August 2022

All Out Life

All Out Life (hereinafter referred to as the Company”) has established a conflict of interest management policy (hereinafter referred to as the Policy”) to ensure that the interests of our customers are not unduly harmed. We will manage transactions appropriately and carry out business operations. In addition to the risk of directly harming the interests of our customers, we will strive to manage our business in a way that will not damage our social reputation or credibility in the financial market.

We will announce the outline of the policy below.

1. What is a conflict of interest?

“Conflict of interest” refers to a situation where a customer’s interests and our company’s interests conflict, or a situation where the interests of customers to whom our company has obligations compete or conflict.

We will appropriately identify transactions where there is a risk of a conflict of interest, and will take every possible measure to ensure that the interests of our customers are not unduly harmed as a result of our transactions.

2.Types of transactions that may cause conflicts of interest

The Company classifies situations of conflicts of interest according to the types listed below, and manages transactions that may have a potential conflict of interest efficiently and without omission.

1. Self-dealing type “Acts in which our company is the counterparty of the transaction when we act as the customer’s agent, and similar activities.”
   
2. Mutual agency type “Acts in which our company acts as an agent for both parties and similar activities”
   
3. Competitive transaction type “Acts that unfairly give priority to the interests of one party when there is a competitive relationship between the customer and the Company, or between the customer and similar activities.”
   
4. Information use type “Acts of illegally using inside information and similar acts”
   

3. Conflict of interest management system

The Company will centrally manage transactions that may cause conflicts of interest, with the Compliance Department as the department responsible for managing conflicts of interest, and the person in charge of the Compliance Department as the person responsible for managing conflicts of interest. The Chief Conflict of Interest Management Officer will ensure that executives and employees are thoroughly informed about conflict of interest management, establish a system necessary for conflict of interest management, and regularly verify this.

4. How to manage conflicts of interest

Our company will appropriately manage the applicable transactions using the following methods or a combination of them, and will work to ensure that the interests of our customers are not unduly harmed.

1. A method of separating departments that conduct transactions that may have a conflict of interest and blocking information.
   
2. How to change the terms or methods of one or both parties in a transaction that may cause a conflict of interest
   
3. How to terminate one side of a transaction that may cause a conflict of interest
   
4. How to disclose to customers that there is a potential conflict of interest
   
5. How to monitor who you share your information with
   
6. Other methods
   

5. Scope of companies subject to conflict of interest management

Our company is the only company subject to conflict of interest management, and there are no other companies. If you have any concerns or requests regarding transactions, please contact us below.

Phone number: (Click here from mobile phone/IP phone) 

Reception hours: 9:30 to 17:00 (excluding Saturdays, Sundays, holidays, and New Year’s holidays)