Basic policy

When trading domestic securities associated with the management of client assets held under a discretionary investment contract or trust assets held under an investment trust contract (hereinafter referred to as "Investment Portfolios"), we may aggregate multiple sell or buy orders for such domestic securities into a single block order when their trading terms are identical (i.e., securities of the same type and issue are being sold or bought via the same type of transaction at the same price or within the same price range).

Securities and transactions subject to aggregation

Securities subject to aggregation are those listed or registered on a financial instruments exchange market, foreign financial instruments market, or over-the-counter trading financial instruments market. The aggregation of orders is limited to cash transactions and derivative transactions.

Order allocation

If an order is not executed in full (i.e., a partial fill), the executed portion of the order will be allocated to each Investment Portfolio in accordance with our internal allocation criteria.
More specifically, when determining the amount to be allocated for either sell and buy orders, the quantity of original orders placed for each Investment Portfolio is first divided by the total order quantity. The resulting value is then multiplied by the executed order quantity. The allocated quantity should not exceed the quantity of original orders placed for each Investment Portfolio.

Best Execution Policy

We will execute client orders based on the most reasonable and best trading terms possible for the client after taking a comprehensive look at the account market conditions, prices, and other factors. The best trading terms are determined not only by price but also by other various factors such as cost, speed, certainty of execution, and liquidity. We may break a block order up into smaller orders before executing them to make the most of them.

Internal Management Structure

We maintain internal rules for executing block orders and ensure that all relevant personnel are aware of them while our Compliance Department checks the process pertaining to block orders.