OVERVIEW OF CONFLICT OF INTEREST MANAGEMENT POLICY
November 1, 2023
Mitsui & Co. Alternative Investments Limited

Mitsui & Co. Alternative Investments Ltd.("the Company" or “we”) has established a Conflict ofInterest Management Policy in accordance with Article 36, Paragraph 2 of the Financial
Instruments and Exchange Law and has established a mechanism to properly managetransactions that may unreasonably harm the interests of customers.
1. Purpose
The Conflict of Interest Management Policy aims to clarify the types of conflicts of interestin transactions, methods of managing conflicts of interest, and framework for managing
conflicts of interest that the Company conducts so as not to unreasonably harm the interestsof our customers. Further details will be separately stipulated in the Companyʼs internal
rules and regulations.
2. Types of Conflicts of Interest
The major types of conflicts of interest the Company manages are as follows.
Case (1) the Company or its affiliates distribute funds structured, managed or sponsored bythem in its securities business or acts as an agent for its customers in connection with thesale or purchase of such funds in its investment management business.
Case (2) the Company solicits to buy shares of a fund to one customer and solicit to sell or
redeem shares of the same fund to the other customer.
Case (3) the Company receives commissions in different types of transactions related to thesame fund.
Case (4) the Company has the authority to determine asset allocation weight to customers
portfolios in concluding discretionary investment advisory agreements with customers, while

Mitsui & Co. Alternative Investments Limited
Registered Financial Instruments Business Operator with Kanto Local Financial Bureau(Registration No.88)
Member of Japan Securities Dealers Association andJapan Investment Advisers Association

it has discretion to accept or refuse requests to purchase or redeem in private placementtransactions with respect to the same fund.
Case (5) the Company selects an execution broker in discretionary investment management
under a discretionary investment contract without consideration of the brokerʼs best
execution ability or other reasonable grounds.
Case (6) the Company chooses to include the underlying assets held by its affiliates ordesignate its affiliates as the administrator when structuring of a fund.
Case (7) the Company provides advice based on financial advisory services, etc., to morethan one customers that are in a competitive or conflicting relationship.
Case (8) the Companyʼs officers and employees offer or receive gifts or entertainment thatexceed the socially accepted scope or conflict with the interests of our customers.
３．Measures for Managing Conflicts of Interest
For transactions managed for a conflict of interest, the Company will manage the conflictof interest by selecting or combining the following methods and other methods.
(1)Separation of departments and other information barriers and information blocks(2)Change of Terms or Method of Trades(3)Suspension of the other transaction(4)Disclosure to Customers That There Is a Risk of Potential Conflict of Interest(5)Oversight of Information Sharers(6)Other measures deemed necessary by the Company.
4. Framework for Conflicts of Interest Management

For transactions managed for a conflict of interest, the Company will manage the conflictof interest by selecting or combining the following methods and other methods.
(1) In managing conflicts of interest, Legal and Compliance Department that is

independent from the front office shall be the Conflict of Interest Control Department
and the Legal and Compliance Department Manager shall be the Conflict of Interest
Control Manager.

Mitsui & Co. Alternative Investments Limited
Registered Financial Instruments Business Operator with Kanto Local Financial Bureau(Registration No.88)
Member of Japan Securities Dealers Association andJapan Investment Advisers Association

(2) The Legal and Compliance Department and its Manager may advise the front office on

consultations and discussions regarding conflict of interest management and require
the front office to provide the necessary information to manage conflict of interest.
(3) The Manager of the Legal and Compliance Department shall be responsible formanaging conflicts of interest together with the front office in the structuring ofproducts, private placements, and selection of investment products in the investment
management business. In addition, in the event that a potential conflict of interest
cannot be completely ruled out by implementing certain controls, the Manager of theLegal and Compliance Department shall have the veto right in the internal committee.
(4) Conflicts of interest shall be managed without fail, and records thereof shall beretained by Legal and Compliance Department for a period of five years from thedate of preparation. The Manager of the Legal and Compliance Department shallreport the status of the management of conflicts of interest to the President and CCO
as appropriate and shall regularly report to the Compliance Committee and the Boardof Directors.
５．Scope of Companies Subject to Conflict of Interest Management
The parties to whom conflict of interest management is applicable shall be stipulated inthe Companyʼs internal rules and regulations.
Our Affiliates Subject to Conflict of Interest Management (as of November1, 2023)(1) Mitsui & Co., Ltd.
(2) Mitsui & Co. Asset Management Holdings Ltd.
(3) MKAM Co., Ltd.
(4) Mitsui & Co., Realty Management Ltd.
(5) Mitsui & Co., Logistics Partners Ltd.
(6) Mitsui Bussan & Idera Partners Co., Ltd.
(7) Mitsui & Co. Digital Asset Management, Ltd.
(8) Rimor Fund I GP Limited(9) Rimor Fund II GP Limited(10) Other subsidiaries and affiliates of Mitsui & Co., Ltd., or other related companies

that the Company can reasonably believe may involve a potential conflict of interest.

Mitsui & Co. Alternative Investments Limited
Registered Financial Instruments Business Operator with Kanto Local Financial Bureau(Registration No.88)
Member of Japan Securities Dealers Association andJapan Investment Advisers Association