Customer-Oriented Business Conduct

We provide products and services that focus not only on the needs of securities companies, that are trading participants, who trade with us, but also on the needs of individual customers of those securities companies, and as a result, we realize customer-oriented business operations. In order to continue to do so, we will indicate that the following is the basic policy for our activities, and we will regularly check and review our efforts and results.

Pursuit of customer's best interest

Since our founding, we have been anticipating changes in the market, and in order to help securities companies participating in our market, and all customers who are connected to them, to streamline and optimize trading execution, we have aimed to expand our business with the policy of providing a healthy market environment. Currently, we are active as Japan's first and only neutral equities PTS operator that does not belong to a specific securities company group. We will continue to maintain that spirit.

Providing appropriate execution services for clients

Laws and regulations concerning best execution policies in Japan oblige execution to take into comprehensive consideration various factors such as price, cost, speed, and enforceability. Currently in most securities companies, the best execution policy is to execute in a market (exchange) with the highest liquidity.

However, at our company, we believe that the execution of better conditions is an important matter regardless of the customer's asset status, trading experience, knowledge, etc. As such, as an entity who plays an important role in the investment chain of execution, we will continue to support the provision of more suitable execution services to customers of each participating securities company.

Appropriate management of conflicts of interest

We maintain an equal distance from all trading participants and operate in a manner that is separate from the risk of conflicts of interest with trading participants. We will continue to manage conflicts of interest appropriately so that they do not fall behind.

In addition, the Company has established a "Conflict of Interest Management Policy," which identifies and classifies transactions that may unfairly harm the interests of customers, and defines the management method, management system, and group companies subject to management of subject transactions. After clarifying, we will manage the subject transactions so that the customer's interests are not unduly harmed.

* Please see here for "Conflict of Interest Management Policy".

About corporate governance

We are committed to enhance independence and transparency of management, and as an entity who plays an important role in the investment chain of execution, we will build a governance system that is deeply trustworthy and always act in the best interest of our clients, including the introduction of outside directors.

Appropriate incentive framework for employees, etc.

We will strive to enhance internal education and training, including for our directors.

In terms of internal performance evaluations, we place importance on the perspective of compliance, and we aim to establish a system that will convince trading participants and their customers that we are appropriately motivating our employees to pursue the best interests of them.