Liberta Investment Partners Co., Ltd. (hereinafter referred to as “the Company”) has established a conflict of interest management policy to appropriately identify and categorize transactions that may pose conflict of interest (hereinafter referred to as “Target Transactions”) and to ensure the protection of customers in a fair manner, preventing undue harm to customers’ interests.

1. Types of Covered Transactions

The types of Target Transactions managed by the Company are categorized in the table below:

type	Transactions between Customers and the Company or Group Companies	Transactions between Customers and Other Customers of the Company or Group Companies
Conflict Type	Transactions where the interests of the customer conflict with those of the Company or its group companies	Transactions where the interests of the customer conflict with those of other customers of the Company or its group companies
Competition Type	Transactions where the customer competes with the Company or its group companies	Transactions where the customer competes with other customers of the Company or its group companies
Information Use Type	Transactions where the Company or its group companies benefit from using information obtained through their relationship with the customer	Transactions where other customers of the Company or its group companies benefit from using information obtained through their relationship with the customer

2. Identification of Managed Transactions

The Company will consider the following points when identifying transactions that are subject to conflict of interest management:

1. When customers have a reasonable expectation that their interests will be prioritized.
2. When the Company may obtain economic benefits or avoid economic losses at the expense of customers.
3. When the Company obtains benefits clearly distinct from those of the customers as a result of transactions with customers.
4. When there are economic or other incentives to prioritize other customers over the customers.
5. When the Company receives or will receive inducements in the form of money, goods, or services other than regular fees or expenses in connection with transactions with parties other than the customers.

3. Management of Target Transactions

The Company will ensure the protection of customers by choosing or combining the following methods:

1. Implementing information barriers to prevent information exchange between departments.
2. Changing the conditions or methods of the Target Transactions.
3. Discontinuing the Target Transactions or transactions with the customers.
4. Appropriately disclosing to customers the potential undue harm to their interests associated with the Target Transactions.

4. Conflict of Interest Management System

The Company designates the Compliance Department, which guarantees independence from the business department, as the Conflict of Interest Management Department. The head of this department is appointed as the Chief Conflict of Interest Management Officer. This department will centrally manage the identification of Target Transactions, overall conflict of interest management, and the establishment of internal systems across the entire company.

5. Scope of Companies Subject to Conflict of Interest Management

The group companies subject to conflict of interest management by the Company are as follows:

1. Shareholders of the Company.
2. Companies controlled by the shareholders of the Company (sister companies).
3. Affiliates of the Company and its shareholders.
4. Other companies deemed necessary by the Conflict of Interest Management Department from the perspective of conflict of interest management.