NOMURA REAL ESTATE SOLUTIONS

Policy on Anti-Bribery of Foreign Public Officials

1 Prohibition of Bribery

No director, officer or employee of Nomura Real Estate Group shall, directly or indirectly, provide any type of bribe, regardless of the amount, to a foreign public official.

2 Compliance with Laws of Each Country

No director, officer or employee of Nomura Real Estate Group shall, directly or indirectly, give, offer or promise any entertainment, gift or other advantage to a foreign public official in contravention of the laws of Japan or any other country.

3 Recordkeeping Obligation

Any payment or gift to, or entertainment of, a foreign public official must be appropriately recorded.

4 Education and Training

On the basis of this policy, Nomura Real Estate Group will periodically implement education and training of its directors, officers and employees to ensure the prevention of bribery of foreign public officials and the appropriateness of operations.

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