MIRARTH Asset Management Co., Ltd. (“the Company”) has established the following Basic Policy on Client-Oriented Business Conduct and publishes it on its website.

In this policy, “clients” refers collectively to customers such as special purpose companies that have entered into discretionary investment management agreements, investment advisory agreements, or similar agreements in connection with private funds and other investment vehicles, as well as the investors in such customers.

Principle 1 :
Establishment and Disclosure of the Basic Policy on Client-Oriented Business Conduct

The Company has established this Basic Policy on Client-Oriented Business Conduct and discloses it on its website. The Company will review this policy on a regular basis and disclose any amendments as appropriate.

Principle 2 :
Pursuit of Clients’ Best Interests

As a financial services provider, the Company is committed to maintaining a high level of professional expertise and ethics and to conducting its business with sincerity and integrity. In order to meet clients’ expectations, the Company strives to enhance the value of assets under management. The Company also seeks to foster a corporate culture in which such client-oriented business conduct is firmly embedded.

Principle 3 :
Appropriate Management of Conflicts of Interest

The Company has established an appropriate framework for managing potential conflicts of interest that may arise in relation to its clients.In connection with its asset management business, discretionary investment management business, Type II Financial Instruments Business, and investment advisory business, the Company has established measures to prevent adverse effects arising from transactions involving conflicts of interest among clients.In addition, to appropriately manage conflicts of interest between clients and companies within the sponsor group headed by the Company’s parent company, MIRARTH Holdings, Inc. (the “Group Companies”), the Company has established regulations governing transactions with interested parties. When acquiring or disposing of managed assets from or to the Group Companies, or when entering into other agreements with them, the Company carefully reviews the fairness of the consideration and other contractual terms before proceeding with such transactions. Transactions with the Group Companies that constitute interested-party transactions are subject to strict review by the Compliance Officer, as well as deliberation and approval by the Compliance Committee and the Investment Committee, taking into account the professional knowledge and experience of external committee members.

Principle 4 :
Clear Disclosure of Fees and Expenses

The Company will provide clients with clear information regarding fees and other expenses borne by clients, including the nature of the services for which such fees and expenses are charged.

Principle 5 :
Provision of Important Information in an Understandable Manner

To ensure transparency for clients, the Company will make disclosures in accordance with the Financial Instruments and Exchange Act and will endeavor to provide, as promptly and clearly as possible, information that it considers necessary and appropriate for clients’ investment decisions.

Principle 6 :
Provision of Services Appropriate to Clients

The Company will endeavor to provide appropriate solicitation and advice based on a full understanding of each client’s knowledge of financial instruments, investment experience, investment objectives, needs, and financial circumstances, and in a manner suited to the client’s intentions and actual situation.

Principle 7 :
Appropriate Employee Incentives and Governance Framework

The Company provides compliance training to all employees in order to encourage conduct that supports the pursuit of clients’ best interests, including fair treatment of clients and the appropriate management of conflicts of interest. The Company also encourages participation in external compliance training programs and works to strengthen compliance awareness across the organization. In addition, compliance awareness and implementation are incorporated into employee evaluation criteria.