ITOPIA Asset Management Co.,Ltd. (hereinafter the "Company") has established a solicitation policy concerning financial instruments as described below in accordance with the Financial Instruments and Exchange Act and the Act on Sales, etc. of Financial Instruments and shall conduct sales, etc. of financial instruments to customers in an appropriate manner.
Matters to be taken into consideration in light of the knowledge, experience and status of property of the person subject to the solicitation, and the purpose of said person for the conclusion of the contract pertaining to the relevant sales of financial instruments
- The Company shall recommend financial instruments that are appropriate to the customer by endeavoring to understand the customer's knowledge, investment experience and status of property and the purpose, etc. for the conclusion of the contract pertaining to the relevant sales of financial instruments.
- To ensure that the customer undertakes appropriate investment decisions at the customer's own judgment, the Company shall endeavor to help the customer fully and accurately understand the content of the target financial instruments, relevant risks and other important matters by providing detailed explanations.
Matters to be taken into consideration for the person subject to the solicitation with regard to the method and time of the solicitation
- The Company shall endeavor to execute solicitation from the standpoint of the customer in compliance with relevant laws and regulations and various other rules, placing utmost importance on gaining the customer's confidence at all times.
- The Company shall endeavor to conduct solicitation based on reasonable grounds and by complying with relevant laws and regulations and other rules.
- The Company shall give due consideration to the time of day and method of conducting solicitation so that it will not cause a nuisance to the customer.
Matters for ensuring the appropriateness of the solicitation
- Officers and employees of the Company shall constantly endeavor to acquire knowledge and skills so as not to betray customers' trust and expectations.
- The Company shall comply with the Financial Instruments and Exchange Act and other relevant laws and regulations as well as the rules of Japan Investment Advisers Association, Type II Financial Instruments Firms Association and other self-regulatory organizations and make company-wide efforts to strengthen its internal control system to ensure appropriate solicitation.
The following matters are prohibited by law pertaining to the investment advisory business to be conducted by the Company.
To conduct the following acts to a customer or for a customer (except where such acts are conducted as Type II Financial Instruments Business):
- Purchase and sale of securities, market derivatives transactions or foreign market derivatives transactions;
- Intermediation, brokerage or agency for the purchase and sale of securities, market derivatives transactions or foreign market derivatives transactions;
- Intermediation, brokerage or agency for entrustment of the following transactions:
- Purchase and sale of securities or market derivatives transactions on a financial instruments exchange market;
- Purchase and sale of securities or foreign market derivatives transactions on a foreign financial instruments market;
- Over-the-counter transactions of derivatives or intermediation, brokerage or agency for such transactions;
The following matters are prohibited by law pertaining to the investment advisory business and the investment management business to be conducted by the Company:
- Receiving a deposit of money or securities from a customer, for any reason, by or having a customer's money or securities deposited to a person being closely related to the Company, except where it is necessary for the Company to conduct such acts for settling transactions of purchasing, selling or other trading of securities conducted for its customer in relation to the Company's investment management business; and
- Lending money or securities to a customer or performing intermediation, brokerage or agency for a third party's lending of money or securities to a customer.