BEST EXECUTION POLICY (TRANSLATION)

PLEASE NOTE :This translated version is intended to be used as reference only.
The Japanese version of our best execution policy (“最良執行方針”) is deemed to be the officialversion.

April 1, 2020
This best execution policy stipulates the policy and method for executing orders from our
trading participants (Type I Financial Services Providers) (“trading participants”) on thebest possible terms in accordance with Article 40-2, Paragraph 1 of the Financial Instruments
and Exchange Act (“FIEA”).
When Japannext (“we”) receive orders from the trading participants involving securities
listed on the financial instruments exchanges (“FIEs”) in Japan, we will use our best
endeavors to execute the orders in accordance with this policy.
1. Applicable Securities“Listed share certificates, etc.” as defined in Article 16-6 of the Enforcement Ordinanceof the FIEA, which includes shares listed on FIEs, exchange-traded funds (ETFs:
beneficiary certificates of investment trust linked to equity indexes), real estate
investment trusts (REITs), etc.
We do not perform transactions for Phoenix stocks, Convertible bonds, etc. which aredefined in Article 67-18, Item (iv) as tradable securities.
2. Method for Executing Orders on the Best Terms
It is our fundamental policy to execute all orders from the trading participants on a private
proprietary trading system (“Japannext PTS”) operated by us in accordance with ourinternal trading rules, i.e. the order we received from the trading participant will bematched with the other order we received from said participant or with the order received

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from a different trading participant and executed on Japannext PTS. We will not conduct
agency brokerage of the orders from the trading participants to a FIE in Japan or the PTS
operated by other financial services providers. Accordingly, any unexecuted orders will
be automatically cancelled.

3. Reason for Selecting the Method Stated in 2.
We mainly operate PTS and we never conduct agency brokerage of purchase and saleof securities to FIEs in Japan or PTS operated by other financial services providers. We
endeavor to assist our trading participants to understand this as well as our PTS Trading
Instructions and PTS Terms of Business. We anticipate that the order we receive fromthe trading participants will be matched and executed on our PTS and we believe thatthe trading participants would consider this as the most reasonable method of matchingand execution that meets their needs.

4. Others
We will not process transactions involving fractional shares or transactions with anamount less than one trading unit (odd lot).
There may be instances where it is unavoidable that we select an order execution method
other than the method selected in accordance with this best execution policy due tosystem failures or other circumstances. Even in such cases, we will endeavor to executethe orders on the best terms possible at that time.
The obligation of best execution not only relates to price but involves the consideration ofvarious factors including cost, speed and probability of execution. Accordingly, the mere factthat an execution appears not to have resulted in the best possible price afterwards will notnecessarily constitute a contravention or violation of such obligation.

Japannext Co., Ltd.

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