Whiz Partners Inc.independent investment firm
Tokyo cityscape

Customer-First Business Conduct Policy

22 August 2017

1. Formulation and Publication of this Policy

Whiz Partners Inc. (the “Company”) endeavors, in accordance with this Policy, to conduct its business with our clients’ interests foremost in mind, and to pursue the continual improvement of that conduct. Should this Policy be revised, we will promptly disclose the changes.

2. Pursuit of the Client’s Best Interest

As a steward of assets entrusted to us, the Company maintains the highest standard of professional expertise and corporate ethics, conducts its business with sincerity and fairness to clients, and pursues the client’s best interest through appropriate risk management.

3. Proper Management of Conflicts of Interest

In accordance with our Conflict-of-Interest Management Policy, the Company manages transactions and situations involving potential conflicts of interest so that the client’s interests are not unduly harmed. We also include provisions concerning conflicts of interest in our investment partnership agreements with clients, and maintain a framework to ensure compliance.

4. Clarity of Fees and Charges

From the planning stage of products and services, the Company communicates closely with prospective qualified institutional investors, with whom asymmetry of information is limited, to determine the level of fees and charges that is appropriate and well understood. When soliciting subscriptions, the Company endeavors to explain in detail, by means of pre-contract written documents and the like, the fees and other expenses to be borne by the client.

5. Clear Provision of Important Information

The Company endeavors to ensure clients’ full understanding of its investment approach, organization, the characteristics of the financial products it offers, the associated risks, the conditions of redemption, and other terms — by explaining these matters in writing. We pay particular attention to alerting clients to information of greater significance. Even after a contract is concluded, the Company continues to provide written information on the status of management of the investments.

6. Provision of Services Suited to the Client

In principle, the Company provides financial products and services tailored to the needs of qualified institutional investors. When the client is not a qualified institutional investor, the Company endeavors, as a basic stance, to understand the client’s financial situation, transaction experience, knowledge, and transaction purpose and needs, and to advise accordingly. Upon that basis, the Company provides its services and products only to clients who well understand the Company’s investment approach and who accept the fees, redemption terms, and other conditions.

7. Appropriate Incentive Frameworks for Employees

The Company evaluates the compensation and performance of its directors and employees based on whether they have contributed to the realisation of the client’s best interest. With respect to recruitment and development, the Company actively recruits professionals with deep expertise and rigorous professional ethics, develops its directors and employees, and provides appropriate training and other opportunities for self-improvement.

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