Blanket Order Policy
Handling Policy for Blanket Orders
In managing the trust property of investment trust and customer assets relating to discretionary investment contracts (hereinafter referred to as the "investment portfolio"), SPARX Asset Management Co., Ltd. may place an order in the form of a so-called blanket order, with regard to such buy and sell orders for securities involving multiple investment portfolios that are subject to the same terms and conditions(which means the order where the types and issues of securities, sell order or buy order, types of transaction and the execution price (including the price range) are the same), by combining such multiple sell orders and buy orders. This aims to ensure the fairness among multiple investment portfolios that tend to sell or buy the same issue. However, this policy shall not apply when it is deemed inappropriate to place a blanket order from the standpoint of the market trend, the urgency of the transaction or the attributes of investment portfolios. The object of blanket order shall be limited to spot transactions and margin transactions of securities (excluding bonds) listed on the stock exchange. However it is not applicable to the blanket order between spot transactions and margin transactions. In the event the ordered quantity cannot be fully executed and has resulted in a so-called "partial completion of an order," allocation shall be made to each investment portfolio according to the allocation standards designated by the Company. Specifically, for both sell orders and buy orders, up to a limit of the ordered quantity of the relevant investment portfolio, the allocation quantity shall be calculated by multiplying "the numerical value arrived at by dividing the ordered quantity of the relevant portfolio by the total ordered quantity" by "the total contracted quantity". In addition, in implementing a blanket order, we are going to develop our in-house operational manual and not only to make it widely known to the persons concerned but also to have it verified by the internal auditing department and the compliance department.