We disclose the summery of the Conflicts of Interest Management Policy as follows in order not to unduly harm the interests of our clients, and appropriately manage transactions that may cause conflicts of interest in accordance with this policy.
(*) The term “Covered Group Companies subject to conflicts of interest management” refers to companies., including those in Japan or overseas that operate banking services or financial instruments transactions of SuMi TRUST Group, which are covered by management that the conflict of interest management control department, set out Section 4 (1) below, implements.
Transactions that may cause conflicts of interest are specified based on the classifications and managed depending on situations, in the following ways. so as not to unduly hurt our clients’ interests.
Typical examples are as follows.
The case where a transaction between a fund under our investment management and a Covered Group Company occurs or services such as administration are provided falls under the classification. There is concern that the transaction is carried out at a rate or under terms and conditions which are disadvantageous to the fund.
The case where a transaction between an investment trust and a company with which we have transactional relationships. occurs falls under the classification. When managing the investment trust, investing in stocks or bonds, there is concern that a sales company selling the investment trust is preferentially selected as an agency that takes orders to buy or sell the stocks or bonds, and the transaction is carried out at a rate disadvantageous to the investment trust.
There is concern that, in the case where our funds invests in stocks of a company with which the corporate sales division of a Covered Group Company has transactional relations, the department requests us to exercise the voting rights, which is advantageous to the company, the issuer of the stocks.
(*) Restrictions on personnel transfers, blocking the flow of information, and restrictions on contact
Restrictions on personnel transfers, blocking the flow of information, and restrictions on contact between the corporate sales divisions of the Covered Group Companies and us are established specifically as follows.