Japan

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

State Street Global Markets (Japan)

Privacy Policy

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

1. Compliance with Laws and Regulations
We hereby declare that we will handle your personal information in compliance with any and all the laws and regulations including the Personal Information Protection Act 2005 of Japan, the guidelines set by the competent ministers and the authorized information protection organization, and this Declaration of Personal Information Protection to ensure the protection of your personal information.

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 use is posted at the head office.  

3. Administrative Measures to Ensure Safety
We will endeavor to keep your personal information accurate and the most up-to-date. In addition, we will take necessary and appropriate administrative measures to ensure safety of your personal information, and properly supervise our managers, employees, and parties having contractual relations with us to prevent leakage or other unauthorized use of it.

4. Continuous Improvement
We will continue to seek improvements by regularly reviewing this Declaration of Personal Information Protection to make the handling of your personal information better and more appropriate.

5. Request for Disclosure
We will endeavor to properly and promptly meet your request of us to, for example, disclose, correct, or delete your personal information held by us by asking for 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 Compliance function (phone number: +81-3-4530-7522) for questions and remarks.

7. Authorized Information Protection Organization
We are a member firm of Japan Security Dealers Association, one of the information protection organizations authorized by the Financial Services Agency. Please contact your local office of the Mediation and Counseling Services Center, Japan Security Dealers Association for complaints and counseling on our handling of personal information.

(Complaints and Counseling)
Personal Information Consultation Office,
Japan Security Dealers Association
Phone Number: +81-3-3667-8537
http://www.jsda or jp/

Conflict of Interest

1. Purpose
Because of the amendment of Financial Instruments & Exchange Law, the restriction for the cross engagement of officers and employees of securities firms and banks has been abolished, and the restriction on sharing non-disclosed customer information has been deregulated. Therefore, the frequency of sharing customer information between group entities might be increased more, and so that we would like to enhance the information security system in terms of conflict of interest management by implementing this policy with respect to the management of nonpublic information that officers and employees of State Street Global markets Japan (the Company) obtain in connection with their duties, client management, trade management, the services to be provided by officers and employees and so forth in order to prevent any transaction that may cause any conflict of interests, and thereby ensuring that the Company conducts its business activities properly.

2. Types of Transactions that may cause Conflicts of Interests; Process of Identification, Etc.

(1) Covered Transactions

"Transactions that may cause conflicts of interests," which are covered by this Policy, means such transactions conducted by the Company or the Parent Bank, etc. (the Parent Banks, 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 the Parent Banks, etc., and their Customers, or (ii) between the Customers of the Company and/or the Parent Banks, etc., and other Customers.

"Customer" means, in relation to the "Financial Instruments Related Business" conducted by the Company or any of the Parent Banks, etc., (i) any customers who have already established business relations, or (ii) any customers who have opened an account with the Company and may establish business relations, (iii) any customers who traded in the past and still have a relationship with the Company legally.

"Financial Instruments Related Business" means any Financial Instruments Business and such Business Incidental to Financial Instruments Business, or any other business activities as provided for in Article 35, of the Financial Instruments and Exchange Law.

(2) Types of Transactions that may cause Conflicts of Interests; Criteria

The following transactions may be considered as types of "transactions that may cause conflicts of interests." in principal.

If any Customer reasonably expects that his/her own interests shall be prioritized through counseling or advice;

If the Company or the Parent Banks, etc. may obtain any economic profit or avoid any economic loss at the expense of any Customer;

If the Company or the Parent Banks, etc. may obtain any extra economic profit other than economic profit of customer any Customer;

If the Company or the Parent Banks, etc. conduct any transaction with any Customer who should be protected by the Company or the Parent Banks, etc.;

If the conditions for similar transactions may not be expected due to the involvement of Company or the Parent Banks, etc. in the same transaction on multiple sides

If the Company or the Parent Banks, etc. obtain or shall 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;

In addition, upon determining whether any conflict of interests has occurred, the Company shall consider whether any impact upon the reputation of the Company or State Street Group has been caused.

This Policy shall not cover any acts other than those that constitute "transactions that may cause conflicts of interests" notwithstanding that such acts are prohibited under the Financial Instruments and Exchange Law, or any other laws or regulations.

(3) Specific Examples

The following transactions and any other similar transactions may be considered as specific examples of "transactions that may cause conflicts of interests" but not limited:

If with the knowledge of potential information regarding securities transaction of any Customers, any officers an employees of the Company or any of their concerned parties conduct any own transaction regarding such securities or providing such information for the purpose of granting any economic benefits;

If the Company or the Parent Banks, etc. involve in any transactions with respect to any securities to which any order has been given by any Customers;

If any employee of the Company or the Parent Banks, etc. receive any gift or entertainment (including any non-monetary benefits) that may prejudice the interests of any Customers.

(4) Process for Identifying a Transaction that my cause Conflicts of Interests

Front office persons should report a transaction that my cause conflicts of interests based on the above No. 3 specific examples to the Compliance Department and follow the advice

If there are any doubt and questions regarding the transaction that my cause conflicts of interests or the control system, contact the Compliance Department.

If there is a discrepancy between the views and opinions for the issue, one of the Risk Management & Compliance Department must be respected.

3. Scope of the Companies covered by Conflict of Interest Management
As stated in 2(1) above, the Covered Transactions are any transactions conducted by the Company or the Parent Bank, Etc. (Parent Bank, Etc. is listed separately.).

4. Conflict of Interest Management System

(1) Establishment of the Conflict of Interest Management Control Division

The Compliance Department shall be the Conflict of Interest Management Control Unit, and the Conflict of Interest Management Control Manager shall be appointed. The Conflict of Interest Management Control Manager shall be independent from the Sales Division, and shall never receive any direction or order regarding the treatment of specific cases from the Sales Division.

The Conflict of Interest Management Control Manager shall control the company-wide management system regarding the identification of transactions that may cause conflicts of interests and the management of conflicts of interests.

(2) Duties of the Conflict of Interest Management Control Manager

The Conflict of Interest Management Control Manager shall assume the responsibilities on reviewing if any division responsible for the relevant business of the Company, Etc. conducts any transaction that may constitute a Covered Transaction in accordance with this policy, and improve the condition if necessary.

The Conflict of Interest Management Control Manager collect relevant information for the management of conflicts of interests, or use any other methods to ensure that the status of the management of conflicts of interests regarding the Covered Transactions.

If Conflict of Interest Management Control Manager identifies any transaction that may cause any conflict of interests and selects the management method thereof, the Conflict of Interest Management Control Manager shall record such measures, and preserve such record for five (5) years from the creation of such record.

The Conflict of Interest Management Control Manager shall provide a training course regarding this Policy and the manners in accordance with this Policy to officers and employees on a regular basis, and ensure to make them aware of Conflict of Interest Management Control System.

(3) Review by Monitoring & Testing

A verification of the Conflict of Interest Management Control in terms of personnel composition regarding the management of conflicts of interests and their business operation system shall be monitored based on the Compliance Department.

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

Opinions and Complaints

Contact Point
State Street Global Markets (Japan),
Compliance Department
Phone No.: +81-3-4530-7500

The below organizations also accept consultation about the Financial Instruments Broker & Dealer business activities, and Investment Management business activities.

For Financial Instruments Broker & Dealer Business:
Japan Securities Dealers Association

For Investment Management Business:
Japan Investment Advisors Association

In cooperation with Japan Securities Dealers Association and Japan Investment Advisors Association, etc., 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 FINMAC.
Phone No.: 0120-64-5005 (tool free)
Service days: Monday – Friday (except for national holidays and other bank holidays)
Service hours: 9:00 am – 5:00 pm

Basic Policy regarding Anti-Social Elements

State Street Global Markets Japan (“the Company”) has prescribed the following basic policy regarding anti-social elements and, through the observance of this policy by all executives and employees, will strive to ensure the appropriateness and safety of its business operations.

1. Response as an organization
In relation to anti-social elements, the Company has established the foundation of express provisions in the Ethical Framework, Code of Conduct and Internal Rules, etc., and will respond as an entire organization, from the top management downward. In addition, the Company will guarantee the safety of employees who would respond to anti-social elements.

2. Cooperation with external specialist organization
Under normal circumstances, the Company endeavors to establish a close cooperative relationship with external specialist organizations such as the police, the Centers for the Elimination of Boryokudan, and lawyers.

3. Blocking of all relationships, including business transaction
The Company shall block all relationships with anti-social elements, including business relationships

4. Civil and criminal legal responses in times of emergency
The Company shall reject improper demands from anti-social elements, and take legal actions on both a civil and criminal basis, as the need arises.

5. Prohibition of secret deals and provision of funds
The Company shall absolutely not engage in secret deals with anti-social elements. The Company shall absolutely not provide funds to anti-social elements.

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