Basic Policy for Customer-Oriented Business Conduct in Japan

I.

Basic Policy for Customer-Oriented Business ConductCredit Agricole Corporate and Investment Bank (CACIB) provides professional financial services tocustomers using its international network in more than 30 countries.
CACIB emphasizes long-term relationships with customers built on trust and transparency. It is theglobal policy that our support and advice to customers should be driven by the long term even at
the expense of short-term opportunities.
In Japan, CACIB Tokyo Branch and Credit Agricole Securities provide tailor-made financialsolutions, based on high level of professional expertise and extensive experience aboard, mainly tofinancial institutions and large corporates, by properly grasping customers’ needs through closecommunication.
This customer-oriented business conduct has been the basic policy of Credit Agricole Group since
its establishment. In practice, CACIB adopted the approach described below, which would bereviewed and updated in response to development or change of market, economic, social and/orregulatory environment.
※Please refer to the business strategy in Japan.
CACIB Tokyo Branch - Business Strategy
CA Securities Japan - Business Strategy

II.

Pursuit of Customers’ Best Interest

CACIB has established this Code of Conduct including the following principles, stipulating that eachemployee should maintain highly qualified expertise and professional ethics, treat our customers
faithfully and fairly, and seek customers’ best interest based on a long-term relationship approach.
CACIB believes that it is possible to develop a long-term and stable relationship with customers bytaking those actions, while ensuring stable profitability.
CACIB makes efforts to ensure the Code of Conduct becomes part of the corporate culture by
discussing it at the annual compliance seminar with all employees.
1. Expertise and Challenges
CACIB employees should pay close attention to the market environment and regulations,strengthen their technical expertise, adapting it to the needs of our customers and contributing toCACIB’s and to the Group’s performances.

2. Knowledge and Adherence to Rules
CACIB employees should know and abide by applicable laws and regulations.
3. Responsibility and Integrity
CACIB employees should act with integrity and in a responsible manner analyzing the risks andconsequences of our actions.
4. Commitment to Customer Service in the Long Term
CACIB employees should develop a long-term relationship with customers built on trust andtransparency.

III.

Appropriate Management of Conflict of Interest

With the diversification of services provided by financial institutions and the development of global
financial conglomerates, there could be multiple competing and conflicting interests within afinancial institution or financial group, which increases potential conflict of interest.
Under such circumstances, CACIB has established a Conflict of Interest Management Policy toprevent the interests of our customers from being unjustly impaired, by stipulating the type andcriteria of potential conflict of interest, the scope of group companies concerned, the methods tomanage potential conflict of interest, and the conflict of interest management system.
※Please refer to “Summary of Conflict of Interest Policy”
CACIB Tokyo Branch - Summary Conflict of Interest Policy
CA Securities Japan - Summary Conflict of Interest Policy

IV.

Provision of Information from Customer-Oriented Point of View

CACIB makes efforts, when providing financial products or services, to explain the related potential
risks in an accurate and straightforward manner in order for customers to make a proper decisionand to ensure customers sufficiently understand the risks considering their knowledge andexperience. Especially in case of highly complex products or other high risk products, CACIB
endeavors to clearly show the potential loss or disadvantage based on the worst case scenario,
using simulations or graphs.
In addition, CACIB makes efforts to ensure transparency regarding the fees as compensation forour service provided to customers in order for customers to make a fully informed decision.
When providing information to customers, CACIB endeavors to specify the information source,
clarify whether facts or assumptions are presented, and ensure such information is accurate andnot misleading.

V.

Provision of Services suitable for Customers

CACIB provides tailor-made financial solutions mainly to financial institutions and large corporates
and in principle does not do business with retail customers.
CACIB makes efforts to provide financial products or services suitable to customers by sufficiently
understanding customers’ purpose of transaction, knowledge, experience and financial situations
through close communication with customers.
When distributing financial products to retail clients through distributors, CACIB endeavors to
distribute products suitable to customers by properly grasping customers’ needs and risk tolerance
through close cooperation with distributors.
※Please refer “Solicitation Policy as link toCACIB Tokyo Branch - Solicitation Policy
CA Securities Japan - Solicitation Policy

VI.

Framework for Motivating Employees Appropriately

CACIB endeavors to disseminate the concepts of the Code of Conduct, Conflict of Interest
Management policy and other policies which stipulate that each employee should treat ourcustomers faithfully and fairly and seek for customers’ best interest by organizing the new joiner
trainings, the annual compliance seminar and other ad-hoc trainings.
CACIB adopts an evaluation system which considers not only quantitative evaluation focusing on
the result such as profits but also qualitative evaluation focusing on the process to achieve such
results, according the same importance to both aspects. Also CACIB adopted the deferred bonus
system which defers the incentive bonus for management and front-office staff for several years
and also links the payments with the company’s performance.
Accordingly, CACIB endeavors to develop frameworks for appropriately motivating employees
along with an appropriate governance system, through trainings and evaluation/remuneration
system, to encourage customer-oriented business conduct based on long-term relationship.

Progress
II. Pursuit of Customers’ Best Interest
CACIB has made efforts to ensure the Code of Conduct becomes part of the corporate culture bydiscussing it at the Annual Compliance Seminar held in March 2023.
At the Seminar, all the mandatory employees, 216 staff, attended.

III. Appropriate Management of Conflict of Interest
CACIB has established the Conflicts of Interest Management Rule, and the Compliance Department
is the department which is responsible for conflict of interest management. Being independent fromthe Sales divisions, Compliance Department collects transaction information of target companies asnecessary, and centrally identifies and manages target transactions.
Transactions with a potential conflict of interest are appropriately reported to the ComplianceManagement Committee.
Conflicts of Interest Management Rule is posted on the company’s intranet that can be viewed by
all the employees, and the importance of management of conflicts of interest were explained during
the Annual Compliance Seminar held in March 2023.

IV. Provision of Information and Services from Customer-Oriented Point of View
CACIB has been making efforts, when providing financial products or services to its clients, toexplain important information and fees in an accurate and straightforward manner in accordancewith the global and local rules, which are periodically monitored by Compliance.
In the Annual Compliance Seminar held in March 2023, it was explained that the importance ofproviding information that helps customers make appropriate investment decisions in a way thatthey can well understand.

V. Provision of Services suitable to Customers
CACIB has established procedures to ensure to provide financial products or services suitable tocustomers by sufficiently understanding customers’ purpose of transaction, knowledge, experienceand financial situations through close communication with customers.
In the Annual Compliance Seminar held in March 2023, the importance of Suitability Principle wasexplained.

When distributing financial products to retail clients through distributors, CACIB has been
conducting on-going KYD (Know Your Distributor) in accordance with the global and local rules.
The number of CACIB’s distributors as of October 2023 is 50 and CACIB conducted on-going due
diligence for all the distributors.
When providing complex structured notes to distributors, CACIB provides “target market” and “fairvalue” to the distributors.
In case there is an administrative sanction or some concern related to a distributor, CACIB has
suspended business with the distributor. Approval of management and compliance is necessary torestart business, after reviewing the implementation status of corrective action plans.

VI.

Framework for Motivating Employees Appropriately

In addition to the Annual Compliance Seminar, all employees are required to take relevant training
courses, which are monitored by Compliance. Compliance reports the status to management everyquarter.
In the 2022 Appraisal, as every year in the past, CACIB has adopted an evaluation system which
considers not only quantitative evaluation focusing on the result such as profits but also qualitativeevaluation focusing on the process to achieve such results, according the same importance to bothaspects. Also CACIB has adopted the deferred bonus system which defers the incentive bonus for
management and front-office staff for several years and also links the payments with the company’sperformance.