Nippon Institutional Securities Co., Ltd. (the “Company”) is fully aware that it is entrusted with the serious responsibility of fulfilling an intermediary role as a leading company in the capital markets, where the finances of the national economy are managed and procured, and therefore constantly strives to ensure that all of its officers and employees habitually maintain the sound common sense and ethics the people of Japan trust them to have as professionals and act with the expertise required of them in accordance with the Principles in the Financial Services Industry announced by the Financial Services Agency.

The Company’s employees, as good citizens, must also respect each other and eliminate and prevent discriminatory comments or any other forms of harassment based on nationality, race, gender, age, beliefs, religion, social status or physical disability.

To this end, the Company has established the following code of conduct for all officers and employees to abide by as a basic attitude when carrying out their duties.

1. Compliance with social norms and laws and regulations

Officers and employees must have a correct understanding of the various rules related to the financial instruments business, such as laws and regulations, in order to protect investors and ensure the fairness of transactions. They must not only strictly comply with these rules, but also maintain and put into practice common sense and an awareness of ethics to compensate for unforeseen matters arising with respect to laws and regulations in accordance with generally accepted social norms.

2. Appropriate control of conflicts of interests

Any conflicts of interests occurring in the course of work must be controlled appropriately. Officers and employees must not use their positions, authorities, information obtained in the course of their work or any other such advantages to further their own interests unfairly.

3. Compliance with duty of confidentiality and information management

With the exception of statutory disclosure information or other such information whose disclosure is accepted under the relevant regulations, officers and employees must exercise extreme caution in managing information they come to know in the course of work and protect it as confidential material.

4. Maintenance of social order and realization of social contribution

As a good corporate citizen, the Company must actively participate in social activities and help maintain societal order and stability. It must also be resolute in dealing with forces or groups that engage in antisocial activities and completely refrain from conducting any transactions with them.

5. Activities that emphasize the interests of clients

Officers and employees must be fully aware of the investment knowledge and experience of clients, as well as the assets available to clients and their investment objectives, and must always act in the best interests of clients in view of their characteristics.

6. Faithful and fair execution of work from the perspective of clients

As an intermediary, the Company must constantly focus on the needs and interests of clients and execute its work faithfully and fairly from the perspective of clients.
The officers and employees of the Company must not use their authorities or positions at the Company, or any information available to them that gives them a comparative advantage, in order to benefit any particular clients. They must also endeavor to establish principles of personal responsibility by ensuring that transactions are based on appropriate investment advice and the clients’ own judgment.
Furthermore, officers and employees must always act in the interests of clients whenever they have fiduciary duties based on contracts with clients.

7. Provision of advice to clients

When providing investment advice to clients, officers and employees must take a neutral standpoint, clearly distinguish between facts and opinions, and exercise their expertise and abilities in any advice they give.
In accordance with related laws, regulations and rules, officers and employees must not provide advice to clients based on non-public information such as insider information deemed likely to have an impact on market value as a result of investment.

8. Activities in capital markets

Even in the absence of provisions in laws and regulations, officers and employees must refer to the Company's code of conduct and pass judgment on the rights and wrongs of activities that may cause mistrust in light of social norms and the Company’s role as a market intermediary.
In accordance with related laws, regulations and rules, officers and employees must appropriately control non-public information such as insider information deemed likely to have a material impact on market value as a result of investment.

9. Awareness of social mission and maintaining and improving soundness and credibility of capital markets

Officers and employees must have a correct understanding of the fairness and soundness of capital markets and must not engage in any activity that hinders their sound development. Officers and employees must also be aware of and act upon the social mission the company is required to carry out by maintaining the soundness of capital markets.
Officers and employees must not erode the confidence placed in association members or engage in inappropriate behavior that could undermine the soundness of capital markets, such as involvement in activities that impair appropriate information disclosure or lead to the distortion of fair pricing.