Mercuria Holdings Co., Ltd. (hereinafter referred to as the "Company") and its group (hereinafter collectively referred to as the "Mercuria Investment Group") provide financial services through its subsidiaries and other group companies, including financial instruments business operators. In order to prevent undue harm to the interests of the clients of Mercuria Investment Group and to appropriately manage, on a group-wide level, transactions that may cause conflicts of interest, we have established the following Basic Policy on Conflict of Interest Management.

1. Companies and Transactions Subject to Conflict of Interest Management

Mercuria Investment Group shall make the Company, companies engaged in the financial instruments business (including companies that perform equivalent services under foreign laws and regulations), and companies deemed necessary to be included in the scope of management in terms of conflict of interest, subjects of the management of conflict of interest. In addition, subject transactions shall mean any transactions conducted by the Mercuria Investment Group in which the interests of a customer may be unduly impaired due to a conflict of interest between (1) the customer and the Mercuria Investment Group, (2) the customer and another customer of the same company in the Mercuria Investment Group, or (3) the customer of one company in the Mercuria Investment Group and the customer of another company in the Mercuria Investment Group.

2. Classification and Identification of Conflicts of Interest

Mercuria Investment Group categorizes conflicts of interest as follows, and if a conflict of interest is deemed to possibly fall under the relevant criteria, the general managers of Mercuria Investment Group companies will identify the conflict of interest.

• (a) When there is a possibility that the Mercuria Investment Group company will gain economic benefit or avoid economic loss at the expense of a customer
• (b) When we obtain, or will obtain in the future, an inducement in the form of money, goods, or services other than the usual fees and expenses in a transaction with a person other than our customer
• (c) When conducting a transaction with a customer of the Mercuria Investment Group
• (d) When conducting a transaction on the part of the counterparty of a customer of the Mercuria Investment Group
• (e) When conducting a transaction with the counterparty of a customer of the Mercuria Investment Group that competes with another customer
• (f) When conducting a transaction to benefit oneself through the use of non-public information about customers of Mercuria Investment Group
• (g) When a transaction is impossible under the same conditions as a normal transaction due to the involvement of the Mercuria Investment Group in multiple capacities in that same transaction

3. Methods of Conflict of Interest Management

• (a) Changes to the content, method, conditions, etc. of a transaction with a conflict of interest
• (b) Termination of a transaction with a conflict of interest
• (c) Disclosure of any conflict of interest to the customer
• (d) Other methods appropriate to the transaction

4. System for Conflict of Interest Management

The Company has designated the Compliance Department as the department responsible for the management of transactions with conflicts of interest, and the Cheif Compliance Officer as the person in overall charge. Information on transactions with conflicts of interest is gathered and centrally managed by the Compliance Department.
The Company has installed a system for appropriately managing conflicts of interest in each Mercuria Investment Group company, whereby if an officer or employee of the Mercuria Investment Group becomes aware of any actual or potential conflict of interest, they shall immediately report information about the conflict to the General Manager of the Compliance Department in accordance with the internal rules of each Mercuria Investment Group company, and the Chief Compliance Officer shall take action after considering the most appropriate way to deal with the conflict.

*This policy is subject to change or publication without notice.