Specific Personal Information Handling Policy

ESR REIT Management Ltd. (the “Company”) sets forth the following specific personal information handling policy (the “Handling Policy”) from the perspective of ensuring the appropriate handling of specific personal information, etc., and endeavors to comply therewith.

1. Compliance with Laws, Regulations and Guidelines

The Company shall comply with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the “My Number Act”), the Act on the Protection of Personal Information (the “Personal Information Protection Act”), the Guideline on Appropriate Handling of Specific Personal Information (for Business Operators) and the (Supplemental Volume) Guideline on Appropriate Handling of Specific Personal Information for Financial Services (collectively, the “Specific Personal Information Guidelines”) and shall ensure the appropriate handling in respect of acquiring, storing, using, providing, disclosing, correcting, suspending the use of and other handling of specific personal information, etc.

2. Acquisition of Specific Personal Information

The Company shall not collect any specific personal information beyond the scope of the affairs specified in “3. Purpose of Use of Specific Personal Information” in this Handling Policy.The Company shall require the provision of individual numbers if it is necessary for processing the affairs specified in “3. Purpose of Use of Specific Personal Information” in this Handling Policy or when the Company can expect affairs related to individual numbers to arise pursuant to the legal relationship, etc., between the Company and the relevant person.

3. Purpose of Use of Specific Personal Information

The purpose of the Company’s use of specific personal information shall be within the scope of the affairs related to the handling of individual numbers listed below.

  1. Affairs related to individual numbers pertaining to officers and employees (including their dependents) (including affairs associated with the items listed below)
    Affairs related to taxes to be withheld at the source by employers in accordance with the Income Tax Act, affairs related to individual inhabitants taxes to be managed by employers in accordance with the Local Tax Act, affairs related to employment insurance to be managed by employers in accordance with the Employment Insurance Act, affairs related to health insurance to be managed by employers in accordance with the Health Insurance Act (regarding applications and benefits) and affairs related to welfare pension insurance to be managed by employers in accordance with the Welfare Pension Insurance Act (regarding applications).
  2. Affairs related to individual numbers pertaining to persons other than officers and employees (including affairs associated with the items listed below)
    Affairs involving the preparation of payment records for remuneration, fees, etc., in accordance with the Income Tax Act; affairs involving the preparation of payment records for the distribution of dividends and surpluses as well as fund interest in accordance with the Income Tax Act; affairs involving the preparation of payment records for real estate usage charges, etc., in accordance with the Income Tax Act; and affairs involving the preparation of payment records for compensation pertaining to the transfer of real estate, etc., in accordance with the Income Tax Act.

4. Safety Management Measures

The Company shall take organizational and personal safety management measures, such as educational training for persons who engage in the affairs related to the handling of individual numbers within the Company to understand and comply with the provisions of laws, regulations and internal rules regarding specific personal information.
In addition, the Company shall take physical and technical safety management measures, such as establishing control areas and handling areas for specific personal information, etc.; controlling access to specific personal information, etc.

5. Storage of Specific Personal Information

The Company shall, within the scope of use specified in “3. Purpose of Use of Specific Personal Information” in this Handling Policy, ensure that specific personal information is correct and up-to-date as well as endeavor to delete the relevant specific personal information without delay if the use thereof becomes no longer necessary.

6. Limitation on Provision of Specific Personal Information

Except for the cases listed in each of the items of Article 19 of the My Number Act, the Company shall not provide any specific personal information to a third party with or without the consent of the relevant person.

7. Safety Management Measures at Consignee

If the Company consigns all or part of the affairs related to individual numbers or the affairs related to the use of individual numbers to a consignee, the Company shall supervise the consignee as necessary and appropriate so that the measures equivalent to the safety management measures that the Company should take are appropriately taken at the consignee.

8. Confirmation of Handling Conditions and Review of Safety Management Measures

The Company shall, as necessary, confirm the records in respect of the application of this Handling Policy, specific personal information, etc., and the handling conditions of specific personal information files and shall take measures to evaluate, review and improve safety management measures in accordance with the results thereof and the verification results pertaining to the status of compliance with laws and regulations, such as the appropriate handling of specific personal information, etc.

9. Response to Complaints

The Company shall, with respect to the handling of specific personal information, set up a point of contact in its Administration Division to receive complaints, etc., regarding the My Number Act, the Personal Information Protection Act, the Specific Personal Information Guidelines or this Handling Policy and shall deal therewith appropriately.

10. Contact for Inquiries

Please contact the following [Contact for Inquiries] for any inquiry or complaint regarding the handling of specific personal information, etc.; any request for disclosing, correcting, suspending the use of and other handling of retained personal information pertaining to specific personal information; or any other inquiries.

[Contact for Inquiries]

Administration Division, ESR REIT Management Ltd.
Address 9th Floor, Kamiyacho Prime Place, 1-17 Toranomon 4-chome, Minato- ku, Tokyo
Tel 03-4578-6880
Business Hours 9:00 a.m. to 5:00 p.m. excluding Saturdays, Sundays, national holidays and New Year’s holidays

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