Vortex Investment Advisors Ltd.
Kanto Local Finance Bureau (FIBO) No.3015

Associations in which a Member: The Japan Investment Advisers Association

Vortex Co., Ltd. (hereinafter referred to as “our company”), based on the "Act on the Provisionof Financial Services", establishes and complies with the solicitation policy in relation to salesof ﬁnancial instruments as follows, conducts proper solicitation and sales, and strives tocomply with compliance and to secure and improve the trust of customers.

Solicitation policy for ﬁnancial instruments
1.

Matters to be considered in light of the knowledge, experience and status of property of theperson to be solicited and the purpose of concluding a contract for the sale of ﬁnancialinstruments（1） When recommending ﬁnancial instruments, our company fully understands thecustomer's knowledge, experience, ﬁnancial status and the purpose of concluding acontract for the sale of ﬁnancial instruments, etc. and endeavors to conduct
solicitation in accordance with the customer's intentions and circumstances.
（2） When recommending ﬁnancial instruments, our company endeavors to make proper
explanation on the contents of the ﬁnancial instruments to recommend and risks, etc.
in light of the customer's knowledge, experience, ﬁnancial status and the purpose ofconcluding a contract for the sale of ﬁnancial instruments, etc.

2.

Matters to be considered for the person subject to the solicitation with regard to themethod and time of solicitation（1） Our company strives to ensure that customers understand important matters such as
the contents of ﬁnancial instruments and risks by delivering documents or otherappropriate methods so that customers can conduct transactions at their own
discretion and responsibility.
（2） In soliciting customers, our company places the highest priority on ensuring the trustof customers, adheres to laws and regulations and various rules, and endeavors tosolicit customers on a customer-oriented basis.
（3） Our company endeavors not to conduct solicitation by telephone or visit during a timethat may be a nuisance to the customer. Please let the person in charge know ifsolicitation causes a nuisance.

Vortex Investment Advisors Ltd.
Kanto Local Finance Bureau (FIBO) No.3015

Associations in which a Member: The Japan Investment Advisers Association

3.

Other matters related to ensuring the appropriateness of solicitation（1） Our company complies with the laws and regulations and various rules and strives tostrengthen its internal control system so that solicitation of customers is madeappropriately.
（2） In order to ensure proper solicitation of customers, our company improves training
system for oﬃcers and employees, and strives to acquire and improve knowledge andskills, including product knowledge.
（3） Our company strives to provide appropriate and suﬃcient information so thattransactions are conducted at the discretion and responsibility of customers.
（4） If you have any complaints, requests, or other concerns, please contact below.
Customer service oﬃce (Tel: 0120-919-076)
Corporation engaging in speciﬁed non-proﬁt activities, Financial Instruments Mediation
Assistance Center (FINMAC)
Address: Daini Shoken Kaikan, 2-1-1, Kayabacho, Nihonbashi, Chuo-ku, Tokyo
Tel: 0120-64-5005
Weekdays: 9:00 to 17:00 (excluding holidays including substitute holidays, December
31 to January 3)
End