Declaration of Privacy Policy

We, Capital Realty, Inc., operating as a Japanese company, will endeavour to protect private information that we hold on borrowers and others and will do our utmost to observe the Japanese Privacy Information Protection Law (2003 Law No. 57) and other relevant statutes. In order to make that happen in our day-to-day operations, we will follow the guidelines below:

1. Due and proper acquisition of private information
In acquiring private information, we will define the business purposes for its utilization, and acquisition will be done in a due and proper manner and only within the bounds necessary for achieving the business purposes.

2. Utilization and provision of private information
Utilization and provision of private information to third parties will be done only within the limits of that consented to.

3. Securing safety and integrity of privacy information
We will take Organizational, Physical and Technological Security Measures to ensure the safety and integrity of private information.

• Organizational Security Measures will define responsibility for administration of privacy information, supervision of employees, setting forth of further security measures, and audits.
• Physical Security Measures will ensure against loss and theft.
• Technological Security Measures will define principles for the use of systems and administration toward the safety and integrity of private information.

4. Announcement on private information
When the principal so requests, the following items regarding utilization of private information will be announced so that he/she will be in a position to know them.

• Purpose for the use of private data we hold.
• Procedures for disclosure of private information we hold.
• Contact point for complaints, requests for correction, amendment, deletion, suspension of use, and suspension of provision to third parties.

5. Compliance program

In order to promote the protection of private information and appropriate administration thereof, we will create a compliance program to provide training and supervision to employees. As laws and circumstances on these issues evolve, we will routinely update these programs.

April 2005
Capital Realty Inc.
Carl Nicholas Everett
Representative Director