Frontier Real Estate Investment Corporation

Code 8964

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Governance Initiatives

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Compliance

Basic Policy on Compliance

FRI and Mitsui Fudosan Frontier REIT Management Inc., the asset management company (the “Asset Management Company”), which are bearers of the listed investment corporation system that plays the role of the financial brokerage system through the securities market, position compliance as the fundamental principle for business operations and proactively work to promote compliance.

The Asset Management Company has established the compliance regulations as its internal rules, in which it defines compliance as “implementing corporate activities with integrity and in a fair manner, fully understanding the social norms as well as strictly abiding by all laws relating to its operations, various regulations, internal rules and market rules.” By incorporating the function to promote compliance into its corporate governance system, it endeavors to ensure appropriate asset management and protect investors.

FRI, in close coordination with the Asset Management Company, implements fair and highly transparent asset management operations through appropriate administration of the Board of Directors and other bodies.

Establishment of System to Eliminate Anti-social Forces

The Asset Management Company shall prepare a manual to cope with anti-social forces as its internal rules, and establish a company-wide system to eliminate anti-social forces. As part of such a system to eliminate them, all officers and employees of the Asset Management Company shall review and assess the attributes of its business partners and shareholders upon initiating transactions as well as confirming the identity of such parties, in order to avoid all involvement, transaction and use of any kind of anti-social forces.

Rules Concerning Conflicts of Interest

The Asset Management Company has determined Rules Concerning Conflicts of Interest regarding transactions with parties.

Rules Concerning Conflicts of Interest

Compliance Promotion Framework

The Asset Management Company promotes compliance based on the following framework.

Annual Compliance Program

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