SMBC Trust Bank Ltd. (the "Company" or "we") hereby discloses the summary of its Conflict of Interest Management Policy that it has adopted.
The purpose of its Conflict of Interest Management Policy is to appropriately manage conflicts of interest within the Company or the companies of the group to which the Company belongs (collectively, the "Group") so that the interests of a customer or customers of the Group (collectively, “Customer”) will not be unduly harmed.
The table below shows major types of "conflicts of interest" that we manage.
On the table, "Conflicts of Interest between Customer and the Group" refer to the circumstances where the Group has an interest independent of Customer associated with a particular transaction (less a relationship whereby the Group receives an economic interest as consideration for providing a product or service to Customer) and Customer's interest threatens to be unduly harmed because of the interest of the Group; and the "Conflicts of Interest between Customers" refer to the circumstances where an interest of Customer and that of another customer of the Group conflict as regards a particular transaction and Customer's interest threatens to be unduly harmed because of another customer's interest.
|Major Types||Conflicts of Interest between Customer and the Group||Conflicts of Interest between Customers|
|Direct Transaction||A situation or status where Customer and the Group are direct parties of a transaction involving a conflict of interest.||A situation or status where Customer and another customer of the Group are direct parties to a transaction involving a conflict of interest.|
|Indirect Transaction||A situation or status where Customer and the Group have mutually-exclusive or competing interests.||A situation or status where Customer and another customer of the Group have mutually- exclusive or competing interests.|
|Use of Information||A situation or status where the Group is structurally able to gain its own benefit by using non-public information that the Company obtained from Customer.||A situation or status where the Group is structurally capable of having another customer of the Group gain a benefit by using non-public information that the Company obtained from Customer.|
In order to appropriately manage conflicts of interest, the Company specifies the transactions that threaten to cause conflicts of interest (the "Transactions to Manage") in the following ways:
We manage the Transactions to Manage by appropriately selecting a method from (1) to (3) below or by other methods, or appropriately combining them in accordance with the details and extent of specific conflicts of interest:
The Company sets up a department to control conflicts of interest independent of its business units, and the department centrally identifies and manages the Transactions to Manage. Further, the Company, in collaboration with other companies of the Group, builds a framework necessary for appropriate conflict-of-interest management, including raising the awareness of the officers and employees of the Company through training and education. In addition, the Company regularly reviews the framework.
The transactions conducted by the Company and the following companies of the Group are the Transactions to Manage by the Company.
※Please refer to Article 13-3-2 of the Banking Act and Article 36, Paragraphs 2 through 5 of the Financial Instruments and Exchange Act.