Regarding Compliance

Compliance Manual (Excerpt)

Introduction
In an increasingly diversified social environment, there is a growing demand for businesses to take on social responsibilities and public missions. This is particularly true in the financial industry, where ethical considerations are becoming more critical. To address these demands, it is essential for all employees and officers of a company to adhere to laws and social norms and carry out business activities with a strong sense of ethics. This is a key social responsibility. Moreover, such a management stance is the foundation for building healthy relationships with both the company and its clients, contributing to the development of society through our work, and ultimately earning the trust and high regard of society.

This compliance manual outlines the fundamental principles that must be followed by all employees without exception, along with the guidelines for practicing these principles. It is not an exhaustive document. If you encounter issues or complex cases that are not covered in this manual, please do not hesitate to raise them within the company. It is easy to forget to ask the right questions, but it is important to always approach situations with a compliance-focused mindset. Reaffirm that the ultimate standards for making decisions related to compliance with laws and ethics lie in your own conscience and integrity.

Through fair and appropriate business activities, we aim to contribute to the well-being of our clients, the healthy development of financial markets, and, by extension, to the advancement of society. Our business is based on fairness, with a mission to enrich society.

Compliance Declaration

 　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　November 1, 2012
　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　GVC Asset Management Inc.
　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　　President & CEO: Yoshio Teramoto

GVC Asset Management Inc. strongly recognizes that the practice of compliance is one of the most important management priorities, and that its implementation and thoroughness form the foundation of our corporate management. In our business activities, we will carry out sincere, fair, and highly transparent actions, prioritizing customer interests and ensuring that all required compliance standards are adhered to.

To achieve this, we hereby establish the following "Basic Compliance Policy.

GVC Asset Management Inc. strongly recognizes that the practice of compliance is one of the most important management priorities, and that its implementation and thoroughness form the foundation of our corporate management. In our business activities, we will carry out sincere, fair, and highly transparent actions, prioritizing customer interests and ensuring that all required compliance standards are adhered to.

To achieve this, we hereby establish the following "Basic Compliance Policy":

１．We will comply with all laws, regulations, and other rules, fulfilling our "legal responsibilities."

２．We will be aware of our social mission and fulfill our "social responsibilities" through concrete actions.

３．We will fulfill our "ethical responsibilities" by conducting business in a sincere and fair manner, and by adhering to social common sense.

Code of Conduct

 Our company and employees will adhere to the following principles in the performance of our duties:

１．　We recognize the social responsibility and public mission of our business and will operate our business in a sound and healthy manner.

２．　We will comply with all laws, regulations, and rules, and conduct our operations with fairness and integrity, following social norms.

３．　We will respect the human rights of all stakeholders and contribute to the healthy development of society and the economy.

４．　As participants in the financial and capital markets, we are conscious of our social mission and will carry out our duties with sincerity and fairness.

５．　We will prioritize the interests of our customers and strive to perform our duties in a trustworthy and loyal manner.

６．　We will acknowledge facts as they are, report honestly, and act with integrity. We will not engage in reporting or actions that could mislead, conceal, or distort facts.

７．　In the event of errors or violations, we will proactively work toward problem resolution.

８．　When profits and ethics are in conflict, we will unhesitatingly choose ethics.

９．　We will handle customer information acquired in the course of our business with the utmost care, fulfilling our duty of confidentiality.

１０．We will maintain a resolute stance against anti-social forces and confront them firmly.

In carrying out the above Code of Conduct, we will ask ourselves the following questions:

• Am I violating any laws?

• Can I confidently talk about this with my family?

• Can I stand proudly if this is announced in the newspaper or on television?

• Am I providing someone with an opportunity to take advantage of the situation?

• Am I seeking a shortcut that allows me to benefit without putting in the effort?