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- Conflicts of Interest Policy
Conflicts of Interest Policy
Purpose
- The Company has established the “Conflicts of Interest Management Policy” for the objective of properly managing transactions that may unfairly impair the interests of clients. To achieve this objective, the Company has put in place an internal system, and defined appropriate methods to manage conflicts of interest in advance as well as the responsibilities of the person in charge of managing conflicts of interest.
Identifying and categorizing transactions that are applicable to management of conflicts of interest
- Whether or not a transaction is subject to the conflicts of interest management policy shall be determine on the basis of specific individual circumstances. However, any transaction specified as below may be considered as a transaction that may cause conflicts of interest.
| Client vs. the Company | Client vs. Client | |
|---|---|---|
| Conflict of interest | Conflict where the Company’s interests may be opposed to one or more clients’ interests | Conflict where a client’s interests may be opposed to one or more other clients’ interests |
|
Competitive transaction |
Conflict where a client and the Company compete for the same Target | Conflict where a client and other clients compete with each other |
| Information usage | Transaction where the Company benefits from the use of information obtained through its relationship with a client | Transaction where a client benefits from information obtained by the Company through its relationship with other clients |
The following are typical examples that need to be managed as "transaction that may cause conflicts of interest.“
●Transactions which involve M&As
●Transactions which involve collective investment schemes
Method of managing transactions that may cause conflicts of interest
- In the case where any transaction that may cause a conflict of interest is identified, the Company will manage it by selecting from any one of, or in combination with, the following methods.
(1) Amend either the conditions or method of transaction, or both.
(2) Discontinue the transaction.
(3) Establish the information barrier protocol which is designed to prevent exchange of information or communication within the organization that could lead to conflicts of interest.
(4) Obtain the consent from the client.
(5) Disclose to the client and related parties the possibility that the interests of such client may be unjustly impaired in connection with the transaction.
Conflicts of interest management system
- The Company has developed a specific method for managing conflicts of interest as its " Code of conflicts of interest.” The Company designates the head of the Legal and Compliance Division as the conflicts of interest management supervisor who will oversee and perform the company-wide conflicts of interest management.