Policies on the Personal Information Protection

Schweitzer Investment Co., Ltd. (the “Company”) and its officers and employees comply strictly with the Act on the Protection of Personal Information, related laws and regulations, and the guidelines of supervisory agencies. To ensure compliance, the Company has adopted the following policies.

1. Personal information shall be handled in accordance with applicable law, and efforts shall be made to ensure that the content of personal information is accurate and up-to-date
2. The use of personal information shall be subject to applicable law. The use of personal information shall not exceed its intended purposes. Also, personal information shall not be provided or disclosed to third parties in the absence of the individual's consent without good cause such as a duty to disclose pursuant to applicable law
3. Personal information may be handled by outside contractors when it is necessary as per the purpose of use of personal information. In such case, such subcontractors shall be supervised under the Company’s responsibility to ensure the protection of personal information
4. Thorough training and education of all officers and employees shall be conducted to prevent leaks and improper use of personal information
5. The Company take measures to safely manage personal information to prevent leakage, loss or unauthorized use of personal information
6. Disclosure, correction, and termination of use of personal information shall be performed in accordance with applicable law upon request from the individual concerned

For inquiries on the Company’s safety measures or the personal information, please contact us at the Contact for Inquiries and Complaints concerning Personal Information listed below.

Use of Personal Information

• Providing the services of Investment Management Business for Qualified
  Investors and related businesses properly
• The provision of information concerning solicitations and services of the
  Company properly
• Exercising rights and performing duties pursuant to contracts with
  customers and applicable law
• Ensuring that transactions with customers and business
  counterparties are implemented properly and efficiently
• Personal information may be used by the Company even after the end of the
  contracts within the scope of the purposes of use in the aforementioned items

Company Profile

Please refer to Company Profile section at < https://schweitzer.jp/?lang=en#company-profile>

• Contact for Inquiries and Complaints concerning Personal Information
  Schweitzer Investment Co., Ltd., Compliance Department

  Hirakawacho KS Building 4F, 2-4-14 Hirakawacho, Chiyoda-ku, Tokyo 102-0093 Japan

  +81-3-6261-7509 (9:00~17:00 Monday through Friday, excluding Holidays)

• Name of Authorized Self-Regulatory Industrial Association
  Contacts for Complaints and Dispute Resolution
  The Japan Investment Advisers Association (hereinafter referred to as “JIAA”)

  Tokyo Shoken Kaikan 7F, 1-5-8 Nihonbashi-kayaba-cho, Chuo-ku, Tokyo 103-0025 Japan

  +81-3-3663-0505 (Monday through Friday 9:00 to 17:00, excluding Holidays)

The contents of this policies may be reviewed and revised from time to time as necessary according to changes in applicable laws. In such case, the Company may announce such changes publicly by posting the revised policies on the Company’s website or by other means.

Basic Policy regarding response against Anti-Social Forces

Schweitzer Investment Co., Ltd. (the “Company”) recognizes that it is necessary and important to resolutely cut off and eliminate any relationship with anti-social forces from the viewpoint of fulfilling our social responsibilities. The Company shall take a firm stand against anti-social forces, shall not provide any benefits under any name, and shall not have any relationship with antisocial forces. The Company declares the following basic policies regarding response against anti-social forces:

1. The Company shall deal with anti-social forces as an organization
2. The Company shall deal with anti-social forces in cooperation with external specialized organizations
3. The Company shall sever all relationships, including business transactions, with anti-social forces
4. In the event of an emergency, we will take legal action, both civil and criminal
5. We will not engage in any backroom deals or provide funds to antisocial forces

Complaints Handling and Dispute Resolution

Schweitzer Investment Co., Ltd. (the “Company” or “Us”) takes measures to handle complaints and resolve disputes, stipulated in the Financial Instruments and Exchange Law, through complaint resolution or mediation conducted by the Japan Investment Advisers Association (outsourced to FINMAC), other than our own complaints handling and dispute resolution measures.

If you have complaints, please contact us or FINMAC at below contacts.

• Our Company Contact

  Compliance Department

  Phone: +81 3 6261 7509

• Contact for Statutory Complaints Handling and Dispute Resolution Measures
  Financial Instruments Mediation Assistance Center (FINMAC)

  2-1-1 Kayabacho, Chuo-ku, Tokyo 103-0025 Japan

  0120-64-5005 (toll free) (Monday through Friday 9:00 to 17:00, excluding Holidays)