This best execution policy sets forth our policy and methods for executing orders from client under the best terms and conditions in accordance with Article 40-2 (1) of the Financial Instruments and Exchange Act. Upon acceptance of a client order for securities defined below, EVOLUTION JAPAN Securities Co., Ltd. (hereinafter called “EJS”) will endeavor to execute that order under the best terms and conditions for the client in accordance with the following methods.
 
1. Applicable Securities

“Listed stocks, etc.” as defined in Article 16-6 of the Enforcement Ordinance of the Financial Instruments and Exchange Law, which includes stocks, convertible bonds, exchange-traded funds (beneficiary certificates of investment trusts linked to equity indexes), real estate investment trusts (REITs), etc.

2. Method for executing orders on the best terms
EJS will place a brokerage order of listed stocks, etc. received from a client on the Market unless requested with specified instructions.
Listed stocks, etc.

EJS will place a brokerage order of listed stocks, etc. received from a client on the Market in Japan without delay. Likewise, for those orders received from a client during off-market hours, EJS will place the order on the Market once the trading session on the Market reopens. This will allow the client’s order to be executed in the floor-trading of the said Market. However, if a client requests methods other than described above (which should be limited to those acceptable to EJS, such as private trading system – PTS, off-exchange transactions, off-floor trading , negotiated transactions with EJS etc.), the client’s order will be executed according to the method and condition agreed between the client and EJS.

①EJS will place a brokerage order received from a client on the Market in Japan without delay. For those orders received from a client during off-market hours, EJS will place the order on the Market once the trading session on the Market reopens.
②Regarding ① EJS will execute in the following method

(a) Where the relevant stock is listed on one Market (single listing), the order will be placed on the said Market.

(b) If the relevant market chosen by the above methods (a) is a market which EJS does not operate in, EJS will place the client orders to a contracted Handling Broker which has the licenses and membership to operate in the designated market for more trade opportunities and increase the probability of realization of the 
client’s orders.

3. Reasons for selection of a particular method
We use financial market rather than off-exchange transactions because we believe that financial market transactions are better from the clients’ standpoint. Financial markets attract a large volume of orders from investors, resulting in greater liquidity, a better possibility of completing a transaction, faster transactions, and other advantages. For securities listed on multiple financial markets, we use the market with the highest liquidity because we believe that this is in the best interests of the client.

4. Other items
(1) Irrespective of the order execution method used as prescribed in the above item 2, the transactions listed below will be executed as follows.

① Transactions in which a client has specified the method of execution (by specifying the Market or the execution hours, or by requesting the execution of basket orders, etc.):
Execution by the method agreed between the client and EJS (with respect to where no specific instruction has been received, EJS will follow the best execution policy.)

②Transactions under a discretionary investment management agreement.
Execution by a method of EJS’s choice within the range of discretion granted by the client or the third party designated by the client in the relevant agreement and so forth.

③Transactions of stocks less than a trading unit (excluding demand for repurchase to and demand for additional purchase to the issuing company)
Execution by placing the order to a financial instruments broker that deals in stocks less than a trading unit.


(2) Transactions related to execution of reverse trades on margin trading will be carried by the method of executing reverse trades in the same Market where a margin position has been established (except for unavoidable cases such as delisting)


(3) There may be instances where we are forced to select an order execution method that is not consistent with this best execution policy due to a computer system malfunction or other problem. In this case, we will do our best to execute the order on the best terms possible at that time.


Our obligation involving the best execution of orders is not restricted to the price. We are obligated to execute orders in the best manner by also taking into account cost, speed, reliability and many other factors associated with the order. Consequently, there may be instances where, following the execution of an order, the terms do not appear to be the best possible based on price alone. However, it is not possible to use solely the price as the basis for determining whether or not a particular transaction is in violation of the best-execution obligation.