Mitsubishi UFJ Morgan Stanley Securities

This policy stipulates the policy and methods for the best execution of transactions to benefit our customers in accordance with the provisions of Article 40-2, Paragraph 1 of the Financial Instruments and Exchange Act (“FIEA”).
When we receive orders from our customers to trade securities listed on financial instruments exchange market in Japan, we will endeavor to execute such orders in accordance with the following policy unless we receive any other specific instructions from the customer.

	(1)	The“Listed Securities, etc”as defined in Article 16-6 of the Financial Instruments and Exchange Act Enforcement Order, including but without limitation, stocks, corporate bonds with stock acquisition rights, ETF, and REIT listed on financial instruments exchange market in Japan; and
	(2)	The“Over-the-Counter Handled Securities”(Toriatsukai Yuka Shoken) as defined in Article 67, Paragraph 18, Item 4 of the Financial Instruments and Exchange Act, including but without limitation, Green Sheet issues, Phoenix issues and corporate bonds with stock acquisition rights, etc.


	We will execute orders from customers in the following manners;

	(1) Listed Securities, etc.

	(The customers, who are dealing with branch offices) An order received from the customers for Listed Securities etc. shall be forwarded to the financial instruments exchange as an order, and we will not engage in off-exchange transactions, nor will we forward an order to PTS (Proprietary Trading System).

(i)	When we receive an agency order from our customers, the order will be promptly forwarded to the financial instruments exchange in Japan where the relevant issue is listed. For an agency order received after trading hours of the exchange, the order will be placed on the exchange after reopening of the exchange.
(ii)	The agency order in (i) shall be forwarded to financial instruments exchange in the following manners:

(a)	If the relevant issue is listed only on a single exchange (the “Single Listing”), then the order shall be forwarded to that financial instruments exchange.
(b)	If the relevant issue is listed on multiple financial instruments exchanges (the” Multiple Listing”), then the order received shall be forwarded to the financial instruments exchange () which displays its stock price information first when the security code of the security is entered into a terminal of QUICK Corp. at the time of execution. ()Such financial instrument exchange is selected because it has the largest trading volume for a certain period according to QUICK's stipulated computation method. With regard to the security, which was listed on multiple financial instruments exchanges from the initial listing, the exchange is selected according to the market ranking, which we specified beforehand. Customers could contact our branch offices for details.
(c)	With regard to those foreign securities listed both on domestic financial instruments exchange and overseas financial instruments exchange:we will forward the purchase order to a major financial instruments exchange, and we will forward the selling order to a listed domestic financial instruments exchange if such securities is in commingled custody in domestic custodian, and to an overseas major financial instruments exchange if it is in commingled custody in overseas custodian. Selected major financial instruments exchanges are posted on our website (www.sc.mufg.jp or http://www.mumss.com). Customers could also contact our branch offices for details.
(d)	With regard to the order with certain expiration date, we will place and execute the order in the exchange which is selected when we receive the order until the expiration date. Customers could contact our branch offices if customers would like to find out the specific exchange which the order is placed or if customers would like to change the exchange to execute the order.
(e)	With regard to the standardized margin transaction, the reversing trade shall be executed at the same exchange where original trade was executed.

(The customers, who are dealing with the Global Markets Business Unit*)

*	When the above Unit is changed by reorganization or for other reasons in the future, such changes will be notified by posting the information on our website (www.sc.mufg.jp or http://www.mumss.com).

An order received from the customers for Listed Securities etc. for Stocks, ETF, REIT shall be forwarded to the financial instruments exchange as an order, and we will not engage in off-exchange transactions, nor will we forward the order to PTS. An order received from the customers for other Listed Securities etc., we will become the direct counterparty for the order if possible, otherwise we shall consult with customers each time on how to execute the orders.

(i)	When we receive an agency order of Stocks, ETF and REIT from our customers, the order will be promptly forwarded to the financial instruments exchange in Japan where the relevant issue is listed. For a commissioned order received after trading hours of the exchange, the order will be placed on the exchange after the reopening of the exchange.
(ii)	The agency order in (i) shall be forwarded to financial instruments exchanges in the following manners:

(a)	If the relevant issue is listed only on a single exchange (the”Single Listing”), then the order shall be forwarded to that financial instruments exchange.
(b)	If the relevant issue is listed on multiple financial instruments exchanges (the ”Multiple Listing”), then the order received shall be forwarded to the financial instruments exchange() which displays its stock price information first when the security code of the security is entered into a terminal of QUICK Corp. at the time of execution. ()Such financial instrument exchange is selected because it has the largest trading volume for a certain period according to QUICK's stipulated computation method. With regard to the security, which was listed on multiple financial instruments exchanges from the initial listing, the exchange is selected according to the market ranking, which we specified beforehand. Customers could contact our sales divisions in charge for details.
(c)	With regard to the standardized margin transaction, the reversing trade shall be executed at the same exchange where original trade was executed.

	(2) Over-the-Counter Handled Securities (Green Sheet issues, Phoenix issues)

We will not, in principle, accept orders for Over-the-Counter Handled Securities, except Securities, which we have reported to JSDA. However, if we have received selling orders from customers for such securities that are specified as Phoenix Issues, a category for the issues delisted by financial instruments exchanges, we forward such orders to financial instruments dealers that solicit investment in such securities. If only a single financial instruments dealer solicits investment in the security, we forward the orders to such financial instruments dealer. If there are two or more of such financial instruments dealers, we forward the orders to the financial instruments dealer that publishes the quotation most favorable to the customer among those financial instruments dealers that publish their current quotation as of the time we forward such orders. Please note that we may not be able to accept orders for certain securities. The securities which we have reported to JSDA are posted on our website (www.sc.mufg.jp or http://www.mumss.com).Customers could also contact sales divisions in our Head Quarter for details.


	(1) Listed Equities, etc.

Most of the investors' demand is concentrated on financial instruments exchanges where there is more liquidity, higher execution probability and higher trading speed as compared with off-exchange transactions. We therefore believe that it is the most reasonable for customers to execute orders in these financial instruments exchange. Furthermore, when the relevant issue is listed on multiple exchanges, we also believe that it is the most reasonable for customers to execute orders in the financial instruments exchange that has the highest liquidity.

With regard to orders from customers who are directly dealing with the Global Markets Business Unit in our Head Quarter are generally in large amount, for listed securities other than stocks, ETF and REIT which have a sufficient liquidity in the market, we believe that it is the most reasonable method for customers that we act as the direct counterparty in consideration of the execution probability and higher trading speed.

	(2) Other Allowed Equity Securities (Toriatsukai Yuka Shoken)

We will not, in principle, accept orders for such securities which we have not reported to JSDA. However, as to the securities specified as Phoenix issues, a category for the issues delisted by financial instruments exchanges, we believe that it is necessary to promptly respond to the cash conversion needs of customers who have been holding such securities since the time they were listed. Forwarding selling orders from customers to the financial instruments dealers soliciting investment in these securities, to which orders tend to be brought intensively, is considered important to secure more execution opportunities and increase the likelihood of satisfying customers' needs.

(1)	The following transactions may be executed by the methods set forth below instead of the methods provided in (2).

(i)	Transactions where specific instructions for executions are received from customers (e.g. the customer's preference for us to enter into a principal trade as a direct counterparty; the customer's preference on a financial instruments exchange on which the order is executed; the customer's preference on the timing of trade to take place etc): These transactions may be executed by the method instructed by the customer.
(ii)	Transactions under a discretionary investment agreement, etc.: These transactions may be executed by the method of our choice within the range of discretion permitted under the agreement.
(iii)	Trades whose execution method is specified by the general trading terms and conditions, etc.: The execution method specified by the general trading terms and conditions, etc.
(iv)	Trading in fractional shares and less-than-unit shares: These orders may be forwarded to financial instruments dealers that handle fractional shares and less-than-unit shares.

(2)	We may inevitably execute orders by a method different from the Policy due to system disruptions or other circumstances if we believe that another method to be the best one at the time.

The best execution obligation is the obligation to execute orders by taking into consideration not only the price but also the cost, the speed, the probability of execution and other various factors in a comprehensive manner.
Therefore, the mere fact that our execution may not result in the best price will not necessarily constitute a breach of such obligation.

May 1st 2010 ( Amendment )