The Company serves the customers' asset management needs through our asset management business activities and has a highly public and important mission to redistribute management funds to the society through investments. Importance of our social mission is increasing year by year due to changes in social structure and economic condition and development of investment technology and information technology.

The Company hereby sets up the Code of Ethics as follows for the purposes of being fully aware of its social responsibilities, upholding its public trust and gaining firm public confidence as a leading company of the industry.

1. Compliance

The Company makes efforts to conduct sensible corporate activities, complying with the laws, association rules, internal rules and other rules and regulations and also respecting societal norms of the society.

2. Awareness of Corporate Ethics

Employees shall fully understand the corporate ethics expected of the Company and act with common sense and duty as a member of society.

3. Compliance with the Code of Ethics

(Areas of business operations)

(1) In the event that an employee commits or discovers any act which violates or is likely to violate this Code, such act of violation shall be promptly reported to teh Compliance Department or Chief Compliance Officer.

(2) The person who makes such report will not receive unfair treatment based on the fact that the report is made by such person.

(3) Those who commit an act violating this Code and those who are aware of such violation and fail to act on it shall be subject to punishment in accordance with the Rules of Employment and other internal rules for violation of internal rules.

(4) If requested by Human Resources Department, Employees shall sign and submit a letter of covenant to the effect that he/she shall comply with this Code.

4. Amendment or abolishement of the Code of Ethics

This code shall be amended or abrogated upon resolution of the Board of Directors.

1. Contribution to Society

Employees shall actively participate in social action programs as corporate citizens and contribute to teh development of the society. Employees shall continue to be engaged in social action programs, such as environmental protection, support for culture and art, cooperation with local communities, participation in volunteer activities and contribution to international community, and play the role as corporate citizens.

2. Compliance with the Laws Regulating Various Sectors of Business

Employees shall comply with the Law Concerning Investment Trusts and Investment Corporations, the Financial Instruments and Exchange Law and other related buiness laws and shall be sure to take procedures, such as obtaining approvals and licenses and notifications.

3. Restriction on Act of Endowmen/Political Donation

(1) Any political donation or endowment for various organizations shall be made in accordance with proper methods in compliance with the relevant laws, such as the Public Election Law and Political Donation and Expenditures Regulation Law.

(2) Employees shall strictly abstain from any act which might cause misunderstanding by the society as having collusive relationship with politicians and the government, let alone bribery, payoff or illegal political contribution, and shall endeavor to build a sound and transparent relationship.

4. Severing Ties with Anti Social Forces

(1) Employees shall endeavor to have basic legal knowledge, common sense and sense of justice and to take a sensible course of action at all time so as not to be involved with any illegal act or antisocial behavior.

(2) Employees shall deal firmly with antisocial forces and shall not be involved therewith. In the event that an Employee receives any unreasonable request from antisocial forces, etc., he/she shall not try to solve the problem by way of giving money, etc.

(3) The Company shall not use antisocial forces in order to benefit itself

(4) The Company shall not make any transaction with any antisocial forces or business partners who have relationship with antisocial forces.