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Declaration for Personal Information Protection

We, NatWest Markets Securities Japan Limited (the "Company") is committed to compliance with the Personal Information Protection Law ("Law") and other relevant laws and regulations. We hereby declare that we will protect customers' personal information which comes into our possession, in accordance with the policy set forth below.


1. Purpose of usage

We will use customers' personal information to the extent necessary to achieve the purposes specified below in regard to the business specified below:


[Business]
 

  • Financial Instruments Business(purchase or sale of Securities, act of intermediary / broker/agent of purchase or sale of Securities, Underwriting, Derivatives business etc.)
  • Registered Financial Institution Business (securities related business, securities intermediation, derivatives transactions and other business in which banks are permitted to engage by laws) and other business auxiliary to Registered Financial Institution Business; and
  • Other businesses in which banks are permitted to engage and business auxiliary to these (including businesses that may be permitted in the future.)

[Purpose]
 

  • For solicitation or sale of the securities or/and the financial products, and providing the information about our services.
  • For solicitation or sale of the financial products provided by the Company, the affiliated firms, and providing the information about services.
  • For suitability check concerning providing the financial products and the services.
  • For confirming identification of the customers or the agents of the customers.
  • For providing the confirmation or/and the statement.
  • For conducting the tasks in relation with the transaction with the customers.
  • For execution of the rights or completion of the obligations based on the agreements with the customers or /and the regulatory requirements.
  • For studying or /and developing the financial products or the services through marketing, data analysis, or/and a questionnaire survey.
  • For conducting the business to treat the whole or the part of the personal data based on the request of the other firms.
  • For conducting other businesses with the customers or the counterparts in an appropriate and timely manner

We will not use customers' personal information for any purpose other than those specified above, unless otherwise provided by the Law or unless we have obtained prior consent from customers.

 

2. Obtaining Personal Information

 

We will obtain personal information in a fair and lawful manner.

 

As well as by requesting customers to complete an application form or to present their ID documents, Company may collect personal information through contacts by mail, phone, and fax, etc., provided that these electronic devices are appropriately secured.

 

As a rule, Company does not collect sensitive information on individuals (i.e. moral principles, membership of labor union,  race, family origin, domicile of origin, medical( medical history, physical disability) and sexual information, and criminal history). Any sensitive information stated on a copy of official ID documents such as domicile of origin will be blacked out before filing.

 

3. Personal Data provided to the third parties

 

We will not provide the personal data of the customers to the third parties except where there is customer consent or where such use is exempted by the laws and regulations.

 

4. How to manage the information

 

We will endeavor to keep customers' personal information accurate and up-to-date, and take all reasonable precautions, including countermeasures against computer virus and unauthorised access, to protect personal information from loss, damages, and leakage.

 

We will appropriately oversee its outsourcing contractors that handle Personal Information.

 

5. Procedure for customer requests

 

When we are requested to disclose, correct or cease using the personal data which we hold, we will take the following actions.

 

  • We will ask the customers to make a request in writing to Compliance Department.
  • We will follow the identification process referring to the Law of Prevention of Transfer of Profit by Crime.
  • We will ask the customers to pay the actual cost for copying or/and sending via mail.

 

6. Contact us

 

Please Contact us if you have any questions or complaint in relation to handling personal data.

 

Compliance Department

Address: Shin Marunouchi Center Building, 1-6-2 Marunouchi, Chiyoda-ku, 100-0005

Phone: 03-6266-3500

Business hours: 9:00am - 5:00pm (excluding weekends and holidays)

 

 

7. Approved personal data protection organisation

 

We are member of the Japan Securities Dealers Association and The Financial Futures Association of Japan, approved personal data protection organisations approved by the Financial Services Agency. The following consultation offices of these associations accept complaints and consultation in relation to the handling of personal data by its member companies.

 

Japan Securities Dealers Association

Personal Information Consultation Office

Address: 1-5-8. Nihonbashi Kayabacho, Chiyoda-ku, Tokyo 103-0025 Japan

Phone: 03-3667-8427

Desk Hours: 9:00 ~ 17:00 (except for Dec 31, Jan 1~3, Saturday, Sunday and Holiday)

 

The Financial Futures Association of Japan

Personal Information and Complaint Consultation Office

Address: 1-3, Kanda Ogawacho, Chiyoda-ku, Tokyo 101-0052 Japan

Phone: 03-5280-0881

Desk Hours: 9:00 ~ 17:00 (except for Dec 31, Jan 1~3, Saturday, Sunday and Holiday)

 

 

8. Sharing the personal data

 

We share the personal data as follows as far as the laws allow us to do.

 

Purpose of sharing information
 

  • For confirming identification of the customer
  • For providing the customers with the total service by RBS Group
  • For performing internal control such as compliance, risk management, and internal audit
  • For Group management

 

The Items of personal data to be shared
 

  • Name and address
  • Organisation (Company) and its address
  • Title
  • Contact (telephone number, facsimile number, email address)
  • Information about an account
  • Contents of transactions
  • Other items necessary to achieve above purposes

 

The parties to share personal data

 

The Royal Bank of Scotland Group plc and its affiliates

 

The party that is responsible for the management of shared personal data

 

NatWest Markets Securities Japan Limited.

 

9. Continuous Improvement, etc.

 

The contents of this policy may be amended according to amendment of the laws or by other reasons. The new one is disclosed at the counter or on the web site of the Company.

 

 

Reclassification expiry date

Last day of the period during which General Investors are treated as Professional Investors

 

Pursuant to Article 58 and 63 of the Cabinet Office Ordinance concerning Financial Instruments Business (the “Ordinance”), we announce the following:

 

The last day of the period during which General Investors are treated as Professional Investors:

 

Last Day: March 31 and September 30 each year

 

The above last day is whichever comes last and falls within one year counting from the Acceptance Date.

 

If you wish to continue to be treated as Professional Investor after the expiry date, please make a renewal request within one month before the expiry date.

 

Basic Principle for Handling Anti-Social Organisations

In order to secure the appropriateness and soundness of business, and with the understanding of the social responsibility to eliminate Anti Social Organisations, NatWest Markets Securities Japan Limited has defined the "Basic Policy to act on Anti Social Organisations".

 

  1. We will seclude ourselves from any relationship (including transactional relationship) with Anti Social Organisations which will pose danger towards social order and safety, by taking resolute attitude.
  2. We will strongly refuse the undue claims from Anti Social Organisations. We will closely communicate with external specialists and act towards Anti Social Organisations from senior management to staff level as a single organisation.
  3. We will not proceed with any funding or inappropriate and/or exceptional benefit sharing towards Anti Social Organisations.
  4. We will reinforce the communication with external specialists from normal circumstances, in order to obtain appropriate advice and cooperation on the occasion of acting towards Anti Social Organisations.
  5. We will act on with firm stance by taking legal actions and etc., towards the undue claims such as a pressure from Anti Social Organisations pretending a client complaint.

 

Outline of NWMJ Conflict of Interest Management

1. Purpose

 

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

Under such circumstances, NatWest Markets Securities Japan Limited (“NWMJ”) is required to manage the transactions that may cause conflicts of interests by the Financial Instruments and Exchange Act (the "Act") so as to prevent the interests of our customers from being unjustly impaired.

NMWJ, under the Financial Instruments and Exchange Act, has established the Conflict of Interest Management Procedure (the "Procedure"), which is required in the creation of the conflict of interest management system under applicable laws and regulations.  Please refer to the outline of the procedure.

 

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 Procedure, means such transactions conducted by NWMJ and 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 NWMJ and/or any of its Parent Financial Institutions, Etc. and their Customers, or (II) between the Customers of NWMJ and /or its Parent Financial Institutions, Etc. and other Customers.

 

"Customer" shall mean, in relation to the "Financial Instruments Related Business" conducted by NWMJ whose principal bank is  or any of its Subsidiary Financial Institutions, Etc., (I) any customer who has already established business relations, or (II) any customer who may establish business relations.

 

"Financial Instruments Related Business" shall mean Financial Instruments Business and its Incidental Business as defined in Article 35, Paragraph 1 of the Financial Instruments and Exchange Act.

 

(2) Types of transactions that may cause conflicts of interest: criteria

 

The following transactions may be considered as types of "transactions that may cause conflicts of interests."  However, as these types are only criteria to determine whether there is any "transaction that may cause any conflict of interests," please note that the satisfaction of any such criteria does not necessarily mean the occurrence of a "transaction that may cause a conflict of interests."  Also, please note that some additions or modifications may be made in the future as may be necessary.

  • If any Customer reasonably expects that his/her own interests will be prioritised through counseling or advice (Duty-of-Loyalty Type);
  • If NWMJ or any of its Parent Financial Institutions Etc., may obtain any economic profit or avoid any economic loss knowing it may impair interest of Customer (Duty-of-Loyalty Type);
  • If NWMJ or any of its Parent Financial Institutions, Etc. 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 NWMJ or any of its Parent Financial Institutions, Etc. conducts any transaction with any Customer who should be protected by NWMJ or such Affiliate (Self-Agency Type);
  • If NWMJ or any of its Parent Financial Institutions, Etc. conducts any transaction under which NWMJ or such Affiliate takes the side of the counterparty of any Customer who should be protected by NWMJ or such Affiliate (Two-Side Agency Type);
  • If NWMJ or any of its Parent Financial Institutions, Etc. conducts any transaction with the counterparty of any Customer who should be protected by NWMJ or such Affiliate, which counterparty competes with such Customer (Competitive Transaction Type);
  • If NWMJ or any of its Parent Financial Institutions, Etc. conducts any transaction through the use of non-public information on any Customer who should be protected by NWMJ or such Affiliate, which transaction results in any benefit to NWMJ or any such Parent Financial Institutions, Etc. (Information Use Type); or
  • If the conditions for similar transactions may not be expected due to the involvement of NWMJ or any of its Parent Financial Institutions, Etc. in the same transaction on multiple sides (Transaction-Internalisation Type).

 

In addition, upon determining whether any conflict of interests has occurred, NWMJ will consider whether any impact upon the reputation of NWMJ or our Group has been caused.

The Procedure will 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 Act, or any other laws or regulations.

 

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 NWMJ or Parent Financial Institutions, Etc.

 

"Parent Financial Institution, Etc." shall mean (I) such parent corporation of NWMJ, (II) such subsidiary corporation of any Parent Corporation, Etc. of NWMJ, such Affiliated Corporation, Etc. of any parent corporation, etc. of NWMJ, or (III) such Subsidiary Corporation, Etc. or affiliated corporation, etc., as is (a) a Financial Instruments Business Operator in any foreign country in accordance with any foreign law or regulation.

 

As of 1 July 2018, the following companies hereto are the "Parent Financial Institutions, Etc." of NWMJ.

 

  • The Royal Bank of Scotland Group plc(UK)
  • NatWest Markets PLC (UL)
  • NatWest Markets N.V. ( Netherlands)
  • NatWest Markets Securities Inc. (US)
  • The Royal Bank of Scotland International (Holdings) Limited
  • RBS Holdings (UK) Limited

 

 

4. Method of managing transactions that may cause conflicts of interests

 

If NWMJ identifies any transaction that may cause a conflict of interests, NWMJ will properly secure the protection of our Customers by selecting from any of, or combining, the following methods and any other methods (the following methods are only examples, and the following measures need not be adopted):

 

  • The method of separating the division conducting the Covered Transaction, and the division conducting the transaction with such Customer;
  • The method of amending the conditions or method of the Covered Transaction or the transaction with such Customer;
  • The method of discontinuing the Covered Transaction or the transaction with the Customer; and/or
  • The method of properly disclosing to the Customer the possibility that the interests of such Customer may be unjustly impaired in connection with the Covered Transaction (only if such disclosure does not violate the duty of confidentiality assumed by NWMJ, or any of its Parent Financial Institutions, Etc.).

 

 

5. Conflict of Interest Management System

 

(1) Establishment of the Conflict of Interest Management Department.

 

Compliance Department of NWMJ will be the Conflict of Interest Management Division.

 

The Conflict of Interest Management Division will be independent from the Sales Departments, and will never receive any direction or order regarding the treatment of specific cases from the Sales Departments.

 

The Conflict of Interest Management Division will support the Global Control Room that primarily controls the Conflict of Interest management for the entire Group, and will engage in the identification of transactions of NWMJ that may cause conflicts of interests for our Customer and the management of conflicts of interests.

 

(2) Duties of the Conflict of Interest Management Division

 

The Conflict of Interest Management Division will assume the following duties in a position independent from the Sales departments.

 

The Conflict of Interest Management Division will identify any Covered Transactions, and also instruct the Sales departments to properly manage any conflicts of interests regarding the Covered Transactions.

 

The Conflict of Interest Management Division shall immediately report to the Internal Control Supervisor and Governance and Control Committee any matter that has a material effect on the management of NWMJ, or that significantly impairs the interests of Customers.

 

The Conflict of Interest Management Division will verify whether the conflicts of interests have been properly managed, and, when necessary, review the procedures for conflict of interest management, or the conflict of interest system.

 

If the interests of our Customers may be unjustly impaired, the Conflict of Interest Management Control Division will instruct the Sales divisions to properly manage conflicts of interests, or review the Covered Transactions, when necessary.

 

The Conflict of Interest Management Division will provide training for the management of conflicts of interests based on the Global Policy, this Principle and “the Conflict of Interest Management Procedure to any officers and employees of NWMJ, and keep them informed of the management of transactions that may cause conflicts of interests.

 


(3) Record and Preservation

 

If any officer or employee of the Sales Departments should identify a transaction that may cause any conflict of interests and select the management method thereof, he/she will report to the Conflict of Interest Management Division, which records the measures, and keep it for five (5) years from its creation.

 

If the Conflict of Interest Management Control Division should identify a transaction that may cause any conflict of interests and select the management method thereof, the responsible person of the Conflict of Interest Management Division will record the measures, and keep it for five (5) years from its creation

 

 

Explanatory document on non-registered ratings

In connection with the amendment of the Financial Instruments & Exchange Law which became effective as of the 1 October 2010, Financial Instruments Business Operators are now required to explain the status of non-registered Rating Agencies in Japan and the significance of registration, etc. to clients whenever it provides credit ratings assigned by these non-registered credit rating agencies on Financial Products.

 

Please make sure to read this ”Explanatory document on non-registered ratings”. This document covers each rating agency, with regard to ratings assigned by non-registered credit rating agencies used in solicitation materials of NatWest Markets.

 

It explains 1) the significance of registration, 2) the name etc. of the rating agency group 3) how to gather summary information on the policy and method used to assign credit ratings, and 4) the assumption, the significance and the limitation of credit rating.

 

Also please make sure to confirm the contents of 3) summary information on the policy and method used to assign credit ratings, by clicking the company website URL provided on the explanatory document for each credit rating agency.

 

 

Explanatory documents

 

Moody’s Investors Service Inc  (PDF, Size: 54 KB)

 

Standard & Poor’s Rating Services  (PDF, Size: 120 KB)

 

Fitch Rating  (PDF, Size: 219 KB)

Solicitation Principle

When soliciting customers for entering into transactions in financial products, NatWest Markets Securities Japan Limited will endeavor to protect the interest of customers in compliance with the policy set forth below.

 

1. Matters that require consideration in light of knowledge, experience, financial conditions and objects of concluding the contract for financial product

  • We will conduct solicitation activities that suit the customer's intention and actual conditions by gaining a good grasp of the customer's knowledge, experience, financial conditions and objects of concluding the contract for financial product.
  • We will recommend a product which we consider suitable for a customer in light of the customer's knowledge, experience, financial condition and the objects of concluding the contract.
  • When recommending a product, we will provide an adequate explanation about the product and associated risks, in light of the customer's knowledge, experience, financial condition and the objects of concluding the contract.

 

2. Matters that require consideration for persons being solicited regarding the method and hours of solicitations

  • In conducting solicitation activities, we are committed to a customer-oriented approach and compliance with laws and regulations so as to maintain customers' trust.
  • We will conduct solicitation activities in compliance with all applicable laws and regulations and based on reasonable grounds.
  • We will not make visits and calls at hours which cause nuisance to customers. If you suffer any inconvenience, please inform your NatWest Markets representative.

 

3. Other matters for ensuing appropriate solicitatio

  • We provide sufficient training to our officers and employees in order to prevent inappropriate solicitation activities. If you have any suggestions or comments, please contact Compliance Department on 03-6266-3000.
  • In order to meet customer confidence and expectations, our officers and employees will endeavor to acquire knowledge and skills and improve their expertise through continuous study.
  • We will endeavor to enhance our internal control system to ensure appropriate solicitation in compliance with the Banking Law, Financial Products Sales Law, Financial Instruments and Exchange Law and other relevant laws and regulations.
  • We will provide customers with sufficient information in order that they can enter into transactions upon their own judgments and responsibilities.

                                        

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