Disclosures

The Investment Risk Management Department, which is independent of the investment division and specializes in monitoring, was set up to appropriately manage risks by monitoring investment status of funds from diverse angles.

The Investment Risk Management Department has established a structure to ensure appropriate fund management by deploying human resources with knowledge of investment theories, related business laws and securities trading regulations, as well as IT skills to efficiently and effectively conduct monitoring operations.

The results of monitoring investment status of funds are periodically reported to the Investment and Risk Committee, which comprises the senior management of the investment division and risk management division, and improvement measures, etc. are deliberated and decided on an as-needed basis.

Furthermore, the status of deliberations at the Investment and Risk Committee meetings is regularly reported to the Executive Committee, which comprises the president and other top management team members, to establish a multi-faceted, multi-layered risk management structure on a company-wide level.

The main items to be monitored regarding the investment status of funds are as follows

Monitoring of risks associated with investment of funds

• Market Risk
• Credit Risk
• Liquidity risk
• Counterparty risk

Compliance monitoring associated with investment of funds

• Status of compliance with the investment guidelines
• Status of compliance with laws and regulations, etc.
• Management of transactions that may cause conflicts of interest

※ The names of the structure, committee, etc. described above may be changed going forward.

Investment Advisory Agreement and Discretionary Investment Management Agreement

Risk

Risk of Potential Loss

Investments under discretionary investment agreements or advice under investment advisory agreements are applied to securities, including domestic and foreign equities and bonds, beneficiary certificates of investment trusts, trust beneficiary rights and interests in collective investment schemes, and financial instruments including loans, real estate, futures, options, swaps and foreign exchange instruments, which are associated with price volatility. Thus a loss of principal may occur due to, among other factors, fluctuations in prices in relation to those asset classes.

Price Fluctuations

Major risks of investing in these asset classes are as follows:

1. Market Risk: The risk of price fluctuation investable assets, due directly to movements in financial instruments markets, such as stocks, interest rates, foreign exchange, and indexes.
2. Credit Risk: The risk of price fluctuation of asset classes due directly to, among other things, changes in businesses or asset conditions of issuers, managers, intermediaries, etc., and their transaction counterparties.
3. Liquidity Risk: The risk of price fluctuation in prices of asset classes, etc. caused directly by, among other factors, the inability or difficulty to execute transactions due to market movements or low trading volume with regard to financial instruments, or forced transactions through excessively unfair below above market pricing. In addition to the above, hedge funds and securitized products, may entail various risks arising from investment methods and schemes.

Fees and Commissions

Expenses, incurred by clients are as follows.

Risk of Potential Loss

[Fees on Investment Advisory Services and Discretionary Investment Management Services]

In principle, fees are to be paid based on a calculation method, where the amount of assets is multiplied by a fee rate. Individual calculation methods cannot be provided in advance because they are determined according to the asset class, the investment management guidelines, and details of investment consultations with clients. Before signing an agreement, please make sure that you confirm the calculation methods for the fees on relevant investment services.

[Trading Costs]

Under discretionary investment management agreements, trading commissions for invested assets, miscellaneous expenses for trust administration, and fees paid to overseas custodians who hold such assets, are deducted from the assets under management, according to the asset classes (in the case of investment in beneficiary certificates of investment trusts, trust fees, partial redemption charges, and other expenses related to such funds may be incurred) The specific amounts, ceilings, and calculation methods vary depending on the types and volume of assets to be actually invested in and managed, and therefore cannot be provided in advance.

[Early Termination Fee]

When terminating an agreement, an early termination fee may apply in accordance with the provisions of the agreement.

Taxes, Public Dues and Administrative Expenses

In addition to the above, under discretionary investment management agreements, various expenses, taxes and other public charges, and expenses necessary for handling taxes, other public charges, and administrative affairs related to invested asset classes are deducted from the assets under management or incurred by the clients. Under investment advisory agreements, when a client buys or sells securities. the tax systems related to securities purchased or sold apply. For example, a client is subject to taxes on profits from stock trading, dividends from securities and taxes on interest.

PLAN (Plan)

The Investment and Risk Committee chaired by the executive officer in charge of the Business Planning Department determines investment strategies for funds and investment styles, and related issues. In accordance with the basic investment policy, etc. determined by the Investment and Risk Committee, the fund managers formulate policies on implementing investments as their investment plans at their respective investment departments, based on the investment specifications and guidelines.

DO (Implementation)

The fund managers of their respective investment departments implement investments in line with the investment plans and manage funds. The general managers of their respective investment departments check the status of investment implementations carried out by the fund managers thereof.

Execution of buy or sell orders is carried out by traders at the Trading Department which is independent of the respective investment departments, based on execution instructions for investments from the respective investment departments.

CHECK (Examination/Assessment)

The Business Planning Department reports the monitoring status of the investment performance at the Investment and Risk Committee meeting (chaired by the executive officer in charge of the Business Planning Department), held on a monthly basis, independently from the respective investment departments in the investment division.

As for the monitoring status and the details of deliberations, feedback is promptly provided to the fund managers by the general managers of their respective investment departments (members of the Committee) and is reflected in the investments of funds.

In addition, regarding risk management and monitoring status of compliance with laws and regulations, etc., in relation to investments, they are handled by the Investment Risk Management Department, which is independent of the investment division. The monitoring results are reported at the Investment and Risk Committee meeting and the Executive Committee meeting (chaired by the president), held every month.

Under these checks and balances, we are striving to maintain an appropriate investment structure through the consistent investment process of the PDC - PLAN-DO-CHECK - cycle.

※ The names of the structure, committee, etc. described above may be changed going forward.

FTSE Fixed Income LLC:

FTSE Fixed Income Index is an index managed by FTSE Fixed Income LLC. FTSE Fixed Income LLC is not a sponsor for any of the funds in the materials and do not recommend, distribute and promote any of the products in the materials. FTSE Fixed Income LLC provides index data only for providing information. It does not guarantee accuracy and integrity nor does it have any liability for any errors, omissions and delays of the index. All rights including intellectual property, such as copy right of this index, belong to FTSE Fixed Income LLC.

Bloomberg Finance L.P:

"Bloomberg®", "Bloomberg Global Aggregate Index" and "Bloomberg World Government Inflation-Linked Bond Index" and their sub-indices and custom indices are service marks of Bloomberg Finance L.P. and its affiliates, including Bloomberg Index Services Limited ("BISL"), the administrator of the indices (collectively, "Bloomberg"), and are licensed for use for specific purposes by Sumitomo Mitsui Trust Asset Management Co., Ltd.. Bloomberg is not affiliated with Sumitomo Mitsui Trust Asset Management Co., Ltd. and does not endorse, support, review or recommend any financial products on the Materials. Bloomberg does not guarantee the timeliness, accuracy, or completeness of any data or information relating to the financial instruments in the Materials.

S&P Dow Jones Indices LLC:

The rights of the index belong to product of S&P Dow Jones Indices LLC (“SPDJI”), and has been licensed for use by Sumitomo Mitsui Trust Asset Management Co., Ltd.. Standard & Poor’s® and S&P® are registered trademarks of Standard & Poor’s Financial Services LLC (“S&P”); Dow Jones® is a registered trademark of Dow Jones Trademark Holdings LLC (“Dow Jones”); and these trademarks have been licensed for use by SPDJI and sublicensed for certain purposes by Sumitomo Mitsui Trust Asset Management Co., Ltd. Sumitomo Mitsui Trust Asset Management Co., Ltd 's financial products on the materials are not sponsored, endorsed, sold or promoted by SPDJI, Dow Jones, S&P, their respective affiliates and none of such parties make any representation regarding the advisability of investing in such product(s) nor do they have any liability for any errors, omissions, or interruptions of the Index.

MSCI:

Copyright MSCI2022. Unpublished. All Rights Reserved. 

This information may only be used for your internal use, may not be reproduced or redisseminated in any form and may not be used to create any financial instruments or products or any indices. None of this information is intended to constitute investment advice or a recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such.  Historical data and analysis should not be taken as an indication or guarantee of any future performance, analysis, forecast or prediction.  This information is provided on an “as is” basis and the user of this information assumes the entire risk of any use it may make or permit to be made of this information. Neither MSCI, any or its affiliates or any other person involved in or related to compiling, computing or creating this information makes any express or implied warranties or representations with respect to such information or the results to be obtained by the use thereof, and MSCI, its affiliates and each such other person hereby expressly disclaim all warranties (including, without limitation, all warranties of originality, accuracy, completeness, timeliness, non-infringement, merchantability and fitness for a particular purpose) with respect to this information.  Without limiting any of the foregoing, in no event shall MSCI, any of its affiliates or any other person involved in or related to compiling, computing or creating this information have any liability for any direct, indirect, special, incidental, punitive, consequential or any other damages (including, without limitation, lost profits) even if notified of, or if it might otherwise have anticipated, the possibility of such damages.

FTSE International Limited:

The financial products on the materials are not in any way sponsored, endorsed, sold or promoted by FTSE International Limited (“FTSE”), by the London Stock Exchange Group companies (“LSEG”) or by Research Affiliates LLC (“RA”) (together the “Licensor Parties”). None of the Licensor Parties make any warranty or representation whatsoever, expressly or impliedly, either as to the results to be obtained from the use of “FTSE RAFI Kaigai 1000 Index” including sub-indices (“Index”) and/or the figure at which the said Index stands at any particular time on any particular day or otherwise. The Index is compiled and calculated by FTSE. None of the Licensor Parties shall be liable (whether in negligence or otherwise) to any person for any error in the Index and none of the Licensor Parties shall be under any obligation to advise any person of any error therein. "FTSE®" is a trademark of LSEG and is used by FTSE under license. All Russell indices and related services are the property of FTSE Russell.

JPX Market Innovation & Research, Inc.:

The intellectual property rights associated with “Tokyo Stock Price Index (TOPIX)”, “Tokyo Stock Exchange Prime Market Index”, “Tokyo Stock Exchange Standard Market Index”, “Tokyo Stock Exchange Growth Market Index”, “Tokyo Stock Exchange Mothers Index”, “Tokyo Stock Exchange REIT Index” including sub-indices belong to JPX Market Innovation & Research, Inc.(“JPXI”). All products described in the materials are not provided, guaranteed or distributed by the JPXI. The JPXI is not liable to any losses or damages incurred by any of the products in the materials.

JPX Market Innovation & Research, Inc. and Nikkei Inc.:

The JPX-Nikkei Index 400 is copyrighted work calculated using an independent methodology developed by the JPX Market Innovation & Research, Inc.(“JPXI”), and the Nikkei Inc. (“Nikkei”) The JPXI and Nikkei own and maintain all intellectual property rights associated with the JPX-Nikkei Index 400 and its calculation methodology. Trademarks and other intellectual property rights associated with the emblems and logos representing the JPX Nikkei Index 400 belong to the JPXI and Nikkei.  All financial products listed in the materials are managed by pension trust service providers and so on under their own responsibility. The JPXI and Nikkei are not liable for the investment management and transactions of these products. The JPXI and Nikkei are under no obligation to provide the JPX-Nikkei Index 400 continually, and are not liable for any errors, delays and interruption in the release of the JPX-Nikkei Index 400. The JPXI and Nikkei maintain all rights in the selection of composites, calculation methodology, index modification and discontinuance of release. “JPX 日経 400” is an abbreviated form of the “JPX日経インデックス400” (the official Japanese name) and “JPX-Nikkei 400” is an abbreviated form of the “JPX-Nikkei Index 400” (the official English name).

Nomura Fiduciary Research & Consulting Co., Ltd.:

The intellectual property rights of  “NOMURA-BPI”, “NOMURA-BPI/Extended”, “NOMURA-BPI/Ladder ”, “NOMURA J-TIPS Index”, “NOMURA Par Yield”  including sub-indices belong to Nomura Fiduciary Research & Consulting Co., Ltd.. Nomura Fiduciary Research & Consulting Co., Ltd. does not guarantee the accuracy, integrity, reliability and utility of the index and is not responsible for the business activities and services associated with the index.

Nomura Fiduciary Research & Consulting Co., Ltd. and Frank Russell Company:

The intellectual property rights of the “Russell/Nomura Japan Index” belong to Nomura Fiduciary Research & Consulting Co., Ltd. and Frank Russell Company. Nomura Fiduciary Research & Consulting Co., Ltd. and Frank Russell Company do not guarantee the accuracy, reliability and utility of the index and are not responsible for the business activities and services associated with the index.

FTSE Fixed Income LLC and Nomura Securities Co., Ltd.:

The financial products on the materials are not in any way sponsored, endorsed, sold or promoted by FTSE Fixed Income LLC  (“FTSE FI”) or Nomura Securities Co., Ltd.(“Nomura”). All rights related to FTSE Nomura Carry and Roll Down World Government Bond Index (“the index”) belong to FTSE FI and Nomura. FTSE® is a registered trademark of the London Stock Exchange Group companies (“LSEG”) and is used by FTSE FI under license. Nomura and 野村 are registered trademarks of the Nomura and are its affiliated companies used by FTSE FI under license. The Index is calculated by FTSE FI or its agency. FTSE FI and Nomura are not liable for (a) use, credibility, or defect of the index, (b) investment in and manipulation of the financial instruments. No claims, forecasts, warranties or representations are made by FTSE FI or Nomura in respect of either the results obtained from the instruments or the suitability of the index for the merchantability of the instruments.

Solactive AG:

The financial instruments in the materials are not funded, promoted, sold or otherwise supported by Solactive AG. Solactive AG does not guarantee for the index, the index trademark, the index price at any point in time, or the result of any other use whether explicit or implicit. The index is calculated or published by Solactive AG. Solactive AG will try to make its best to calculate the accurate index. Notwithstanding the compulsory for index suppliers, Solactive AG is not liable to pointing for the mistakes of index for investors in the financial instruments or the third parties including financial intermediary. The publication of index, licensing of index for use in connection with such financial instruments and index trademarks by Solactive AG does not mean that Solactive AG recommends it and shows the any guarantee or opinion regarding any investments in such financial instruments.

Hedge Fund Research, Inc: Source:

Hedge Fund Research, Inc.www.hedgefundresearch.com, © 2022 Hedge Fund Research, Inc. All rights reserved. “The HFRI Fund Weighted Composite Index”, “WWW.HEDGEFUNDRESEARCH.COM”, “HFRI”, “HFR” are trademarks and service marks and are used under license from Hedge Fund Research, Inc (“HFR”). HFR is not affiliated or associated with Sumitomo Mitsui Trust Asset Management Co., Ltd. (“SMTAM”), its affiliates, or its financial products and funds. HFR does not participate in the creation or establishment of SMTAM’s financial products or funds, does not endorse or approve its financial products or funds, and does not recommend investing in its financial products or funds.

FTSE International Limited:

The financial products on the materials are not in any way sponsored, endorsed, sold or promoted by FTSE International Limited (“FTSE”), by the London Stock Exchange Group companies (“LSEG”) or by Global Wealth Allocation Limited (“GWA”) (together the “Licensor Parties”). None of the Licensor Parties make any warranty or representation whatsoever, expressly or impliedly, either as to the results to be obtained from the use of “FTSE GWA Japan Index”, “FTSE GWA Developed ex Japan Index（FTSE GWA Kaigai Index）including sub-indices ” (“Index”) and/or the figure at which the said Index stands at any particular time on any particular day or otherwise. The Index is compiled and calculated by FTSE. None of the Licensor Parties shall be liable (whether in negligence or otherwise) to any person for any error in the Index and none of the Licensor Parties shall be under any obligation to advise any person of any error therein. "FTSE®" is a trademark of LSEG and is used by FTSE under license.

BLOOMBERG and MSCI:

BLOOMBERG® is a trademark and service mark of Bloomberg Finance L.P.. MSCI is a trademark and service mark of MSCI Inc. (collectively, “MSCI” with its affiliates) and is used under license. Bloomberg Finance L.P. and its affiliates (collectively, “Bloomberg”), Bloomberg Index Services Limited(“BISL”) which is a user of the Index, or Bloomberg licensors including MSCI own all proprietary rights to the Bloomberg MSCI Global Aggregate Sustainability Index, its sub-indices, and its custom indices, etc. Bloomberg and MSCI are not affiliated companies of Sumitomo Mitsui Trust Asset Management Co., Ltd. (“SMTAM”) and do not approve, endorse, verify, or recommend any financial products on the materials. Both of Bloomberg and MSCI do not guarantee the timeliness, accuracy, and completeness of data and information relating to the Bloomberg MSCI Global Aggregate Sustainability Index and its sub-indices and its custom indices, etc nor does it have any liability for SMTAM, investors in financial products on the materials, and the other third parties regarding use of data and its accuracy contained in the Bloomberg MSCI Global Aggregate Sustainability Index and its sub-indices and its custom indices, etc.

S&P, Japan Exchange Group, and JPXI:

S&P/JPX Carbon Efficient Index (the “Index”) belongs to product of S&P Dow Jones Indices LLC (“SPDJI”), Japan Exchange Group, Inc. (“JPX”), and JPX Market Innovation & Research, Inc.(“JPXI”); and has been licensed for use by Sumitomo Mitsui Trust Asset Management Co., Ltd. (“SMTAM”). Standard & Poor’s® and S&P® are registered trademarks of Standard & Poor’s Financial Services LLC (“S&P”). Dow Jones® is a registered trademark of Dow Jones Trademark Holdings LLC (“Dow Jones”); and these trademarks have been licensed for use by SPDJI and sublicensed for certain purposes for use by SMTAM. JPX® is a registered trademark of JPX; and these trademarks are licensed for use by SPDJI and sublicensed for certain purposes for use by SMTAM. Index figures and a registered trademark of TOPIX are the intellectual property of JPXI and All rights relating to TOPIX, including the calculation of stock price indices, publication and use of index figures, know-how, all rights relating to the TOPIX trademark are maintained by the JPXI. The financial products on the materials are not endorsed, approved, sold or promoted by SPDJI, Dow Jones, S&P, their affiliates, JPX Group and JPXI, and none of these parties makes any representation regarding the advisability of investing in such products or assumes any liability for any errors, omissions, or interruptions in the Index.