the Company conducts necessary and proper supervision of the third parties to ensure that the personal data which the third parties are consigned to handle is securely managed.

7. Continuous Improvement

This Privacy Policy may be revised based on amendments to applicable laws, regulations, or other relevant factors.

8. Contact for Inquiries

Please contact the following [Contact for Inquiries] for any question or complaint regarding personal information; any request for disclosures, etc. in respect of retained personal data; or any other inquires.

[Contact for Inquiries]

Name	Administration Division, ESR REIT Management Ltd.
Address	9th Floor, Kamiyacho Prime Place, 4-1-17 Toranomon, Minato-ku, Tokyo
Phone	+81-3-4578-6880
Business Hours	9:00 a.m. to 5:00 p.m. excluding Saturdays, Sundays, national holidays and New Year holidays

However, with respect to matters related to the unitholders' register and handling of administrative tasks of the Investment Corporation, the point of contact is the administrator of the unitholders' register. Please direct your inquiries to the contact information provided below.

Name	Transfer Agent Department, Mitsubishi UFJ Trust and Banking Corporation
Phone	0120-232-711 (toll-free number)
Business Hours	9:00 a.m. to 5:00 p.m. excluding Saturdays, Sundays, national holidays and New Year holidays

The Company is a subject business operator of the Investment Trusts Association, Japan, an authorized organization for the protection of personal information. The Association provides consultation for and accepts complaints on how subject business operators handle personal information.

Name	Investor Consultation Office, Investment Trusts Association, Japan
Address	2-1 Nihonbashi Kabutocho, Chuo-ku, Tokyo
Phone	+81-3-5614-8440

ESR REIT Management Ltd.
9th Floor, Kamiyacho Prime Place, 4-1-17 Toranomon, Minato-ku, Tokyo 105-0001, Japan
Kazuhiko Watanabe, Representative Director and President