Compliance | Governance | SOSiLA Logistics REIT, Inc.

Compliance Declaration

Sumisho Realty Management Co., Ltd. (“SRM”), as a financial instruments business operator, profoundly recognizes its significant responsibility to maintain the fairness and transparency of financial markets. Furthermore, in order to meet the trust placed in SRM by all stakeholders including investors, SRM positions thorough compliance as its most critical management goal. Therefore, SRM hereby establishes a “Compliance Declaration,” to which all officers and employees shall adhere.

We will comply with all applicable laws, regulations and rules, including the Financial Instruments and Exchange Act.
We will always faithfully perform our fiduciary duties to our investors and will give top priority to their interests.
We will ensure fair and transparent decision-making and will practice sound business operations.
We will enhance our expertise as a financial instruments business professional and will maintain a high level of ethics in order to fulfill our social responsibilities.
We will aim to enhance sustainable and long-term business value and will promote the continuous improvement of our system for compliance with laws and regulations.

Established on January 15, 2026

Basic Policy for Compliance

SLR and SRM are committed to ensuring compliance with relevant laws and regulations, preventing corruption and conflicts of interest, and ensuring appropriate information management, while taking into consideration human rights and diversity, through the establishment of the following policies and management structure.
SRM understands the importance of SLR's asset management business, where SRM manages the assets of SLR, as a business managing the funds of SLR's unitholders. To build an appropriate management structure, SRM established the Compliance Department in charge of compliance-related matters and appointed Chief Compliance Officer responsible for supervising compliance-related matters, thereby ensuring the effectiveness of the internal supervision of compliance in the other departments. In addition, SRM has established the Compliance & Risk Management Committee as a part of its establishment of a multilayered compliance system.

Compliance structure

Organizations	Major roles
Board of Directors	The Board of Directors will seek full compliance as the administrative body ultimately responsible for the execution of business, receive reports on matters approved by the Compliance & Risk Management Committee, etc., and adopt resolutions regarding important compliance matters.
Compliance & Risk Management Committee	The Compliance & Risk Management Committee carries out the tasks set out in the Compliance & Risk Management Committee Regulations in cooperation with the Board of Directors, Chief Compliance Officer(CCO) and the Compliance Department.
CCO	As the person responsible for supervising the compliance matters of SRM, CCO will seek to establish a compliance system and foster an awareness of legal compliance at SRM. To that end, CCO will always monitor compliance with laws and regulations in the execution of business in SRM's management of assets for SLR and will monitor and oversee compliance with laws and regulations in the day-to-day execution of business.
Compliance Office	The Compliance Department is in charge of compliance matters at SRM.
Chief Risk Management Officer(CRO)	CRO will be responsible for establishing risk management and monitoring frameworks for each business line and overseeing and supervising the due process for decision-making activities.
Business Risk Management Office	Business Risk Management Office will conduct daily monitoring and risk management of specific front-office work processes from commencement, by each business line and Strategic Investment and Acquisition Department, of discussions on acquisitions to the process of requests of real estate appraisers prior to putting forward proposals to each Committee.

Establishment and Implementation of a Compliance Manual

SRM has created a Compliance Manual to ensure compliance.
The Compliance Manual is revised as necessary in response to the enactment, revision, or abolishment of laws and regulations, and all executives and employees are notified of any revisions.

Compliance training

SRM implements thorough compliance through the appropriate operation of internal management systems designed to maintain the high ethical standards of its officers and employees, and ensure compliance with laws and regulations. To build a foundation for implementing these measures, SRM conducts training for its officers and employees to ensure that they have sufficient knowledge of compliance.

	FY2020	FY2021	FY2022	FY2023	FY2024
Training sessions	12	12	12	12	11

Internal Reporting System

When compliance issues arise, they are reported and handled through the established channels. In addition to the normal established channels, SRM has established a system that enables employees who notice issues to report them directly to a contact point when the established channels are difficult for some reason.

Responding to Compliance Violations

Article 12 of SRM's Compliance Regulations stipulate that if officers and employees, etc. become aware of any violation of laws or regulations or an action that is likely to violate laws or regulations at SRM, they shall report the violation or action immediately to Chief Compliance Officer or the Compliance Department.

Response to Anti-Social Forces

SRM has established regulations banning all relationships with anti-social forces. The regulations stipulate that the Compliance Department shall supervise the establishment of a system that prohibits all relationships with anti-social forces and deals with anti-social forces at SRM and that Chief Compliance Officer has supervisory responsibility over this. The regulations also stipulate that SRM shall provide internal training to officers and employees on guidelines for handling anti-social forces and the management of information about anti-social forces to increase their awareness.

In addition, SRM has declared a basic policy on anti-social forces to prohibit all relationships with anti-social forces, based on which it strives to develop a system that prohibits all such relationships. It has established regulations and standards for the verification of the customer's identity at the time of transactions and the reporting of suspicious transactions, to set standards for the verification of customers' identities at the time of transactions, the preservation of transaction records, and the reporting of suspicious transactions under the Guidelines for Anti-Money Laundering and Combating the Financing of Terrorism, the Act on Prevention of Transfer of Criminal Proceeds (the "Act"), the Order for Enforcement of the Act, and the Ordinance for Enforcement of the Act.

Prevention of corruption and bribery

Anti-corruption

As a member of the Sumitomo Corporation Group, SRM is engaged in initiatives to prevent bribery when entertaining business partners or giving gifts.
Specifically, in the Compliance Manual, we have established rules for preventing bribery. We have also established detailed rules regarding expenses for entertainment and decision-making authority, and detailed rules for handling of receiving gifts and invitations, which specify specific details.

Prohibition of political contributions

As a member of the Sumitomo Corporation Group, we are engaged in initiatives to prevent illegal political contributions.
Specifically, in the Compliance Manual, we have established rules prohibiting illegal political contributions.