Basic Policies for Client-First Conduct


Policy 1 Pursuit of Clients' Best Interests

Nippon Value Investors’ management vision is ‘To provide the highest level of investment management services in the industry on a global basis, and to be the company which is the best choice for our clients. We consider our clients to be our first priority, and we will always pursue their best interests as professionals with extensive experience and expertise in our field.


Policy 2 Appropriate Management of Conflicts of Interest

Based on its internal rules, Nippon Value Investors monitors all transactions involving securities and other financial instruments in the personal accounts of our directors and employees and involving investments in our own investment program (fund) which have potential conflicts of interest with our clients. Monitoring is performed by our Compliance Group to check in advance for any actual conflicts with the interests of our clients.


Policy 3 Clarification of Fees and Expenses

Nippon Value Investors sets a fee structure that reflects the content of the investment management services required by each client, thereby making sure that each fee structure is fair for all clients on a rational basis. We also publish a standard fee structure as the basis for determining individual fee structures.


Policy 4 Easily Understandable Provision of Important Information

Nippon Value Investors provides information about its investment program’s characteristics, potential investment returns and risks in a manner that is easy for our clients to understand.


Policy 5 Provision of Services Suited to Each Client

Nippon Value Investors provides its investment management services only after clients understand that the return-and-risk characteristics of our investment program suit their investment needs.


Policy 6 Frameworks for Motivating Directors and Employees Appropriately and Other Measures

Nippon Value Investors evaluates the performance of directors and employees with the aim of encouraging them to always put the client's interests first, and we reflect this goal in our remuneration strategy. In addition, we encourage both directors and employees to be shareholders of Nippon Value Investors so that our overall, companywide policy of putting clients’ interests first is maintained over the long term.


Policy 7 Establishment and Publication of Policies Concerning Client-First Business Conduct

Nippon Value Investors regularly reviews the above policies and periodically notifies clients of its efforts and initiatives associated with these reviews.


Key Performance Indicators (KPI) for Basic Policies for Client-First Conduct