Fiduciary Duty Policy

Standard Chartered Bank, Tokyo Branch

Pursuit of Best Interest of Clients

Standard Chartered Bank, Tokyo Branch (the “Branch”) has high level of expertise and professional ethics, and serves its clients in a faithful and fair manner.

The Branch aims to gain trust of clients and expand business, by offering clients high quality financial products/services that matches their needs and making efforts to serve the best interest of clients.

Appropriate Management of Conflict of Interest

While the Branch is a member of Standard Chartered Group (the “Group”) that offers a number of financial products/services, various conflict of interest may arise when the Branch sells or recommends the products/services provided by another company in the Group. Therefore the Branch ensures that the interest of clients are adequately protected, by exercising appropriate control over such activities.

Further, the Branch has established Conflict of Interest Management Policy. Under this Policy the Branch identifies and classifies the transactions that may unduly impair the interest of clients, and specifies the method and organisation/system to manage any relevant transactions as well as the Group companies to be the objectives of such management actions, so that it can control the relevant transactions without unduly impairing the interest of clients.

Clarification of Fees and Other Expenses

When the Branch provides the financial products/services, it receives fees and other expenses separately from their prices.

Further, when the financial products/services are originally provided by the Group, the Branch receives sales commission from the Group, separately from the expenses paid by the clients.

The fees and other expenses received by the Branch are the consideration for various expenses such as the followings: (a) transaction related expenses to develop and structure financial products/services, (b) operational expenses associated with preparation and delivery of explanatory materials, prospectus, transaction reports and registration documents of various types of products, (c) personnel expenses for provision of financial services by sales staff, and (d) cost for improving infrastructure including development/maintenance of trading systems.

Provision of Material Information in Easy and Understandable Manner

When the Branch provides information relating to the financial products/services, it gives the information necessary for making investment decision, such as the basic return, potential loss or other risks, and transaction terms, of the financial products or services.

In proposing financial products/services to clients, the Branch explains that it appropriately manages the risk of conflict of interest, if any.

Further, the Branch provides clear, simple, non-misleading and faithful information that suit the client’s financial expertise and the nature of the product, in consideration of the complexity and the extent of risk exposure of the financial products/services.

Provision of Services that Suit Clients

The Branch works to offer the most suitable financial products/services to each client, by first checking the client’s asset situation, transaction experience, expertise and purpose of the transaction, and, before making actual proposal of financial products/services, by hearing the intention and needs of the client from a number of viewpoints.

In developing and structuring the financial products, the Branch tries to identify the profile of the potential sales target clients in light of the extent of risk exposure and complexity of the financial products, and ensures that the financial business operators engaged with the sale carry out the sales activity in a way that suits the client profile.

Framework of Appropriate Motivation of Employees

The Branch attempts to enhance the internal education and training so that the employees act in a faithful and fair manner, in consideration of the clients’ best interest.

For assessment of performance and remuneration, the Branch does not heavily rely on each employee’s contribution to the profit, but evaluates how the employee acted to achieve the result in accordance with the Code of Conduct of the Branch and the Group.

Through such internal trainings, and performance and remuneration assessment system, the Branch properly motivates the employees to pursue best interest of clients.