Compliance | Governance | SOSiLA Logistics REIT, Inc.

Compliance Declaration

SRM has set forth and published a Compliance Declaration to clarify its management policy of prioritizing compliance with laws and regulations.

Compliance Declaration

Sumisho Realty Management Co., Ltd. ("SRM") keenly recognizes its serious responsibility for safeguarding fairness and transparency in financial markets as a financial instruments business operator, and to live up to the trust placed in SRM by investors and all other stakeholders, has positioned thorough compliance as a priority management issue. Accordingly, SRM has formulated this Compliance Declaration to be observed by all officers and employees.

We will comply with various laws, regulations, rules and other requirements, including the Financial Instruments and Exchange Act.
We will always faithfully execute our duties on behalf of investors and prioritize their interests.
We will engage in fair and transparent decision making, and practice sound business management.
We will hone our capabilities as experts in the financial instruments business, and maintain high ethical standards to fulfill our social responsibilities.
We will strive to enhance sustainable and long-term business value and drive ongoing improvements to our compliance structure.

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.
Specifically, SRM understands the importance of SLR's asset management business, in which SRM manages the assets of SLR, as a business managing the funds of SLR's unitholders. To build an appropriate management structure, SRM's Compliance Department is the department in charge of compliance matters and SRM has appointed a Chief Compliance Officer to be the person responsible for supervising compliance matters, 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 Risk Management Officer, Chief Compliance Officer and the Compliance Department.
Chief Compliance Officer and Head of Compliance	As the person responsible for supervising the compliance matters of SRM, the Chief Compliance Officer will seek to establish a compliance system and foster an awareness of legal compliance at SRM. The Head of Compliance 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 will be reviewed as necessary.

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	FY2025
Training sessions	12	12	12	12	11	12

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 SMR's Compliance Regulations stipulates 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 SMR, they shall report the violation or action immediately to 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 the 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 Anti-Money Laundering and Combating the Financing of Terrorism, 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.