BASIC POLICY

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BASIC POLICY

BASIC POLICY
ON CUSTOMER-ORIENTED BUSINESS OPERATIONS

PRINCIPLE 1Establishment and Disclosure of Basic Policy on
Customer Oriented Business Operations
Takara Asset Management Co., Ltd. (hereinafter referred to as “our company”) will establish and disclose the “Basic Policy on Customer Oriented Business Operations.” In this basic policy, “customers” refer to special purpose companies that have entered int o investment management agreements or investment advisory agreements, as well as investors of such customers, in private funds and other similar arrangements. We will periodically review this basic policy and publicly disclose any revisions that have been made.
PRINCIPLE 2Pursuit of Customer’s Best Interests
As a financial institution, our company establishes and maintains an appropriate governance structure, aiming for the enhancement and growth of the value of managed assets, and conducts business operations sincerely and faithfully to meet the expectations of our customers. Furthermore, we strive to ensure that such business operations become ingrained in our corporate culture.
PRINCIPLE 3Proper Management of Conflicts of Interest
Our company has established a management system to appropriately manage conflicts of interest that may arise with our customers, as follows:

For our “Asset Management Business,” “Investment Discretion Business,” “Type II Financial Instruments Business,” and “Investment Advisory Business,” we have established measures to prevent the disadvantages caused by potential conflicts of interest transactions among our customers.

In order to properly manage conflicts of interest transactions between our company and companies belonging to the sponsor group, including MIRARTH Holdings Co., Ltd. (referred to as “Our Group Companies”), we have established the “Transactions with Interested Parties Regulations.” When acquiring, transferring, or entering into other contracts involving managed assets from Our Group Companies, we rigorously examine the fairness of the consideration and other contract conditions before executing the transaction.

Regarding transactions with Our Group Companies as interested parties, we ensure strict examination by the Compliance Officer and obtain deliberation and resolution based on the expertise and experience of external members in the Compliance Committee and e ach Fund Headquarters Operations Committee.
PRINCIPLE 4Transparency of Fees and Charges
Our company provides clear information to our customers regarding the details of fees and other expenses they bear, including the nature of the services for which those fees and charges are applicable. We ensure that our customers can easily understand this information.
PRINCIPLE 5Clear Provision of Important Information
In order to ensure transparency to our customers, our company adheres to the regulations established by the Financial Instruments and Exchange Act, Investment Trusts and Investment Trusts Association, Investment Adviser Association, and Type II Financial Instruments Dealers Association. We provide information disclosures in accordance with these regulations. Additionally, we strive to promptly and clearly provide our customers with information that is necessary and appropriate for their investment decisions
PRINCIPLE 6Provision of Appropriate Services to Customers
Our company strives to provide appropriate solicitation and advice based on our customers’ financial product knowledge, investment experience, investment objectives, needs, and the status of their assets, fully understanding their preferences and circumstances.
PRINCIPLE 7Framework for Appropriate Motivation of Employees
We expect our employees to strive for fair treatment of customers and appropriate management of conflicts of interest as actions to pursue the best interests of our customers. To achieve this, we provide internal compliance training for all employees and encourage participation in external compliance training, aiming to foster and improve compliance awareness. We also consider compliance awareness and practices as one of the indicators for evaluating employee performance.

That’s all.
Enacted on March 18, 2019