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Crédit Agricole Securities Asia B.V., Tokyo Branch

In connection with the diversification of services provided by financial institutions and the development of global financial conglomeratization, multiple interests compete or conflict with each other within a financial institution or financial group increasing the possibility of conflicts of interests.

Under such circumstances, Crédit Agricole Securities Asia B.V., Tokyo Branch (the "Branch") is required to manage the transactions that may cause conflicts of interests in order to prevent the interests of our customers from being unjustly impaired.

The Branch, a Type 1 Financial Instruments Business Operator engaging in Securities-Related Business under the Financial Instruments and Exchange Act (Act No. 25 of April 13, 1948), has established the Conflict of Interest Management Policy (this "Policy"), which is required in the creation of the conflict of interest management system under applicable laws and regulations.

(1) Covered Transactions

"Transactions that may cause conflicts of interests," which are covered by this Policy, means such transactions conducted by the Branch or any of its Parent Financial Institutions, Etc. that may unjustly impair the interests of our Customers (the "Covered Transactions").

Conflicts of interests may occur (I) between the Branch and/or any of its Parent Financial Institutions, Etc. and their Customers, or (II) between the Customers of the Branch and/or any of its Parent Financial Institutions, Etc. and other Customers.

"Customer" means, in relation to the "Financial Instruments Related Business" conducted by the Branch, (I) any customer who has already established business relations, or (II) any customer who may establish business relations.

"Parent Financial Institution, Etc." means our parent corporation, etc., our subsidiary corporation, etc., or affiliated corporation, etc. of any parent corporation, etc., as is a Financial Instruments Business Operator, a bank, an insurance company (including any foreign insurance company, etc.), or a person who engages in Financial Instruments Business, banking business or insurance business in any foreign country in accordance with any foreign law or regulation.

"Financial Instruments Related Business" means any Financial Instruments Business and such Business Incidental to Financial Instruments Business, as provided for in Article 35, Paragraph 1 of the Financial Instruments and Exchange Act, that are conducted by the Branch.

(2) Types of Transactions That May Cause Conflicts of Interests; Criteria

The following transactions may be considered as types of "transactions that may cause conflicts of interests." However, as these types are only criteria to determine whether there is any "transaction that may cause any conflict of interests," please note that the satisfaction of any such criteria does not necessarily mean the occurrence of a "transaction that may cause a conflict of interests." Also, please note that some additions or modifications may be made in the future as may be necessary.

○If any Customer reasonably expects that his/her own interests will be prioritized through counseling or advice (Duty-of-Loyalty Type);
○If the Branch or any of its Affiliates may obtain any economic profit or avoid any economic loss at the expense of any Customer (Duty-of-Loyalty Type);
○If the Branch or any of its Affiliates obtains or will obtain any incentive in the form of money, goods or services other than the usual commission fees or expenses in connection with the transactions with any person other than their Customers (Duty-of-Loyalty Type);
○If the Branch or any of its Affiliates conducts any transaction with any Customer who should be protected by the Branch or such Affiliate (Self-Agency Type);
○If the Branch or any of its Affiliates conducts any transaction under which the Branch or such Affiliate takes the side of the counterparty of any Customer who should be protected by the Branch or such Affiliate (Two-Side Agency Type);
○If the Branch or any of its Affiliates conducts any transaction with the counterparty of any Customer who should be protected by the Branch or such Affiliate, which counterparty competes with such Customer (Competitive Transaction Type);
○If the Branch or any of its Affiliates conducts any transaction through the use of non-public information on any Customer who should be protected by the Branch or such Affiliate, which transaction results in any benefit to the Branch or any such Affiliates (Information Use Type); or
○If the conditions for similar transactions may not be expected due to the involvement of Branch or any of its Affiliates in the same transaction on multiple sides (Transaction-Internalization Type).

In addition, upon determining whether any conflict of interests has occurred, the Branch will consider whether any impact upon the reputation of the Branch or our group has been caused.

This Policy will not cover any acts other than those that constitute "transactions that may cause conflicts of interests" notwithstanding that such acts are prohibited under the Financial Instruments and Exchange Act, or any other laws or regulations.

(3) Specific Examples

The following transactions and any other similar transactions may be considered as specific examples of "transactions that may cause conflicts of interests":

• If the Branch or any of its Affiliates provides any advice regarding financing or M&A to multiple Customers concerning same project which compete or conflict with each other;
• If the Branch or any of its Affiliates provides any advice regarding subscription or issuance of securities to any Customer while recommending another Customer to deal in such securities;
• If the Branch or any of its Affiliates provides any investment research regarding any Customer to whom the Branch or such Affiliate provides any financing advice or any credit;
• If the Branch or any of its Affiliates provides any advice regarding M&A to one Customer while intermediating in financing another Customer who intends to acquire such Customer, and competes and conflicts with such Customer;
• If with the knowledge of potential information regarding securities transaction of any Customer, the Branch or any of its Affiliates conducts any proprietary transaction regarding such securities;
• If the Branch or any of its Affiliates conducts any proprietary transaction, participates in subscription or is otherwise involved through trustees or managers with respect to any securities to which any order has been given by any Customer;
• If the Branch or any of its Affiliates recommends or sells any securities issued or created by the Branch or such Affiliate or any securities held for its own account to any Customer (except the case the Branch or its Affiliates discloses that the Branch or its Affiliates issued or created the financial products in the sales material);
• In case of internalization of transaction, i.e. the Branch puts an order to, or receives an order from, its affiliated financial institutions (except the case where such transaction is a regular one and is executed at the standard market price level);or
• If any employee of the Branch or its Affiliates receives any gift or entertainment (including any non-monetary benefits) that may prejudice the interests of any Customer.

Conflict of interest management applies to the transactions which involve Crédit Agricole Corporate and Investment Bank., Tokyo Branch, Amundi Japan Ltd., and/or Crédit Agricole Life Insurance Japan Ltd., etc., as well as the Branch The transactions handled by Crédit Agricole Corporate and Investment Bank and/or other foreign group companies are also included in the scope of conflict of interest management.

If the Branch identifies any transaction that may cause a conflict of interests, the Branch will properly secure the protection of our Customers by selecting from any of, or combining, the following methods and any other methods (the following methods are only examples, and the following measures need not be adopted):
○The method of separating the division conducting the Covered Transaction, and the division conducting the transaction with such Customer;
○The method of amending the conditions or method of the Covered Transaction or the transaction with such Customer;
○The method of discontinuing the Covered Transaction or the transaction with the Customer; and/or
○The method of properly disclosing to the Customer the possibility that the interests of such Customer may be unjustly impaired in connection with the Covered Transaction (only if such disclosure does not violate the duty of confidentiality assumed by the Branch, or any of its Parent Financial Institutions, Etc.).

(1) Establishment of the Conflict of Interest Management Control Division

The Compliance Department of the Branch will be the Conflict of Interest Management Control Division, and the Head of Compliance Department will serve as chief of such division.

The Conflict of Interest Management Control Division will be independent from the Sales Division, and will never receive any direction or order regarding the treatment of specific cases from the Sales Division.

The Conflict of Interest Management Control Division will control the company-wide management system regarding the identification of transactions that may cause conflicts of interests and the management of conflicts of interests.

(2) Duties of the Conflict of Interest Management Control Division

The Conflict of Interest Management Control Division will assume the following duties in a position independent from the division responsible for the relevant business. The Conflict of Interest Management Control Division will identify the transactions that may cause conflicts of interests and the management of conflicts of interests in liaison with Interest Management Control Division at Crédit Agricole CIB Head Office in Paris.

The Conflict of Interest Management Control Division will identify any Covered Transactions, and also instruct the divisions responsible for such business to properly manage any conflicts of interests regarding the Covered Transactions.

The Conflict of Interest Management Control Division shall quarterly report to the Joint Compliance Management Committee any "transactions that may cause conflicts of interests" that have been identified and managed.

The Conflict of Interest Management Control Division will receive from sales staff the reports on the status of the management of conflicts of interests regarding the Covered Transactions on a regular basis or on a case-by-case basis, and verify whether the conflicts of interests have been properly managed, and, when necessary, review the procedures for conflict of interest management, or the conflict of interest system.

If the interests of our Customers may be unjustly impaired, the Conflict of Interest Management Control Division will instruct the divisions responsible for such business to properly manage conflicts of interests, or review the Covered Transactions, when necessary.

The Conflict of Interest Management Control Division will regularly provide training for the management of conflicts of interests based on this Policy and the Conflict of Interest Management Rule to any officers and employees and keep them informed about the management of transactions that may cause conflicts of interests.

(3) Record and Preservation

The Conflict of Interest Management Control Division identifies any transaction that may cause any conflict of interests and selects the management method thereof, the responsible person of the Conflict of Interest Management Control Division will record such measures, and preserve such record for five (5) years from the creation of such record.

(4) Internal Audit by the Internal Audit Division

The Internal Audit Division of the Branch will, based on a risk-based approach, regularly conduct a verification of the Conflict of Interest Management Control Division and other personnel composition regarding the management of conflicts of interests and their business operation system.