This Code of Business Conduct and Ethics for Deutsche Bank Group describes the values and minimum standards for ethical business conduct that we expect all of our employees to follow and that guide all of our interactions with internal and external stakeholders.

This Code of Business Conduct and Ethics for Deutsche Bank Group

Deutsche Securities Code of Ethics

Deutsche Securities Inc. (the “Company”), as a member of the Deutsche Bank Group, is entrusted with the responsibility as a leader and intermediary in the capital markets for the investment and procurement of funds in the Japanese national economy. Each and every director, officer or staff member of the Company, fully understanding the foregoing, shall act in accordance with the Identity and Mission of the Deutsche Bank Group, and shall make tireless efforts to improve him- or herself in order to at all times maintain the sound common and ethical sense required to be a trusted professional by the Japanese public, as well as to provide requested professional services.
Furthermore, directors, officers and staff of the Company shall respect each other in the spirit of good citizenship in Japan, and shall reject and prevent all discriminatory remarks and all types of harassment based on nationality, race, sex, age, creed, religion, social status, or disability.
To achieve the foregoing, the Company hereby adopts the Code of Ethics to provide guidance to its directors, officers and staff in performing their respective duties, and declares its compliance.

Code of Ethics

1. Compliance with laws, regulations and rules, as well as social norms
We shall correctly understand and strictly comply with all rules relating to financial instruments transactions, including laws and regulations to protect investors and ensure fairness of trading, and we shall, in conformity with generally accepted social norms, maintain and enforce the common and ethical sense necessary to properly handle matters not foreseen by any law, regulation or rule.

2. Proper management of conflict of interest
We shall properly manage all conflicts of interest arising in connection with the Company's operations. We shall not gain any unjust profit by utilizing information which becomes available to us by reason of any status, authority or professional duty.

3. Confidentiality and information management
We shall take meticulous care in managing information which comes to our knowledge in the course of performing our professional duties and shall safeguard the confidentiality of such information, except for any information the disclosure of which is legally required in accordance with laws, regulations, and internal rules governing information disclosure.

4. Maintenance of social order and implementation of social contributions
As a good corporate citizen, we shall actively participate in social activities and contribute to the stability and maintenance of social order. We shall take a resolute stand against groups and organizations engaged in anti-social activities and shall never transact with any such groups or organizations.

5. Action with a high regard for customer interests
We shall fully comprehend the investment knowledge and experience, assets, and investment purposes of each of our customers and, judging based upon the foregoing factors, shall at all times act for the best interests of each of our customers.

6. Good-faith and fair performance of duties with due regard to the customer position
As an intermediary in the capital markets, we shall always emphasize the needs and interests of our customers, and shall perform our duties fairly and in good faith with due regard to the position of each of our customers.
We shall not treat particular customers preferentially by utilizing our authority or position at the Company or information available within the Company which would give a comparative advantage. We shall commit ourselves to transactions based on proper solicitation and self-judgment by our customers so as to establish the principle of self-responsibility.
Should fiduciary responsibility arise on the basis of an agreement entered into with a customer, we shall at all times act in good faith with respect to the customer’s interests.

7. Advisory activities for customers
When we advise our customers relating to their investments, we shall render advice distinguishing clearly between facts and views and making full use of our professional abilities.
In compliance with relevant laws, regulations and rules, we shall not provide advice to customers on the basis of “inside information” or any other non-public information which would reasonably affect the value produced by an investment.

8. Behavior in the capital markets
As for any behavior which is not prohibited or regulated by any law, regulation or rule but may be deemed questionable in light of the social conventions or the standards applicable to the intermediary in the capital markets, we shall judge whether it is right or wrong in accordance with this Code of Ethics, the Code of Conduct, and other Company internal rules and procedures.
In compliance with relevant laws, regulations and rules, we shall properly control and manage inside information and other non-public information which would reasonably affect the value produced by an investment.

9. Self-awareness of social mission and maintenance and improvement of the soundness and reliability of the capital markets
We shall appreciate the importance of fairness and soundness as to the capital markets, and shall not engage in any activity which might hinder the sound development of the capital markets. In addition, we shall, by endeavoring to maintain the soundness of the capital markets, realize our imperative social mission to be carried out and act accordingly.
We shall not engage in any improper behavior that might result in the loss of customer trust in the Company or undermine the soundness of the capital markets, such as failure to disclose information in a proper and timely manner or involvement in any activity which may thwart fair price formation.