Basic Policies for Conflict of Interest Management & Prevention of Damage Caused by Anti-social Forces

Basic Policy for Conflict of Interest Management

We have established this policy in order to comply with laws and regulations and to properly manage and carry out operations so that conflicts of interest arising from transactions with customers do not unfairly harm our customers' interests.

1. 1. Definition of Conflict-of-Interest Transactions

   "Conflict-of-interest transactions" refers to transactions in which the interests of the customer may be unfairly harmed due to situations in which the interests of the Company and the customer are in conflict or situations in which the interests of the Company’s customers are in conflict.

2. 2. Identifying Types of Conflict-of-Interest Transactions

   We classify and identify conflict-of-interest transactions as types (1) to (4) below, and manage them so as not to unfairly harm the interests of our customers.
   1. Transactions that produce a conflict of interest between the Company and customers
   2. Transactions that produce a conflict of interest among the Company’s customers
   3. Trading based on inappropriate use of information
   4. Transactions other than those in (1) to (3) that have the potential to unduly harm customers' interests

3. 3.　Management of Conflicts of Interest

   The Company manages conflict-of-interest transactions by appropriately selecting or combining the methods enumerated below.
   1. Separating department divisions that may generate conflicts of interest
   2. Adjusting the terms or methods of one or both parties to prevent conflict-of-interest transactions
   3. Unilaterally cancelling the conflict-of-interest transaction
   4. Disclosing to the customers that the transaction produces a conflict of interest
   5. Other appropriate methods other than the aforementioned (1) to (4)

4. 4.　Measures to Prevent Conflicts of Interest

   If it is determined that a conflict of interest will unfairly harm the interests of our customers, we will change the terms of the transaction, stop the transaction, disclose such facts to the customer, include suitable provisions in the contract, or take other appropriate action.

Basic Policy for Prevention of Damage Caused by Antisocial Forces

Kasumigaseki Capital Co.,Ltd. has established the following basic policy on anti-social forces, and all officers and employees will comply with it in order to confront anti-social forces in a resolute manner and thoroughly terminate any relationships with anti-social forces.
1. We will terminate all relationships, including business relationships, with anti-social forces.
2. The entire organization will strive to confront the unfair demands of antisocial forces and to ensure the safety of officers and employees who do so.
3. In preparation for confronting the unfair demands of antisocial forces, we will build close relationships of cooperation with outside specialized agencies such as the police, the Centers for Removal of Criminal Organizations, and lawyers.
4. We will reject all unfair demands of antisocial forces, and take legal action on both a civil and criminal basis.
5. We will never engage in concealed transactions with or provision of funds to antisocial forces.