Policy for Conflicts of Interest Management
Mitsubishi UFJ Financial Group ("MUFG") and its subsidiaries and affiliates (collectively, "MUFG Group") shall establish the following policy for conflicts of interest management and take all necessary actions to ensure all officers and employees to comply with the policy and not to falsely harm clients' interest and materialize customer–oriented business conduct based on MUFG Basic Policy for Fiduciary Duties.
Chapter 1 Conflicts of Interest
1. Conflicts of Interest
A conflict of interest means the situation where an MUFG Group's client's
interest conflicts with MUFG Group's or one MUFG Group's client's interest conflicts
with other MUFG Group's clients'.
While such conflicts of interest occur on a day-to-day basis as a result of conglomerations of financial institutions and diversification of financial trading, MUFG Group shall establish appropriate business management and compliance system to prevent adverse effects from conflicts of interest within the Group.
Chapter 2 Conflicts of Interest Management based on Banking Act, Financial Instruments and Exchange Act, and Others
1. Identifying Transactions with Potential Risk of Adverse Effects from Conflicts of Interest
MUFG Group shall identify in advance businesses, which require special management ("Managed Businesses"), from businesses in the following situations. MUFG Group shall intensively manage transactions with potential risk of adverse effects from conflicts of interest in performing the Managed Businesses, taking into consideration reputation risk.
(1)Situations where a client reasonably expects MUFG Group to prioritize the client's best interest (e.g. advisory service)
(2)Situations where MUFG Group could inappropriately benefit in the market using information obtained from transactions with clients
(3)Situations where high reputation risk resulting from transactions between MUFG Group and clients could arise
Examples for Managed Businesses include:
- M&A advisory
- Securitization of Assets/Receivables
- Loan Syndication
- Principal Investment
- Equity and Debt Underwriting
- Bond Management
2. Companies with Requirement for Conflicts of Interest Management
MUFG Group companies conducting Managed Businesses shall be required
to develop appropriate management system for conflicts of interest.
Examples of companies with requirement for conflicts of interest management include:
- The Bank of Tokyo-Mitsubishi UFJ, Ltd.
- Mitsubishi UFJ Trust and Banking Corporation
- Mitsubishi UFJ Morgan Stanley Securities Co., Ltd.
- kabu.com Securities Co., Ltd.
- The Chukyo Bank, Ltd.
3. Management System for Conflicts of Interest
MUFG Group shall centralize the management of conflicts of interest
by establishing divisions responsible for management and control of conflicts
of interest at each company under a legal duty to establish management system
for conflicts of interest.
MUFG Group shall comply with applicable laws and regulations related to conflicts of interest and maintain appropriate management for conflicts of interest.
4. Measures for Management of Conflicts of Interest
With the following measures MUFG Group shall prevent adverse effects from conflicts of interest issues and avoid falsely damaging clients' interest.
(1)Separating a division/company conducting a transaction with potential risk of adverse effects by conflicts of interest from other divisions/companies
(2)Changing the conditions/methods of either/both transactions with potential risk of adverse effects by conflicts of interest
(3)Terminating either one of transactions with potential risk of adverse effects by conflicts of interest
(4)Notifying clients of potential risk of adverse effects by conflicts of interest
Chapter 3 Conflicts of Interest Management based on MUFG Basic Policy for Fiduciary Duties
MUFG Group shall manage conflicts of interest properly with the following items under 4. Provision of line of products to meet customers’ diverse needs and 5. Sophistication of investment for the improvement of customers’ investment results from MUFG Basic Policy for Fiduciary Duties.
(1)Selection of products that contribute to customers’ asset building and provision of sales procedures
(2)Ensuring independence and transparency of investment management
Examples of companies with requirement for practice under MUFG Basic Policy for Fiduciary Duties include:
The Bank of Tokyo-Mitsubishi UFJ, Ltd., Mitsubishi UFJ Trust and Banking Corporation, Mitsubishi UFJ Morgan Stanley Securities Co., Ltd., Mitsubishi UFJ Morgan Stanley PB Securities Co., Ltd., kabu.com Securities Co., Ltd., Mitsubishi UFJ Kokusai Asset Management Co., Ltd., The Master Trust Bank of Japan, Ltd., and MU Investments Co., Ltd.