The following is an English translation of the original Japanese version.
If there is any inconsistency between the two versions, the Japanese version shall prevail.

SPARX Asset Management Co., Ltd. has committed that we will resolutely oppose to any Anti-Social Forces (ASF) and will not have any business and transactions with ASF in compliance with the Service Regulations applicable to all officers and employees and our basic policy is established in the Internal Control System with resolution by the Board of Directors.

Basic Approach Towards the Exclusion of Anti-Social Forces

SPARX Asset Management Co., Ltd. established the basic policy against ASF, which threatens social order and sound business activities, that we will not have any relations with ASF, will not give economic benefits to them, will not make backstage deals with them and will not accept undue or illegal demands from them. To realize the policy, we will carry out thorough compliance education to the officers and employees in charge and will associate with police, lawyers, or other external professionals.