Summary of the Policy for the Management of Conflicts of Interest
Mizuho Bank, Ltd. (hereinafter referred to as "MHBK") shall, in accordance with applicable laws and regulations, publish the summary of the policy for the management of conflicts of interest by MHBK, the consolidated subsidiaries, and the equity method affiliates of MHBK that are shown in the financial statements, etc. (hereinafter collectively referred to as the "MHBK Group"), as follows:
Policy for the Management of Conflicts of Interest
The MHBK Group 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, Inc or any of the consolidated subsidiaries and equity method affiliates of the Mizuho Financial Group, Inc that are shown in the financial statements (hereinafter collectively referred to as the "Group"). This is done for the purpose of eliminating and preventing the opportunity for the interests of the customers of the MHBK Group 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.
MHBK 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.
Companies Subject to the Management of Conflicts of Interest
The Companies Subject to the Management of Conflicts of Interest comprise the banks and the securities companies etc. under the MHBK Group. The representative examples of such companies are as follows.
- Mizuho Bank, Ltd.
- Mizuho Capital Co., Ltd.
- Mizuho Capital Partners Co., Ltd.
- Mizuho Corporate Advisory Co., Ltd.
- Mizuho Bank (China), Ltd.
Types of the Transactions Subject to the Management of Conflicts of Interest
The MHBK Group 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: (a) transactions where the interest of one customer of the Group conflicts with the interest of another (e.g., cases where the Group provides advisory services on acquisition to customers who are competing with each other or who are adversaries in some way), or (b) transactions where the interest of a customer of the Group conflicts with the interest of the Group (e.g., cases where the Group sells underwritten corporate bonds to customers while the Group receives repayment of the loan from the respective bond issuer).
Method of Management
The MHBK Group 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 follows:
- Introducing a Chinese Wall to segregate information between the divisions/departments of those that have conflicts of interest with each other
- 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
The MHBK Group may share customer information or information concerning customer transactions with the Companies Subject to the Management of Conflicts of Interest of the 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".
The representative examples of the Companies Subject to the Management of Conflicts of Interest of the Group are as follows.
- Mizuho Financial Group, Inc.
- Mizuho Bank, Ltd.
- Mizuho Securities Co., Ltd.
- Mizuho Trust & Banking Co., Ltd.
The MHBK Group 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.