Our mission is to invest risk capital in a wide range of industries in Japan and in the process add value to companies. We believe this work makes a social contribution. We take our responsibility to our investors seriously. One of our obligations is to conform faithfully to legal requirements. To fulfill this obligation we have established compliance policies, incorporated in a compliance manual, which are summarized below:

Compliance policies

1.We take seriously our social responsibility as an investment company.

2.We strictly observe law, rules and social expectations.

3.We keep strictly confidential and do not exploit for ourselves information received from clients and counterparties.

4.We report violations to the enforcement authorities and make clear our commitment to maintain these norms.

Since our founding* we have maintained a perfect record of compliance with established laws and rules.

We have established internal regulations and controls against insider trading since our founding. All employees are required to make full disclosure regarding their investments in securities of public companies. We conduct regular inspections and audits to ensure compliance.

We organize and operate compliance structure on the basis of policies above.

*Our founding relates back to the founding of our predecessor, Phoenix Capital.