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.

Summary of the Conflict of Interest Management Policy

With regard to the transactions that may cause a conflict of interest between the Company or a company of the Company Group and a client, and between the clients, SPARX Asset Management Co., Ltd.,(hereinafter referred to as to "Company") shall comply with laws and regulations, etc., and the conflict of interest management policy and appropriately fulfill its operations not to unfairly damage our clients' interests. The Company, in accordance with laws and regulations, etc., hereby announces the summary of the Company's conflict of interest management policy.

• Transactions subject to the conflict of interest management (subject transactions) and the identifying method
  A "conflict of interest" shall mean the situation in which the interests are conflicting between the Company or a company of the Company Group and a client, and between the clients for the Company to conduct transactions. A conflict of interest may occur in a financial instruments transaction on a routine basis, and the Company shall manage the transactions that fall under the following (i) and (ii) as the transactions that are subject to the conflict of interest management and may cause a conflict of interest ("subject transactions"):

  • (i) That under our client's disadvantages, there exists a situation where the Company or the Company Group seems to be gaining advantages.
  • (ii) That the situation mentioned in (i)　above goes against the obligation which is based on a position related to a contract with a client or under the principle of good faith and mutual trust.

• Types

  Subject transactions are the transactions that are determined whether they fall under subject transactions according to the specific circumstances and, for example, the following transactions may be deemed to be subject transactions:

  	A client and the Company	A client and another client of the Company
  Conflict of interest type	Conflict of interest transaction between a client and the Company or a company of the Company Group	Conflict of interest transaction between client and another client of the Company
  Competing transaction type	Competing transactions for the same subject matter between a client and the Company or a company of the Company Group	Competing transactions between a client and another client of the Company Competing transactions between a client and another client of the Company
  Information usage type	Transaction in which the Company or a company of the Company Group gains advantages by using the information obtained by the Company through its relationship with a client	Transaction in which using the information obtained by the Company through its relationship with a client, another client of the Company gains advantages

  • In the event that the supervisory department for the conflict of interest management determines that there is no alternative but to share non-disclosure information of a corporate client and personal information of an individual client between the companies of the Company Group for the purpose of business, etc., the Company shall share such information after receiving the Letter of Consent to Information Sharing from the client (Adoption of the opt-in method).

• Conflict of interest management system

  To fulfill appropriate conflict of interest management, the Company shall appoint the internal control supervisory manager as the person in charge of the conflict of interest management. The person in charge of the conflict of interest management shall not be commanded or ordered by the sales department in terms of the handling in the conflict of interest management. The person in charge of the conflict of interest management shall perform identification of transactions that may cause a conflict of interest and company-level management for the conflict of interest management in cooperation with the Administration Department and the Legal &Compliance Department. In managing subject transactions, the Company shall conduct the conflict of interest management by selecting any of the following methods or appropriately selecting and combining some of them:

  • (1) Blocking between departments, etc., by setting an information barrier (not limited to a physical one);
  • (2) Modification of terms or methods of either or both of a subject transaction and a transaction with the relevant client;
  • (3) Suspension of either of a subject transaction or a transaction with the relevant client;
  • (4) Disclosure to a client to the effect that a subject transaction may cause a conflict of interest;
  • (5) Monitoring of the person who shares information;
  • (6) Other methods.

• Scope of the companies subject to a conflict of interest
  In terms of the Company, companies subject to the conflict of interest management are the Company and the following Group companies

  • SPARX Group Co., Ltd.
  • SPARX Asset Trust &management Co., Ltd.
  • SPARX Green Energy &Technology Co., Ltd.
  • SPARX AI &Technologies Investment Co., Ltd.
  • SPARX Innovation for Future Co., Ltd.
  • Nomura SPARX Investment, Inc.