Japan

Legal Terms and Conditions
State Street Trust and Banking Policies
State Street Global Markets Policies
State Street Bank and Trust Policies

State Street Global Advisors (Japan) Co., Ltd. Policies

Privacy Policy

We hereby announce this Declaration of Personal Information Protection as part of our policy on handling your personal information.

1. Compliance with relevant laws and regulations
We hereby declare that we will comply with any and all the laws and regulations including the Personal Information Protection Act 2005 of Japan, the guidelines set by the ministers in charge and the policies of the authorized personal information protection organizations, and this Declaration of Personal Information Protection.

2. Purposes of Use
We will limit the use of your personal information to the extent necessary to carry out our purposes of use. Such limitation of use will not be applicable when you consent otherwise, and the laws or regulations require exceptional handling of it.

The notice of our purposes of using your personal information is posted at the head office and on our website, etc.

3. Measures to Ensure Safety Control
We will endeavor to keep your personal information accurate and the most up-to-date. In addition, we will take necessary and appropriate measures to ensure safety control of your personal information, and properly supervise our managers and employees, and the subcontracting parties in order to prevent the leakage or other unauthorized use of your personal information.

4. Continuous Disclosure
We will continue to seek improvements of this Declaration of Personal Information Protection by the appropriate review in order to make the handling of your personal information better and more appropriate.

5. Procedure for Requesting Disclosure
We will endeavor to properly and promptly respond to your request to, for example, disclose, correct, or suspend the use of your personal data held by us after confirming your identification.

6. Questions and Remarks
We will endeavor to properly and faithfully respond to your questions and remarks about our handling of personal information. Please contact our following division for questions and remarks:

Compliance and Risk ManagementDepartment
Toranomon Hills Mori Tower 25F
1-23-1 Toranomon, Minato-Ku,
Tokyo 105-6325
Phone number: +81-3-4530-7085 (service hours: 9 a.m.-5 p.m. on weekdays)

7. Authorized Personal Information Protection Organization
We are a member firm of the Japan Investment Advisers Association, the Investment Trusts Association and the Japan Security Dealers Association, which are the personal information protection organizations authorized by the Financial Services Agency. Please contact the common “Complaints Counseling Services Center” managed by these organizations for complaints and counseling on our handling of personal information.

(Complaints and Counseling)
Complaints and Counseling Services Center for Financial Instruments Transactions
(phone number: 0120-64-5005).

Conflict of Interest

1. Purpose
In connection with the diversification of services provided by financial institutions and the development of global financial conglomeratization, multiple interests compete or conflict with each other within a financial institution or financial group and the possibility of conflicts of interests is increasing.

Under such circumstances, SSGA (Japan) (the “Company”) is required to manage the transactions that may cause conflicts of interests so as to prevent the interests of our customers from being unjustly impaired.

As a Type I Financial Instruments Business Operator engaging in Securities-Related Business under the Financial Instruments and Exchange Act, the Company hereby establishes the Conflict of Interest Management Policy (the “Policy”), which is required in the creation of the conflict of interest management system under applicable laws and regulations.

2. Types of Transactions That May Cause Conflicts of Interests
(1) Covered Transactions

“Transactions that may cause conflicts of interests," which are covered by this Policy, mean such transactions conducted by the Company or any of its Parent Financial Institutions, Etc. (as defined in 3 below) that may unjustly impair the interests of our Customers (the “Covered Transactions”).

Conflicts of interests may occur (i) between the Company and/or any of its Parent Financial Institutions, Etc., and their Customers, or (ii) between the Customers of the Company and/or any of its Parent Financial Institutions, Etc., and other Customers.

“Customer” means, in relation to the “Financial Instruments-Related Business” conducted by the Company, (i) any customer who has already established business relations, or (ii) any customer who may establish business relations.

“Financial Instruments-Related Business” means any financial instruments business conducted by the Company, and any business incidental to financial instruments business as provided for in Paragraph 1 of Article 35 of the Financial Instruments and Exchange Act.

(2) Types of Transactions That May Cause Conflicts of Interests
The types of “transactions that may cause conflicts of interests” are as follows:

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

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

If the Company 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 Company or such Affiliate (Two-Side Agency Type);

If the Company or any of its Affiliates conducts any transaction with the counterparty of any Customer who should be protected by the Company or such Affiliate, which counterparty competes with such Customer (Competitive Transaction Type);

If the Company or any of its Affiliates conducts any transaction through the use of non-public information on any Customer who should be protected by the Company or such Affiliate, which transaction results in any benefit to the Company or such Affiliate (Information Use Type); or

If the conditions for similar transactions may not be expected due to the involvement of the Company or any of its Affiliates in the same transaction on multiple sides (Transaction-Internalization Type).

This Policy will not cover any actions other than those that constitute “transactions that may cause conflicts of interests,” notwithstanding that such acts are prohibited by the Financial Instruments and Exchange Act, or any other laws or regulations.

(3) Transactions That May Cause Conflicts of Interests
“Transactions that may cause conflicts of interests” are transactions set out in Exhibit 1. Please note that some additions, modifications or deletions may be made in the future as necessary.

3. Scope of the Companies Covered by Conflict of Interest Management
As stated in 2(1) above, the Covered Transactions are transactions conducted by the Company or any of its Parent Financial Institutions, Etc. (the Parent Financial Institutions, Etc. of the Company are referred to as the “Affiliates”).

The companies listed on Exhibit 2 are the “Parent Financial Institutions, Etc.” of the Company.

4. Method of Managing Transactions That May Cause Conflicts of Interests
If the Company identifies any transaction that may cause a conflict of interests, the Company will properly secure the protection of the relevant Customers by selecting from any of, or combining, the following methods and any other methods:

(i) The method of separating the division conducting the Covered Transaction and the division conducting the transaction with such Customer, and blocking information;

(ii) The method of amending the conditions or method of the Covered Transaction or the transaction with such Customer;

(iii) The method of discontinuing the Covered Transaction or the transaction with such Customer;

(iv) The method of properly disclosing before the Covered Transaction and reporting after the Covered Transaction to the Customer the possibility that the interests of such Customer may be unjustly impaired as a result of such Covered Transaction (only if such disclosure and reporting do not violate the duty of confidentiality assumed by the Company or any of its Parent Financial Institutions, Etc.); and/or

(v) The method of managing transactions that may cause conflicts of interests by applying internal rules and other regulations.

For major management methods in relation to “transactions that may cause conflicts of interests,” see Exhibit 1.

5. Conflict of Interest Management System
The Compliance and Risk Management Department of the Company will be the Conflict of Interest Management Control Division, and the Manager of the Compliance and Risk Management Department shall serve as the chief of such division.

It is guaranteed that the Conflict of Interest Management Control Division will be independent from the Sales Division. The Conflict of Interest Management Control Division will never receive any direction or order regarding the treatment of specific cases from the Sales Division.

The Conflict of Interest Management Control Division will control the Company-wide management system regarding the identification of transactions that may cause conflicts of interests and the management of conflicts of interests.

Opinions and Complaints

Contact Point
State Street Global Advisors (Japan) Co., Ltd.
Compliance and Risk Management Department
Phone No.: +81-3-4530-7085

The below organizations also accept consultation about the Type I Financial Instruments business activities, Type II Financial Instruments business activities, Investment Advisory business activities and Investment Management business activities.

For Type I Financial Instruments Business:
Financial Instruments Mediation Assistance Center (FINMAC)

For Type II Financial Instruments Business:
The Investment Trust Association, Japan

For Investment Advisory Business:
Japan Investment Advisers Association

For Investment Management Business:
The Investment Trust Association, Japan or Japan Investment Advisers Association

In cooperation with Japan Securities Dealers Association, The Investment Trust Association, Japan and Japan Investment Advisors Association, Financial Instruments Mediation Assistance Center (FINMAC) has been established as a direct contact point for various consultations and inquiries regarding member associations’ activities and has been endeavoring for solving issues efficiently and comprehensively.

For more details, please see the website of the FINMAC.
Phone No.:0120-64-5005 (local toll free)
Service days: Monday – Friday (except for national holidays and other bank holidays)
Service hours: 9:00 am – 5:00 pm

Anti-Social Forces

Click here for State Street Global Advisors Anti-Social Forces

Important Note

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