ARK Mori Building 31F
1-12-32 Akasaka, Minato-ku
Tokyo 107-6031 Japan

Charter of Corporate Behavior

From our responsibilities to our Stakeholders come the foundations of our corporate governance framework, our commitment to compliance with all applicable laws and regulations, dedication of time and resource to charitable and philanthropic works, a commitment to minimize the environmental impact of our business, and a commitment from Senior Management to maintain the highest standards and ethical business practices.

Together with Our Values, the following principles outline our commitment to making this a reality for our Stakeholders.

1. Client Focus - From the moment our clients start preparing to enter a new economy or market, right through to the maturity, sale or securitization of their assets, we shall continually strive to deliver knowledge and expertise at the highest levels of service. We shall continually engage our clients to understand their present and future needs and shall continually strive to anticipate industry changes to provide forward-looking solutions that offer our clients a competitive advantage.

2. Ethical Leadership - Capital's Senior Management shall take responsibility for implementing this charter and raising awareness of it among employees. Senior Management recognizes that in order to give this Charter "life and substance" it must strive to exemplify these principles in both business leadership and ethical best practice.

3. Ethical Business Practices - Through our Corporate Governance initiatives, a commitment to compliance, our internal and external audit processes, our employee Codes of Conduct and by creating anonymous reporting communication channels for employees and other interested parties; we shall continually ensure that our business is conducted with integrity and honesty.

4. Respect for Privacy - During the normal course of carrying out our business, we recognize that we gather and hold the personal and sometimes proprietary data of our customers, clients and employees. We are committed to protecting this information and proactively take steps to increase and ensure its security.

5. Ensuring Equality & Freedom from Harassment - Beyond a commitment to ensuring local labor laws are adhered to in both the letter and the spirit of the law, we recognizes that the presence of a formal policy on equality and freedom from harassment in the workplace is to the benefit of all stakeholders.

6. Respect for Others - With Stakeholders from many countries and cultures, we strive to respect each other as individuals. In this way, we endeavor to create an inclusive thriving work environment that promotes mental and physical well-being as well as exceptional results.

7. Open Communication - Capital's Senior Management is committed to listening to the voices of our stakeholders to further promote and strengthen ethical business systems. There is commitment to ensuring our employees and other interested parties can contact us anonymously at the highest levels.

8. Responsibility & Recognition - as a company, we shall recognize and reward fairly those who seek, accept and manage their responsibilities in an exemplary manner, who work hard within our values framework to help us build a strong and sustainable business, and who achieve exceptional results through their own efforts or through the efforts of their teams. Further, we shall formalize this process as part of an annual review for all staff and managers.

9. Sustainable Profitability & Growth - Through adherence to this Charter, we shall seek to achieve sustainable profit and growth allowing us to operate to the benefit of all stakeholders.

10. Environmental Mind Set - We recognize that all companies have a responsibility to the environment and are committed to proactively finding ways to lessen the environmental impact of our business, big or small.

11. Community Engagement - We believe that every company has a responsibility to engage the communities in which it does business in with philanthropic endeavors. Our Community Action Program (CAP) is based on this belief.

12. Commitment - Where this Charter is found to have been violated, the incident will be investigated and reforms developed to prevent recurrence. Responsibility for the incident shall be clarified and disciplinary action taken regardless of the seniority of the violator. We believe in these principles, we will live by them, and we will enforce them.