Legal Information

Conduct is a critical component of all of HSBC’s business activities. It is embedded within the Group’s strategy, business models and planning, our culture and behaviours, interaction with customers, products and services, financial markets operations, and governance and oversight processes.

We have established a Global Conduct Framework with five pillars and 15 outcomes describing the behaviours to which we aspire. It increases our understanding of how the decisions we make affect customers and other stakeholders, helping us to strengthen our business.  Our conduct framework governs everything we do and aligns to the JFSA’s Client Centric Fiduciary Principles for which our businesses in Japan fully support.

Each global business and global function must ensure that its policies are designed to deliver the outcomes set out in the Global Conduct Framework.

The Pillars	Global Conduct Outcomes
Pillar 1: Strategy and Business Models	Our strategy, business models, and the decisions we make deliver fair treatment of customers and do not disrupt market integrity
Pillar 2: Culture and Behaviours	Our culture supports our people and empowers them to consistently do the right thing for our customers and markets in which we operate Our people are competent and committed to the fair treatment of customers and not disrupting the integrity of markets We are open to challenge, we acknowledge when things go wrong, we fix things and we learn from our mistakes We reward and incentivise performance, behaviours and attitudes which deliver the fair treatment of customers and uphold market integrity
Pillar 3: Customer	We know our customers and understand their needs - we actively listen to them and ask the right questions Our products are designed to meet the different needs of our customers, to be competitive and to be understandable Our products and services provide a balanced exchange of value between HSBC and our customers Throughout our sales and servicing we are efficient, transparent and customer-focused We manage our products and services so that our customers’ experience is in line with the expectations we set
Pillar 4: Markets	We seek to prevent and will proactively identify actions and behaviours that constitute market misconduct, and respond appropriately Trades are executed in a timely, clear and controlled manner ensuring that optimal execution is achieved for our customers and that HSBC trades are not manipulative We manage conflicts of interest and appropriately handle information to reduce the opportunity for misuse
Pillar 5: Governance and Oversight	Our governance framework provides effective oversight of how we fairly treat customers and uphold market integrity We engage with regulatory bodies in a timely, open and transparent manner

The Bank has set the following policy with respect to the handling of the customer’s Personal Information, Individual Number and Specific Personal Information (collectively, "Personal Information, etc.").

When handling customer’s Personal Information, etc, the Bank will comply with this policy in addition to the relevant laws and regulations, including the Personal Information Protection Law (“PIPL”), and the relevant guidelines, including the Personal Information Protection Guideline in the Financial Industry (“Financial Industry Guideline”). The Bank will continually review and improve this policy about handling of Personal Information, etc.

In this policy:

"Connected Person" means a person whose information the customer provides to the Bank in connection with transactions with the Bank. Connected Person may include, but is not limited to, any agent, any beneficiary, trustee or settler, and any substantial owner, representative, director or officer of the customer.

“Sensitive Information” is the one defined in Financial Industry Guideline, it includes below “Special Care-required Personal Information” and other information like membership of workers’ unions, family origin, registered domicile, health record and sex life etc. (excluding the parts under “Special Care-required Personal Information”).

“Personal Information” is the one defined in PIPL, it means information about a living individual which can identify the specific individual by a name, date of birth or other description contained in such information; or information containing an individual identification code defined in PIPL.

“Personal Data” is the one defined in PIPL, it means Personal Information constituting a personal information database etc. defined in PIPL;
"Individual Number" means the number obtained by converting a resident record code in order to identify a person (so called “My Number”);
"Specific Personal Information" means the Personal Information that includes the Individual Number;

"Special Care-required Personal Information" is the one defined in PIPL, it means personal information comprising a principal's race, creed, social status, medical history, criminal record, fact of having suffered damage by a crime, or other descriptions etc. of which the handling requires special care so as not to cause unfair discrimination, prejudice or other disadvantages to the principal.

1. Purposes of Use of Personal Information, etc.

The Bank will use Personal Information, etc. of the customer (including its Connected Persons to the extent necessary for the implementation of the following purpose of use) to the extent necessary for the following purposes of use within the following business operations, , except where the Bank obtains such customer’s consent or where permitted under the relevant laws and regulations. For the avoidance of doubt, the Bank will use the Individual Number and Specific Personal Information only to the extent permitted under the relevant laws and regulations.

(1) Business Operations

1. Deposit operations, exchange operations, currency operations, loan operations, credit card issuance, foreign exchange operations and such other operations related thereto.
2. Any other operations that the Bank may engage in and such other operations related thereto (including operations in which the Bank may be allowed to engage in the future).

(2) Purposes of Use

The Bank and any affiliated or associated company of the Bank will use the customer's Personal Information, etc. for the following purposes in relation to the provision of financial products and services. Note, however, that in compliance with Article 13-6-6 of the Ordinance for Enforcement of the Banking Act (“Ordinance for BA”) etc, such information regarding the repayment abilities of the (prospective) borrower provided to the Bank by a personal credit information bureau will be used only for the purposes of investigating the repayment abilities of such (prospective) borrower. Note, further, that in compliance with Article 13-6-7 of the Ordinance for BA etc., the Bank will not use, nor shall it provide to a third party, any sensitive and non-public Personal Information of the customer, such as race, religious affiliation, family origin, registered domicile or health and criminal records, unless the Bank deems it necessary to do so for its proper business operations or otherwise.

The Bank will endeavour to decide the purposes of use as concretely as possible so that they are transparent to the customers, and will endeavor to specify the purpose limitedly at the time of acquiring the information. For example, if the Bank intends to propose its products using Personal Information acquired by conducting a questionnaire, the Bank will disclose such intention.

1. To solicit and sell various financial products and/or securities, to open accounts and otherwise to provide information of, and accept applications for, financial products and services.
2. To (i) ascertain the customer's identity under the Act on Prevention of Transfer of Criminal Proceeds, Foreign Exchange and Foreign Trade Law and Hong Kong Monetary Authority Guidelines, (ii) avoid financial crimes, money laundering, and comply with sanctions programmes that are administered by Japan, the United States, the United Kingdom, the European Union, Hong Kong, United Nations, etc. or (iii) ascertain the customer's qualifications for eligibility to certain financial products and/or services.
3. To administer ongoing transactions, including for term administration in deposit transactions and loan transactions, etc.
4. To make decisions about loan applications and continuous use of loan facilities, etc.
5. To make decisions about the appropriateness of providing financial products and services, such as decisions made in light of the principle of suitability.
6. To provide information to third parties to the extent necessary to carry out appropriate operations, such as providing Personal Information, to an affiliated personal credit information bureau when engaging in the business of providing credit.
7. To appropriately carry out commissioned operations when commissioned with all or part of the processing of Personal Information by another business etc.
8. To fulfill obligations and exercise rights based on contracts with the customer or based on laws.
9. To research and develop financial products and services by conducting market research, as well as data analysis and questionnaires.
10. To make proposals on financial products and services, by sending out direct mail etc.
11. To make proposals on the products and services of HSBC Group Companies or associated companies etc.
12. To effectuate cancellations of various transactions and to conduct follow-up management after the cancellations.
13. To monitor and control the various risks that are necessary for the management of the HSBC Group.
14. To accomplish the transactions and others for customers.

Notwithstanding the purpose of use provided in each item above, the Bank will not use Individual Number and Specific Personal Information for the purposes other than those permitted under the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures. The Bank’s purposes of the use of Individual Number and Specific Personal Information are as follows;

1. Preparation of legal documents regarding financial instrument transactions
2. Processing of account opening and reporting regarding financial instrument transactions
3. Preparation of legal documents regarding overseas remittance etc.
4. Processing of linking Individual Numbers and deposit/saving accounts
5. Preparation of legal documents regarding payment records
6. Other purposes in relation to i through v above.

About purpose of using Personal Information, etc. by the Bank, it will be seen from the Bank's web page.

(3) Discontinuance of Direct Marketing

In case a customer himself/herself requests the Bank to stop using his/her Personal Information for the purpose of direct marketing such as sending direct mails or solicitation by phone, the Bank will discontinue the usage for such purpose.

2. Proper Acquisition of Personal Information, etc.

The Bank will acquire the customer’s Personal Information, etc. if deemed necessary to achieve the purposes of use specified in item 1 above by the appropriate and legitimate methods.

<Examples>

• When the customer provides the information by filling out the forms such as an account application and submitting them directly to the Bank (Submission of the form by the customer himself/herself, Registration of data through Web site by the customer himself/herself, etc.)
• When the third parties such as joint users of clearing houses at various locations or personal credit information bureaus provide the information.
3. Personal Data Provided to Third Parties

The Bank will not provide any of customer’s Personal Data it retains to third parties without the prior consent of the individual concerned, except as permitted by the relevant laws and regulations. However, in the case where the Personal Data is provided accompanied by the Bank entrusting the handling of the Personal Data within necessary scope to achieve a utilisation purpose or in the case where the Personal Data to be jointly utilised by a specified person set forth in item 6 below, the Bank may provide customer’s Personal Data even without prior consent of customers.

For providing the Persona Data to third parties in foreign countries (including above cases of the entrustment of the handling of the Personal Data and the joint use of the Personal Data), the Bank will not do so without getting prior consent of the customer for this provision, except the cases permitted by the relevant laws and regulations. For the avoidance of doubt, for a third party in foreign countries which prescribed by rules of the Personal Information Protection Commission (“PPC”) as a foreign country establishing a personal information protection system recognized to have equivalent standards to that in Japan, or a third party establishing a system conforming to standards prescribed by rules of the PPC as necessary for continuously taking action equivalent to the one that a personal information handling business operator shall take concerning the handling of the Personal Data, the Bank may provide the customers’ Personal Data to the third party without getting prior consent of the customer.

Further, the Bank will not provide any of Individual Number and Specific Personal Information to third parties beyond what is allowed under the laws and regulations.

4. Handling the Sensitive Information

The Bank will not acquire, utilize, nor provide to third parties, customer’s Sensitive Information, except cases as illustrated by the Financial Industry Guideline including the case based on laws and regulations and the case in which there is a prior consent of the individual concerned within the scope of business need.

5. Entrustment of the Operation concerning Personal Data

The Bank entrusts its operations concerning the Personal Data to the third party within the necessity to achieve the purposes of use as exemplified below. Note that the Bank, in entrusting its operations to a third party, will execute an agreement with the third party regarding the stringent handling of the Personal Data within such third party, and ensure that there are appropriate security control measures in place.

<Examples>

• Operation to issue transaction advices /statements
• Operation related to outward remittance such as foreign exchange
• Operation to send out direct mails
• Operation and maintenance of computer systems
• Maintenance of books and records relating to the business operations
6. Joint Use of Personal Data

The Bank may jointly use the Personal Data (excluding Individual Number and Specific Personal Information) with the other parties as follows:

(1) Joint Use of Information from Official Gazette (kanpo)

1. Items Jointly Used
   Information published on the Official Gazette (such as name, address, fact of being bankrupt etc., date, etc.)
2. Scope of Joint Users
   Members of Personal Credit Information Center of Japanese Bankers Association ("CIC") and Japanese Bankers Association ("JBA") Note: CIC is a personal credit information bureau that was established and is operated by JBA, and its membership qualifications are as follows:
1. An official member of JBA
2. A bank other than a. above and other financial institution that is deemed as bank under laws and regulations.
3. A governmental financial institution or one similar to it.
4. A credit guarantee corporation established under the Credit Guarantee Corporations Law (Law No. 196 of 10th August, 1953).
5. Any other legal entity which engages in the business of credit extension to individuals and which a member under i to iii above has recommended.
3. Purpose of Use
   A member of CIC will use the information to decide on matters regarding its own credit extension transactions.
4. Name of Party Responsible for Management of the Personal Data Japanese Bankers Association

(2) Joint Use of Information of Dishonor (Fuwatari)

1. Items Jointly Used
   Information on the drawer of a dishonored draft or check, and on the party requesting the opening of a current account. More specifically as follows:
1. Name of that drawer (in case of a legal entity, its name, the name of its representative and his/her title).
2. Trade name, if that drawer has one.
3. Address (in case of a legal entity, its place of business) (inclusive of postal code).
4. Name of the party requesting the opening of a current account (in case of a legal entity, its name, the name of its representative and his/her title, as well as its trade name, if it has one).
5. Date of birth.
6. Occupation.
7. Stated Capital (applicable only to legal entities).
8. Type and face amount of that draft or check.
9. Whether it is a report on dishonor (first time dishonor) or a report on suspension of bank transaction (suspension of bank transactions).
10. Date of clearing (date of presentment).
11. Paying bank (inclusive of the name of its department or branch).
12. Presenting bank (inclusive of the name of its department or branch).
13. Reason for dishonor.
14. Date of imposition of suspension of bank transaction.
15. Clearing house in which the paying bank (branch) of the dishonored draft or check participates, and the bankers association to which such clearing house belongs.

Note: The information under i to iii above will include such information as it appears on the dishonored draft or check, if such information is different from the information registered with the Bank.

2. Scope of Joint Users
• Clearing houses at various locations.
• Participant financial institutions of such clearing houses.
• CIC which was established and is operated by JBA.
• Local bankers associations at various locations which are special members of JBA (inclusive of such local bankers associations' reference centers for parties subject to suspension of bank transactions).

Note: For the list of Joint Users, please refer to the webpage of JBA.

3. Purpose of Use
   

   The information will be used for the procurement of smooth negotiation of drafts and checks, and by the financial institutions to decide on matters regarding its own credit extension transactions.

4. Name of Party Responsible for Management of the Personal Data
   Bankers association to which the clearing house (in that the paying bank of the dishonored draft or check participates) belongs to.

(3) Joint Use of Information among HSBC Group Companies

The Bank may jointly use the Personal Data with HSBC group companies by the destination to provide high value-added production and service and/or realize strong risk management and enhancement on the whole HSBC group business control. This joint use will be made under necessary control measure, and when there are restriction set by applicable laws/rules such as Financial Instruments and Exchange Act other than PIPL, the Bank will comply with such laws/rules.

1. Items Jointly Used
   Information of the customer (including its Connected Persons to the extent necessary for the implementation of the Purpose of Use) regarding the Bank's deposit, lending, exchange and other transactions (name, address, date of birth, contents and purpose of the transaction, occupation).
2. Scope of Joint Users
   The Bank and other HSBC Group Companies the ultimate parent company of which is HSBC Holdings plc.
   (http://www.hsbc.com/about-hsbc/structure-and-network)
3. Purpose of Use
• The information will be used to monitor and manage the various risks that are necessary to be so monitored and managed for the business operations of the HSBC Group.
• To (i) ascertain the customer's identity under the Act on Prevention of Transfer of Criminal Proceeds, Foreign Exchange and Foreign Trade Act and Hong Kong Monetary Authority Guidelines, (ii) avoid financial crimes, money laundering, and comply with sanctions programmes that are administered by Japan, the United States, the United Kingdom, the European Union, Hong Kong, United Nations, etc. or (iii) ascertain the customer's qualifications for eligibility to certain financial products and/or services.
• To properly and smoothly implement the transactions with customers.
4. Name of Party Responsible for Management of the Personal Data The Hongkong and Shanghai Banking Corporation Limited
7. Procedures for Disclosure etc. of Retained Personal Data

The Bank, upon the customer's request/demand for Disclosure etc. (“Demand for Disclosure etc.”) (the term of "Disclosure etc." means notification of purpose of utilise, disclosure, correction, addition or deletion, utilisation cease or deletion, ceasing a third party provision etc.) of the "retained personal data" defined in PIPL (“Retained Personal Data”), will effectuate the Demand for the Disclosure etc. without delay, by means of delivering documents or by other means agreed to by the customer.

In case the customer inquiries about the existence of his/her Individual Number in the Bank's record, the Bank will disclose whether it retains such Individual Number or not.

(1) Exception

The Bank will not disclose the Retained Personal Data in its entirety or in part under the following circumstances:

1. Where the disclosure may harm the life, body, property or other rights and interests of the principal or of a third party.
2. Where the disclosure may significantly hinder the fair implementation of the operations of the Bank.
3. Where the disclosure may result in the breach of another law or regulation.

If the Bank decides not to accept the customer's Demand for Disclosure etc. in whole or in part, the Bank will notify the customer thereof without delay.

(2) Procedures for Disclosure etc.

In order to make a Demand for Disclosure etc., the customer is required to submit the form required by the Bank. Note that the Bank, in effectuating the Disclosure etc. will conduct the identity checking process with regard to the customer or his/her agent in such a manner as comparable to the procedures required by the Act on Prevention of Transfer of Criminal Proceeds etc., by requesting the customer or such agent to submit official documents etc.

(3) Request by Agent

An agent who may make a Demand for Disclosure etc. on behalf of the customer shall be one of the following agents:

1. A legal guardian of the customer who is a minor or a ward that is of age.
2. An agent authorized by the customer to make the request for Disclosure etc.

The Bank will request a public certificate or power of attorney to confirm the agent's authority, in addition to the above mentioned identity checking process.

(4) Handling Fee

The Bank will charge a fee for handling the request for notice of utilise purpose and disclosure of JPY 1,080 per each request. The fee is payable at the time of such request and will be paid in cash or by deduction from the depositary account with the Bank.

8. Security Control Action

The Bank is taking necessary and appropriate action for the security control to avoid data leakage, loss or damage of customers’ Personal Information, etc. And the Bank will exercise necessary and appropriate supervision over staffs and outsourced vendors who are handling customers’ Personal Information, etc.

9. Contacts

The Bank will be dealing with complaints properly and timely about handling of Personal Information etc. If the customer has any questions or comments on the Bank's operation handling and security control action for Personal Information etc., complaints to the Bank or a Demand for Disclosure etc., please contact:

• Retail Services, Service Delivery:
  
  • 0120-777-268 (domestic/toll -free)
  • 81-3-5204-5001 (overseas/charged)
    9 am - 5 pm, Monday to Friday (Tokyo time)

The Bank is a member of Authorized Personal Information Protection Organizations listed below. Those organizations receive complaints and consultations regarding its member's handling of Personal Information, etc.

• All Banks Personal Information Protection Council (http://www.abpdpc.gr.jp/)
  [Contact for complaints/consultations] JBA Customer Relations Center or Consumer Relations Center nearby Tel: 03-5222-1700
  
• Japan Securities Dealers Association (http://www.jsda.or.jp/)
  Personal Information Consulting Centre
  [Contact for complaints/consultations] Tel: 03-3667-8427
  
• The Financial Futures Association of Japan (http://www.ffaj.or.jp/)
  [Contact for complaints/consultations] TEL: 03-5280-0881
  

The Hongkong and Shanghai Banking Corporation Limited declares the following Solicitation Policy on Financial Products in accordance with Law on Sales of Financial Products.

1. All staff of the Hongkong and Shanghai Banking Corporation Limited (hereafter referred as "the Bank") shall abide by all the laws and regulations as well as this Solicitation Policy in order to conduct marketing financial products in an appropriate and sound manner.
2. The Bank shall solicit financial services/products which the Bank determines to be suitable to the customers, after the bank understands well each customer's knowledge and experience of financial products, financial conditions, purpose of investments.
3. The Bank shall provide proper explanation on products, including the features and associated risks, which is sufficient for customers understanding, based on customers knowledge and experience.
4. The Bank shall not solicit neither at places nor during hours inappropriate to the customers.
5. In order to prevent misleading solicitation, the Bank shall provide truthful information, including those information that may be unfavorable to our customers, and shall not provide judgmental information.
6. The Bank shall make efforts to improve knowledge and skills on our financial products in order to conduct solicitation in an appropriate manner.
7. The Bank shall take sincere attitudes and respond to customer inquiries and complaints with regard to our solicitation, and then shall exploit such learnings in the further improvement of solicitation.

To preserve the confidentiality of all information you provide to us, we have adopted the following privacy principles:

1. We only collect information that we believe to be relevant and required to understand your financial needs and to conduct our business.
2. We use your information to provide you with better customer services and products.
3. We may pass your information to other HSBC Group companies or agents and our outsourced vendors, as permitted by the relevant laws and regulations.
4. We will not disclose your information to any external organisation unless we have your consent or otherwise are permitted by the relevant laws and regulations.
5. We may be required from time to time to disclose your information to Governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority.
6. We aim to keep your information up-to-date.
7. We maintain strict security systems designed to prevent unauthorised access to your information by anyone, including our staff.
8. All Group companies, all our staff and all third parties with permitted access to your information are specifically required to observe our confidentiality obligations.

By maintaining our commitment to these principles, we at HSBC will ensure that we respect the inherent trust that you place in us.

Data Security

Security is our top priority. HSBC will strive at all times to ensure that your Personal Information, etc. will be protected against unauthorised or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Information, etc.

Our web servers are protected behind firewalls and our systems are monitored to prevent any unauthorised access.

All practical steps will be taken to ensure that Personal Information, etc. will not be kept longer than necessary and that HSBC will comply with all statutory and regulatory requirements concerning the retention of Personal Information, etc.

Security Assurance

Both you and HSBC play an important role in protecting against online fraud. You should be careful that your bank account details including your User ID and/or Password are not compromised by ensuring that you do not knowingly or accidentally share, provide or facilitate unauthorised use of it. Do not share your User ID and/or Password or allow access or use of it by others. If you think your User ID and/or Password has been disclosed to a third party, is lost or stolen and unauthorised transactions may have been conducted, please inform us immediately. We endeavor to put in place high standards of security to protect your interests.

Collection of Personal Information

Your visit to this site may be recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be gathered through the use of 'cookies'. Cookies are small bits of information that are automatically stored on a person's web browser in their computer that can be retrieved by this site. Should you wish to disable these cookies you may do so by changing the setting on your browser. However, you may be unable to enter certain parts of our website.

Occasionally we may collect Personal Information from visitors to this site. Such information is only collected from individuals who voluntarily provide us with their Personal Information. We may use this information to advise them of products, services and other marketing materials which we think may be of interest to them. We may also invite visitors to this site to participate in market research and surveys and other similar activities.

If we ask you to provide Personal Information, etc., we will always specify the purpose of collection of Personal Information, etc. and ensure that it is used only for the purpose specified at the time of collection.

Disclosure pursuant to the Banking Act Article 12-3

The Japan Branches of The Hongkong and Shanghai Banking Corporation Limited have signed an agreement with the Japanese Bankers Association (JBA) with respect to the use of customer complaint and dispute resolution procedures to be provided by JBA which is a Designated Dispute Resolution Body under the Banking Act.

Contact Information
JBA Customer Relations Center
Address:	Ginko-Kaikan, 3-1, Marunouchi 1-chome, Chiyoda-Ku, Tokyo,〒100-8216
Phone:	0570-017109 or 03-5252-3772
Website:	http://www.zenginkyo.or.jp/adr/

The Customer Complaint and Dispute Resolution Procedures for Registered Financial Institution business (securities related business), based on the Financial Instruments and Exchange Act Article 37-7, are set out below;

The customer complaint and dispute resolution procedures for this area of business are provided by the Japan Securities Dealers Association/ the Financial Futures Association of Japan ( both through the Financial Mediation Assistance Center(FINMAC))

Contact Information
FINMAC
Address:	Daini Shoken Kaikan, 1-1, Nihombashi Kayaba-Cho 2-chome, Chuo-ku, Tokyo, 〒103-0025
Phone:	0120-64-5005
Website:	http://www.finmac.or.jp

Explanatory Note on Unregistered Credit Rating (For S&P Global Ratings)

From the viewpoint of ensuring fairness and transparency in the markets, Financial Instruments and Exchange Law has introduced the registration system for credit rating agencies. In accordance with this regulation, financial instruments business operators, etc are required to inform customers of the fact that the rating is not registered and the rationale for the registration system, etc. whenever marketing any financial products which are rated by unregistered credit rating agencies.

Rationale for the Registration System

Registered credit rating agencies are subject to the following regulations: (1) the duty of good faith; (2) the duty to maintain an operational management system which prevents conflicts of interest and ensures the fairness of the credit rating process, etc.; (3) the prohibition on giving a credit rating to a security which they hold; and (4) the duty to disclose information including to prepare and make available for public inspection the policies for credit ratings and the documents for public release and explanation. Registered credit rating agencies are also subject to supervision by the Financial Services Agency, including orders to submit information, onsite inspections and business improvement orders. However, unregistered credit rating agencies are not subject to such regulation or supervision.

Name of the Credit Rating Agency Group, etc.

Name of the Credit Rating Agency Group:
S&P Global Ratings (“S&P”)
Name of the Registered Credit Rating Agency within the Group and its Registration Number:
S&P Global Ratings Japan Inc. (FSA Commissioner (Rating) No. 5)
S&P Global SF Japan Inc. (FSA Commissioner (Rating) No. 8)

Method of Obtaining the Information about the Summaries of the Policies and Criteria for Credit Rating

The information is published in the “Unregistered Rating Information” (「無登録格付け情報」http://www.standardandpoors.co.jp) which can be found in the menu under “Library/Regulation Related” (「ライブラリ･規制関連」) on the website of S&P Global Ratings ( http://www.standardandpoors.co.jp/unregistered).

Assumptions, Significance and Limitations of the Rating

Credit ratings assigned by S&P Global Ratings are statements of opinion on the future credit quality of specific issuers or issues as of the date they are expressed and do not indicate the probability of default or guarantee the credit of the specific issuers or issues. Credit ratings are not a recommendation to purchase, sell or hold any securities, or a statement of market liquidity or prices in the secondary market of any issues.

Credit ratings may change depending on various factors, including issuers' performance, changes in external environment, performance of underlying assets, creditworthiness of counterparties and others. S&P Global Ratings conducts rating analysis based on information it believes to be reliable and provides ratings only when it believes to have enough information in terms of quality and quantity to support its opinion. However, S&P Global Ratings does not perform an audit, due diligence or independent verification of any information it receives from issuers or other third parties, nor guarantees accuracy, completeness or timeliness of the information received or the results caused by use of such information. It should be noted that, depending on the credit ratings, there may be inherent risks associated with the limitation on available historical data.

This information is prepared as of 1 May 2018 based on sources which we believe are reliable, but we do not guarantee its accuracy or completeness. For details, please refer to the above mentioned website of S&P Global Ratings.

Explanatory Note on Unregistered Credit Rating (For Moody’s Investors Service)

From the viewpoint of ensuring fairness and transparency in the markets, Financial Instruments and Exchange Law has introduced the registration system for credit rating agencies. In accordance with this regulation, financial instruments business operators, etc. are required to inform customers of the fact that the rating is not registered and the rationale for the registration system, etc. whenever marketing any financial products which are rated by unregistered credit rating agencies.

Rationale for the Registration System

Registered credit rating agencies are subject to the following regulations: (1) the duty of good faith; (2) the duty to maintain an operational management system which prevents conflicts of interest and ensures the fairness of the credit rating process, etc.; (3) the prohibition on giving a credit rating to a security which they hold; and (4) the duty to disclose information including to prepare and make available for public inspection the policies for credit ratings and the documents for public release and explanation. Registered credit rating agencies are also subject to supervision by the Financial Services Agency, including orders to submit information, onsite inspections and business improvement orders. However, unregistered credit rating agencies are not subject to such regulation or supervision.

Name of the Credit Rating Agency Group, etc.

Name of the Credit Rating Agency Group:
Moody’s Investors Service
Name of the Registered Credit Rating Agency within the Group and its Registration Number:
Moody’s Japan K.K. (FSA Commissioner (Rating) No. 2)
Moody’s SF Japan K.K. (FSA Commissioner (Rating) No. 3)

Method of Obtaining the Information about the Summaries of the Policies and Criteria for Credit Rating

The information is published in the “Matters Related to the Explanation of Unregistered Ratings” (「無登録格付説明関連」) in the page of “Use of Credit Ratings Given by Unregistered Companies” (「無登録業者の格付の利用」) which is displayed after clicking “Credit Rating Business” on the website of Moody’s Japan K.K. and Moody’s SF Japan K.K. https://www.moodys.com/pages/default_ja.aspx).

Assumptions, Significance and Limitations of the Rating

Credit ratings are Moody’s Investors Service ("Moody’s ") current opinions of the relative future credit risk of entities, credit commitments, or debt or debt-like securities. Moody’s defines credit risk as the risk that an entity may not meet its contractual, financial obligations as they come due and any estimated financial loss in the event of default. Credit ratings do not address any other risk, including but not limited to: liquidity risk, market value risk, or price volatility. Credit ratings do not constitute investment or financial advice, and credit ratings are not recommendations to purchase, sell, or hold particular securities. No warranty, express or implied, as to the accuracy, timeliness, completeness, merchantability or fitness for any particular purpose of any such rating or other opinion or information is given or made by Moody’s in any form or manner whatsoever.

Based on the information received from issuers or from public sources, the credit risks of the issuers or obligations are assessed. Moody’s adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources Moody’s considers to be reliable. However, Moody’s is not an auditor and cannot in every instance independently verify or validate information received in the rating process.

This information is prepared as of 1 May 2018 based on sources which we believe are reliable, but we do not guarantee its accuracy or completeness. For details, please refer to the above website of Moody’s Japan K.K. and Moody’s SF Japan K.K.

Explanatory Note on Unregistered Credit Rating (For Fitch Ratings)

From the viewpoint of ensuring fairness and transparency in the markets, Financial Instruments and Exchange Law has introduced the registration system for credit rating agencies. In accordance with this regulation, financial instruments business operators, etc. are required to inform customers of the fact that the rating is not registered and the rationale for the registration system, etc. whenever marketing any financial products which are rated by unregistered credit rating agencies.

Rationale for the Registration System

Registered credit rating agencies are subject the following regulations: (1) the duty of good faith; (2) the duty to maintain an operational management system which prevents conflicts of interest and ensures the fairness of the credit rating process, etc.; (3) the prohibition on giving a credit rating to a security which they hold; and (4) the duty to disclose information including to prepare and make available for public inspection the policies for credit ratings and the documents for public release and explanation. Registered credit rating agencies are also subject to supervision by the Financial Services Agency, including orders to submit information, onsite inspections and business improvement orders. However, unregistered credit rating agencies are not subject to such regulation or supervision.

Name of the Credit Rating Agency Group, etc.

Name of the Credit Rating Agency Group:
Fitch Ratings (“Fitch”)
Name of the Registered Credit Rating Agency within the Group and its Registration Number:
Fitch Ratings Japan Limited (FSA Commissioner (Rating) No. 7)

Method of Obtaining the Information about the Summaries of the Policies and Criteria for Credit Rating

The information is published in the “Overview of Policies etc for Credit Rating” (｢格付方針等の概要｣) in the “Regulation Related” (｢規制関連」) section on the website of Fitch Ratings Japan Limited (http://www.fitchratings.co.jp).

Assumptions, Significance and Limitations of the Rating

Ratings assigned by Fitch are opinions based on established criteria and methodologies. Ratings are not facts, and therefore cannot be described as being "accurate" or "inaccurate". Credit ratings do not directly address any risk other than credit risk. Credit ratings do not comment on the adequacy of market price or market liquidity for rated instruments. Ratings are relative measures of risk; as a result, the assignment of ratings in the same category to entities and obligations may not fully reflect small differences in the degrees of risk. Credit ratings, as opinions on relative ranking of vulnerability to default, do not imply or convey a specific statistical probability of default.

In issuing and maintaining its ratings, Fitch relies on factual information it receives from issuers and underwriters and from other sources Fitch believes to be credible. Fitch conducts a reasonable investigation of the factual information relied upon by it in accordance with its ratings methodology, and obtains reasonable verification of that information from independent sources, to the extent such sources are available for a given security or in a given jurisdiction. The assignment of a rating to any issuer or any security should not be viewed as a guarantee of the accuracy, completeness, or timeliness of the information relied on in connection with the rating or the results obtained from the use of such information. If any such information should turn out to contain misrepresentations or to be otherwise misleading, the rating associated with that information may not be appropriate. Despite any verification of current facts, ratings can be affected by future events or conditions that were not anticipated at the time a rating was issued or affirmed.

For a detailed explanation on the assumption, significance, and limits of credit rating, please refer to the section on “Definition regarding credit rating and other forms of opinions” on Fitch’s Japanese website.

This information is prepared as of 1 May 2018 based on sources which we believe are reliable, but we do not guarantee its accuracy or completeness. For details, please refer to the above mentioned website of Fitch Ratings　Japan Limited.

Tokyo Branch and Osaka Branch of The Hongkong and Shanghai Banking Corporation Limited (a bank incorporated under the laws of Hong Kong SAR, the "Bank") is a branch office in Japan of a foreign bank. Deposits held with the Bank's Tokyo Branch are not covered by the Deposit Insurance System of Japan. In case of failure of the Bank, there is a possibility that the depositors might not be able to withdraw the deposits promptly. In addition, the deposits are not covered by the Deposit Protection Scheme in Hong Kong where the Bank is headquartered. Ultimate sources of foreign bank's capabilities lie in the foreign bank as a whole and the Bank's soundness is supervised by the regulatory authorities in Hong Kong.

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.

Please refer to Japanese version.

It has recently come to our attention that third parties (see list below) are fraudulently portraying themselves as belonging to the HSBC Group for illegal financial gain, using registered trade names such as "The Hongkong and Shanghai Banking Corporation Limited", "HSBC" and "HSBC Private Bank". Should you have any suspicion that you have been approached by a fraudulent third party, please exercise caution and contact us

The following organisations have no relationship to the HSBC Group:

• HSPC
• HSBC BANK PAYMENT <hsbconlinebank@mail.md>
• US Fortune Group（美国财富集团）

Protecting Oneself

Phishing/Spam Email

It has recently come to our attention that a third party(s) is fraudulently portraying itself as belonging to the HSBC Group and using the email address "payment.advice@hsbc.com.hk" to send spam email. Please be advised that this email address does not belong to the HSBC Group and that we do not send payment related correspondence to multiple customers using a single email. Should you receive such an email, please delete it immediately, without opening any of the attachments.

Fraudulent individuals can make an email look as if it comes from someone else. Identifying a fake email can be difficult and fraudsters constantly change their methods. However the fake emails often display some of the following characteristics:

• The sender's email address doesn't tally with the trusted organisation's website address.
• The email is sent from a completely different address or a free web mail address.
• The email does not use your proper name, but uses a non-specific greeting like "dear customer".
• A prominent website link. These can be forged or seem very similar to the proper address, but even a single character's difference means a different website.
• A request for personal information such as user name, password or bank details.
• You weren't expecting to get an email from the company that appears to have sent it.

Fake Websites

It is very easy for fraudulent individuals to develop a fake website. However, here are some tips to help identify them:

• Look for evidence of a physical presence, for example, an address or telephone number. If in doubt, make a phone call or write a letter to establish whether they really exist.
• The website's address is different from what you are used to, perhaps there are extra characters or words in it or it uses a completely different name or no name at all, just numbers.
• Right-clicking on a hyperlink and selecting "Properties” should reveal a link's true destination − beware if this is different from what is displayed in the email.
• A request for personal information such as user name, password or other security details IN FULL, when you are normally only asked for SOME of them.

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 Bankers 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.

Hyperlinks from HSBC to Websites outside the HSBC Group

There may be cases on our website when the HSBC Group ("HSBC") provides hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related to HSBC. They have been included in our website to enhance your user experience and are presented for information purposes only. We endeavor to select reputable websites and sources of information for your convenience.

However, by providing hyperlinks to an external website or webpage, HSBC shall not be deemed to endorse, recommend, approve, guarantee or introduce any third parties or the services/ products they provide on their websites, or to have any form of co-operation with such third parties and websites unless otherwise stated by HSBC.

We are not in any way responsible for the content of any externally linked website or webpage. You use or follow these links at your own risk and HSBC is not responsible for any damages or losses incurred or suffered by you arising out of or in connection with your use of the link. HSBC is not a party to any contractual arrangements entered into between you and the provider of the external website unless otherwise expressly specified or agreed to by HSBC.

Any links to websites that contain downloadable software are provided for your convenience only. Again we are not responsible for any difficulties you may encounter in downloading the software or for any consequences from your doing so. Please remember that the use of any software downloaded from the Internet may be governed by a licensed agreement and your failure to observe the terms of such licensed agreement may result in an infringement of intellectual property rights of the relevant software provider which we are not in any way responsible.

Please be mindful that when you click on a link and leave our website you will be subject to the terms of use and privacy policies of the other website that you are going to visit.

Hyperlinks from HSBC to Other HSBC Group Websites

We may also include hyperlinks to other HSBC Group websites for your convenience. The products and services offered on these websites may be limited to persons located or residing in only that particular jurisdiction. In addition, the content on these linked websites may not be intended for persons located or residing in jurisdictions that restrict the distribution of such content. The terms and conditions governing the use of the website of each HSBC Group entity may differ and you should consult and carefully read the applicable terms and conditions before using the website.

Hyperlinks from External Websites to our HSBC Websites

You must always obtain the prior written approval of HSBC before creating a hyperlink in any form from a third party website to any HSBC website. HSBC may or may not give such approval at its absolute discretion. In normal circumstances, we may only approve a hyperlink which displays plainly our name or website address. Any use or display of our logos, trade names and trademarks as a hyperlink will not be approved unless in very exceptional circumstances and may be subject to a fee as HSBC may determine at its absolute discretion.

HSBC is not responsible for the setup of any hyperlink from a third party website to any HSBC website. Any links so set up shall not constitute any form of co-operation with, or endorsement by, HSBC of such third party website. Any link to our website shall always be an active and direct link to our website and shall be made directly to the home or front page of our website only and that no "framing" or "deep-linking" of our web page or content is allowed.

The HSBC Group is not liable for any loss or damage incurred or suffered by you or any third party arising out of or in connection with such link. For further trademarks and copyright information, please refer to the paragraph below. HSBC reserve the right to rescind any approval granted to link through a plain-text link or any other type of link, and to require the removal of any such link to any of the HSBC Group websites, at our discretion at any time.

Our Trademarks and Copyright

The content and information contained within our website or delivered to you in connection with your use of our website is the property of HSBC and any other third party (where applicable). The trademark, trade names, service marks and logos (the "Trade Marks") that are used and displayed on our website include registered and unregistered Trade Marks of ourselves and other third parties. Nothing on our website should be construed as granting any licensed or right to use any Trade Marks displayed on our website. We retain all proprietary rights on our website. Users are prohibited from using the same without written permission of HSBC or such other third parties.

The materials on this website are protected by copyright and no part of such materials may be modified, reproduced, stored in a retrieval system, transmitted (in any form or by any means), copied, distributed, used for creating derivative works or used in any other way for commercial or public purposes without the Bank's or such other third parties prior written consent.

No Warranties

While every care has been taken in preparing the information and materials contained in this site, such information and materials are provided to you "as is" without warranty of any kind either express or implied. In particular, no warranty regarding non-infringement, security, accuracy, fitness for a particular purpose or freedom from computer virus is given in conjunction with such information and materials.

IMPORTANT: By accessing this web site and any of its pages you are agreeing to the terms set out above.

This section contains the Terms of Use of this website. By accessing this website and any of its pages, you are agreeing to these Terms.

Use of Information and Materials

Products and services referred to in this website are offered only in countries where they may be lawfully offered by a member of the HSBC Group. The materials on these pages are not intended for use by persons located in, or resident in, countries that restrict the distribution of such materials.

Non-provision of financial services or products

Neither [The Hongkong and Shanghai Banking Corporation Limited] (the "Bank") nor any HSBC Group members offer any financial services or products through their use and operation of this website, or gateway (the "Site"). Products or services on this Site do not constitute an offer or recommendation of any products or services provided by any of the HSBC Group members. The information provided on this Site is not intended for distribution to, or use by, any person in any jurisdiction where such distribution or use would be contrary to law or regulation. This Site shall not be considered as communicating any invitation or inducement to engage in banking or investment activity or any offer to buy or sell any securities or other instruments outside any jurisdiction where the Bank is not licensed or authorised to perform such activities (hereinafter the "Authorised Countries").

Not all the products and services that you may be able to view via this Site may be available in all geographical locations served by HSBC Group members. You should access only the Local Site(s) associated with your country of residence ("Your Local Site"). If you own products that are not discussed on Your Local Site, information about such products may be accessible on this or another HSBC website. Products and services discussed outside Your Local Site may not be available in your jurisdiction of residence or in the Authorised Countries and may not be appropriate for you. It is the responsibility of any persons accessing this Site and any information available through this Site to inform himself or herself of and to observe fully the applicable laws and regulations of any relevant jurisdiction. HSBC Group members may decline to provide you with products and services solely based on your country of residence.

Products discussed on this Site may not have been registered or authorized by any central bank, governmental or regulatory authority in the Authorised Countries or in the country of your residence. Accordingly, you may not have the benefit of protection from the securities laws, banking laws and other relevant laws and regulations of your country of residence with respect to products or services referred to on or through this Site.

No representation is given that any securities, products, or services discussed in or accessible through this Site are suitable for you or any particular person. You acknowledge that your use of this Site and any requests for information you have made as a result of visiting this Site have not been solicited by the Bank or any of its affiliates and that the provision of any information through this Site shall not constitute or be considered investment or financial advice.

The information contained in these pages is not intended to provide professional advice. Persons accessing these pages should obtain appropriate professional advice when necessary.

Copyright and Trademarks

The Group and other parties own the trademarks, logos and service marks displayed on this website. These may not be used without the written permission of the HSBC Group or the party owning these.

Materials on this site are protected by copyright. No part of these materials may be modified, reproduced, stored in a retrieval system, transmitted, copied, distributed or used in any other way for commercial or public purposes without HSBC's prior written consent.

No Warranties

Whilst every care has been taken in preparing the information materials contained in this website, such information and materials are provided 'as is' without warranty of any kind, either express or implied. In particular, no warranty regarding non-infringement, security, accuracy, fitness for a purpose or freedom from computer viruses is given in connection with such information and materials.

Linked Websites

HSBC is not responsible for the contents available on or the set-up of any other websites linked to this site. Access to and use of such other websites is at the user's own risk and subject to any terms and conditions applicable to such access/use. By providing hyperlinks to other websites, HSBC shall not be deemed to endorse, recommend, approve, guarantee or introduce any third parties or the service/products they provide on their websites, or have any form of cooperation with such third parties and websites. HSBC is not a party to any contractual arrangements entered into between you and the provider of the external website unless otherwise expressly specified or agreed to by HSBC.

Email

Email messages sent to HSBC over the Internet cannot be guaranteed to be completely secure. HSBC is not responsible for any damages incurred by users if they send a message to HSBC, or if HSBC sends a message to them at their request, over the Internet. HSBC is not responsible in any way for direct, indirect, special or consequential damages arising out of the use of this website.

Transmitting over the Internet

Due to the nature of the Internet transactions may be subject to interruption, transmission blackout, delayed transmission and incorrect data transmission. HSBC is not liable for malfunctions in communications facilities not under its control that may affect the accuracy or timeliness of messages and transactions you send.

Downloading

We do not represent or warrant that the Site will be available and meet your requirements, that access will not be interrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system. You have sole responsibility for adequate protection and back up of data and/or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses or other destructive properties. We make no representations or warranties regarding the accuracy, functionality or performance of any third party software that may be used in connection with the Site.

IMPORTANT: By accessing this web site and any of its pages you are agreeing to the terms set out above.