VARECS Partners Limited have established the following Solicitation Policy regarding discretionary investment management business and investment advisory business. We shall comply with the following policy in addition to related laws, ordinances, rules and regulations when soliciting clients.
１．We will endeavor to solicit clients considering the client’s investment knowledge, experience, financial standing, purpose of the transaction.
（１）We will recommend investment discretionary management or investment advisory management contract considering the client’s investment knowledge, experience, financial conditions, purpose of concluding a financial product transaction contract.
（２）We seek to explain important matters such as products and risks in an easy-to-understand manner, considering to the methods and degree necessary for customers to understand them, and to ensure that they are fully understood.
２．We will give due consideration to the time, place and method of solicitation and will not cause inconvenience to clients
（１）We always place the highest priority on securing trusts of our clients and endeavor to solicit from customer-oriented perspective.
（2）We will give due consideration to the time, place and method of solicitation when soliciting by telephone or visiting and avoid inconvenience to the clients. We will refrain from visiting or making phone calls during times that would disrupt the peace of business or daily life.
３．Others
（１）We do not solicit clients by making affirmative judgments of unconfirmed events, making assertions that differ from actuality, providing false information or misconstruing information.
（２）When entering into agreements with clients, we strive to provide appropriate explanations concerning the risks and other important aspects of our investment products.
（３）When entering into agreements with clients, we provide ample documented explanation beforehand, forming agreements based on client understanding.
（４）We will provide internal training to our employees and make our best efforts to strengthen our internal management system for proper solicitation complying with laws and orders such as “Act on the Provision of Financial Services”, “Financial Instruments and Exchange Act” and regulations of Japan Securities Investment Advisors Association.
（５）We will respond to complaints and requests from clients faithfully.