Conflict of
Interest Management Policy

Conflict of Interest Management Policy

1.Purpose

Leifras Co., Ltd. establishes the following Conflict of Interest Management Policy. We will implement measures to prevent any conflicts of interest that could unfairly harm our business partners, ensuring that our interests do not compete or conflict with those of our partners, and that the interests of one partner do not compete or conflict with those of another.

2.Definitions

A conflict of interest refers to a situation where the interests of our business partners conflict or compete with those of our company, or where the interests of multiple business partners, for whom we have obligations, are in competition or conflict. To prevent any negative effects from conflicts of interest within our company, we will establish an appropriate management and compliance system.

3.Identification and Categorization of Transactions with Potential for Conflicts of Interest

We will proactively identify and categorize business activities that are more likely to give rise to the situations listed below and require management (“Managed Activities”). We will carefully manage transactions that may pose a risk of conflicts of interest, paying attention to reputational risks. As an example of Managed Activities, we may receive business assignments from a counterparty with whom we have an outsourcing agreement, either in connection with that contract or unrelated to it.

• (1)Situations within our contractual relationship with a business partner where it is reasonably expected that the partner's interests will take precedence
• (2)Situations where we may unfairly gain an advantage by using information obtained from a business partner
• (3)Situations where, due to our contractual relationship with a business partner, there is a high risk of reputational damage

4.Conflict of Interest Management Framework

We have established a department to manage and oversee conflicts of interest, centralizing their management. We also comply with relevant laws and regulations related to conflicts of interest and will continuously improve our management framework.

5.Conflict of Interest Management Methods

We will take measures to prevent the negative effects of conflicts of interest by appropriately combining the methods listed below, ensuring that the interests of our business partners are not unfairly harmed.

• (1)Separating departments involved in transactions with potential conflicts of interest from other departments
• (2)Changing the terms or approach of one or both transactions that have the potential for conflicts of interest, or terminating one of the transactions
• (3)Obtaining consent from the business partner regarding the potential for conflicts of interest, or disclosing the information to the business partner