• Privacy Policy/Security Policy
  
  
• Best Execution Policy
  
  
• HSBC JAPAN POLICY ON CONFLICTS OF INTEREST (Summary)
  
  
• Standing Firm Against Anti-Social Forces (ASFs)
  
  
• Alternative Dispute Resolution procedures for Complaint and Dispute
  

Please refer to Privacy & Security and Terms of Use for our declaration of personal data protection and security of personal data.

Use of Personal Information
We will limit the use of personal information to the extent necessary for our business operations and the implementation of the purpose of use as disclosed below.

Business Operations

• Securities business (including selling, brokering and underwriting shares) and any other related activities;
• Businesses and any other activities in which the securities companies are permitted to be engaged, including insurance offering, futures, investment advisory and commodity trades; and
• Any other activities and related businesses in which the securities companies may be engaged in (including activities which may be permitted in the future).

Purpose of Use
The Company and any affiliated or associated company of the Company shall use personal information for the following purposes in relation to the providing of financial products and services. Note, however, that we shall not use personal information such as race, religious affiliation, ethnicity or nationality or health and criminal records, or provide such information to third parties, in accordance with any laws and regulations concerning securities companies, unless we deem it appropriate to do so in the ordinary course of business.

• To provide information for the solicitation and sale of financial products and services based on the Financial Instruments and Exchange Law.
• To provide information for the invitation and sale of financial products and services on behalf of the Company and its affiliates.
• To determine the appropriateness of the products and services based on the principle of adequateness.
• To check the customers' or customers' agents' identity under the Customer Due Diligence Law and the Hong Kong Monetary Authority Guidelines.
• To report to the customers regarding their transactions and balances.
• To conduct administrative work regarding the customers' transactions.
• To conduct market investigations and for the purposes of research and development of products and services by analysing data and questionnaires.
• To appropriately pursue the delegated businesses whether wholly or partly, such as handling of personal information.
• To propose products and services of the HSBC Group Companies and their affiliates.
• To introduce other HSBC Group Companies and their affiliates.
• To accomplish the transactions for the customers.

We may use personal data jointly with HSBC Group companies or agent companies to implement the purpose of use as disclosed above, within the scope legally permitted. You can veto a purpose of use that involves the sending of such direct mail.

Procedures for Disclosure
In response to your request for the purpose of use, disclosure, correction, addition, deletion, stopping the use or providing third parties with personal data (hereinafter referred to as "requests for disclosure") we will disclose such personal data within 10 days from the request. We will do so by delivering it in writing or by a means agreed by the person who requested the disclosure. However, where any one of the following items applies, we may choose not to disclose any part or all of the data.

1. Where disclosure would harm the life, person, property, or other rights and interests of the principal or of a third party
2. Where disclosure would significantly hinder the fair implementation of the operations of the Business Handling Personal Information
3. Where disclosure would result in the breach of another law
   If we decide that any part or all of the requested personal data is not to be disclosed, we will notify such decision to that effect without delay.

Please request and submit the request form provided when making a request for disclosure. We will conduct a customer identity checking process including agents in accordance with the procedures required by the Customer Identification Law.
Agents who may make a request for disclosure shall be the following agents:

1. A legal guardian of a minor or ward that is of age
2. An agent authorised by the principal to make the request for disclosure

We will request a public certificate or power of attorney to confirm the agent's authority, in addition to the customer identity checking process.

We will charge a service fee when we are requested to make a disclosure. We will set the the service fee within a range deemed to be reasonable considering the actual cost, which will be minimum JPY 5,250 per request. The fee will be payable in cash when you make the request or by bank transfer.

Contact
We will make every effort to make ongoing improvements of our security policy and comply with the relevant laws and ordinances. If you have any questions on our security measures for personal data, complaints or request for disclosure, please contact the Compliance Department.

HSBC Securities (Japan) Limited
Tel: 03-5203-3000

We are a member of the Japan Securities Dealers Association, an authorised personal data protection organisation in the financial industry. The Japan Securities Dealers Association accepts complaints and provides consultation to its members.

Complaints Section, Japan Securities Dealers Association
Contact for complaints/consultation - Tel: 03-3667-8008

March 2008
HSBC Securities (Japan) Limited, Tokyo Branch

This Best Execution Policy establishes the policy and method in order to execute orders on the best possible terms for the client as stipulated in Article 40-2, Paragraph 1 of the Financial Instruments and Exchange Law.

When HSBC Securities (Japan) Limited ("HSBC Japan") receives an order from a client involving securities listed on financial markets in Japan, we will do our best to execute the order in accordance with the following policy, unless the client provides other instructions concerning how the transaction should be executed.

1. Applicable securities
   
   (1)"Listed stocks, etc." as defined in Article 16-6 of the Enforcement Ordinance of the Financial Instruments and Exchange Law, which includes stocks, convertible bonds, exchange-traded funds (beneficiary certificates of investment trusts linked to equity indexes), real estate investment trusts (REITs), etc.
   (2) Although "securities handled" as defined in Article 67-18, Item 4 of the Financial Instruments and Exchange Law, which includes Green Sheet stocks and Phoenix stocks, convertible bonds, etc., are legally covered by the best execution policy, we do not perform transactions for these securities.
   
   
2. Method for executing orders on the best terms
   
   We will handle all orders received from clients as brokerage orders and will not serve as the direct counterparty for these transactions. All orders from clients concerning listed stocks, etc. will be executed on financial markets in Japan. We will not use off-exchange transactions, including proprietary trading systems (PTS).
   
   (1) When an order is received from a client, we will immediately execute the transaction on a financial market in Japan where the applicable security is listed. When an order is received after trading hours for financial markets, the order will be executed after the financial market reopens. (2) Orders from clients will be executed on financial markets as follows.
   
   (a) For securities listed on a single financial market, the order will be executed on that market.
   
   (b) For securities listed on multiple financial markets, the order will be executed on the market that we select as having the highest liquidity based on trading volume and other items during a specific period. Specific reasons for selection of a particular market, in addition to the items that we already disclose, will be provided to clients upon request.
   
   (c) If we are not a participant or member of the market used in (a) or selected as described in (b), we will execute the transaction on that market using a party that is a participant or member of that market and with which we have a brokerage contract for orders on that market.
   
   
3. Reason for selection of a particular method
   
   We use financial market rather than off-exchange transactions because we believe that financial market transactions are better from the clients' standpoint. Financial markets attract a large volume of orders from investors, resulting in greater liquidity, a better possibility of completing a transaction, faster transactions, and other advantages. For securities listed on multiple financial markets, we use the market with the highest liquidity because we believe that this is in the best interests of the client.
   
   
4. Other items
   
   (1) Irrespective of the order execution method used as prescribed in the above item 2, the transactions listed below will be executed as follows.
   
   (a) For transactions where the client specifies a particular execution method (request for HSBC Securities to act as the direct counterparty, request for execution on a particular financial market, request for execution during a particular time of day, etc.), we will use the specified method.
   (b) For transactions involving odd lots or amounts of less than one trading unit (tangen), we will use financial product companies that handle these transactions
   
   (2) There may be instances where we are forced to select an order execution method that is not consistent with this best execution policy due to a computer system malfunction or other problem. In this case, we will do our best to execute the order on the best terms possible at that time.

Our obligation involving the best execution of orders is not restricted to the price. We are obligated to execute orders in the best manner by also taking into account cost, speed, reliability and many other factors associated with the order. Consequently, there may be instances where, following the execution of an order, the terms do not appear to be the best possible based on price alone. However, it is not possible to use solely the price as the basis for determining whether or not a particular transaction is in violation of the best-execution obligation.

HSBC Holdings plc, its subsidiaries and associates (HSBC Group) is a global organisation which provides an extensive range of financial services to its customers around the world. In Japan, HSBC Group entities include branches of The Hongkong and Shanghai Banking Corporation as well as HSBC Securities (Japan) Limited and HSBC Global Asset Management (Japan) KK.

As the HSBC Group engages in a wide range of commercial and investment banking, brokerage, funds management, hedging transactions and investments it is possible that companies or businesses within the HSBC Group may from time to time potentially have interests which conflict, or potentially conflict, with its customers' interests or with the duties that it owes to its customers.

The types of conflicts include (a) those arising between the interests of HSBC on the one hand and with the interests of its customers on the other, (b) those conflicts between different customers, and (c) conflicts between an employee of HSBC Group and a customer.

For example, HSBC Group may trade proprietary positions in a security when at the same time another business or entity within HSBC Group may have information about future transactions with customers in relation to that security. HSBC Group may also provide advisory and financing services to one customer in respect of a bid and seek to provide financing services to another customer in respect of the same bid.HSBC Group has therefore established comprehensive Conflict of Interest Management procedures which are designed to identify and manage such potential conflicts of interest. A key element of such procedures is that HSBC Group staff engaged in different business activities involving a potential conflict of interest must carry on those activities independently of one another.

In Japan, the Compliance Department, which is managed independently from business departments, is the responsible department for Conflict of Interest Management. The Compliance Department identifies potential conflicts of interest by monitoring the necessary business information and where applicable taking appropriate measures to manage and control conflicts of interest when they arise. These control procedures include organisational measures and administrative arrangements to safeguard the interests of customers and clients.

Where necessary, HSBC Group maintains arrangements which restrict the flow of information to certain employees in order to protect its customers' interest and to prevent improper access to customer information. Rules are also in place to prevent insider dealings by employees of HSBC Group.

In certain circumstances, HSBC Group may consider it appropriate to disclose a potential conflict of interest to a customer and obtain the customer's formal consent to proceed.

However, HSBC Group will decline to act in any circumstance where a customer declines to give consent or where it considers that the potential conflict of interest cannot be managed without risk of damage to the interest of any customer.

The scope of conflicts of interest management is the activities of The Hongkong and Shanghai Banking Corporation Limited, HSBC Securities (Japan) Limited, HSBC Global Asset Management (Japan) KK and all other HSBC Group companies worldwide which engage in financial business. Please be advised that HSBC Global Asset Management (Japan) KK does not share individual customer information with remaining HSBC Group companies.

Any customer requiring more details of our Conflict of Interest Management procedures should contact their Relationship Manager or other contacts at any of HSBC's offices in Japan.

As a responsible organisation the HSBC Group is committed to actively engaging in activities which contribute to the maintenance of stability and social order. It is our policy to take a firm stance against any group or organisation which engages in activities that may be deemed anti-social. Our position is in accordance with recent guidelines issued by both the Financial Services Agency and the Japan Securities Dealers Association, namely we will:

1. Resolutely oppose any attempt by ASFs to associate with us.
2. Take all reasonable measures to protect HSBC staff against the activities of ASFs during the performance of their jobs.
3. We will continue to support external parties, including the police and legal professionals, in their fight against ASFs.
4. We will use the Japanese legal system to protect our staff and our business against ASFs.