Basic Policy for Conflict of Interest Management

1 Purpose

The Norinchukin Bank and its group companies (hereinafter, collectively or respectively, referred to as the "Bank Group") shall manage transactions with the risk of a conflict of interest and appropriately conduct daily operations in order to avoid undue harm to the interests of customers and to achieve customer-oriented business conduct.

2 Bank Group subject to management

The management of a conflict of interest herein shall be applied to the transactions conducted by The Norinchukin Bank and the following of its group companies:

The Norinchukin Trust & Banking Co., Ltd.
Norinchukin Value Investments Co., Ltd.
Norinchukin Zenkyoren Asset Management Co., Ltd.
JA MITSUI LEASING, LTD.
The Agribusiness Investment & Consultation Co., Ltd.
Ant Capital Partners Co., Ltd.
Norinchukin Australia Pty Limited
Norinchukin Bank Europe N.V.
Norinchukin Capital Co., Ltd.
Nochu-JAML Investment Advisors Co., Ltd.

3 Identifying transactions with the risk of a conflict of interest

For the purpose of protecting the interests of customers, the Bank Group shall, in advance of businesses, identify transactions that require careful management from the following perspectives:

(Perspectives of the situation)

  • Situation where there is a concern that duty of loyalty of such Bank Group under the contracts between it and its customer will not be fulfilled due to a conflict of interest.
  • Situation where the interests of a customer with a contractual relationship with such Bank Group are potentially unduly harmed through a transaction conducted by such Bank Group with another customer who competes or conflicts with the former customer.
  • Situation where the interests of a customer are potentially unduly harmed by using non-public information of such customer beyond a reasonable scope.

(Perspectives of the type of the business)

M&A advisory businesses
General Partner businesses of a partnership
Turn-around businesses
Syndicated loan businesses
Corporate bond management businesses
Wealth management businesses

4 Method of managing transactions with the risk of a conflict of interest

The Bank Group shall appropriately protect customers' interests by managing transactions with the risk of a conflict of interest by appropriately combining the following methods.

  • Blocking information between divisions/business group
  • Disclosing the situation of the conflict of interest or acquiring the customer's consent for such situation
  • Changing the terms and conditions of the transaction
  • Cancelling one of the transactions
  • Other methods

5 Management framework for a conflict of interest

The Bank Group shall establish a supervising division for managing transactions with a conflict of interest, identify and manage such transactions, and will continuously improve the management framework for a conflict of interest through implementing the framework, including training of employees. In addition, the Bank Group shall conduct internal audits of the management framework for a conflict of interest and periodically verify its appropriateness and effectiveness.
Furthermore, The Norinchukin Bank, The Norinchukin Trust & Banking Co., Ltd., Norinchukin Value Investments Co., Ltd., and Norinchukin Zenkyoren Asset Management Co., Ltd. shall manage and check the lineup of investment trust products sold by JA Bank from the viewpoint of a conflict of interest based on the Basic Policy on Customer-Oriented Business Conduct announced by The Norinchukin Bank.

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