COMPLAINTSHANDLING POLICY
February 1, 2023

Nomura Fiduciary Research & Consulting Co., Ltd.
Index Services Department

INTRODUCTION
Nomura Fiduciary Research & Consulting Co., Ltd. (NFRC) makes every effort toprovide high-quality index services. NFRC takes index user complaints very
seriously, and strives to improve its operations based on such feedback. NFRC
acts for the benefit of index users as a matter of policy.
NFRC acts as the licensor of intellectual properties related to the NFRC’s
indices, while the Index Services Department (ISD) acts as administrator of theindices. The Complaints Handling Policy stipulates that ISD handles any
complaints made against the NFRC’s indices in its role as administrator.
This policy should in principle be reviewed by ISD annually, with the results of thereview reported to the Director in charge of ISD. Material changes on the policy
require approval by the Strategic Solutions Committee.

DEFINITION
ISD’s definition of what constitutes a “complaint” or an “enquiry” makes thedifference between the two quite distinct. Complaints are defined as expressions ofdissatisfaction from or on behalf of an eligible complainant against the NFRC’sindex determination. Alternatively, enquiries are other expressions relating to theNFRC’s indices (i.e., communications which do not express dissatisfaction). Index
users, market participants, and market authorities (regulatory authorities, selfregulatory organizations, regulated markets or exchanges) are all eligible to raisecomplaints with ISD against the NFRC’s index determination.

NFRC outsources the index calculation and distribution functions to third parties.
For example, Nomura Research Institute, Ltd. (NRI) is involved both as acalculation agent for the NFRC’s indices and as an index distributor that makes theNFRC’s indices available to users through NRI’s systems. Index users, market
participants, and market authorities are advised to refrain from addressing
complaints to individual vendors that are calculation agents or distributors of theNFRC’s indices even if they are dissatisfied with the NFRC’s indices. An index
user, market participant, or market authority should address any complaint
regarding any aspect of the NFRC’s indices to ISD only.

1PRINCIPLE-Complaints must be handled in a fair and timely manner.

PROCESS-Complaints must be submitted to ISD via e-mail (idx_mgr@nfrc.co.jp).

-ISD will judge whether the e-mail is a complaint or an enquiry and whether itis related to the NFRC’s Indices or not. In order to seek professional advice
on complaint handling, ISD may consult with the Compliance Department in
NFRC in accordance with the NFRC’s internal rule.

-Any complaint or enquiry unrelated to the NFRC’s Indices, but related to theservices other departments in NFRC provide, are forwarded to thosedepartments in accordance with NFRC’s internal rules.

-ISD will answer in compliance with the internal rules if the communication isclassified as an enquiry.

-ISD will acknowledge that the communication is a complaint against theNFRC’s Indices and enter the following process.

-Complainants must provide the following details to allow for a proper
investigation by and response from ISD or NFRC:• Full name, organization, and telephone number of the complainant• Index name, time period, index value, and supporting information for thecomplaint-

ISD will ask the sender for additional information if any of the requirements
above are not met.

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ISD will conduct thorough investigation into the complaint without involving
any personnel in charge of the index subject to the complaint.

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ISD will commence its review and investigation into the complaint within two
business days of delivery.

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ISD will escalate the complaint to the Compliance Department and theDirector in charge of ISD.

-ISD will also consider appropriate preventive measures or mitigation
measures if deemed necessary as a result of the investigation.

2-The time needed to handle a complaint will vary according to its nature, but
ISD will work to respond within two weeks. However, if information provided
by the complainant is inadequate or if a conflict of interest or a deviation fromsocial norms is suspected, the response could be delayed.

-ISD will notify the complainant of the investigation result and mitigation
measures via e-mail as soon as reasonably possible after the conclusion ofits investigation. The complaint should be escalated to the Director in
charge of ISD in such cases where the complainant is not satisfied with itsresponse as appropriate. However, if a complaint is judged as a deviationfrom social norms, the response could not be made at all.

-The investigation result and mitigation measures are reported to theCompliance Department and the Director in charge of ISD. Non-urgent
complaints are reported through Front Office Supervision.

-If a complaint results in material changes to the index determinations,
NFRC will disseminate this information to the index users andstakeholders in accordance with the procedures of changes tomethodologies stipulated in “Index Calculation Policy” and the internalrules.

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NOTE
ISD must retain records relating to complaints, investigations, preventive measures,and mitigation measures for at least five years subject to the applicable law orregulation.
The information provided by the complainant may be used throughout theinvestigation and reporting processes and, as such, may not be kept confidential (inparticular in connection with any related legal, regulatory, or other type ofproceeding).
NFRC handles the personal information received from clients subject toJapanese laws and regulations.
Further details:-NFRC (Japanese site)
https://www.nfrc.co.jp/nfr-t/policy/privacy.html

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Revision history
Revision date

Details

March 27, 2019

First edition

January 24, 2020 Revisions to overall text
March 19, 2021

Partial revision of “PROCESS”

February 1, 2023

Revisions to overall text due to the business succession.

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