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Notice Regarding the Sharing of Corporate Client Information
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Notice Regarding the Sharing of Corporate Client Information

"Opt Out" Notice

Alternative Investment Capital Limited ("AIC") wishes to fulfill a useful role for its clients by providing high value-added financial products and services in closer cooperation with various related companies. Accordingly, AIC has issued the following "opt out method*" notice in regard to its policy on sharing corporate client information.

* The "opt-out method" refers to the policy of AIC sharing corporate client information after having giving clients prior notification of this policy, and having excluded clients who do not wish to share information and have requested AIC to stop sharing such information. This differs from the "opt-in method," a policy by which AIC shares information only about clients who have expressed their consent to share information in writing or by other means.

Policy regarding the sharing of information based on the opt-out method

  1. Clients subject to this method
    Corporate clients who are interested in the financial services provided by AIC, or corporate clients who have a trading relationship with AIC
  2. Purpose of information use
    Client information shall be provided to the entities set forth in item 4. below for the purpose of providing comprehensive services regarding private equity to the clients.
  3. Scope of information subject to sharing
    (1) Names of clients, head office location and other basic information
    (2) Details of transactions conducted between AIC and clients, as well as details of transactions that clients are interested in
    (3) Status of investment in funds managed by AIC
    (4) All other corporate information incidental to the above matters
  4. Scope of companies with which information will be shared
    (1) AIC shareholders (Mitsubishi Corporation, Daido Life Insurance Company, Sumitomo Mitsui Banking Corporation, Mitsubishi UFJ Trust and Banking Corporation)
    (2) Subsidiaries of the parent company of AIC (Mitsubishi Corporation)
  5. Method of sharing information
    Information shall be provided by post, fax, email and other means, in addition to directly handing print-outs of information to relevant recipients.
  6. Method of information management at recipients
    Recipients shall take the utmost care in managing the information received as a result of sharing, such as by prohibiting the use of information for other than intended purposes and preventing information leaks, following the recipients' own confidentiality regulations, information management regulations and other rules, in accordance with external laws and regulations.
  7. Method of notice and confirmation
    AIC will provide notices concerning its policy on sharing information on its corporate website. These notices shall reflect continuous updates of the latest situation. For questions and other inquiries concerning details of these notices, please contact AIC at the contact point shown at the end of this notice.
  8. Stopping of information sharing
    If AIC receives a request from a client to stop sharing undisclosed information, AIC shall promptly stop sharing said undisclosed information.

Notes

1. Please note that AIC shall not stop sharing information that it is carrying out for the purpose of conducting its own internal management (defined as operations concerning compliance management, operations concerning managing the risk of losses, internal audit, operations concerning internal audit, operations concerning finances, operations concerning accounting and operations concerning taxation) along with the sharing of information based on external laws and regulations.

2. In cases where clients have applied for specific products, services and so forth, and have already consented to sharing information, please be advised that AIC will continue to share information as necessary unless specifically instructed otherwise.

3. In cases where information has been shared among various companies before AIC receives a request to stop sharing information from a client, the companies that have received information from the client will continue to use the information. However, companies that have received the information through sharing will dispose of said information using proper methods to ensure no leakage of information.

Contact for requesting the stopping of information sharing

Clients who wish to request the stopping of information sharing are asked to contact AIC at the following telephone number.

Tel: +81-3-5218-5230

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