日本語

Crédit Agricole Securities Asia B.V., Tokyo Branch

With the diversification of services provided by financial institutions and the development of global financial conglomeratization, multiple competing and conflicting interests within a financial institution or financial group exists, which increases the possibility of conflicts of interests.

Under such circumstances, Credit Agricole Securities Asia B.V., Tokyo Branch (the "Branch") has established the Conflict of Interest Management Policy (this "Policy") to manage the transactions that may cause conflicts of interest(“Covered Transactions”) in order to prevent the interests of our customers from being unjustly impaired. The Branch hereby inform you the outline of the Policy.

The Covered Transactions means such transactions conducted by the Branch and/or any of Companies defined as below that may unjustly impair the interests of our Customers.　However, these are only criteria to determine whether there is any Covered Transactions. Please note that fitting these criteria does not necessarily mean the occurrence of a Covered Transactions. Also, please note that some additions or modifications may be made in the future as may be necessary.

・ If any Customer reasonably expects that his/her own interests will be prioritized through counseling or advice (Duty-of-Loyalty Type);
・ If the Branch or Covered Companies as defined below may obtain any economic profit or avoid any economic loss at the expense of any Customer (Duty-of-Loyalty Type);
・ If the Branch or Covered Companies obtains or will obtain any incentive in the form of money, goods or services other than the usual commission fees or expenses in connection with the transactions with any person other than their Customers (Duty-of-Loyalty Type);
・ If the Branch or Covered Companies conducts any transaction with any Customer who should be protected by the Branch or such Affiliate (Self-Agency Type);
・ If the Branch or Covered Companies conducts any transaction under which the Branch or such Affiliate takes the side of the counterparty of any Customer who should be protected by the Branch or such Affiliate (Two-Side Agency Type);
・ If the Branch or Covered Companies conducts any transaction with the counterparty of any Customer who should be protected by the Branch or such Affiliate, which counterparty competes with such Customer (Competitive Transaction Type);
・ If the Branch or Covered Companies conducts any transaction through the use of non-public information on any Customer who should be protected by the Branch or such Affiliate, which transaction results in any benefit to the Branch or any such Affiliates (Information Use Type); or
・ If the conditions for similar transactions may not be expected due to the involvement of the Branch or Covered Companies in the same transaction on multiple sides (Transaction-Internalization Type).

In addition, upon determining whether any conflict of interests exists, the Branch will consider whether any impact upon the reputation of the Branch or Crédit Agricole Group.

Conflict of interest management applies to the transactions which involve with the Branch and following companies (“Covered Companies) under the Financial Instruments and Exchange Act.

・ Crédit Agricole Corporate and Investment Bank, Tokyo Branch
・ Amundi Japan Ltd.
・ Crédit Agricole Life Insurance Japan Ltd.
・ Crédit Agricole SA
・ Crédit Agricole Corporate and Investment Bank
・ Any other foreign affiliates to involve Covered Transactions

Once identifying Covered Transactions, the Branch will properly secure the protection of our Customers by selecting from any of, or combining, the following or any other methods (the following are only examples, and these measures may not always be adopted):

・ By separating the division conducting the Covered Transaction, and the division conducting the transaction with such Customer;
・ By amending the conditions or method of the Covered Transaction or the transaction with such Customer;
・ By discontinuing the Covered Transaction or the transaction with the Customer; and/or
・ By properly disclosing to the Customer the possibility that the interests of such Customer may be unjustly impaired in connection with the Covered Transaction (only if such disclosure does not violate the duty of confidentiality assumed by the Branch or Covered Companies).

Compliance Department shall engage as the Conflicts of Interest Management Control Division. Compliance Department shall collect necessary information of the Covered Companies, identify and manage any Covered Transaction in the integrated function independently from the relevant business divisions.