Our mission is to offer global investment opportunities to Japan, as well as provide the world with a wealth of investment opportunities sprouting out of the Asia-Pacific region. We are fully committed to and engaged in fulfilling the fiduciary duties and other responsibilities entrusted to us by both Japanese and global investors. Nikko AM Group companies and related parties provide a variety of services, and so the interests of our customers do not succumb to undue harm, we conform to the laws listed below and publicly disclose a summary of our Conflict of Interest Control Policy, and shall properly manage transactions with possible conflicts of interests by following the Policy.

1. Transactions with Possible Conflicts of Interest

Among transactions made by Nikko AM Group companies (hereinafter “group companies”), transactions with possible conflicts of interest are those conducted by Nikko AM's parent financial institutions and subsidiary financial institutions in which undue harm may be caused to the interests of customers of financial instruments business, as listed below*

  • When a conflict of interest occurs between a customer and group companies or other customers
  • When there is competition between a customer and group companies or other customers
  • When group companies use information obtained from a customer, benefitting group companies or other customers

* Group companies including Nikko AM's parent financial institutions and Nikko AM's subsidiary financial institutions are listed separately.

2. Types of Transactions with Possible Conflicts of Interest

Transactions with possible conflicts of interests are classified as below, and are managed as not to cause undue harm to the interests of customers:

  1. Transactions with possible conflicts of interest deemed by law as applicable to separate rules of conduct, restricted activities, and measures to prevent harmful effects
  2. Transactions with possible conflicts of interest in operations concerning mergers and acquisitions, acquisition capital finance, etc.
  3. Transactions with possible conflicts of interest in which group companies are involved from multiple positions, including liquidation schemes
  4. Transactions other than those listed above in which undue harm may come to the interests of customers

3. Controlling Conflicts of Interest

Transactions with possible conflicts of interests, in principle, are controlled with the following methods in suitable combination with others. However, group companies that must protect the confidentiality of parties related to transactions with possible conflicts of interests will control any issues without disclosing details on said transactions with possible conflicts of interests. In addition, if there are logical reasons for doing so upon consideration of the degree of the conflict of interest and other circumstances, degrees of control may be established:

  1. Isolate information managed by the departments that handle transactions with possible conflicts of interests and the departments that handle customers
  2. Change the conditions for and/or methods for handling transactions with possible conflicts of interests and/or customers
  3. Stop the handling of transactions with possible conflicts of interests and/or customers
  4. Appropriately disclose information to concerned customers and, if necessary, receive consent from them, regarding the fact that the interests of customers may succumb to undue harm due to transactions with possible conflicts of interest.

In principle, control methods applicable to classification types A through D listed above are:

  1. Transactions with possible conflicts of interests deemed by law as applicable to separate rules of conduct, restricted activities, and measures to prevent harmful effects. In accordance with the intentions of the regulations, comply with the laws so that undue harm is not incurred on the interests of customers. Also, prevent the inappropriate use of customer information through information blocking practices.
  2. Transactions with possible conflicts of interests in operations concerning mergers and acquisitions, acquisition capital finance, etc. Within the Nikko AM Group, confirm that the interests of customers do not conflict with one another by collecting information from each responsible department in advance and/or via consensual validation between concerned departments. When conflicting transactions are discovered, they will either be handled upon explanation of the matter, or depending on the circumstances, one of the transactions will be declined.
  3. Transactions with possible conflicts of interests in which group companies are involved from multiple positions, including liquidation schemes. When customer interests may succumb to undue harm because group companies are involved from multiple positions, transactions will be made upon explanation of the conflicts of interest, or it will be verified if the transaction conditions are impartial.

4. Conflict of Interest Control Framework

In order to properly manage transactions with possible conflicts of interests, Nikko AM has appointed the Business & Regulatory Compliance Department as the department responsible for conflict of interest control and the head of the Business & Regulatory Compliance Department as the manager responsible for overseeing conflict of interest control. They are charged with maintaining the conflict of interest control framework and periodically verifying its effectiveness, as well continuously striving to improve it; and also communicating all aspects of conflict of interest control to officers and employees through education and training practices.

Appendix: Related Group Companies

• Sumitomo Mitsui Trust Bank, Limited.
• Sumitomo Mitsui Trust Research Institute Co., Ltd.
• Sumitomo Mitsui Trust Asset Management Co., Ltd.
• Japan Trustee Services Bank, Ltd.
• SBI Sumishin Net Bank, Ltd.
• Sumitomo Mitsui Trust Card Co., Ltd.
• Sumitomo Mitsui Trust Loan & Finance Co., Ltd.
• Sumitomo Mitsui Trust Panasonic Finance Co., Ltd.
• Sumitomo Mitsui Trust Leasing (SINGAPORE) Pte, Ltd.
• Sumitomo Mitsui Trust Investment Co., Ltd.
• Sumitomo Mitsui Trust (Hong Kong) Limited
• Tokyo Securities Transfer Agent Co., Ltd.
• Japan Securities Agents, Ltd.
• Sumitomo Mitsui Trust Realty Co., Ltd.
• Sumitomo Mitsui Trust Real Estate Investment Management Co., Ltd.
• Top REIT Asset Management Co., Ltd.
• Mitsui & Co., Logistics Partners Ltd.
• Nikko Asset Management Co., Ltd.
• Nikko Asset Management Americas, Inc.
• Nikko Asset Management Asia Limited
• Nikko Asset Management Australia Limited
• Nikko Asset Management Europe Ltd.
• Nikko AM Limited
• Nikko Asset Management International Limited
• Asian Islamic Investment Management Sdn. Bhd.
• Nikko Asset Management New Zealand Limited
• SIM Funds Management Limited
• Nikko Asset Management Hong Kong Limited
• Ambit Mauritius Investment Managers Private Limited
• Nikko AM Equities Australia Pty Limited
• Affin Hwang Asset Management Berhad
• Ambit Investment Advisors Private Limited
• Sumitomo Mitsui Trust International Limited
• Sumitomo Mitsui Trust Bank (Luxembourg) S.A.
• Sumitomo Mitsui Trust Bank (U.S.A) Limited
• Sumitomo Mitsui Trust (UK) Limited
• OIF (PANAMA) S.A.
• STB Finance Cayman Ltd.
• STB Preferred Capital 3 (Cayman) Ltd.
• STB Preferred Capital 4 (Cayman) Ltd.
• Fresco Asset Funding Corporation
• Crecer Asset Funding Corporation
• Vector Asset Funding Corporation
• Nexus Asset Funding Corporation
• Affin Capital Services Berhad
• Nikko AM Japan Property Fund I Pte. Ltd.
• Nikko AM Japan Property I-I Pte. Ltd.
• Nikko AM Japan Property I-II Pte. Ltd.
• Sky Ocean Asset Management Co., Ltd.
• Sea Bridge Finance Limited
• Trust Capital Mezzanine 2015 Investment Partnership
• Trust Capital Private Equity Partners Investment Partnership VIII
• Sumitomo Mitsui Trust Bank (Thai) Public Company Limited
• SBI Card Co., Ltd.
• JP Asset Management Co., Ltd.
• FA Leasing Co., Ltd.
• Sumitomo Mitsui Trust Club Co., Ltd

(As of December 1, 2016)