Asset Management One

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Policy for the Management of Conflicts of Interest

Asset Management One Co., Ltd. (hereinafter referred to as “the Company”) hereby publish the summary of the policy for the management of conflicts of interest as follows:

Policy for the Management of Conflicts of Interest

The Company shall manage any conflicts of interest that may arise out of or in relation to transactions to be concluded by and between customers and Mizuho Financial Group, or Dai-ichi Life Group. This is done for the purpose of eliminating and preventing the opportunity for the interests of the customers of the Company to be unfairly impaired as a result of those transactions, and we shall maintain our continuous efforts in ensuring protection and the enhanced convenience of the customers.

“Mizuho Financial Group” refers to Mizuho Financial Group, Inc. and companies (consolidated subsidiaries and equity method affiliates) managed by the company mentioned in the securities reports and other related documents.
“Dai-ichi Life Group” refers to Dai-ichi Life Holdings, Inc. and its subsidiary companies, etc.

Management Structure

The Company shall facilitate an appropriate structure for the management of conflicts of interest through various efforts, including appointment of personnel responsible for the management of conflicts of interest.

Types of the Transactions Subject to the Management of Conflicts of Interest

The Company shall, in advance, identify/categorize the types of transactions that may cause conflicts of interest and shall review those on a regular basis, as well as on an as-needed basis. Transactions that may cause conflicts of interest can be categorized into either transactions where the interest of one customer conflicts with those of customers of Mizuho Financial Group or Dai-ichi Life Group or transactions where the interest of a customer conflicts with the interest of Mizuho Financial Group or Dai-ichi Life Group. The representative examples of such Types of the Transactions Subject to the Management of Conflicts of Interest are as follows:

  • When the Company conducts transactions between the assets of one customer and those of another customer
  • When the Company conducts transactions between the assets of a customer and other companies within Mizuho Financial Group or Dai-ichi Life Group
  • When the Company invests assets of one customer in companies where business departments within Mizuho Financial Group or Dai-ichi Life Group have transaction relationships
  • When the Company exercise voting rights in companies where the Company has transaction relationships or where business departments within Mizuho Financial Group or Dai-ichi Life Group have transaction relationships

Method of Management

The Company shall endeavor to correctly understand the situation of conflicts of interest involved in transactions with customers and shall address such conflicts of interest according to the prevailing situation by taking such countermeasures, etc. as listed below. The Company shall also endeavor to provide information on the specific details of any conflicts of interest, etc., in a customer–friendly manner.

  • Securing appropriate independence from business departments within Mizuho Financial Group or Dai-ichi Life Group
  • Establishing a process for selecting products, a process for setting reasonable fees, and an appropriate performance evaluation system, that truly meet customer needs
  • Introducing information barriers to segregate information between the divisions/departments of those that have conflicts of interest with each other
  • Confirmation of the fairness of transaction conditions
  • Obtaining consent from or disclosing to customers the situation concerning a conflict of interest
  • Modifying the terms or the methods of the transaction concerned
  • Avoiding the transaction concerned

Information Sharing

The Company may share customer information or information concerning customer transactions with the companies subject to the management of conflicts of interest of Mizuho Financial Group without obtaining consent from the customers to the extent that the management of conflicts of interest, which is an internal management operation is required as “business operation related to compliance management” of Mizuho Financial Group.

Continuous Improvement

The Company shall continuously endeavor to improve its framework for the management of conflicts of interest through verifying the effectiveness and appropriateness of the framework thereof and making necessary changes that reflect the results of such verification.

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