Statement of Protection of Personal Information

In our efforts to faithfully comply with and execute in accordance with our corporate philosophy (i) the applicable laws and regulations regarding the protection of personal information and (ii) guidelines of the competent minister and of the authorized personal information protection organizations regarding the same that apply to the personal information of our clients and international and domestic business contacts (hereinafter referred to as our "Clients") used in the course of our business, we hereby make, as our policy on the personal information of our Clients, this Statement of Protection of Personal Information as follows. We declare to practice, maintain and improve the contents hereof as well as make our best efforts towards security and maintenance in order to prevent divulgence of personal information.

1. Compliance with Laws and Regulations

We shall comply with the "Law for the Protection of Personal Information" and other (i) applicable laws and regulations and (ii) guidelines of the competent minister and of the authorized personal information protection organizations regarding the protection of personal information as well as this Statement of Protection of Personal Information.

2. Appropriate Use of Personal Information and Use and Provision to a Third Party of Sensitive Information

Pursuant to the Ordinance of the Cabinet Office Concerning the Regulations, etc. of the Conduct of Securities Companies, any information on race, creed, family origin, legal domicile, health and medical history or criminal record or any other special undisclosed information shall only be used or provided to a third party for an appropriate business operation or for any other purposes considered to be necessary. We acquire personal information necessary for the following purposes of use within the legal limits and handle the information to the extent necessary to achieve the purpose of use:

(1) Acquisition and maintenance of identification information under the Act on Prevention of Transfer of Criminal Proceeds.

(2) Opening of accounts for various financial products and account management, execution or performance of agreements, exercise of rights or performance of obligations under laws and administration of rights and obligations under agreements and laws.

(3) Aside from (1) and (2) above, (i) personal information acquired through mutual information exchange including telephone conversations or exchange of business cards or e-mails between our officers or employees and the representatives or contact persons of corporate bodies or organizations having, or which may have in the future, direct or indirect business relationships with us (including (a) investment management companies that handle our current or future products, their affiliates and related companies associated with such products (hereinafter referred to as the "Management Companies") and (b) our customers and potential customers (hereinafter referred to as the "Customers"); hereinafter collectively, the "Corporate Bodies") on the other side, and (ii) personal information described in documents in the form of, including but not limited to, writing or electronic files, where permission to use has been given by the individual, corporate bodies to which the individual belongs or a third party individuals belonging to the Corporate Bodies shall be used for the following purposes:

  1. provision of information regarding investment products and other products/services (hereinafter referred to as the "Products") or provision of various information necessary for development/formation of the Products including investor trends in Japan to the Corporate Bodies;
  2. receiving and/or research of information regarding investment including investment needs and other information for the Corporate Bodies;
  3. solicitation, sales or proposal of the Products to the Corporate Bodies;
  4. provision to the Management Companies of personal information regarding the Customers' personnel in charge of receiving the information of the Management Companies which is provided through us;
  5. development of new products/services to be provided to the Corporate Bodies;
  6. report of the results of transactions and/or outstanding balances thereof to the Corporate Bodies;
  7. assistance in reporting the results of transactions and/or outstanding balances thereof to our customers by the Corporate Bodies;
  8. business alliances and/or business cooperation with the Corporate Bodies; or
  9. responses to inquiries and/or requests.

3. Provision to a Third Party

(1) (i) Personal information acquired through mutual information exchange including telephone conversations or exchange of business cards or e-mails between our officers or employees and the representatives or contact persons of the Corporate Bodies on the other side, and (ii) personal information described in documents in the form of, including but not limited to, writing or electronic files, where permission to use has been given by the individual, Corporate Bodies to which the individual belongs or a third party individuals belonging to the Corporate Bodies may be provided by us to a third party via telephone conversation, e-mail, electronic file, fax or document without the prior consent of the individual for the following purposes; provided, however, that upon receipt of request by such individual in writing or through e-mail to suspend the provision of such personal information to a third party, provision of such personal information to a third party shall be promptly suspended irrespective of the purpose of use thereof:

  1. provision of information regarding the Products to the Customers;
  2. provision of various information necessary for development/formation of the Products including demand trends and research information to the Management Companies;
  3. solicitation, sales or proposal of the Products to the Customers;
  4. provision to the Management Companies of personal information regarding the Customers' personnel in charge of receiving the information of the Management Companies which is provided through us;
  5. development of new products/services to be provided to the Customers;
  6. report of order receipts, the results of transactions and/or outstanding balances thereof and investment status to the Customers;
  7. assistance to the Management Companies or the Customers for the contacts between them;
  8. business alliances and/or business cooperation with the Management Companies or the Customers; or
  9. responses to inquiries and/or requests from the Corporate Bodies.

(2) The scope of personal data that may be provided to a third party pursuant to (1) above is as follows:

  1. name;
  2. corporate name;
  3. name of the department to which the individual belongs;
  4. title of the individual;
  5. company address (including the address of the company for which such individual works)
  6. company telephone number (including the number allotted to the individual or his/her department);
  7. company facsimile number (including the number allotted to the individual or his/her department);
  8. company e-mail address (including the address allotted to the individual or his/her department); and
  9. information that reference materials and other various types of data had been received.
Furthermore, the following information shall also be provided in addition to the foregoing personal data of individuals belonging to the Management Companies:
  1. licenses held;
  2. background (including academic record and career history);
  3. photograph thereof; and
  4. other personal information that provided by the Management Companies with an intention to introduce the individuals belonging to the Management Companies to such Corporate Bodies.

(3) Other than (1) above, we shall not provide personal information to a third party without the individual consent of our Clients, unless the provision is:

  1. required pursuant to the laws and regulations;
  2. necessary for the protection of the life, body and/or property of a person and the individual's consent is difficult to obtain;
  3. deemed especially necessary for the improvement of public health or the promotion of healthy rearing of children and the consent of the individual is difficult to obtain; or
  4. necessary in connection with the collaboration required to the implementation of the matters as set forth in laws and regulations by the agencies of the state or the local public entities or any person appointed thereby and obtaining the individual's consent threatens to hinder the implementation of such matters.
We shall not, except where provided for by any law or regulation, provide to a third party the collected personal information without the consent of our Clients.

4. Obtainment by Fair and Lawful Means

We shall, in obtaining any personal information, exercise fair and lawful means; we shall not obtain thereof by unlawful means and shall obtain the consent of the individual of the personal information regarding the purpose of use or notify necessary matters in this statement on our website.

5. Security and Maintenance of Personal Information

We shall implement necessary and appropriate security and maintenance measures to prevent any demolition, damage, alteration and divulgence of personal information as well as appropriately supervise officers, employees and delegates. In addition, in order to execute this statement, we shall prepare internal rules regarding protection of personal information and endeavor to continuously enhance thereof, as well as execute, improve and maintain the contents hereof through thoroughly familiarizing our employees (including officers and employees in general as well as dispatched employees) and other related persons.

6. Procedures for Disclosure Requests of Registered Information

We will maintain the content of our Clients' personal information as accurately and as currently as possible. Should there be any request by the Clients for disclosure, correction, or suspension of use regarding the personal data we hold with respect to our Clients, we shall confirm the content and endeavor to appropriately and promptly respond to such request upon confirmation of identification. Based on the confirmation of the content, we will add to, modify, correct or delete the registered information as required.

7. Continuous Enhancement of this Statement

For the appropriate treatment of our Clients' personal information, we shall review this protection statement from time to time and make endeavors for its continuous enhancement.

8. Questions/Opinions

We shall endeavor to promptly and faithfully respond to any questions or opinions from our Clients with respect to any personal information. For questions or opinions, please contact our General Affairs and Personnel Department below in writing:

Mitsui & Co. Alternative Investments Limited
General Affairs and Personnel Department
11th Floor, Chiyoda First Bldg.South Wing, 3-2-1 Nishikanda, Chiyoda-ku, Tokyo, 101-0065, Japan
Telephone: +81-3-6361-0420
Office hours: 9:00 am through 5:00 pm

9. Authorized Personal Information Protection Organization

We are a member of the Japan Securities Dealers Association, which is an authorized personal information protection organization authorized by the Personal Infomation Protection Commission. Complaints and inquiries regarding treatment of personal information of the association's members are received at the Personal Information Consultation Office of the association.

[Complaints and Inquiries Section]
Personal Information Consultation Office, Japan Securities Dealers Association:
Telephone: 03-6665-6784
URL: http://www.jsda.or.jp/