Important notices and policies

Purpose of use

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)
• Businesses incidental to the Financial Instruments Business, businesses notified to the Prime Minister of Japan or businesses approved by the Prime Minister of Japan; and
• Other businesses in which banks are permitted to engage and business auxiliary to them.

[Purpose]

• For solicitation or sale of  securities and/or  financial products, and providing information about our services.
• For solicitation or sale of  financial products provided by the Company, the affiliated firms or partner companies, and providing the information about services.
• For suitability checks concerning providing the financial products and the services, etc.
• For confirming identification of the customers or the agents of the customers.
• For providing the confirmation or/and the reports including the statement showing the amount of the deposits.
• For conducting the administrative processes in relation with the transaction with the customers.
• For execution of the rights or completion of the obligations based on the agreements with  customers and/or the regulatory requirements.
• For studying and/or developing  financial products or services through marketing, data analysis, and/or questionnaires surveys, etc.
• For conducting the outsourced business to process whole or part of the personal information based on the request of other firms as a outsourcer.
• For conducting other businesses with customers or  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 Act or unless we have obtained consent from customers.

Obtaining personal information

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

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

As a general rule, Company does not ask about sensitive information on individuals 《Examples of this type of information include: race, social status etc.Special care-required personal information (e.g. race, creed, social status, information on medical history or physical disabilities, etc. and criminal record or facts that the individual is a victim of a crime) and membership in a labor union, family origin, domicile of origin, health and medical care and information on sexual life)》. Any sensitive information stated on a copy of official ID documents such as domicile of origin will be blacked out before filing.

Personal data provided to the third parties

We will not provide the personal information of the customers to  third parties except where there is customer consent or where such use is exempted by the Act.

How to manage the information

We provide appropriate measures to keep customers' personal information accurate and up-to-date. We conduct appropriate management by taking institutional security control measures, human security control measures, physical security control measures and technological security control measures to protect customers’ personal information from loss, damages, and leakage, etc.

We may outsource all or part of the handling of personal data of customers to third parties other than us (including third parties located in a foreign country). We will appropriately oversee its outsourcing contractors that handle personal data. When handling the personal data of customers in foreign countries, we provide appropriate management by understanding the external environment.

Procedure for customer requests

When we are requested to inform the purpose, disclose, correct, add, delete, cease using, or erase the personal data which we hold, or to stop providing to third parties or to disclose records on provision to third parties, we will take the following actions.

• We will ask customers to make a request in writing to our Compliance Department (Please refer to the “Complaint and Contact” as described below).
• We will follow the identification process referring to the Act for Prevention of Transfer of Criminal Proceeds.
• We will ask  customers to pay the actual cost for copying and/or sending via mail, etc.

Complaint and contact

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

Compliance department

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

Phone: 03-6266-3500

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

Approved personal data protection organization

We are member of the Japan Securities Dealers Association, an accredited personal data protection organisation bythe Financial Services Agency of Japan. The following consultation offices of this association accept complaints and consultation in relation to the handling of personal data by its member companies:

Japan Securities Dealers Association

Personal Information Consultation Office

https://www.jsda.or.jp/en/personal-information/index.html

Phone: 03-6665-6784

Sharing personal data

We share personal data as follows as far as the law allows us to do.
Sharing with group entities

Purpose of sharing information:

• confirming identification of customers in accordance with laws and regulations for avoiding money laundering
• providing customers with the total service by NatWest Markets Group and NatWest Group
• performing internal control such as compliance, risk management, and internal audit
• Group management
  The items of personal data to be shared
• Name and address
• The name of Organszation (Company) that an individual belongs to 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 NatWest Group plc (Holding company) and its affiliates

The management of the parties to share personal data

The regulations on the protection of personal information in countries other than Japan may not be the same as the regulations under the Act on the Protection of Personal Information of Japan, but we will take appropriate measures to ensure that the treatment of personal information is consistent with the objectives of the Act. In addition, as a global financial institution, NatWest Markets Group and NatWest Group are subject to the financial regulations and any other laws and supervision by the authorities of each country. We may provide personal information to third parties including, without limitation, the supervisory authorities, to the extent necessary to comply with  applicable laws or instructions and/or orders by supervisory authorities.

The name and address and representative’s name of the party that is responsible for the management of shared personal data:

Name:  NatWest Markets Securities Japan Limited

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

Representative:  Kenji Yamamoto

Continuous improvement, etc.

The contents of this policy may changeaccording to amendment of the laws or because of other reasons. The new one is disclosed at our place of business or on our website.

Purpose

With the diversification of services provided by financial institutions and the development of global financial conglomerations, multiple interests compete and conflict with each other within financial institutions and financial groups, increasing the possibility for conflicts of interest.

Under these circumstances, NatWest Markets Securities Japan Limited (hereinafter referred to as "NWMSJ") is required to manage the transactions that may cause conflicts of interest by the Financial Instruments and Exchange Act so that customers' interests are not unfairly impaired.

NWMSJ, a Type I Financial Instruments Business Operator engaged in securities-related business under the Financial Instruments and Exchange Act, has a conflict of interest management policy (hereinafter referred to as the "Policy"), which is required in the development of a conflict of interest management system based on the Financial Instruments and Exchange Act and other related laws and regulations. 

Process for typifying and identifying transactions that may cause conflicts of interest

(1) Covered transactions:

"Transactions that may cause a conflict of interest" subject to this policy refer to NWMSJ or its parent financial institution, etc. (see 3 below) means transactions that may unfairly impair the interests of customers (hereinafter referred to as "covered transactions").

Conflicts of interest may arise between (1) NWMSJ or its parent financial institution, etc. and their customers, or (2) NWMSJ or its parent financial institution, etc. and other customers.

Here, "customer" means (1) a customer who already has a business relationship with NWMSJ or (2) a customer who may enter into a business relationship with NWMSJ, in relation to the "financial instruments-related business" conducted by NWMSJ. However, they exclude customers who are not recognised as related to domestic business (which refers to the business conducted by NWMSJ in Japan).

"Financial instruments related business" means the financial instruments business and the business incidental to the financial instruments business stipulated in Article 35, Paragraph 1 of the Financial Instruments and Exchange Act conducted by NWMSJ.

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

The types of transactions that may cause a conflict of interest are considered as follows. These types are the criteria for determining whether there is a "conflict of interest," but falling under these categories does not immediately constitute a "transaction that may have a conflict of interest." In addition, future additions and corrections may be made as necessary.

• If, through counselling or advice, customers have a reasonable expectation that they will put their interests first (duty-of-loyalty type).
• When there is a possibility that NWMSJ or its parent financial institution, etc. will obtain economic benefits or avoid economic losses contrary to the interests of the customer (duty-of-loyalty type).
• In connection with a transaction with someone other than customer, NWMSJ or its parent financial institution are induced or will be obtained in the future in the form of money, goods or services other than the usual fees or expenses (duty-of-loyalty type).
• When conducting transactions with customers to whom NWMSJ should protect (self-agency type).
• When conducting transactions that stand on the side of the counterparty of a client to be protected by NWMSJ (two-side agency type).
• When NWMSJ engages in a competitive transaction with the customer to be protected (competitive transaction type).
• When conducting transactions that benefit NWMSJ or its parent financial institution, etc. through the use of non-public customer information that should be protected by NWMSJ (information use type).
• When the company is involved in the same transaction from multiple roles and cannot be expected to have the same conditions as a normal transaction (transaction-internalization type).

In determining whether or not a conflict of interest has occurred, NWMSJ will also consider circumstances such as whether there is any impact on the reputation of NWMSJ and the Group. In addition, this 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 Act, or any other laws or regulations.

Scope of companies covered by conflict of interest management:

As described in 2 (1), the covered transactions are transactions conducted by NWMSJ or its parent financial institution, etc.

"Parent financial institution, etc." means a parent corporation, a subsidiary corporation of a parent corporation, or an affiliated corporation of a parent corporation, which falls under any of the following categories:

• business operators,
• banks,
• insurance companies, or
• persons engaged in financial instruments business, banking business, or insurance business in a foreign country in accordance with the laws and regulations of a foreign country.

As of July 1, 2018, the following companies fall under the "parent financial institution, etc." of NWMSJ.

NatWest Group Plc (UK)

NatWest Markets Plc (UK)

Nat West Markets N.V. (Netherlands)

NatWest Markets Securities, Inc. (USA)

Royal Bank of Scotland International (Holdings) Limited,

RBS AA Holdings (UK) Limited

How to manage transactions that may cause conflicts of interest:

If NWMSJ identifies a transaction that may cause a conflict of interest, NWMSJ will appropriately ensure the protection of customers by selecting or combining the following methods and other methods:

• separating the departments that conduct the covered transactions and the departments conducting the transaction with customers
• amending the conditions or method of the covered transaction or the transaction with customer
• discontinuing the covered transaction or the transaction with the Customer
• appropriately disclosing to the customer that there is a possibility that the interests of the customer may be unfairly impaired in connection with the covered transaction (provided that it does not violate the confidentiality obligation of NWMSJ or its parent financial institution, etc.) 

Conflict of interest management system:

(1) Establishment of a control department responsible for managing conflicts of interest

The company shall designate the compliance department as the control department in charge of conflict of interest management.

The conflict of interest management control department:

• is guaranteed independence from the sales department and never receives instructions from the sales department regarding the handling of specific cases.
• supports the Global Control Room, which primarily manages conflicts of interest for the entire Group, and supervises the management system for identifying transactions that may cause conflicts of interest, and managing conflicts of interest at NWMSJ.

(2) Responsibilities of the conflict of interest management control department

It is independent of the sales department and has the following responsibilities:

• In addition to identifying the covered transactions, it instructs the sales department to implement appropriate conflict of interest management related to the covered transactions.
• Matters that have a significant impact on management or significantly impede the interests of customers will be promptly reported to the Chief Internal Control Manager and the Management Committee.
• The department will verify that the covered transactions are managed appropriately, and if necessary, review procedures related to conflict of interest management and the conflict of interest management system.
• If there is a risk that the interests of customers will be unfairly impaired, the department will instruct the sales department to implement appropriate conflict of interest management and review the covered transactions.
• It will provide training to employees on the management of conflicts of interest based on the Global Policy, the Policy, and the Conflict of Interest Management Regulations, and strive to disseminate information on the management of transactions that may cause conflicts of interest.

(3) Records and preservation

When an officer or employee of the sales department identifies a transaction that may have a conflict of interest and selects a management method, they will report to the conflict of interest management control department. They shall prepare an identification record for such transactions and conflict of interest management measures and keep them for five years from the date of creation.

When the department identifies a transaction that may have a conflict of interest and selects a management method, it shall create an identification record for the transaction and the conflict of interest management measures and keep it for five years from the date of creation.

Matters to be considered in light of the knowledge, experience, and financial status of the customers to be solicited and the purpose of entering into a financial instruments transaction agreement.

• The Company fully understands the customers’ knowledge, experience, financial status, purpose of entering transaction agreement, etc., and strives to give solicitation that is suitable for their’ intentions and actual situations.
• The Company solicits products that it considers appropriate in light of the customers’ knowledge, experience, financial status and the purpose of entering the financial instruments transaction agreement.
• In solicitating our products to customers, the Company strives to appropriately explain the structure of products and risks in light of their knowledge, experience, financial status, and purpose of entering financial product transaction agreement.

Matters to be considered regarding solicitation manners and times for the person subject to the solicitation

• In solicitation, we shall put the highest priority on securing the trust of our customers while complying with relevant laws and regulations and devote ourselves to customer-oriented investment solicitation.
• In addition to complying with laws and regulations, the Company strives to solicit based on reasonable grounds.
• The Company will not conduct solicitation activities through telephone calls or visits during hours that are inconvenient to the customers. If our solicitation activities are inconvenient to you, please inform the sales representatives in charge.

Other matters related to ensuring the appropriate solicitation

• The Company conducts appropriate internal training to our employees to prevent inappropriate solicitation. If you have any problems, please contact the Compliance Department.
• Our employees are constantly striving to acquire and improve their knowledge and skills so that we will not disappoint the trust and expectations of our customers.
• The Company complies with the Banking Act, the Act on the Provision of Financial Services, the Financial Instruments and Exchange Act, and relevant laws and regulations, and intends to improve its internal control so that appropriate solicitation is conducted.

The Company intends to provide appropriate information to our customers so that all transactions are conducted based on our customers’ decision and responsibility.

Scope of information shared

Non-public information about customers that NWMSJ has learned to date ("non-public information" such as transaction details, prospective transaction, transaction timing, etc.) including other non-publicly known information about customers obtained in the course of transactions (hereinafter referred to as "non-public information") and non-public information about customers that may be known in the future.

Scope of companies that exchange non-public information

NatWest Markets Group and NatWest Group.

Method of exchanging non-public information

Non-public information may be exchanged orally, in writing, by email, by granting or sharing access to a database, or by other means.

Method of managing non-public information at the recipient

NWMSJ and its Group shall take necessary measures regarding the management of non-public information so that it is not illegally accessed or used by appropriately managing access rights and other methods.

Purpose of sharing non-public information

• To prevent money laundering, such as identity verification based on laws and regulations.
• To provide the comprehensive services of NatWest Markets Group and NatWest Group.
• For compliance, risk management, internal audits and other internal controls.
• For the management of the Group.

How to manage non-public information when the exchange of non-public information is suspended

Customers may opt-out of receiving or sharing non-public information with us at any time in accordance with the contents of this notice. If customers request that NWMSJ stop receiving non-public information between its group and NWMSJ receive such notice, NWMSJ will not provide such non-public information to the other two companies for business purposes. In addition, NWMSJ and its Group will continue to retain non-public information received from the other two companies prior to the request for suspension of such suspension after appropriate management, and may use the non-public information to solicit transactions in the future.

If you wish to stop the exchange and sharing of non-public information among the group (opt-out), please contact the sales representative of NWMSJ in charge of the customer or the person in charge below.

Compliance department
Address: Shin Marunouchi Center Building, 1-6-2 Marunouchi, Chiyoda-ku, Tokyo 100-0005
Phone: 03-6266-3500
Business hours: 9:00am - 5:00pm (excluding weekends and holidays)