Policy on Customer-oriented Business Conduct

Principle  1

Formulation and Publication of Policy for Customer-oriented Business Conduct

Consonant Investment Management Co., Ltd. ("CIM") formulates and publishes our policy on customer-oriented business conduct (the "Policy"). In addition, the initiatives related to the Policy are regularly checked, and the Policy is reviewed as necessary in order to realize better business conduct.

Principle  2

Pursuit of Customers' Best Interests

As a financial business operator, CIM maintains a high level of expertise and professional ethics, conducts our operations with integrity and fairness to our customers, and pursues the best interests of our customers based on adequate research and analysis.

CIM shall make efforts to ensure such business conduct becomes established as its corporate culture.
For details, please refer to "Policy & Strategy".

Principle  3

Appropriate Management of Conflicts of Interest

In order to accurately understand the possibility of conflicts of interest in transactions conducted by Invincible Investment Corporation ("INV") and to properly manage any potential conflicts of interest, CIM has established the "Regulations on Transactions with Sponsor-related Parties" and the "Manual on Management of Transactions with Sponsor-related Parties" as CIM's voluntary rules, in addition to regulations imposed by related laws and regulations. CIM has defined interested parties, such as CIM's shareholders, as "Sponsor-related Parties". CIM has defined transactions with potential conflicts of interest, such as the purchase and sale of properties with sponsor-related parties and the outsourcing of operations for a fee to sponsor-related parties, as "Transactions with Sponsor-related Parties" and has clearly defined the criteria and procedures for conducting such transactions. In addition, in conducting Transactions with Sponsor-related Parties, CIM requires approval by the Compliance Committee, including external experts, and has a system in place to properly manage transactions that may involve conflicts of interest. CIM properly manages conflicts of interest by following such established procedures.

Details of CIM's efforts against conflicts of interest transactions and the status of transactions with interested parties are published in INV's Securities Report.

Principle  4

Clarification of Fees and Other Charges

CIM provides easy-to-understand information on the details of the fees and other charges incurred by INV, including what services such fees and other charges relate to.

For details of the fees and other charges incurred by INV, please refer to following reports on "IR Library".
- Article 41, Chapter VIII of the "Articles of Incorporation"
- "Overview of Expenses and Liabilities" of the "Asset Management Report"

Principle  5

Provision of Important Information in an Easy-to-understand Manner

CIM provides important information that can be disclosed, such as the management policy, financial condition, status of assets under management, and asset management fees that CIM receive, in addition to information disclosure stipulated by laws and regulations. The information is provided promptly and accurately in an easy-to-understand manner, according to the level of complexity and importance, in the financial results briefing materials and on INV's website.
For details, please refer to "Press Releases" and "IR Library".

Principle  6

Provision of Services Suitable for Customers

In order to maximize the value of investment units, from a mid-and-long term perspective, CIM conducts asset management of INV with the aim of ensuring steady growth and stable earnings of assets owned by INV.
For details, please refer to "Policy & Strategy".

Principle  7

Framework for Appropriately Motivating Employees

To promote actions in pursuit of the best interests of customers, fair handling of customers, and appropriate management of conflicts of interest, CIM has positioned compliance awareness and implementation status as one of the indicators for employee evaluation. CIM has also endeavored to foster and improve compliance awareness among all employees by regularly conducting in-house compliance training for all employees.
For details, please refer to " Initiatives for Society "and " Initiatives for Governance".