Disclosures.

Investment Lab Co., Ltd. (“the Company”) and its officers and employees will comply with the Act on the Protection of Personal Information, related laws and regulations, guidelines of supervisory authorities, rules of industry associations, and the Company’s compliance rules, and will handle personal information appropriately and take appropriate measures for security management as described below.

In addition, we will provide thorough guidance and education to our officers and employees to ensure that the provided personal information is handled appropriately in the course of business, and we will periodically check whether the information is being handled properly and continuously improve the process if any issues are found.

Acquisition of Personal Information

We will acquire personal information to the extent only necessary for our business and by proper and fair means.

Purpose of Use of Personal Information

We will use personal information in an appropriate and fair manner for the purpose of conducting the following businesses and operations. When handling personal information beyond the scope necessary to achieve the purpose of use, the Company shall obtain the consent of the individual to whom the information pertains, except in the cases specified in each item of Article 16, Paragraph 3 of the Act on the Protection of Personal Information. If the purpose of use is changed, in principle, the Company will notify the customer about the change.

Our Business Description

· Investment Management Business and other related businesses thereto
· Investment Advisory and Agency Business and other related businesses thereto
· Type II Financial Instruments Business and other related businesses thereto
· Other business that may be conducted, and related businesses thereto

Purpose of Use

· To conduct our business
· To conduct appropriate solicitation and marketing of our business
· To identify the person in charge at our business partners and to make necessary contacts
· To provide appropriate services to our customers
· To conduct appropriate talent hiring activities

Provision of Personal Information to Third Parties

We will not provide personal information to third parties except in the following cases:

· When the person concerned has given prior consent
· When required by law, or in accordance with the provisions of the Personal Information Protection Law
· When we provide personal information to our business partners to the extent necessary for the services

Sensitive Information

We will not acquire, use, or provide to third parties any sensitive information as defined in “Article 6 of the Guidelines for Personal Information Protection in the Financial Sector”, except as otherwise provided by law or other guidelines.

Disclosure, Correction, Suspension of Use, etc. of Retained Personal Data under the Act on the Protection of Personal Information

When we receive a request from a customer to disclose, correct, or discontinue the use of retained personal data pertaining to the customer, we will promptly respond to the request after confirming the identity of the customer, unless there is a special reason not to do so.

Management of Personal Information

In order to prevent leakage, loss, or damage of personal information and to otherwise safely manage personal information, we take sufficient security measures, including the maintenance of rules and regulations for handling personal information, access control, restrictions on taking out personal information, measures to prevent unauthorized access from outside, and other safety management measures, and we also take steps to ensure that personal information is accurate and up-to-date as required for the achievement of the purposes of use. In the event that we outsource the handling of personal information to an external party, we will establish criteria for selecting the party to be outsourced, check the information management system of the party to be outsourced, and monitor its performance after the outsourcing, as well as conduct other necessary and appropriate supervision of the party to be outsourced.

Contact for Inquiries and Complaints concerning Personal Information

Investment Lab Co., Ltd., Compliance Division
Address: 8-1 Nihonbashi-kabuto-cho, FinGATE TERRACE 4F, Chuo-ku, Tokyo 103-0026 Japan

Name of Authorized Self-Regulatory Industrial Association & Contacts for Complaints and Dispute Resolution

(1) Investment Management Association of Japan, Investor Consultation Office (Membership Audit Department)
(2) Type II Financial Instruments Firms Association
Address: 2-11-2, Nihombashi, Chuo-ku, Tokyo 103-0027 Japan (Taiyo Seimei Nihonbashi Bldg. 12F)

Policy Changes

We will review the contents of this policy from time to time and revise or change it as necessary. In such cases, the Company will publicly announce such changes by posting the revised policy on the Company’s website or by other means.

In accordance with the Act on the Provision of Financial Services and the Improvement of the Environment for Use Thereof (formerly the Act on the Sales, etc. of Financial Instruments), we have established the following solicitation policy for sales of financial products to our customers.

1. To Consider Customers’ Investment Knowledge, Experiences, Financial Conditions and Investment Objectives

We will try to fully understand our customers’ investment knowledge, experiences and objectives, as well as their financial conditions and risk tolerance level, etc., and to solicit proper financial products that match our customers’ actual needs by providing appropriate explanations which is necessary for proper decision-making process.

2. To Consider Proper Ways & Timing for Customer Solicitation

We will provide accurate information around details and risks of financial products and will pay sufficient attention to the method of explanations, etc., so that customers themselves can make appropriate investment decisions. When soliciting by telephone or visiting customers, we will conduct solicitation during appropriate hours so as not to inconvenience them.

3. Other Matters Related to Ensuring Appropriateness of Solicitation

When soliciting customers, we will not make definitive judgments or provide false information that may mislead customers, and we will always place the utmost importance on maintaining customer trust and will strive to solicit investments in a customer-oriented manner based on reasonable grounds.

In order to conduct appropriate solicitation, we will always maintain an appropriate management system and strive to raise awareness of compliance with laws and regulations among our officers and employees.

To prevent inappropriate solicitation, we will provide sufficient internal training to our officers and employees to maintain and improve correct product knowledge, and strengthen our internal control system to ensure appropriate solicitation. We take customer opinions and requests seriously, and strive to reflect them in our solicitation activities. We will strive to respond promptly and appropriately to customer inquiries.

We recognize that it is not only indispensable to gain the trust of our customers and stakeholders, but also necessary and important from the viewpoint of fulfilling our social responsibility, to resolutely cut off and eliminate any relationship with antisocial forces.

In addition, the Company shall take a firm stand against antisocial forces, shall not provide any benefits under any name, and shall not have any relationship with antisocial forces.

The Company declares the following items as its basic policy in dealing with antisocial forces:

(1) The Company shall deal with antisocial forces as an organization.
(2) The Company shall deal with antisocial forces in cooperation with external specialized organizations.
(3) The Company shall sever all relationships, including business transactions, with antisocial forces.
(4) In the event of an emergency, we will take legal action, both civil and criminal.
(5) We will not engage in any backroom deals or provide funds to antisocial forces.

Any inquiries, complaints regarding our business operations are accepted at the following points of contacts:

1. Direct Contact to Investment Lab

If you have any questions regarding personal information, or if you wish to discontinue provision of personal data to a third party, or if you wish to request disclosure, correction, or complaints, or if you have any other inquiries, please contact us at the Compliance Division.

2. Contact for Legal Complaints Handling and Dispute Resolution Measures

We have taken the following measures for each type of business for which we are registered, as legal complaints handling and dispute resolution measures stipulated in the Financial Instruments and Exchange Law.

(1) Investment Management Business, and Investment Advisory and Agency Business

We will take measures to handle complaints and resolve disputes related to Investment Management & Advisory businesses through complaint resolution or mediation conducted by the Investment Management Association of Japan.

(2) Type II Financial Instruments Business

We will take measures to handle complaints and resolve disputes related to The Type II Financial Instruments Business through complaint resolution or mediation conducted by the Type II Financial Instruments Firms Association.

Financial Instruments Mediation Assistance Center (FINMAC)

In accordance with the provisions of laws and ordinances, the Financial Instruments Mediation Assistance Center (FINMAC) will take measures to handle complaints and resolve all disputes related to the Financial Instruments Businesses (Investment Management Business, Investment Advisory and Agency Business, and Type II Financial Instruments Business) for each type of business, in accordance with the contracts with the Investment Management Association of Japan and the Type II Financial Instruments Firms Association.

Financial Instruments Mediation Assistance Center (FINMAC)
Address: 2-1-1 Kayabacho, Chuo-ku, Tokyo 103-0025 Japan
(Monday through Friday 9:00 to 17:00, excluding Holidays)

Investment Lab Co., Ltd. respects the dignity and personality of all officers, employees, contractors, business partners, and visitors. The Firm does not tolerate harassment of any kind in the workplace or in business activities, and maintains the following basic policy:

1. Scope of prohibited conduct

The Firm prohibits the following, regardless of whether the conduct meets a legal threshold:

• Power harassment — including the abuse of superior status, authority, or relationships to inflict mental or physical suffering on others, or to damage the working environment.
• Sexual harassment — including unwelcome sexual conduct or remarks that create a hostile working environment.
• Maternity, paternity, and care-related harassment — adverse treatment in connection with pregnancy, childbirth, childcare, or family caregiving.
• Any other conduct that damages the working environment or the dignity of others.

2. Consultation channels

The Firm provides internal consultation channels for officers and employees who experience or witness harassment. Consultations are handled with confidentiality and the consulting party is protected from retaliation.

3. Investigation and response

The Firm promptly investigates reports of harassment, takes appropriate corrective measures, and applies disciplinary action where warranted in accordance with internal rules.

4. Prevention and training

The Firm provides ongoing training to officers and employees on harassment prevention, and continuously reviews the working environment to maintain dignity and respect.

5. Application to external parties

This policy applies equally to interactions with business partners, service providers, and other external parties. Harassment by or against external parties is treated with the same seriousness as internal cases.

This policy is firm-wide and applies in all jurisdictions where the Firm conducts business.

This website is intended for informational purposes regarding the Firm’s business activities. It does not constitute an offer to sell, a solicitation of an offer to buy, or a recommendation of any security, fund interest, or financial instrument in any jurisdiction. Whether any service is made available is determined on a case-by-case basis taking into account investor attributes, suitability, applicable legal requirements, and the Firm’s internal review.

1. Risk of Loss of Principal

Strategies, funds, and accounts operated, advised, or managed by the Firm are subject to losses arising from equity price movements, interest rates, foreign exchange, credit, liquidity, valuation of unlisted securities, and other factors. Investment principal is not guaranteed and may be reduced below the original amount invested.

2. Principal Risks

The Firm’s Japanese listed equity strategies are subject to equity price risk, credit risk, liquidity risk, currency risk, and interest rate risk, among others. The hedge fund strategy makes use of derivatives, short selling, and leverage; losses may exceed initial expectations as a result.

Venture capital investments in unlisted securities carry distinct risks including extremely limited liquidity, uncertain valuation, uncertain timing and amount of capital recovery, the possibility of issuer insolvency, and (depending on the fund structure) long lock-up periods and transfer restrictions.

Investment advisory engagements may result in losses from price movements of the underlying instruments. The Firm’s advice does not guarantee investment outcomes; final investment decisions must be made by the client.

3. Fees and Costs

Fees and costs borne by clients may include management fees, advisory fees, performance fees, administration fees, brokerage and execution costs, audit costs, and other fund- or contract-specific expenses. The specific amounts, caps, calculation methods, and aggregate fees vary by fund, contract structure, investment size, holding period, and operating conditions, and cannot be displayed on this website. Detailed fee information is provided in pre-contract documents and contract terms made available individually to qualified investors.

4. Redemption and Transfer Restrictions

Depending on the fund, contract, or asset, restrictions may apply on redemption, early termination, or transfer. Unlisted-equity investments and certain funds carry low liquidity and may require long holding periods for capital recovery. Redemption proceeds may fall below the original investment amount.

5. Portfolio, Track Record, and Market View Disclosures

Information on this website regarding portfolio companies, advisory engagements, past performance, simulations, and market views does not constitute a recommendation to invest in any specific security or company, and does not suggest or guarantee any future performance, capital recovery, enterprise value, or stock price. Statements regarding markets and industries include the Firm’s opinions and views.

6. Conflicts of Interest

The Firm operates a Japanese listed equity strategy, a venture capital business, and an advisory business in parallel. Conflicts of interest may arise between or within these businesses. The Firm maintains internal policies to identify and manage such conflicts so that clients’ interests are not unfairly impaired.

7. For More Information

Detailed information regarding any service (risk, fees, terms) is available through pre-contract documents, product materials, and contracts provided individually. Please contact info@investmentlab.co.jp.