Policy for managing conflicts of interest

Strategic Capital’s (“SC”) policy for managing conflicts of interest is as follows.

Policy

In order to ensure that the interests of our CLIENTS are not unfairly impaired in relation to the business we conduct, SC shall appropriately manage transactions that may cause conflicts of interest in order to protect the CLIENTS and maintain their trust.

Management structure

The Chief Operating Officer (COO) shall be appointed the person responsible for promoting the appropriate management regarding conflicts of interest.

Type of transactions covered

SC shall identify and categorize transactions that may cause conflicts of interest in advance. We shall review such transactions periodically and on an as-needed basis. Types of transactions that may cause conflicts of interest include transactions in which the interests of a CLIENT conflict with those of other CLIENTS, and transactions in which the interests of a CLIENT conflict with those of SC.

Management method

SC shall assess what is causing the conflict of interest and shall take the appropriate measures according to the situation. In addition, SC shall strive to provide clear communication regarding the specific details of the conflicts of interest.

1. In principle prohibit transactions between CLIENT assets and the Company or related parties
2. Confirm the fairness of any terms regarding the transaction
3. Disclose the details regarding the conflict of interest and/or obtain CLIENT consent.
4. Establish a product development process, a rational process for setting commissions and an appropriate performance evaluation system that truly meets the needs of the CLIENT

Continuous improvement

SC shall review the effectiveness and appropriateness of the management of conflicts of interest and strive to continuously improve based on the results of the review