日本語

Crédit Agricole Securities Asia B.V., Tokyo Branch This best execution policy sets forth, in accordance with Article 40-2(1) of the Financial Instruments and Exchange Law, our policy and methodology for execution under the best trading conditions for the customer.
Upon acceptance of a customer order for securities listed on a financial instrument exchange in Japan (hereinafter “Exchange”), we will endeavor to execute it in accordance with the following policy when there is no specific customer instruction regarding the execution method.

(1)	“Listed share certificates, etc.,” as prescribed under Article 16-6 of the Financial Instruments and Exchange Law Enforcement Order, including shares of stocks, bonds with share option, ETFs (beneficiary certificates in investment trusts linked to a stock index), REITs (investment certificates in real estate investment trusts), etc which are listed on an Exchange.
(2)	We do not deal with “Tradable Securities”, such as Green Sheet Stocks and bonds with share option, as set forth in Article 67-18(iv) of the Financial Instruments and Exchange Law.

In principle, we will treat all customer orders for listed share certificates, etc. as agency order and place them with an Exchange, and will not execute such orders on the “off-exchange” market including by means of our acting as the direct counterparty or using a PTS (Proprietary Trading System).

(i)	Upon receipt of an agency order we will promptly place it with an Exchange where the issue is listed. Orders received from a customer outside of floor-trading hours of the Exchange will be placed after the floor-trading reopens on that Exchange.
(ii)	Agency orders received pursuant to (i) will be placed with an Exchange as follows:
	(a) if the issue is listed on a single Exchange (single listing), we will place the order with said Exchange; (b) if the issue is listed on more than one Exchange (multiple listing), we will place the order with the Exchange that Bloomberg Terminal etc. initially shows (chosen as having the highest trading volume during a certain period by a computation method prescribed by Bloomberg. Please call the Branch for details.) when Securities Code No. is inputted into such terminal as of the date of execution; (c) if the Branch is not a participant or member of the Exchange selected through (a) or (b) above, we will place the order with said Exchange through an exchange participant or member with whom we have entered into an agreement for handling agency orders on said Exchange;

Financial instruments exchange markets have a high concentration of the demand from many investors, and they are believed to be a superior marketplace in terms of liquidity, execution probability and execution speed, etc. in comparison with off-exchange trade. We believe that execution on an Exchange would be the most reasonable method for our customers.
If a security is listed on more than one Exchange, we believe that it would be most reasonable for the customer to execute it on the Exchange with the highest liquidity for that security.

(1)

Notwithstanding 2. above, we will execute the following types of transactions as indicated below: (i) Execution by a method instructed by the customer (our acting as the direct counterparty, on a specific Exchange, during specific period of time, etc): We will execute the order as instructed. (ii) Execution under a discretionary trading agreement, etc.: We will execute the order by a method we choose within the range of discretion permitted under the contract. (iii) Transaction in which execution method is specified under General Terms, etc. such as cumulative stock investment and stock mini investment, etc.: We will execute the order by the prescribed execution method. (iv) Odd-lot shares or shares of less than a trading unit: We will place the order with a financial instruments firm that handles such shares.

(2)

In some cases as a result of a system failure, etc we may have no alternative but to execute an order by a method other than the one selected based on this best execution policy. In such cases, we will endeavor to execute it on the best terms possible.

The duty of best execution requires the broker to execute orders taking into consideration not just the price but various factors such as cost, speed and certainty of execution.
That a trade appears after the fact not to have been executed at the best possible price does not by itself necessarily constitute a violation of the duty of best execution.