Summary of Conflicts of Interest Management Policy

JPMorgan Asset Management (Japan), Ltd.

Enactment Date: 1 June, 2009

The risk of conflicts of interest is increasing with competing or opposing interests within a financial company or its affiliates due to the diversification of financial services and the consolidation of the financial industry.

J.P. Morgan Group (“J.P. Morgan”) including JPMorgan Asset Management (Japan), Ltd. (“The Company”) manages conflicts of interests to prevent the interests of a customer from being unfairly impacted.

J.P. Morgan has businesses in Japan including investment banking, cash settlement, asset management and global custody to provide our customers with the most appropriate service to meet their various business needs. The Company has developed the Conflicts of Interest Management Policy (this Policy), and has established a system of managing conflicts for "transactions that may cause conflicts of interests" between J.P. Morgan and its customers, and among customers, while improving service further. The outline of this Policy is laid out as below.

1. Types of Transactions That May Cause Conflicts of Interest

The following examples may be considered as types of "transactions that may cause conflicts of interests". These types are only criteria to determine whether there is any "transaction that may cause any conflict of interests". The satisfaction of these criteria does not necessarily mean a "transaction that may cause a conflict of interests" has occurred, likewise there may also be cases not listed here which will need to be managed as "transaction that may cause a conflict of interests." Also, please note that some additions or modifications to the types and criteria of transactions may be amended in the future as necessary.

• Firm vs. Client – Conflict where J.P. Morgan’s interests may be opposed to one or more clients’ interests

Example: A case where J. P. Morgan conducts any proprietary transaction regarding securities on its own account with the knowledge of information regarding such securities transaction of the Customer.

• Employee vs. Client – Conflict where an employee of J.P. Morgan’s interests may be opposed to one or more clients’ interests

Example: A case where an employee of J.P. Morgan trades securities in his personal account while in possession of insider information on the subject financial instrument.

• Client vs. Client – Conflict where a client’s interests may be opposed to the interests of one or more other clients

Example: A case where a “Cross Trade”, defined as Buy and Sell transactions in the same issuer at the same price between (or among) our investment assets, is executed.

• Employee vs. Firm – Conflict where an employee of J.P. Morgan’s interests may be opposed to J.P. Morgan’s interests

Example: A case where an employee of J.P. Morgan takes up the post as a board member of a competitor of J.P. Morgan.

2. Conflicts of Interest Management System

The Global Conflicts Office of J.P. Morgan is responsible for the oversight of conflicts of interest management from an enterprise point of view. The Company designates Compliance departments as independent from the Sales Department and as the Conflicts of Interest Management Control Division with the head of Compliance department as the Conflicts of Interest Management Control Supervisor to perform appropriate conflicts of interest management. The Company identifies transactions that may cause conflicts of interest, and has established a system of Conflicts of Interest Management from a local point of view as based on this Policy.

3. Method of Managing Transactions That May Cause Conflicts of Interest

The Company, with respect to the management of conflicts of interest, has by appropriately managing customer information by complying with laws / regulations and the various internal rules and the separation of departments and Segregation of Duties established a system of preventing transactions that may cause conflicts of interest from occurring. For example, the Company restricts transactions between assets under management related to the Discretionary Investment Business provided to customers, the Company’s proprietary account and the Company’s employee personal dealing. In addition, in order for such restrictions to function effectively, Compliance department, etc. monitors the compliance status, and transactions that may cause conflicts of interest are avoided.

Furthermore, in the case that the Company identifies any transaction that may cause a conflict of interest, the Company will manage the transaction in order not to unjustly impair the interests of customers by selecting from any one, or combination, of the following methods or any other methods that might not be listed (the following methods are only examples, and the following measures need not be adopted):

• The method of restricting information sharing between divisions or within a division.
• The method of amending either the conditions or method of transaction with a client if there is a possibility of a conflict of interest, or both.
• The method of discontinuing the transaction that may cause conflicts of interest with such customer.
• The method of properly disclosing to such customer the possibility that the interests of such customer may be unjustly impaired in connection with the transaction or receiving the consent from such customer.
• The method of approving transactions in advance.

4. Scope of the Companies Covered by Conflicts of Interest Management

On the basis of the Financial Instruments and Exchange Act, in Company transactions which involve JPMorgan Chase Bank, N.A., Tokyo Branch, JPMorgan Securities Japan Co., Ltd. and J.P. Morgan Mansart Management Japan Co., Ltd. as well as the Company are intended to manage conflicts of interests. In principle, the Company will not share non-public information between them, so they will manage information by way of regulating the share of information between them through use of the information barrier. Also, the transactions which involve foreign affiliates of J.P. Morgan other than those which do not engage in Financial Instruments Business and Bank business are intended to manage conflicts of interest.

If you have any questions, feel free to contact responsible employees or Compliance Division of the Company (03-6736-1554).

Amended as of February 1, 2010:
Added Prima Investment YK as the Scope of the Companies Covered by Conflicts of Interest Management.

Amended as of April 1, 2011:
Deleted J.P. Morgan Worldwide Securities Services Japan, Ltd. from the Scope of the Companies Covered by Conflict of Interest Management due to the merger with JPMorgan Securities Japan Co., Ltd.

Amended as of August, 2014:
Changed J.P. Morgan Finance Japan YK into J.P. Morgan Finance Japan GK, based on its organization change.

Amended as of October 1, 2014:
Amended in accordance with absorb-type merger of Prima Investment YK into J.P. Morgan Finance Japan GK.

Amended as of February 1, 2015:
Amended in accordance with absorb-type merger of J.P. Morgan Finance Japan GK into JPMorgan Securities Japan Co.,Ltd.

Amended as of September 1, 2018:
Revision due to review of words and phrases.

Amended as of May 1, 2020:
Revision on review of Types of Transactions That May Cause Conflicts of Interest and the examples.

Amended as of April 1, 2021:
Revision in 4. Scope of the Companies Covered by Conflict of Interest Management: JP Morgan Mansart Management Co., Ltd. has been added in the scope of the conflict of interest management.