JPMorgan Chase Bank, N.A., Tokyo Branch

Summary of Conflicts of Interest Management Policy

JPMorgan Chase Bank, N.A., Tokyo Branch
Enactment Date: 1 June, 2009

J.P. Morgan Group ("J.P. Morgan") (of which JPMorgan Chase Bank, N.A., Tokyo Branch (the "Company") is a part of) runs businesses in Japan such as investment banking business, cash settlement business, asset management business and intermediary of global custody business which establishes a system to provide our customers with the most appropriate service to meet their various kinds of needs.  In connection with the deregulation of firewall regulations, which prohibit holding the concurrent post in a bank and a securities company, J.P. Morgan will make every effort to increase the level of management of transactions that may unjustly impair the interests of our customers ("transactions that may cause conflicts of interest") as well as improve service further.  The Company has established the internal policy, etc. with the purpose of identifying and managing "transactions that may cause conflicts of interests" between J.P. Morgan and its customers, or between its customers, the outline of which is laid out below.

1. Types and Criteria of Transactions That May Cause Conflicts of Interest

The following examples may be considered as types of "transactions that may cause conflicts of interests."  However, these types are only criteria to determine whether there is any "transaction that may cause any conflict of interests," related to the customers who should be protected or not.  Therefore the satisfaction of any of these criteria does not necessarily mean a "transaction that may cause a conflict of interests" has occurred and there may also be cases not listed here which will need to be managed as transactions as "transaction that may cause a conflict of interests."  Also, please note that some additions or modifications of these types and criteria of transactions may be made in the future as necessary.

Examples of Abuse of Customer Information Type: A case where J.P. Morgan or other customers of J.P. Morgan, based on information gained from or through J.P. Morgan, conducts a transaction of securities on the proprietary account using information regarding the securities transactions of customers who should be protected.

Examples of Breach of Duty Type: A case where J.P. Morgan, or other customers with the help of J.P. Morgan, considers an acquisition of a target company which other customers of J.P. Morgan, who should be protected, are considering acquisition.

Examples of Conflict of Interest Type: A case where J.P. Morgan or other customers with the help of J.P. Morgan conducts a transaction of securities or financial instruments with customers of J.P. Morgan who should be protected.

Examples of Others Type: A case where J.P. Morgan makes a transaction of securities issued by another company, while J.P. Morgan is hiring said other company’s officers or any other employees who are in a position that they can influence the management policy decisions of the company.

2. Conflicts of Interest Management System

The Company has established separate from the Sales Department the Conflicts of Interest Management Control Division and the Conflicts of Interest Management Control Supervisor in the Legal Division and the Compliance Division to carry out the appropriate conflicts of interest management.  Both of them will collect transaction information of the “Scope of the Companies Covered by Conflicts of Interest Management”, as described below, or any other information as needed, and also identify and manage transactions that may cause conflicts of interest in an integrated fashion.

3. Method of Managing Transactions That May Cause Conflicts of Interest

The Company, with respect to the management of conflicts of interest, has by appropriately managing customer information by complying with laws / regulations and the various internal rules and the separation of departments and Segregation of Duties established a system of preventing transactions that may cause conflicts of interest from occurring. For example, in the case that the Company acts as an intermediary in a sale of a financial instrument with a customer in principle the Company will share such customer’s information only to the extent that the Company will need to share it to carry out the business described above because the Company has established the information barrier and the Company will not convey said information to any principal investment division.  Also, the Compliance Division monitors the compliance situation to make these regulations work effectively and the Company prevents transactions that may cause conflicts of interests.

Furthermore, in the case that the Company identifies any transaction that may cause a conflicts of interest, the Company will manage the transaction in order not to unjustly impair the interests of customers by selecting from any one, or combination, of the following methods or any other methods that might not be listed (the following methods are only examples, and the following measures need not be adopted):         

4. Scope of the Companies Covered by Conflicts of Interest Management

On the basis of the Financial Instruments and Exchange Act, in Company transactions which involve JPMorgan Securities Japan Co., Ltd. and JPMorgan Asset Management (Japan) Limited as well as the Company are intended to manage conflicts of interests.  In principle, the Company and JPMorgan Asset Management (Japan) Limited will not share non-public information between them, so they will manage information by way of regulating the share of information between them through use of the information barrier.  Also, the transactions which involve foreign affiliates of J.P. Morgan other than those which do not engage in Financial Instruments Business and Bank business are intended to manage conflicts of interest.

If you have any questions, feel free to contact with responsible employees. 


Amended as of February 1, 2010:
Added Prima Investment YK as the Scope of the Companies Covered by Conflicts of Interest Management.

Amended as of April 1, 2011:
Deleted J.P. Morgan Worldwide Securities Services Japan, Ltd. from the Scope of the Companies Covered by Conflict of Interest Management due to the merger with JPMorgan Securities Japan Co., Ltd.

Amended as of September 11, 2012:
Amended in accordance with the reorganization of the Legal and Compliance Division into the Legal Division and the Compliance Division.

Amended as of August 11, 2014:
Changed J.P. Morgan Finance Japan YK into J.P. Morgan Finance Japan GK, based on its organization change.

Amended as of October 1, 2014:
Amended in accordance with absorb-type merger of Prima Investment YK into J.P. Morgan Finance Japan GK.

Amended as of February 1, 2015:
Amended in accordance with absorb-type merger of J.P. Morgan Finance Japan GK into JPMorgan Securities Japan Co.,Ltd.

Amended as of August 1, 2018:
Amended to reflect the changes of terms, etc..

 

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