Basic Policy on Best Execution

May 2018 All Out Life This basic policy for best execution establishes policies and methods for executing transactions under the best trading conditions for customers, in accordance with the provisions of Article 40-2, Paragraph 1 of the Financial Instruments and Exchange Act.

  1. Our company handles ETFs (exchange traded funds) that are listed on overseas financial instruments exchanges (those similar to financial instruments exchanges and established under foreign laws and regulations). In addition, our company handles listed stocks, etc. (stocks listed on domestic financial instruments exchanges, preferred equity securities, ETFs (stock index-linked investment trust beneficiary certificates), REITs (real estate investment trusts), etc.) Purchase and sale of securities (those stipulated in Article 16-6 of the Financial Instruments and Exchange Act Enforcement Order), handling securities (Phoenix stock certificates, corporate bonds with stock acquisition rights, etc., Article 67-18-4 of the Financial Instruments and Exchange Act) We do not handle the buying and selling of products (specified in 2013) or derivative transactions.
  2. As a general rule, our company forwards orders received from customers to overseas financial instruments exchanges.
  3. Orders in 2. are executed directly at overseas financial instruments exchanges via local overseas brokers.
  4. Demand from many investors is concentrated on financial instruments exchanges, and compared to off-exchange trading, they are considered to be superior in terms of liquidity, execution possibility, transaction speed, etc. This is because it is judged to be the most reasonable option for the customer.
  5. Based on the discretionary investment contract, the Company may execute purchases and sales through over-the-counter transactions in which the Company is the direct counterparty of the customer, in accordance with applicable laws and procedures prescribed by the Company.
  6. Due to system failures, etc., we may be forced to implement a method different from the method selected based on this policy. Even in such cases, we will endeavor to execute under the best conditions at that time.
  7. Best execution involves comprehensive consideration of various factors, including not only price, but also cost, speed, and certainty of execution. Therefore, even if you only focus on price and find out that it is not the best after the fact, that alone does not necessarily constitute a violation of the basic policy of best execution.