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  2. Conflict of Interest Management Policy

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.

The following points are posted on the Financial Services Agency's website.

Crypto asset exchange registration list

・ The crypto assets included in this list have only been confirmed, upon request for explanation from the handling crypto asset exchange service provider, to satisfy the definition under the Payment Services Act.

・ The Financial Services Agency and Finance Bureau do not guarantee or endorse the value of the crypto assets included in this list. Please note that crypto assets are not necessarily backed by any underlying assets, and are merely electronic data recognized as having property value.

・ Please pay attention to the following points when trading in crypto assets.

(Notes concerning the use of crypto assets)

・ Crypto assets are not "legal tender" with values guaranteed by the state, such as the Japanese yen or US dollar. They are electronic data exchanged over the Internet.

・ The price of crypto assets may fluctuate. There is a possibility of incurring losses, as the price of crypto assets may plummet or suddenly become worthless.

・ Crypto asset exchange service providers are required to register with the Financial Services Agency/Finance Bureau. Please confirm whether the provider you intend to use is a registered business operator.

・ When trading crypto assets, please seek explanations from the provider, fully understand the details of the transaction, and proceed based on your own judgment.

・ Consultations regarding crypto assets and fraudulent coins are on the rise. Please be cautious of scams and malicious business practices that exploit the use of crypto assets or piggyback on the introduction of crypto asset exchange services.

(Disclaimer)

・ Crypto assets may be used to settle payments only where the party receiving the payment has agreed to such use.

・ The purchase, sale, or exchange of crypto assets for other crypto assets involves the risk of loss due to fluctuations in the price of crypto assets. The price of crypto assets may decline due to changes in the balance of supply and demand, movements in prices, fiat currencies, or other markets, or changes in circumstances relating to crypto assets.

・ Please fully review the contents of the crypto asset trading manual and other related documents, and conduct transactions based on your own judgment and responsibility.

・ Malfunctions in the trading system or communication lines may result in delays in processing, or the inability to place, execute, confirm, or cancel orders.

・ Crypto assets may be lost, in whole or in part, due to cyberattacks or other causes.

・ Changes in the external environment, including the strengthening of legal regulations concerning crypto assets, or deterioration in the financial condition of the Company or the Company's group, may result in the Company being unable to continue its business.

・ Transaction fees and other charges may apply when conducting transactions.

Laser Digital Japan Co., Ltd.

Crypto Asset Exchange Service Provider, Director-General of the Kanto Local Finance Bureau No.00032

Member of Association for Certified Payment Service Providers: Japan Virtual and Crypto assets Exchange Association

Laser Digital Japan is a subsidiary of Laser Digital, a full-service digital asset firm specializing in Trading, Asset Management, Solutions, and Early-Stage Investing.

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