When soliciting customers, the Company shall comply with the Commodity Derivatives Transaction Act and related laws, regulations and rules, and shall make appropriate solicitations for foreign commodity market transactions and over-the-counter(OTC) commodity derivatives transactions in accordance with the following policy, with the primary aim of securing the trust and confidence of its customers.

1. Customers to be solicited

Customer to be solicited are limited to firms, business corporations, institutional investors and other legal entities with risk hedging needs for the commodity markets offered by the company, and not individual investors.
The services performed by the company and Toyota Tsusho Metals Limited (TTM) are intended for corporate customers who meet the criteria for Professional Client or Elective Professional Client according to the category rules of the EU’s Markets in Financial Instruments Directive (MiFID).


Notes: For information on the content of the Client Category Rules, please contact us directly. Please note if you do not meet these criteria, we may refuse to open an account.

2.Matters to be considered in light of the knowledge, experience, and financial situation of the customer to be solicited

After strictly screening whether the principle of suitability is met, the company and Toyota Tsusho Metals Limited will carry out account opening for customers who have been recognized as being solicited by the above. Specifically, based on the customer profile filled out by the customer, the Company conducts screening to open an account with TTM, the parent company, based on the company name, address, financial situation, purpose of use of futures trading, and trading experience such as commodity futures trading.


The Company(TTMJ):Negotiation with the customer (guidance of necessary documents, communication of contents and other questions from TTM, etc.). Identity verification (conducted in a manner that also meets UK regulations) and independent suitability screening.
Creation of client information cards. Among the screening operation performed by TTM, the intermediary of credit application documents submitted by TTM to the Investment and Credit Department of Toyota Tsusho Corporation, which is entrusted with credit screening operations.


Toyota Tsusho Metals Ltd (TTM): Screening of the relevant categories of customers under the UK Financial Conduct Authority and the MiFID Regulation, the implementation of suitability screening in accordance with UK regulations, the preparation and drafting of credit applications

3.Matters to be considered for the customer subject to solicitation regarding the method and time of solicitation

The Company’s solicitation methods for foreign commodity market transactions and OTC commodity derivatives transactions shall be through introductions from Toyota Tsusho Group Companies and its counterparties, or by providing information on products and services handled through the Company’s website, e-mail, trade journals and other media, holding seminars, etc., and by providing information to help customers make a decision to deal with such products and services. The Company shall only make a solicitation when a request for solicitation from a customer is accepted. The Company shall give due consideration to the time and method of solicitation so as not to disturb customers.

4. Other matters related to ensuring the appropriateness of solicitation

The Company will comply with the Commodity Derivatives Transaction Act, etc., and the rules of The Commodity Futures Association of Japan, and will strive to strengthen its internal management system to ensure appropriate solicitation. The Company’s officers and employees shall always strive to acquire and improve knowledge and skills so as not to betray the trust and expectations of customers.

Formulated in April 2013
Revised in September 2023