Account Management Policy
In accordance with Article 9 of the Act on Sales, etc. of Financial Products of Japan, Nippon Value Investors KK sets for the following account management policy with regard to discretionary investment advisory contracts and non-discretionary investment advisory contracts (collectively “advisory contracts”) , and provides investment advisory services based on such policy.
1. Matters that should be considered in light of the knowledge, experience, financial condition and the purpose of entering into advisory contract of clients.
Nippon Value Investors KK will propose clients to enter into advisory contracts in a manner that is consistent with the intention and circumstances of each client after determining the knowledge, investment experience, investment objectives, financial condition and other conditions of each client as well as its purpose of entering into the advisory contract with the company.
Nippon Value Investors KK will provide advice on investment strategies or products that the company believes are suitable based on each client’s knowledge, experience, financial condition and purpose of entering into the advisory contract with the company.
When providing advice on investment strategies or products, Nippon Value Investors KK will explain the investment asset class and risks associated with such strategy or product in a manner that is suitable based on each client’s knowledge, experience and other conditions.
2. Matters that should be considered regarding persons entering into advisory contracts
When proposing clients to enter into advisory contracts, Nippon Value Investors KK shall place the highest priority on earning the trust of clients, comply with applicable laws and regulations, and be consistent with the best interests of clients in every respect.
Nippon Value Investors KK shall perform its services in compliance with all applicable laws and regulations and based on a reasonable approach.
In proposing clients to enter into advisory contracts, Nippon Value Investors KK shall do so at such times and in a manner intended to minimize any inconvenience to its clients.
3. Other measures to ensure proper conduct
Nippon Value Investors KK provides its officers and employees with what it believes to be adequate training to prevent the use of inappropriate methods in proposing that clients enter into advisory contracts. Individuals with concerns about any inappropriate conduct should contact Nippon Value Investors KK’s chief compliance officer (Tel: 81-3-6551-2796).
Officers and employees of Nippon Value Investors KK shall constantly strive to acquire and enhance the knowledge and skills necessary to prevent any betrayal of the confidence and trust of the clients.
Nippon Value Investors KK seeks to continually reinforce its internal management systems in order to comply with the Financial Instruments and Exchange Act of Japan the regulations of the Japan Investment Advisers Association and other applicable laws and regulations in proposing that clients enter into advisory contracts.
Nippon Value Investors KK shall strive to provide clients with appropriate information so that clients can properly evaluate the company’s investment advisory operations, discretionary investment operations and investment fund operations.