Japan Excellent, Inc. (JEI) recognizes the protection and appropriate management of personal information as one of its key social responsibilities and is committed to doing so based on the following privacy policy, which governs the handling of personal information possessed by JEI. With regard to individual numbers and specific personal information (each as defined in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures, or Act No. 27 of 2013), JEI shall separately formulate a basic specific personal information policy and comply with it.

Fundamental Policy

JEI strives to implement appropriate handling and sound, rigorous control and management of personal information while complying with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the Personal Information Protection Act) and other related laws and regulations. Moreover, JEI continuously reviews its privacy policy in order to meet its legal requirements and further improve its protection of personal information.

Handling Personal Information

1.Acquiring and Using Personal Information

JEI shall acquire personal information in an appropriate and legal manner within the scope required by its business (JEI shall not acquire personal information requiring special care, as defined in the Personal Information Protection Act, without the prior consent of the relevant individual, unless otherwise stipulated by the applicable laws and regulations). Moreover, it shall disclose or provide notification of the usage purpose of personal information, and unless otherwise stipulated by the applicable laws and regulations, handling of personal information shall not exceed the scope required to achieve the intended usage purpose without the consent of the relevant individual.

2.Usage Purpose of Personal Information

JEI shall use personal information for the following purposes in order to conduct its business in an appropriate manner. It shall not use personal information in ways that foster illegal or improper conduct or that are liable to induce such conduct.

1. To support unitholders in exercising their rights and JEI in fulfilling its obligations, based on the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951; hereinafter referred to as the Investment Trust Act) and other related laws and regulations, as well as to implement measures for facilitating smooth interaction between JEI and its unitholders
2. To prepare and submit various reports and other documents about JEI based on the Investment Trust Act, other related laws and regulations, and rules of stock exchanges
3. To manage unitholder information, such as creating data about JEI’s unitholders
4. To issue corporate bonds and additional investment units from JEI
5. To respond to inquiries, requests for documents, etc. made to JEI
6. To execute other JEI operations in an appropriate, smooth manner
7. To disclose or provide personal information to third parties within the scope required to achieve the usage purposes described in items a to f above

3.Provision of Personal Information to Third Parties

JEI shall not provide personal information to third parties without obtaining the prior consent of the relevant individual, except in the following cases.

1. When required by laws and regulations
2. When it is necessary to protect human life, body, or property and obtaining the consent of the relevant individual is difficult
3. When it is particularly necessary to improve public health or promote the sound upbringing of children and obtaining the consent of the relevant individual is difficult
4. When it is necessary to cooperate with national or local governmental organizations or parties commissioned by them in order to carry out clerical work stipulated by laws or regulations and obtaining the consent of the relevant individual could hinder the carrying out of said clerical work
5. When provision is permitted by the Personal Information Protection Act for other reasons

4.Safe Management of Personal Data

1. JEI shall handle personal data of customers (referring to personal information which JEI has acquired or is attempting to acquire and including those scheduled to be handled as personal data. The same applies in a. and b. below) in an appropriate, careful manner and implement necessary and appropriate safe management to prevent unauthorized access, loss, damage, falsification, leaks, etc. involving personal data (hereinafter referred to as “leaks, etc.”).
2. In the event that leaks, etc. of personal data occur, JEI shall implement countermeasures to minimize the damage and take corrective actions to prevent recurrence.
3. In the event that a matter relating to ensuring the safety of personal information, such as a leak, loss, or damage involving personal data handled by JEI that represents a significant risk of harming the rights and interests of an individual occurs, as stipulated in the Ordinance for Enforcement of the Act on the Protection of Personal Information (Rules of the Personal Information Protection Commission no. 3 of 2016; hereinafter referred to as the “Ordinance for Enforcement”), JEI shall notify the relevant individual that the incident has occurred, as stipulated in the Ordinance for Enforcement. However, this shall not apply if it is difficult to notify the relevant individual and the necessary alternative measures are taken to protect the relevant individual’s rights and interests.

5.Outsourcing the Handling of Personal Information

In conjunction with the outsourcing of personal information handling, either in whole or in part, within the scope required to achieve its usage purposes, JEI may provide customers’ personal information to another party. In such a case, it shall select a party that implements thorough measures to protect personal information and perform necessary and appropriate supervision of the outsourcee.

6.Consultation Services for Inquiries about Personal Information, Etc.

JEI shall respond as promptly and sincerely as possible to complaints, inquiries, etc. concerning personal information. Requests to disclose (including disclosure of records provided to third parties; the same applies hereinafter) or revise customers’ personal information possessed by JEI, suspend its use, or stop providing it to third parties and questions or complaints submitted regarding the handling of personal information (safe management measures, etc.) based on the Personal Information Protection Act shall be handled by the following consultation services.

a.Contact Information for Inquiries, Etc.

Inquiries about matters described in the unitholder registry

The administrator of the unitholder registry shall respond to inquiries about matters described in the unitholder registry which are included in the personal information handled by JEI.

【Stock Transfer Agency Department, Mizuho Trust & Banking Co. Ltd.】
Phone	0120-288-324 (toll-free, Japan only)

Inquiries, etc. about personal information other than the above

JEI’s Asset Management Company shall respond to inquiries about personal information other than matters described in the unitholder registry which is included in the personal information handled by JEI.

【Business Management Department, Japan Excellent Asset Management Co., Ltd.】
Phone	03-5412-7911 (representative)

b.Procedure for Requesting Disclosure of Personal Information

In cases of a request to disclose, revise, or suspend use of personal information or stop providing it to third parties based on the Personal Information Protection Act, the procedures designated by the consultation services specified in item a. above will be followed. For details, please contact the consultation services indicated above.

7.Modification of the Privacy Policy

JEI may revise the privacy policy for the purpose of protecting customers’ personal information or to comply with changes in the laws, regulations, or standards. Please check the date of the latest update.

(Latest update: April 1, 2024)