Tosei Group Basic Policy on Customer Harassment

Tosei Group (hereinafter "we, and "the Group") upholds the corporate philosophy of "creating new value and inspiration in all aspects of real estate." To achieve this philosophy, we believe it is essential to respect the human rights of all employees working within the Group, to tolerate absolutely no discrimination or harassment whatsoever, and to ensure a positive workplace environment. To ensure mutual respect for the human rights of our customers and employees and to sustainably provide high-quality products and services, we have established the Tosei Group Basic Policy on Customer Harassment.

1. Definition of Customer Harassment

Based on the Japanese Ministry of Health, Labour and Welfare's the Customer Harassment Prevention Corporate Manual, customers' requests/demands or words/behavior directed at employees that lack reasonable justification in their content, or for which the means or manner of approach are deemed socially unacceptable, thereby damaging the working environment for our employees, are defined as customer harassment.

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The following are examples and are not an exhaustive list.

(1) Unreasonable demands

Unreasonable demands concerning matters outside the authority of the Group
Unreasonable demands concerning matters difficult for the Group to address
Excessive demands deviating from prescribed procedures

(2) Words or behavior where the means or manner of fulfilling the demand is socially inappropriate

Assault or battery
Threatening behavior such as shouting, or banging on or kicking desks
Threatening behavior such as mentioning recording or photographing interactions for provision to the media or online publication
Words or behavior implying connections to antisocial forces
Disclosure of personal information, such as publishing the names of employees online
Coercive behavior
Repeat the same words or behavior during a single visit or phone call
Persistently visiting, making phone calls (including silent calls), or sending letters multiple times, repeating the same words or behavior
Intimidating words or behaviors
Repeatedly forcing employees to explain the same matter or apologize
Extended phone calls
Refusing to leave or lingering
Remarks denigrating an employee's character, discriminatory remarks, or sexual remarks
Harassment such as defamation, stalking, or other hostile behavior toward employees
Words or behavior causing psychological distress to employees
Other illegal or improper behavior

2. Customer Harassment Policy

If we determine that customer harassment has occurred as described above, we will take firm action to protect our employees. If we discover that an employee's personal information, such as their name, has been published online, we will take appropriate measures, including requesting its removal and pursuing other legal action. If we deem the behavior to be malicious, we will collaborate with external agencies (such as the police or lawyers) and take strict measures, including legal action.

3. Initiatives to Prevent Customer Harassment

(1)

We will take measures to ensure that employees acquire knowledge about customer harassment and learn appropriate response methods.
(2)

We will respond to consultations and reports from employees carefully and systematically, while striving to protect employees' privacy and provide mental health support.
(3)

We will educate employees to prevent them from engaging in customer harassment themselves.