Rules on Operations by Officers and Employees, etc. to Trade Shares, etc. on Their
Own Accounts
Established on January 16, 2009
Revised on October 15, 2009
Revised on December 20, 2012

Article 1.

PurposeThe purpose of these Rules is to prevent conflict of interest transactions and any other inappropriate
transactions by providing for internal rules and establishing an internal system to comply with Article 3 of theRules for Full Members’ Business Operations, etc. in connection with transactions of shares, etc. made on theirown accounts by officers and employees, etc. involved in the operation and investigation, etc. of shares, etc. of
Full Members (meaning the Full Members set forth in Article 7, Paragraph 1, Item 1 of the Articles ofIncorporation; the same shall apply hereinafter), thereby contributing to securing the fairness and reliability ofbusiness pertaining to investment trusts and protecting investors.

Article 2.

Definition

1. “Shares, etc.” in these Rules means domestic and foreign shares and rights and corporate bonds, etc. that canbe converted into shares including corporate bonds with share warrants or share options.
2. “Officers and Employees, etc. Involved in the Operation and Investigation, etc. of Shares, etc.” in theseRules means any officer or employee of Full Members (excluding Full Members who only perform asset
management for a real estate investment trust or Real Estate Investment Corporations; the same shall applyhereinafter) who is in charge of the management business of an investment trust property or assets of aninvestment corporation to be invested in shares, etc. (hereinafter referred to as the “Trust Property, etc.”),who is in a position to know such management trends, or who is in a position to know unpublished important
information or any other special information (hereinafter referred to as “Important Information”) pertaining
to issuing companies in the course of duties, or any relative who shares a livelihood with such persons(excluding any person who is a lineal descendant and whose investment decision is not affected by an officer
or employee of the investment trust entrustment company).
It should be noted that the term “relative who shares a livelihood” may includes not only those who livewith such persons (excluding anyone who obviously lives financially independently) but also those who live
separately from such persons while also habitually remitting living expenses, school fees, medical expenses,
etc.
3. “Proprietary Trading” in these Rules means any of the following transactions pertaining to shares, etc.
conducted on one’s own account. Provided, however, that these Rules shall not apply to any transaction set
forth in the By-laws.
(1) Stock trading, margin transactions, futures transactions, option trading, and over-the-counter derivatives
transactions(2) Acquisition of shares, etc. through public offering or secondary distribution(3) Acquisition of shares, etc. under Cumulative Investment Contract–1–(4) Transaction pertaining to stock mini investment plan.
4. “Fund Manager” in these Rules means any person who selects the issues traded, trading conditions, andvolume, etc. of shares, etc. in Trust Property, etc.
5. “Trader” in these Rules means any person who places orders for the sale and purchase of shares, etc. in TrustProperty, etc. with a Type I Financial Instruments Business Operator (meaning a Type I Financial
Instruments Business Operator prescribed in Article 28, Paragraph 1 of the Financial Instruments andExchange Act).
6. “Analyst” in these Rules means any person engaged in corporate research pertaining to management of Trust
Property, etc.
7. “Valid Period of Approval” in these Rules means the valid period of approval as stipulated in Article 6(hereinafter referred to as the “Valid Period”) for implementation of proprietary trading.
8. “Period for Prohibition of Proprietary Trading” in these Rules means the period in which proprietary tradingis prohibited for fund managers, traders, and analysts.
* Article 2 of the By-laws

Article 3.

Formulation of Internal Rules, etc.

1. Full Members shall provide for the Internal Rules concerning the proprietary trading of shares, etc.
conducted by officers and employees, etc. involved in the operation and investigation, etc. of shares, etc., andshall take the necessary measures such as providing regular training, etc. so that officers and employees
comply with such rules.
In addition, the matters established in the Internal Rules shall be those established in these Rules and theBy-laws.
2. Full Members shall appoint a person in charge of screening the proprietary trading of shares, etc. conductedby officers and employees, etc. involved in the operation and investigation, etc. of shares, etc. (hereinafterreferred to as “Person in Charge of Screening for Proprietary Trading”), and have such Person in Charge ofScreening for Proprietary Trading examine whether there are any facts that constitute a violation of theInternal Rules.
Multiple persons in charge of screening for proprietary trading may be assigned to divide the screening
amongst them.
* Article 3 of the By-laws

Article 4.

Prohibited Acts

Officers and employees, etc. involved in the operation and investigation, etc. of shares, etc. shall not engage inany of the acts set forth in the following items:(1) Transactions leveraging their professional position or transactions based on Important Information which
they have learnt in the course of their duties;(2) Transactions solely for the purpose of seeking speculative profits;(3) Transactions in priority to customer profits such as front running, etc.;(4) Any other transactions prohibited under laws and regulations, etc.
–2–Article 5.

Limitation of Holding Period

In order to prevent transactions for the purpose of seeking speculative profits or other unfair transactionsprescribed in Item 2 of the preceding article, Full Members shall establish in their Internal Rules a period of 6months or more as the holding period (i.e. lock-up period) of shares, etc.
However, that if the applicant and a relative who shares a livelihood with such applicant acquire the same issue
more than once, the date of the last acquisition shall be regarded as the initial date of reckoning. In the case ofacquisition of shares, etc. under a Cumulative Investment Contract, the date of the first acquisition shall beregarded as the initial date of reckoning.

Article 6.

Prior Application

Officers and employees, etc. involved in the operation and investigation, etc. of shares, etc. shall apply inadvanced in writing (including by electromagnetic means) to the Person in Charge of Screening for Proprietary
Trading and obtain approval for such proprietary trading in performing any proprietary trading of shares, etc.
However, application and approval for the acquisition of shares, etc. under the Cumulative Investment Contract
shall be made in accordance with the procedures set forth in the By-laws.
* Article 4 of the By-laws

Article 7.

Screening

1. The Person in Charge of Screening for Proprietary Trading who has received the prior application under thepreceding article shall screen the matters set forth in the following items:(1) The limitation of holding period prescribed in Article 5 is met. Provided, however, that this shall not
apply to cases approved by the Person in Charge of Screening for Proprietary Trading as an unavoidable
circumstance for the applicant (e.g. cases where the applicant and a relative who shares a livelihood
with such applicant become unable to earn a living due to illness, etc.).
(2) If the applicant is any of the following persons (including applications for transactions by a relative whoshares a livelihood with such applicant), the application shall not be for the shares, etc. set forth in thefollowing. Provided, however, that this shall not apply to cases where shares, etc. are acquired under a
Cumulative Investment Contract or to cases approved by the Person in Charge of Screening forProprietary Trading as an unavoidable circumstance (e.g. cases where acquired shares, etc. are sold andappropriated for the payment of inheritance tax due to succession to the estate, etc.).
(A) Fund ManagerShares, etc. traded or scheduled to be traded during the Period for Prohibition of Proprietary Trading
concerning the Trust Property, etc. which the applicant is responsible for managing at the time of theapplication (excluding the Trust Property, etc. aimed at investment performance linked to arepresentative stock price index on the market; hereinafter the same shall apply in the followingarticle);(B) Trader (including a person who also serves as a fund manager)
Shares, etc. traded or scheduled to be traded during the Period for Prohibition of Proprietary Trading–3–

based on the instructions for purchase orders received by the applicant from the fund manager for
determining a part of the execution of trading at the time of application;(C) Analysts (including fund managers or traders who conduct corporate research through company
tours, etc.)
Shares, etc. issued by any company (including affiliated companies) which the applicant researchedor intends to research during the Period for Prohibition of Proprietary Trading as part of suchapplicant’s duties at the time of application.

2. Full Members shall establish in their Internal Rules the periods set forth in the following items as the Period
for Prohibition of Proprietary Trading for the persons set forth in the Item 2 of the preceding paragraph:(1) Period for Prohibition of Proprietary Trading for the persons set forth in (A) and (B): A period from 3
business days or more before the previous business day of the scheduled transaction date (hereinafterreferred to as “Base Date”) until 3 business days or more after the next business day of the Base Date as
established by Full Members.
However, if a period of 2 days or more is established as the Valid Period, the Base Date shall be the firstday of such Valid Period, and the period shall be from 3 business days or more before the previous
business day of such date until 3 business days or more after the next business day of the final day of theValid Period as established by Full Members.
(2) Period for Prohibition of Proprietary Trading for any of the persons set forth in (C): A period from 1
month or more before the Base Date until the Base Date as established by Full Members.
However, if the Valid Period is established, a period from 1 month or more before such Base Date until thefinal day of the Valid Period as established by Full Members.

Article 8.

Confirmation in Trading of Trust Property, etc. After Application Date

1. If the applicant is a fund manager and trades shares, etc. pertaining to the application for the Trust Property,etc. which such applicant is responsible for managing within a fixed period from application until after theproprietary trading contract, such applicant shall obtain prior confirmation from the Person in Charge of
Screening for Proprietary Trading.
Provided, however, that this shall not apply to cases where the proprietary trading by the applicant is atransaction provided for in the By-laws (hereinafter the same shall apply in the following article).
2. Full Members shall establish in their Internal Rules a period of 3 business days or more for the fixed period
specified in the preceding paragraph.
* Articles 3 and 5 of the By-laws

Article 9.

Report, etc.

When a proprietary trading of shares, etc. has taken place, the applicant shall report to the Person in Charge ofScreening for Proprietary Trading without delay.
* Article 3 of the By-laws–4–

Article 10.

Retention of Records

1. Full Members shall retain records concerning prior applications, the details of screenings, and the contents ofany violations and the status of corrective measures therefor and other related records.
2. Full Members shall establish in their Internal Rules a period of 5 years or more as the retention period in thepreceding paragraph.

Article 11.

By-laws

Necessary matters for the enforcement of these Rules shall be stipulated in the By-laws.

Article 12.

OthersAny matters not provided for in these Rules regarding proprietary trading by officers and employees, etc.
involved in the operation and investigation, etc. of shares, etc. may be decided by a resolution of the Board ofDirectors.

Article 13.

Delegation to Competent Committee

1. The Board of Directors shall be entitled to delegate to the Self-Regulation Committee the authority to amend
any By-laws relating to these Rules.
2. The Self-Regulation Committee shall promptly report to the Board of Directors, the contents of any
decisions made by the Self-Regulation Committee with respect to any matters delegated thereto (limited todecisions deemed necessary by the Board of Directors.).

Supplementary Provisions
1. These Rules shall come into effect on January 16, 2009.
2. “Considerations in Preparing Internal Rules for Transactions of Shares, etc. by Officers and Employees, etc.
on Their Own Accounts (November 17, 2006)” shall be repealed as of January 16, 2009.

Supplementary Provisions
1. This amendment shall come into effect on October 15, 2009.
However, the provisions of Articles 3, Article 4, Article 7 and Article 8 after amendment shall apply fromJanuary 18, 2010.
2. Notwithstanding the foregoing proviso 1. above, Full Members shall not be precluded from operating under
the provisions of Article 3, Article 4, Article 7 and Article 8 after the amendment before the date of suchapplication.

Supplementary ProvisionThis amendment shall come into effect on January 4, 2013.

–5–<Reference>
Rules on Operations by Officers and Employees, etc. to Trade Shares, etc. on Their Own Accounts
Period for Prohibition of Proprietary Trading Prescribed in Article 7, Paragraph 2Article 7, Paragraph 2 of the Rules stipulates the Period for Prohibition of Proprietary Trading for fundmanagers, etc., and this period is illustrated as follows.
The Period for Prohibition of Proprietary Trading is required to be stipulated based on the following
information in the Internal Rules concerning the proprietary trading of shares, etc. conducted by officers
and employees, etc. involved in the operation and investigation, etc. of shares, etc.
1. Period for Prohibition of Proprietary Trading for Fund Managers and Traders (Article 7, Paragraph 2,Item 1 of the Rules)(1) Period set forth in the main clause of Item 1
Period for Prohibition of Proprietary Trading

T-2

~ T-3

T-1

Scheduled date ofproprietary trading (T)

T+1

T+2

T+3~

T+N+2

T+N+3~(2) Period set forth in the proviso to Item 1
Period for Prohibition of Proprietary Trading

~ T-3

T-2

T-1

Commencement
date of Valid
Period (T)Final day of Valid
Period (T + N) T+N+1* The Valid Period of Approval is for N days (the same shall apply to 2. (2)).
2. Period for Prohibition of Proprietary Trading for Analysts (Article 7, Paragraph 2, Item 2 of theRules)(1) Period set forth in the main clause of Item 2
Period for Prohibition of Proprietary Trading

Proprietary Trading
Scheduled date (T)~ T-1 month(2) Period set forth in the proviso to Item 2
Period for Prohibition of Proprietary Trading~ T-1 month

Valid Period
Commenceme
nt date (T)– 6 –Valid Period
Final day (T + N)