Article 1. Basic Policy

We commit to protecting the privacy of personal information in accordance with the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003, including subsequent amendments).
We comply with the Act on the Use of Personal Identification Number in Administrative Procedures (Act No. 27 of May 31, 2013, including subsequent amendments) (hereinafter referred to as the "Number Act"), related laws, regulations, guidelines, and internal rules, etc., and strive for appropriate and safe management and operation.

Article 2. Purpose of Use of Personal Number

The purposes of our use of personal numbers are as follows

1. Specified Personal Information, etc. of Customers, Business Partners and Shareholders
   1. To perform clerical work for the preparation of records pertaining to financial instruments transactions, etc.
   2. To prepare payment records concerning payment of remuneration, fees, contracts, prize money, and other consideration for services or rights
   3. To prepare payment records related to payments for the use or acquisition of real estate, etc.
   4. To prepare payment records concerning payment of dividends, surplus or interest, and other distributions of profits
   5. For the preparation of records in which personal numbers are required to be entered pursuant to laws and regulations
   6. For other administrative work related to (a) through (e) above
   7. For the preparation of statutory reports, etc., in which personal numbers are required to be entered pursuant to other laws and regulations
2. Specified Personal Information, etc. of our officers and employees and their relatives
   1. Preparation of withholding tax slips for employment income and retirement income, payroll reports, deductions for dependents, etc.
      （To submit (change of) tax returns, to submit the application for deduction of insurance premiums and special exemption for spouse for employment income earners, and for other administrative work related to withholding at source, etc.
   2. To submit tax returns and other documents related to property-forming housing accumulations, property-forming pension accumulations, etc.
   3. For the administration of notifications and applications concerning health insurance, employees' pension insurance, unemployment insurance, and other social and labor insurance, or corporate pension (including Category 3 insured persons under the National Pension Law).
   4. For those who are members of an employee stock ownership plan, to provide the information to the employee stock ownership plan.
   5. For other affairs related to (a) through (d) above

We shall use specified personal information only to the extent necessary for the purpose of use (hereinafter referred to as "Purpose of Use"), and shall not use the specified personal information for any other purpose.
In addition, we will not change the purpose of use of Specified Personal Information beyond the scope that is reasonably deemed to be relevant to the original purpose of use.

Article3. Acquisition

Obtaining Personal Numbers

We may request the provision of personal numbers from the individual or other personal number-related business operators only when it is necessary in order to process the affairs stipulated in Section. Requests for the provision of personal numbers will be made when the need arises to process such affairs or when the occurrence of such affairs can be anticipated.

Identification

Upon receiving a personal number, the identity of the individual shall be verified by each of the methods stipulated in Article 16 of the Personal Identification Number Law. In addition, with respect to a representative, the identity of such representative, the authority of representation, and the personal number of the individual concerned shall be verified by each of the methods set forth in the same article.

Article 4. Provision of Specified Personal Information to Third Parties

We will not provide specified personal information to any third party, except in the cases listed in each item of Article 19 of the Numbering Act.

Article 5. Ensuring Accuracy

We will keep the specified personal information accurate and up-to-date to the extent necessary to achieve the purpose of use, and will endeavor to delete the specified personal information without delay when there is no longer a need to use it.

Article 6. Safety Control Measures

We will manage specified personal information appropriately and safely, and take necessary and appropriate measures to prevent unauthorized access to or unauthorized use, loss, destruction, falsification, or leakage of specified personal information from outside the company.

Article7. Entrustment of Handling of Specified Personal Information

There are cases in which we may outsource the handling of specified personal information held by us.
When outsourcing all or part of the handling of specified personal information to an outside contractor, we will carefully select the contractor and conclude an outsourcing contract on the condition that the contractor has established and implemented a management system to appropriately protect the specified personal information.
In addition, we will exercise necessary and appropriate supervision over the subcontractor to ensure the safe management of the specified personal information.

Article 8. Continuous Improvement

We will establish internal rules, etc. concerning specified personal information, including this Policy on the Protection of Specified Personal Information, and will continuously review and improve these rules.
In addition, the Company may revise this Specific Personal Information Protection Policy as necessary due to legal amendments or other reasons.

Article 9. Response to applications and requests for notification of purpose of use, disclosure, correction, etc., suspension of use, etc., or suspension of provision to third parties of specified personal information

You may make such an application or request to the contact point of our company for notification, disclosure, correction, addition, deletion, suspension of use, or deletion of your Specified Personal Information to us, or suspension of provision to a third party.
In such cases, we will respond within a reasonable period of time after confirming the identity of the applicant/claimant (e.g., by submitting a copy of a driver's license) .
In the case of a representative, we will respond within a reasonable period of time after confirming the representative's identity.
Questions regarding the content of this Specific Personal Information Protection Policy should also be directed to our contact person.

Contact

Name	Hoosiers Capital Management., Ltd. Business Administration Department,
Address	10F Marunouchi-Nakadori Bldg, 2-2-3 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan
Phone	03-3243-8118
Hours	9:00-12:00, 13:00-18:00 (except Saturdays, Sundays, national holidays, and holidays designated by us)

We are an authorized personal information protection organization, and we also accept complaints and consultations regarding specified personal information at the following contact point.

Authorized Personal Information Protection Organization

Name	The Investment Trusts Association, Japan
Phone	03-5614-8440
Hours	Weekdays 9:00-11:30, 12:30-17:00 (except Saturdays, Sundays, national holidays, and holidays designated by the association)
Name	Japan Investment Advisers Association
Phone	03-3663-0505
Hours	9:00 - 17:00 (except Saturdays, Sundays, national holidays, and holidays designated by the Association)