Japan

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State Street Bank and Trust Company, Tokyo Branch

Privacy Policy

State Street Bank and Trust Company, Tokyo Branch (the “Bank”) hereby establishes this policy regarding the appropriate protection and use of personal information and anonymously processed information (hereinafter collectively referred to as “Personal Information, etc”) in accordance with the “Personal Information Protection Act (Law No. 57 of 2003) of Japan,” thereby taking all possible measures to ensure the protection of your personal information.

1. Compliance with Laws and Regulations
The Bank hereby declares that the Bank will comply with any and all laws, regulations and other requirements, and matters set out in this Declaration in relation to the appropriate protection and use of personal information.

2. Purposes of Use of Personal Information
The Bank shall identify the purposes of use of your personal information in advance. The notice of our purposes of use is posted at the office of the Bank.

The Bank shall never use your personal information without your consent for purposes other than those specified in advance, unless otherwise required by any law or regulation.

The Bank will suspend the use of your personal information for direct mail, telemarketing or other direct marketing, if you request us to do so. If you do not wish that the Bank uses your personal information for direct marketing, please call the contact center described in 8 below.

3. Acquisition and Provision of Personal Information
The Bank shall acquire your personal information via lawful and fair means to the extent necessary to achieve the specified purposes of use. In addition, except under exceptional circumstances, such as requirement by any law or regulation, the Bank shall not acquire, use or provide to third parties any sensitive information. The Bank will not acquire, use, or provide to third parties any special required personal information that is specified by law without your consent.

The Bank shall not provide your personal information to third parties without your prior consent, unless otherwise required by any law or regulation.

If the Bank outsources the handling of personal information, the Bank shall select the person whom the Bank considers appropriately handles personal information, and exercise the necessary and appropriate supervision over such person.

When providing Personal Data to a third party in a foreign country, the Bank shall, in principle, obtain your consent, except for cases permitted under the laws and regulations. However, with respect to entrustment and shared use of Personal Data between the Bank and affiliate companies (hereinafter referred to as “group affiliate companies”) of the Bank’s parent company, State Street Corporation (hereinafter referred to as “SSC”), such entrustment and shared used between the Bank and the group affiliate companies are allowed without your consent, provided that the Bank admits that such group affiliate companies satisfy the standards set forth under Article 24 of the Law.

4. Disclosure and Other Procedures
Upon receiving request from you for disclosure, correction, or suspension of use of the personal data held by the Bank (the “Disclosure etc.”) pursuant to laws and regulations, the Bank will appropriately and promptly respond to such request by asking for your identification. To request the Disclosure etc. of personal data held by the Bank, please call the contact center described in 8 below.

5. Security Management Measures
The Bank will implement the security management measures necessary and appropriate to prevent illegal access, loss, destruction, falsification, leakage, or other unauthorized use of your personal information.

6. Complaint Handling
Upon receiving complaints concerning the handling of personal information, the Bank will appropriately handle such complaint by the prompt investigation of the facts.

7. Efforts for Continual Improvement
The Bank will strive for continual improvement in handling personal information (including security management measures), such as reviewing as needed.

8. Contact Center
For inquiries, counseling or complaints regarding the Disclosure etc. of personal data held by the Bank or handling of personal information, please call the following Department:

Contact center for personal information: Compliance and Risk Department:
Phone: +81-3-4530-7690
Service Hours: 9 a.m.-5 p.m. (Monday-Friday, except public holidays and other bank holidays)

Authorized information protection organizations to which the Bank belongs:
The Bank is a member firm of the All Banks Personal Data Protection Council, an authorized information protection organization in the financial field. The Complaints Counseling Services Center of the All Banks Personal Data Protection Council (bank transaction counseling center) receives complaints and gives counseling regarding the handling of personal information by member firms.

All Banks Personal Data Protection Council: http://www.abpdpc.gr.jp

(Complaints and Counseling) phone number: +81-3-5222-1700 or your nearest bank transaction consulting center.

Conflict of Interest

1. Purpose
As the services provided by financial institutions become increasingly more diverse, and the development of global financial conglomerization continues to take place, the possibility increases for multiple interests competing or conflicting with each other within financial institutions or financial groups, thereby raising concerns over potential conflicts of interest.

Under these conditions, State Street Bank and Trust Company, Tokyo Branch (State Street Bank and Trust Company shall be referred to as “Bank” and State Street Bank and Trust Company, Tokyo Branch shall be referred to as “Branch” hereinafter) must manage transactions that involve possible conflicts of interest to ensure that the interests of its customers are not unduly harmed.

In keeping with its status as a branch of a foreign bank under the Banking Act, the Branch has formulated the Conflicts of Interest Management Principles (hereinafter referred to as “Principles”) as part of its mandate under the aforesaid law to develop and maintain a system for the management of conflicts of interest.

2. Patterns of Transactions Involving Possible Conflicts of Interest, and the Process of Identifying Such Transactions
(1) Covered Transactions
“Transactions Involving Possible Conflicts of Interests,” which are covered under the Principles, refer to transactions entered into by the Branch, the Bank (excluding the Branch), any Parent Financial Institution, Etc. (as defined in Numbered Item 3 below) or Subsidiary Financial Institution, Etc. (as defined in Numbered Item 3 below) of the Bank that may unduly harm the interests of customers (such transactions shall be hereinafter referred to as “Covered Transactions”).

Conflicts of interest may occur (1) between (i) the Branch, the Bank (excluding the Branch), or any Parent Financial Institution, Etc. or any Subsidiary Financial Institution, Etc. of the Bank and (ii) their customers; (2) between (i) customers of the Branch, the Bank (excluding the Branch), banking agents who are principally affiliated with the Branch, any Parent Financial Institution, Etc. or Subsidiary Financial Institution, Etc. of the Bank and (ii) other customers.

“Customer” means, in relation to the “Banking-Related Operations” (as defined below) carried out by the Branch, the Bank (excluding the Branch), banking agents who are principally affiliated with the Branch, or any Subsidiary Financial Institution, Etc. of the Bank, (1) a customer who has an existing business relationship, or (2) a customer who may possibly establish a business relationship, provided, however, that Customers of any Subsidiary Financial Institution, Etc. that are considered to have no connection to domestic operations (operations that are carried out by the Branch or any Branch Affiliate (as defined below) within Japan) shall be excluded.

“Banking-Related Business” means “businesses which can be conducted by banks,” and includes core business (deposit, loan and exchange transactions) (Paragraph 1 of Article 10 of the Banking Act), ancillary business (Paragraph 2 of Article 10), financial instruments and exchange business (Article 11) and other statutory business (Article 12).

(2) Patterns of Transactions Involving Possible Conflicts of Interest, and Judging Criteria
The following describes the patterns of Transactions Involving Possible Conflicts of Interest that one may encounter. However, it must be kept in mind that these patterns only serve as the judgment criteria for Transactions Involving Possible Conflicts of Interest, and, therefore, transactions should not necessarily be considered “Transactions Involving Possible Conflicts of Interest” because they fit such criteria. Also note that these patterns may be expanded or modified as necessary in the future.

If any Customer reasonably expects that his/her own interests will be prioritized through counselling or advice (Duty-of-Loyalty Type);

If the Branch or any of its Affiliates may obtain any economic profit or avoid any economic loss at the expense of any Customer (Duty-of-Loyalty Type);

If the Branch or any of its Affiliates 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 any of its Affiliates conducts any transaction with any Customer who should be protected by the Branch or such Affiliate (Self-Agency Type);

If the Branch or any of its Affiliates conducts any transaction under which the Company 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 any of its Affiliates 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);

The Branch or any Branch Affiliate enters into a transaction whereby it obtains a profit through the use of undisclosed information of a Customer who should be protected by the Branch or such affiliate (information exploitation)

The Branch or any Branch Affiliate becomes involved in the same transaction by representing multiple sides, and as a result the transaction is not expected to have the same terms and conditions as the transaction under the normal circumstances (internalization of transactions).

Further, when determining whether or not there is any conflict of interest, the Branch will take into consideration all relevant factors, including the impact on the reputation of the Branch and its group companies. Note that any acts that are prohibited under the Financial Instruments and Exchange Act, and any other applicable laws and regulations are not covered under the Principles.

In addition, upon determining whether any conflict of interests has occurred, the Branch will comprehensively consider whether the reputation of the Branch and its group has been affected.

This Policy will not cover any actions prohibited by the Banking Act, the Financial Instruments and Exchange Act, or any other laws or regulations.

(3) Specific Examples
"Transactions Involving Conflicts of Interest" may be described as the specific examples shown below, as well as any transactions similar thereto:

A Customer is asked by the Branch or any Branch Affiliate to enter into a separate fee-based service agreement as a condition for setting up a new credit line or increasing the amount of an existing credit line for foreign exchange futures.

A financial institution offering a wide range of services internalizes a transaction (including the case where the Branch places orders with a securities firm, etc. within the same group).

An employee of the Branch of any Branch Affiliate receives gifts or entertainment (including those with no monetary value) that may possibly conflict with the interests of a Customer.

(Even though it is very unlikely that the following cases will actually occur within the Branch, or between the Branch and any of its subsidiaries, etc., they are nonetheless presented herein for the purpose of raising awareness regarding the management of conflicts of interest among employees.)

The Branch or any Branch Affiliate offers advice, etc. relating to the raising of funds to multiple customers who compete or are in conflict with each other.

The Branch or any Branch Affiliate offers advice, etc. relating to the raising of funds to a Customer, while making a principal investment in the Customer, purchasing an asset from the Customer, or engaging in similar transactions.

The Branch or any Branch Affiliate provides an investment research service to a Customer who receives advice relating to the raising of funds or credit, etc. from the Branch or such affiliate.

The Branch or any Branch Affiliate offers advice relating to corporate defense to a Customer, while providing financing to another Customer competing or in conflict with the said Customer who plans to take over the said Customer.

3. Scope of Companies Covered under the Conflict of Interest Principles
As stated in Numbered Item 1-(1) above, Covered Transactions refer to transactions that are entered into by the Branch, or any Parent Financial Institution, Etc., or Subsidiary Financial Institution, Etc. of the Bank (any banking agents who are principally affiliated with the Branch, any Parent Financial Institution, Etc., or Subsidiary Financial Institution, Etc. of the Bank shall be collectively referred to as “Branch Affiliates”).

“Parent Financial Institution, Etc.” means any party falling under either of the following: (1) the parent legal entity, etc. of the Branch or the Bank, (2) a subsidiary legal entity, etc. or affiliated legal entity, etc. of the parent legal entity, etc., or (3) a subsidiary corporation, etc. or affiliated corporation, etc. of any specific individual shareholder of the company, as is (a) a Financial Instruments Business Operator, (b) a bank, (c) an insurance company (including any foreign insurance company, etc.), (d) a securities finance company, etc., or (e) a person who engages in such financial business as banking business, financial instruments business or insurance business in any foreign country in accordance with any foreign law or regulation.

“Subsidiary Financial Institution, Etc.” means any party falling under either of the following: (1) a subsidiary legal entity, etc. of the Branch or the Bank, (2) an affiliated legal entity of the Branch, or the bank as is (a) a financial instruments business operator; (b) a bank, (c),a business operator who lends money or acts as an intermediary for the borrowing and lending of money or (d) a securities finance company; (e) a person or party who engages in financial instruments business, banking business or insurance business in a foreign country in accordance with the laws of that country.

As of May 13, 2009, the Parent Financial Institution, etc or Subsidiary Financial Institution, Etc. of the Branch or the Bank that are listed in the Exhibit attached hereto fall under the category of the entities that we manage conflicts of interest.

4. Organizational Structure for Managing Transactions Involving Possible Conflicts of Interest
Compliance shall be the department in charge of managing transactions involving possible conflicts of interest, and the manager of Compliance shall be an accountable personnel. Such department in charge shall be responsible for identifying possible transactions that would have potential conflicts and maintaining all necessary management structures of the branch, and independence from sales department should be fully warranted. Compliance shall not be directed by sales with regard to the treatment on actual cases.

5. Methods for Managing Transactions Involving Possible Conflicts of Interest
When Transactions Involving Possible Conflicts have been identified, the Branch will use any, or a combination of the methods described below and other methods so as to protect the Customers that are impacted by these transactions in an appropriate manner (keep in mind that the methods described below are examples only, and therefore they may not actually be put into practice):

Separation of the department that handles the Covered Transaction concerned from the department that handles other transactions with the Customer concerned.

Modification of the terms or method of the Covered Transaction concerned or other transactions with the Customer concerned.

Discontinuation of the Covered Transaction concerned or other transactions with the Customer concerned.

Proper disclosure to the Customer concerned of the possibility that that his/her interests may be unduly harmed as a result of the Covered Transaction concerned (however, such disclosure shall be permitted only when there will be no breach of confidentiality on the part of the Bank, or any Parent Financial Institution, Etc. or Subsidiary Financial Institution, Etc. of the Bank).

Supplementary Provisions

The Principles shall be established on May 26, 2009, and shall come into force as of June 1, 2009.

(Exhibit 2)

List of the Parent Financial Institutions, Etc. of the Branch to which this Policy applies:
State Street Global Markets (Japan)
State Street Global Advisors (Japan) Co., Ltd.
State Street Trust and Banking Co., Ltd.

Opinions and Complaints

Contact Point
State Street Bank and Trust Co., Tokyo Branch
Compliance Department
Phone No.: +81-3-4530-7690

The below organizations also accept consultation about banking transactions:
Japanese Bankers Association Consultation Center
Japanese Bankers Association Consultation Center is operated by the Japanese Bankers

Association as the contact point for various consultations and inquiries regarding a bank and opinions and complaints to a bank. Consultation, inquiries, etc., is free.

For more details, please see the website of the Japanese Bankers Association:
Phone No.:0570-017109 or +81-3-5252-3772
Service days: Monday – Friday (except for national holidays and other bank holidays)
Service hours: 9:00 am – 5:00 pm

*The Japanese Bankers Association is a designated dispute resolution organization under the Banking Act and our Branch holds a membership.

Basic Policy against Anti-Social Forces

State Street's action in response to the Anti-Money-Laundering (AML) initiatives