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RBS Securities Japan Limited, Legal Information

Ethics Policy

As member of RBS Securities Japan Limited - whose role is to support the capital market, where fundraising and fund management in the nation's economy take place - we are well aware that we bear heavy responsibility as intermediaries in the capital market. In compliance with the spirit of "The Principles in the Financial Services Industry" issued by the Financial Services Agency, we devote ourselves to self-edification in order to maintain sound common sense and a sense of ethics, be trusted by the general public, and respond to its requirements as professionals.

We respect each other as good citizens and reject and prevent any discriminatory remarks or harassment regarding nationality, race, gender, age, creed, religion, social status, or physical disability.

We hereby establish the following code of ethics as a basic guideline for RBSSJ officers and employees in the performance of their duties and declare out commitment to it.

1. Observance of social norms and legislation

We fully understand and strictly observe all rules related to financial instrument transactions, including legislation and regulations aimed at protecting investors and ensuring the fairness of transactions. In accordance with social norms, we maintain and follow social common sense and a sense of ethics that cover developments not foreseen in legislation, regulations, etc.

2. Proper management of conflicts of interest

We must properly manage conflicts of interest that arise in business operations. Furthermore, we will not attempt to make an unjust profit by using information obtained through the use of our status, power, or business.

3. Observance of confidentiality and management of information

We pay the utmost attention to the handling of information obtained in the course of our work and protect its secrecy unless otherwise required under the rules of disclosure or by legislation.

4. Maintenance of social order and contribution to society

As good corporate citizens, we actively take part in various social activities and contribute to the stabilization and maintenance of social order. We tale a resolute stand against disruptive elements, groups, etc., that engage in antisocial activities and will never enter into a business transaction with them.

5. Behavior that attaches importance to customer interest

We understand the investment knowledge and experience of out customers, their assets, and their purpose of investment, and with these in mind we always act in their best interest.

6. Sincere and fair work that is in the customer's interest

As intermediaries, we always attach importance to customer needs and interest and work sincerely and fairly.

We do not favor any particular customer by using our power or position at our company or information that may lead to comparative advantage. We strive to uphold the principle of self-accountability by soliciting investment in a proper way and ensuring that customers understand the rule that holds them responsible for their investment decisions.

In cases where we are under contract to assume the responsibility of a fiduciary, we will always act sincerely in the customer's interest.

7. Counseling customers

When we give investment advice to customers, we do so by clearly distinguishing fact from opinion without bias and making use of our professional ability.

We do not provide advice based on information that has not been announced publicly, such as inside information. Doing so may affect the investment's value according to related legislation or regulation.

8. Actions concerning the capital market

In cases where certain actions are not governed by legislation or rules, we determine whether such actions are right or wrong in light of our code of ethics if they are questionable from the viewpoint of social common sense or our role as intermediaries.

We appropriately manage information that has not been announced publicly, such as inside information. Failure to do so may affect the investment’s value according to related legislation or regulations.

9. Awareness of our social mission and the maintenance and promotion to the soundness and reliability of the capital market.

We fully understand the fairness and soundness of the capital market and will never engage in any action or activity that may hinder its sound development. We act with the awareness of our social mission through our efforts to maintain the soundness of the capital market.

We will never engage in any action or activity that may discredit RBSSJ members in the eyes of the general public or damage the soundness of the capital market, such as failing to properly disclose information or distorting a fair price formation.