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Conflict of Interest Management Policy
1. Purpose
Laser Digital Japan Co., Ltd. (hereinafter referred to as "the Company") hereby establishes and publishes the following Conflict of Interest Management Policy. Based on the provisions of Article 23, Paragraph 2, Item 3 of the Cabinet Office Ordinance concerning Virtual Asset Exchange Operators, the Company shall categorise transactions with customers relating to its virtual asset exchange business that may unduly harm customer interests (hereinafter referred to as "Target Transactions") by appropriate means. and categorise transactions that may unduly harm the interests of customers (hereinafter referred to as "Target Transactions") in an appropriate manner, and to establish a system for managing Target Transactions to ensure the proper protection of customers. This is formulated and published as the Conflict of Interest Management Policy.
2. Identification and Categorisation of Target Transactions
While the applicability of Target Transactions is determined based on individual specific circumstances, we consider the following types to be transactions with a high risk of conflict of interest:
・ Transactions where the Company improperly utilises customer information
(Examples of Transactions) Where customer information obtained by a specific department is leaked to another department and used in other transactions.
・ Transactions where a conflict of interest or competition arises between the customer and our company or its interested parties
(Primary Transaction Examples) Providing services that unduly harm the customer's interests, such as charging unreasonable fees or expenses.
The Company identifies target transactions using the following methods.
・ Aggregating information on transactions that may typically give rise to conflicts of interest, and individually identifying transactions with potential conflicts by considering their relationship to other transactions conducted by our company
・ Identifying transactions relating to products or services that, due to their nature or structure, may give rise to conflicts of interest as subject transactions in a lump sum
3. Management System for Target Transactions
The Conflict of Interest Management Department centrally manages the identification of Target Transactions and the establishment of company-wide management and internal systems concerning conflicts of interest.
4. Methods for managing subject transactions
The Company shall, in principle, manage Target Transactions by selecting or combining the management methods specified below and other appropriate conflict of interest management methods, thereby ensuring the proper protection of customers.
・ Method of separating departments conducting Target Transactions from departments conducting transactions with customers whose interests may be unduly harmed by Target Transactions
・ Modifying the terms or methods of the relevant transaction or of transactions with customers whose interests may be unduly harmed by the relevant transaction, or discontinuing the transaction
・ A method of appropriately disclosing to the relevant client that their interests may be unduly harmed as a result of the relevant transaction
・ Other methods for appropriately managing relevant transactions
5. Scope of Interested Parties Subject to Conflict of Interest Management
The Company shall designate the Company and the following companies as stakeholders subject to conflict of interest management.
・ Nomura Holdings, Inc. and its affiliated companies
・ Laser Digital Group Holdings AG and its affiliated companies
・ Other companies deemed necessary for management by the Company
Established on 17 October 2025
Laser Digital Japan Co., Ltd.