BASIC POLICY
ON CUSTOMER-ORIENTED BUSINESS OPERATIONS

PRINCIPLE 1Establishment and Disclosure of Basic Policy on
Customer Oriented Business Operations

MIRARTH Asset Management Inc. (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.