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 is committed to providing the best investment intelligence in its quest to be the most trusted and respected investment company in the world. We resolutely pursue this goal every day. We solicit investments in financial instruments in accordance with the policy outlined below:

• Matters to be considered in light of the knowledge, experience, and assets of the persons subject to solicitation
  • We strive to offer investments that are compatible with the intentions and circumstances of our clients, after sufficiently understanding their investment experience, objectives, and financial position. We recommend financial instruments we believe are appropriate in light of these matters.
  • We make every effort in our solicitations to account for the characteristics and attributes of our clients, and to provide an adequate explanation of our products and their risks in light of our clients' knowledge, experience, and financial position.
• Matters to be considered for the persons subject to solicitation in terms of solicitation approaches and timeframe
  • We always place the highest priority on securing the trust of our clients in us. Thus we strive to comply with all related laws, regulations, and rules in our efforts to conduct client-oriented investment solicitation.
  • Regarding the method, opportunities and time of solicitation, we carefully consider our clients' circumstances to ensure that we provide an appropriate solicitation approach. We would like to ask all our clients to notify our sales manager if our solicitations cause any inconvenience.
• Other matters related to ensuring the propriety of our solicitations
  • We strive to make solicitations on a reasonable basis. In addition, our departments in charge of internal administration always works to confirm in advance that we publish the appropriate information on our website and other portals.
  • We make every effort to comply with the Financial Instruments and Exchange Act and all other related laws, regulations, and rules. Furthermore, we strive to improve our internal control system to ensure that we conduct solicitation appropriately.
  • Our officers and employees are continuously studying and acquiring the knowledge and skills required for preventing inappropriate solicitation.
  • We endeavor to provide appropriate information with our clients so that they can execute transactions at their discretion and responsibility.