Fiduciary Declaration

Policy For Implementing 'Customer-Oriented' Business Operations

Introduction

We are an independent investment management firm established in 2003 with the philosophy "Contributing to society through capital markets."

In the ever-changing financial market, we have been investing in companies that intend to grow by adapting themselves to the changing social needs and that have a unique strength to achieve stable growth under any circumstances.

In Japan, personal financial assets remain heavily skewed toward savings deposits. Although the government has been working to promote a shift from savings to investment, significant progress has yet to be made. We are committed to realizing a world in which all people can benefit from financial services 'Financial Inclusion' and are actively promoting the spread of investment to a wide range of people. Our commitment based on this management philosophy of "Contributing to society through capital markets" remains unwavering.

Our fund management efforts are not simply a matter of helping clients realize their financial goals; we are committed to achieving our clients' overall satisfaction and ensuring that they are 'happy to be a fund holder.' To that end, we proactively disclose information and frequently provide enjoyable activities for retail clients.

We are committed to ensuring the long-term satisfaction of our clients through dedication in investing the funds our clients have entrusted to us for superior long-term performance, impeccable operations, and effective open communication with clients. Therefore, we believe the continuous company-wide efforts to improve on these client values are very much at the core of our 'Customer-Oriented Business Operations.' Naturally, client value improvement efforts include sincere client communication with regards to the explanation of our fees and compensation commensurate with our services.

These principles provided below are the basic policies of our activities as they self-evidently follow our philosophy "Contributing to society through capital markets." As always, we will continue to conduct 'Customer-Oriented Business Operations.'

Pursuing the best interest of our clients

The Company's philosophy "Contributing to society through capital markets" is reflected in all the Company's business decisions as well as in the hiring, training, and rewarding of our associates. In this context, "society" encompasses the companies that we invest in and the capital markets, as well as Japanese people in general; but we especially place importance on positively impacting our clients. As such, we believe it is imperative that all personnel of the Company have the necessary high level of expertise, professional ethics, and strong sense of duty.

Appropriately managing conflicts of interest

We strictly adhere to internal regulations and controls to appropriately manage any transactions which may potentially be of conflict of interest so that our clients' interests will not be unduly harmed.

Making fees transparent to clients

As highly experienced investment professionals, we pursue the best results for our clients by demonstrating an exceptional level of expertise for which we receive appropriate fees. The validity of our fees is routinely monitored and discussed by a Fiduciary Duty Committee (hereinafter, "FD Committee"), where the majority of the members are outside experts. The costs borne by clients for our products will be disclosed in each product's prospectus and investment reports in plain language. The prospectuses and investment reports are available on our website and can also be accessed through the distributors of each product.

Providing important information in ways that are easy to understand

We provide clients with important information concerning, among others, sales of financial products and services, by engaging in dialogue with them on a regular basis or by other means, such as delivering Investment Reports. Moreover, we cautiously evaluate sales partner financial institutions when distributing our products. We carefully consider the status of their compliance with regards to strict examinations of suitability concerning a customer's financial means and the contents of transactions, understanding and the sense of resonance toward our investment philosophy, commitment to promoting long-term regular investment, and so forth. Furthermore, we conduct follow-up interviews with each financial institution concerning the status of client service and its considerations. Additionally, these policies and operating processes are regularly monitored by the FD Committee.

Providing services suitable to the client

For our philosophy "Contributing to society through capital markets," to become reality, we not only advocate the benefits of long-term investment, but we also convey the appeal and enjoyment of investing. Rather than blindly push new products, we take tremendous care in considering what kind of product is worthwhile to the client and refining the product so that it is appreciated year after year. The process of creating a new product is regularly monitored by the FD Committee to check for appropriateness and adherence of the product to this principle. Taking into account the characteristics of each product, we share information on the anticipated client profile with distributors and receive from them information on the attributes of clients who have actually purchased the product. As a company involved in both the creation and distribution of products, we strive to ensure that products suitable for our clients are offered in order to realize their best interests.

Frameworks for appropriately motivating our associates

We will earnestly work to be an investment management firm where all personnel vigorously act in the best interest of our clients with a deep and profound understanding of our philosophy "Contributing to society through capital markets." To conduct 'Customer-Oriented Business Operations' we will hire, train, and reward people with the highest level of expertise and professional ethics.

The FD Committee will routinely monitor our business operations to assure adherence with these policies. Additionally, the board of directors take responsibility such that the overall business operation is 'Customer-Oriented.'

Policy on Product Governance

Under the "Policy for Implementing 'Customer-Oriented' Business Operations," we have established the following "Policy on Product Governance" and are committed to ensuring that products offered to clients serve their best interests.

Policy 1: Basic Philosophy

Based on our management philosophy of "Contributing to society through capital markets," we are committed to realizing a world in which all people can benefit from financial services--"Financial Inclusion." In line with this philosophy, we will ensure that the products we offer serve the best interests of our clients (Product Governance).

Policy 2: Product Governance Framework

In order to provide better products to our clients, we will establish a framework to ensure the effectiveness of quality control in each process of product creation, provision, and management, as well as a framework to ensure the effectiveness of product governance throughout the entire lifecycle from creation to redemption. The appropriateness and effectiveness of these frameworks will be regularly reviewed by the Fiduciary Duty Committee, which includes external experts.

Policy 3: Responses at the Time of Product Creation

At the time of product creation, we verify that the product meets the genuine needs of our clients, that the risk/return/cost profile is reasonable, and that the product is sustainable over the long term. We also clarify in advance the anticipated client profile based on the characteristics of the product and share sufficient information with distributors to ensure mutual understanding and accurate grasp of the actual situation.

Policy 4: Responses After Product Creation

For products after their creation, we continuously verify whether the product characteristics assumed at the time of creation are being maintained, whether the management structure is appropriate, and whether the balance of risk/return/cost is appropriate, including management by external delegates. We also share information with distributors to realize the best interests of our clients and use this information to improve product management and creation.

Policy 5: Providing Easy-to-Understand Information to Clients

To help clients select better financial products, we disclose the names and investment philosophies of the fund managers responsible for each fund, and provide easy-to-understand information on our management structure and product characteristics. We also publish the results of our reviews of our product governance framework through updates on the status of our Fiduciary Declaration initiatives, and provide easy-to-understand information on these efforts.