Legal Information

The Hongkong and Shanghai Banking Corporation Limited

We will assess our success against five outcomes as follows:

  1. 1. We understand our customers’ needs

    …and design, market and sell products and services that recognise the long-term interests of customers.
  2. 2. We provide products and services that offer a fair exchange of value

    …which balance customer and HSBC interests and do not undermine market competition.
  3. 3. We service customers’ ongoing needs, and put it right if we make a mistake

    …ensuring products and standards of service continue to have a positive impact.
  4. 4. We act with integrity in the financial markets we operate in

    …acting in our customers’ interests and not in ways which manipulate or undermine markets.
  5. 5. We operate resiliently and securely to avoid harm to customers and markets

    …across digital, physical and operational arrangements to support customer needs and wider financial system stability.

April 2022

The Hongkong and Shanghai Banking Corporation Limited, Japan Branch

Handling of Customers’ Personal Information etc. (Personal Information Protection Policy)

The Hongkong and Shanghai Banking Corporation Limited, Japan Branch (hereinafter, the “Bank”) has established the following policy with respect to the handling of customer Personal Information, Individual Number and Specific Personal Information (collectively, "Personal Information, etc.").

When handling customer Personal Information, etc., the Bank will comply with this policy in addition to relevant laws and regulations, including the Personal Information Protection Act (hereinafter referred to as "PIPA"), and relevant guidelines, including the Guidelines for the Protection of Personal Information in the Financial Sector (hereinafter referred to as the "Guidelines"). The Bank will continually review and improve its policy for 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 defined in the Guidelines. It includes "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 Related Information" is defined in the PIPA. It refers to information about a living individual, which is not Personal Information nor Kana Processed Information and Anonymously Processed Information that are defined in the PIPA.

"Personal Information" is defined in the PIPA. It refers to information about a living individual that 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 the PIPA.

"Personal Data" is defined in the PIPA. It refers to Personal Information constituting a personal information database etc. defined in the PIPA.

"Individual Number" refers to a number obtained by converting a resident record code in order to identify a person (so called "My Number").

"Specific Personal Information" refers to Personal Information that includes Individual Number information.

"Special Care-Required Personal Information" is defined in the PIPA. It refers to personal information comprising a principal's race, religious affiliation, 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 Connected Persons) 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 Individual Number and Specific Personal Information only to the extent permitted under the relevant laws and regulations.

(1) Business Operations

  1. The acceptance of deposits, fund transfers, currency exchange, lending of funds, foreign exchange, credit card issuance, and other businesses ancillary to these businesses.
  2. Any other activities and related businesses in which banks may be engaged in (including activities that may be permitted in the future).

(2) Purposes of Use

The Bank and its affiliates and associated companies will use customers’ Personal Information, etc. for the following purposes in relation to the provision of financial products and services. Pursuant to article 13, paragraph 6, item 6, etc. of the Ordinance for Enforcement of the Banking Act, the Bank shall not use or provide to a third party any information on the repayment capacity of a person seeking funds which was provided by an Individual Credit Information Organization for purposes other than for the investigation of the repayment capacity of the person seeking the funds. Further, pursuant to article 13, paragraph 6, item 7 of the Ordinance for Enforcement of the Banking Act, the Bank shall not use, nor shall it provide to a third party, any Sensitive Information of the customer unless the Bank deems it necessary to do so for its proper business operations or otherwise. The Bank will endeavor to decide the Purposes of Use as concretely as possible so that they are transparent to customers, and will endeavor to specify the purpose 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 provide information for the solicitation and sale of financial products, introduction, receiving an application, management, and execution of services in accordance with the Bank’s business operations.
  2. To: (i) ascertain the customer's identity under the Act on the Prevention of the Transfer of Criminal Proceeds, the Foreign Exchange and Foreign Trade Act and Hong Kong Monetary Authority Guidelines, (ii) avoid financial crime and 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., and (iii) ascertain a customer's eligibility for certain financial products and/or services.
  3. Management of ongoing transactions, such as the management of dates in various transactions;
  4. To make decisions on offers for various transactions, confirm eligibility for using instruments and services, and ongoing transactions, 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 personal information to a third party to the extent necessary for the performance of our business, including where personal information is provided to a Individual Credit Information Organization, etc. in the course of our lending business.
  7. To appropriately carry out 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. For research and development of products and services through market research, data analysis, and questionnaire surveys.
  10. For making proposals concerning products and services by means of direct mail, email, etc.
  11. To make proposals on the products and services of HSBC Group Companies or associated companies etc.
  12. Cancellation of various transactions and post-cancellation management of transactions.
  13. To monitor and control the various risks that are necessary to be managed by HSBC Group Companies.
  14. Appropriate and smooth performance of transactions with customers.

Notwithstanding the Purposes of Use provided in each item above, the Bank will not use the 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 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 transactions of domestic and international remittances, etc..
  4. Processing related to the numbering of deposit and saving accounts.
  5. Preparation of legal documents regarding payment records.
  6. Other purposes in relation to 1 through 5 above.

The Purposes of Use of Personal Information, etc. by the Bank, may be found on the Bank's website.

(3) Discontinuance of Direct Marketing

In case a customer requests the Bank to stop using his/her Personal Information for the purposes 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.

To the extent necessary for the achievement of the Purposes of Use specified in item 1 above, the Bank will acquire Personal Information, etc. of the customer orally or in writing by appropriate and lawful means, for example, from the following information sources.

<examples>

  • Where the information is provided directly by a document that the customer is required to fill in and submit (e.g. submission of an application form by the person in question, data entry via the website by the person in question).
  • Cases where personal information is provided by third parties, such as Joint Users and a personal credit information organization.

3. Personal Information etc. Provided to Third Parties

The Bank will not provide a customer’s Personal Data it retains to third parties without the prior consent of the individual concerned, except as permitted by relevant laws and regulations. However, in the case where the Bank entrusts the Personal Data to a third party within the necessary scope to achieve its Purposes of Use, or in the case where the Personal Data is to be jointly utilized by a specified party set forth in item 6 below, the Bank may provide a customer’s Personal Data even without the prior consent of the customer.

Where providing Persona Data to third parties in foreign countries (including the 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 obtaining prior consent of the customer, except for cases permitted by relevant laws and regulations. If a third party is located in a foreign country which has established a personal information protection system recognized to have equivalent standards to that of Japan (as set forth in the rules of the Personal Information Protection Commission (“PIPC”)) the Bank may provide the customers’ Personal Data to the third party without obtaining the prior consent of the customer.

In addition, the Bank may provide a customer’s Personal Information, without obtaining prior consent, to a third party in a foreign country which has developed a framework that conforms to the standards set forth in the rules of PIPC and is regarded as equivalent on an ongoing basis to the measures that a business operator handling Personal Information is required to take pursuant to the provisions of the PIPA (hereinafter referred to as "Equivalent Measures"). In such event, the Bank shall take measures necessary to ensure the continuous implementation of the Equivalent Measures by such third parties, and a customer may seek information on such measures.

At the time of obtaining consent from the customer, it might be difficult to specify the name of the foreign country, or obtain and provide information on its regime for protecting personal information, or information on the measures to be taken by the third party to protect Personal Information in an appropriate and reasonable manner. Therefore, a customer may request the Bank to provide the aforementioned information at a later date.

The Bank shall not provide all or part of the information with respect to any requests for information in the event that there is a risk that the proper performance of its business will be seriously impaired.

In providing customers’ Personal Related Information to a third party and where the third party is expected to receive the Personal Related Information as Personal Data, except as otherwise provided by relevant laws and regulations, the Bank shall confirm and provide the information in accordance with the provisions of such laws and regulations.

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

4. Handling of Sensitive Information

The Bank will not acquire, utilise, nor provide to third parties, customer’s Sensitive Information, except in cases as illustrated by the Guidelines including cases based on relevant 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 Operations Concerning Personal Information etc.

The Bank shall entrust its operations concerning Personal Data to a 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 >

  • Operations regarding printing and dispatch of documents to be sent to customers.
  • Operations related to transactions
  • Operations to send out direct mails
  • Operations and maintenance of computer systems
  • Maintenance of books and records relating to business operations

6. Joint Use of Personal Data

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

(1) Joint Use of Information from Japan Official Gazette

  1. Jointly Used Personal Data Information published in Japan Official Gazette (name, address, bankruptcy, the date, etc.)
  2. Scope of Joint Users Members of the Individual Credit Information Center held by the Japanese Bankers Association (hereinafter referred to as the "Association"). To note, the Association’s Individual Credit Information Center is a Individual Credit Information Organization which is established and managed by the Association. Conditions for participation are as follows:
    1. An official member of the Association
    2. Other banks than the ones mention at (i). above or financial institutions that are equivalent to a bank under relevant laws and regulations
    3. Government-related financial institutions and equivalent institutions
    4. Credit Guarantee Association which is established in accordance with the Credit Guarantee Association Act (10 August 1953, the Law no.196)
    5. Corporate entities that run credit businesses related to individual customers, which are endorsed by members of the above (i).~ (iii).
  3. Purposes of Use To make decisions concerning own lending deals by the members of the Association’s Individual Credit Information Center.
  4. The entity name, location, and the name of the Representative Director responsible for management of Personal Data The Japanese Bankers Association The location and representative’s name can be found at the following website: https://www.zenginkyo.or.jp/abstract/outline/
(2) Joint Use of Information in Relation to Non-Performing Transactions
  1. Jointly Used Personal Data The following information in relation to the drawer of a non-performing disbursed draft, cheque or bill (for a bill of exchange, the underwriter) (the same shall apply hereinafter) and the customer who initiated the transaction.
    1. the name of the drawer (if the drawer is a juridical person, its name, representative name, and representative’s title)
    2. if there is a trade name with respect to the said drawer, the said trade name
    3. Address (office address if legal entity) (to include postal code)
    4. The name of the customer who initiated the transaction for the time period (if a juridical person, its name, representative name, and representative’s title. If there is a trading name, the said trading name).
    5. Date of birth
    6. Occupation
    7. Stated Capital (limited to cases of juridical persons)
    8. The type and face value of said draft, check or bill
    9. Whether the report is a for a non-payment (the first non-payment) or a report of in relation to the cessation of the transaction (cessation of transaction order)
    10. Exchange Date (Presentation Date)
    11. Payment bank (including department and branch name)
    12. Beneficiary bank (including department and branch name)
    13. Reason for non-performance
    14. The date on which the person received the cessation of transaction order
    15. Clearing organisation of which the payment bank (branch) of the non-performing disbursed draft, cheque or bill is a member and the bankers association of which the clearing organisation is a member.

    Note: In relation to i. through iii. above, where the information contained on the non-performing disbursed draft, cheque or bill differs from the information notified to the payment bank, the information contained in the said draft, cheque or bill shall be included.

  2. Scope of Joint Users
    • Clearing organizations of drafts, cheques or bills in each region
    • Financial institutions that participate in the local clearing organisations
    • All Individual Credit Information Organisations that are established and managed by the Association
    • Regionally-based bankers associations, which are Special Members of the Association (including the organisation in relation to the cessation of transaction order)

    The list of Joint Users can be found on the webpage of the Association.

  3. Purposes of Use To maintain smooth transactions of drafts, cheques and bills and to make decisions concerning own lending deals by financial institutions.
  4. The entity name, location, and the name of the Representative Director responsible for management of Personal Data:

    Bankers Association of the clearing organisation that the payment bank (branch) of the non-performing disbursed draft, cheque or bill is a member of.

    The location and representative’s name of each Bankers Association can be found at the following website etc.: https://www.zenginkyo.or.jp/abstract/clearing/

(3) Joint Use of Information among HSBC Group Companies

The Bank may jointly use Personal Data with HSBC Group Companies in order to provide high value-added products and services and/or conduct strong risk management and enhancement of HSBC group business controls. This joint use will be undertaken under necessary control measures, and when there are restrictions set by applicable laws and regulations other than the PIPA, such as the FIEA, the Bank shall comply with such laws and regulations.

  1. Jointly Used Personal Data Information (name, address, date of birth, contents and purpose of a transaction, and occupation) of the customer (including its Connected Persons to the extent necessary for the implementation of the Purposes of Use) regarding the Bank 's eposits, loans, and fund transfers and other transactions.
  2. Scope of Joint Users The Bank and other HSBC group companies, the ultimate parent company of which is HSBC Holdings plc. (“HSBC Group Companies”). http://www.hsbc.com/about-hsbc/structure-and-network
  3. Purposes 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, the Foreign Exchange and Foreign Trade Act and Hong Kong Monetary Authority Guidelines, (ii) avoid financial crime and 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 a customer's eligibility for certain financial products and/or services.
    • To plan and develop various financial products and services and related proposals.
    • To properly and smoothly implement transactions with customers.
  4. Entity name, address, and the name of the Representative Director responsible for management of Personal Data are shown below: The Hongkong and Shanghai Banking Corporation Limited, Japan Branch 11-1, Nihonbashi 3-chome Chuo-ku, Tokyo Japan Edward Weeks President and Chief Executive Officer in Japan

7. Procedures for Disclosure etc. of Retained Personal Data

Upon receipt of a request/demand for disclosure etc. by a customer in relation to the purpose of utilization, disclosure, correction, addition or deletion, ceasing of provision to a third party, disclosure of a third party provision record of the customer’s Retained Personal Data, as defined in the PIPA (hereinafter referred to as a “Disclosure Request, etc.”), the Bank shall action the Disclosure Request, etc., without delay, by means of providing an electronic record, delivering documents or by other means agreed with the customer.

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

(1) Cases that cannot be handled

The Bank may not respond to the Disclosure Request, etc. in the following cases:

  • if we cannot confirm the identity of the customer or if we cannot confirm the authority of the agent of the customer;
  • if the application form is inadequately completed or if the fee is not paid within the prescribed period;
  • if we are not required to respond under relevant laws and regulations, for example, because the item requested does not fall within the definition of Retained Personal Data; or
  • if there is threat to seriously interfere with our business.
    If the Bank decides not to accept the customer's Demand for Disclosure etc., in whole or in part, the Bank shall notify the customer thereof without delay.

(2) Documentation and Procedures for Handling a Disclosure Request, etc.

In order to make a Disclosure Request, etc., the customer shall submit a form prescribed by the Bank. The Bank, in handling the Disclosure Request, etc. shall confirm the identity of the customer or his/her agent in a manner comparable to the procedures required by the Act on the Prevention of the Transfer of Criminal Proceeds etc., by requesting the customer or his/her agent to submit necessary documents etc.

(3) Disclosure Request, etc. by an Agent

An agent who makes a Disclosure Request, etc. on behalf of a customer shall be one of the following:

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

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

(4) Handling Fee

The Bank will charge a fee of JPY 1,100 per case for the handling of a Disclosure Request, etc. The fee is payable at the time of such request and shall be paid in cash.

8. Security Control Measures

The Bank takes necessary and appropriate action in relation to security controls to avoid data leakage, loss or damage of customers’ Personal Information, etc. The Bank shall exercise necessary and appropriate supervision over staff and outsourced vendors (including subcontractors) who are handling customers’ Personal Information, etc.

(Development of Rules on the Handling of Customers' Personal Data)

  • The Bank shall establish rules for the handling of customer Personal Data detailing how to handle the data, clarifying those in charge and for defining the roles at each stage of data processing (acquisition, use, storage, provision, deletion, disposal, etc).

(Organizational Security Control Measures)

The Bank shall:

  • Assign a person to be responsible for the management of Personal Data.
  • Maintain Security Control Measures under its Rules of Employment etc.
  • Process Personal Data by applying the above mentioned rules.
  • Maintain methods by which the handling status of Personal Data can be checked.
  • Maintain and conduct a regime for monitoring and auditing the handling status of Personal Data.
  • Maintain a regime to deal with incidents such as leakage etc.

(Measures for Human Security Management)

The Bank shall:

  • Enter into a non-disclosure agreement etc. with employees covering Personal Data.
  • Clarify employees’ roles and responsibilities.
  • Inform, educate, and train employees regarding these Security Control Measures.
  • Check employees’ compliance with processes to manage Personal Data.

(Physical Security Control Measures)

The Bank shall:

  • Establish measures to prevent theft of equipment, etc.
  • Manage recording media, etc. appropriately.
  • Prohibit Personal Data to be taken outside the designated managed area in principle.
  • Prohibit usage of floppy disk、USB port, personal laptop, etc., in principle.
  • Strictly manage a log of entrance and exit of employees and visitors based on its rules for access management.
  • Prevent mistakes of sending Personal Data by fax, telex, and emails and conduct checking of recipients and receipts to prevent Personal Data loss, etc.
  • When disposing or returning equipment, process deletion of Personal Data in recordable media in the equipment appropriately.
  • Dispose paper-based Personal Data in the box dedicated to the collection and disposal of sensitive documents.

(Technical Security Control Measures)

The Bank shall:

  • Identify and verify users of Personal Data.
  • Set up area controls and limit access to Personal Data.
  • Manage access entitlements to Personal Data.
  • Establish measures to prevent leakage and destruction of Personal Data.
  • Record and analyze access to Personal Data.
  • Record and analyze the ongoing status of information systems that process Personal Data.
  • Monitor and audit information systems that process Personal Data.

(Understanding of External Environments)

  • When handling Personal Information of customers in foreign countries, the Bank y shall implement appropriate Security Control Measures, after understanding the regime, etc. related to the protection of Personal Information in the foreign countries concerned.

9. Contacts

The Bank shall deal with complaints regarding the handling of Personal Information etc. properly and in a timely manner. Please use the following phone number for any inquires, comments, complaints, and Disclosure Request, etc. concerning the Bank’s handling of Personal Information etc. and Security Control Measures.

(Corporate sector)

Please contact your Relationship Manager or the following contact: Non-Financial Risk team, Wholesale Chief Operating Officer Office Address: 11-1, Nihonbashi 3-chome Chuo-ku, Tokyo Japan Telephone: 03-5203-3037 (9am to 5 pm on weekdays, not toll free)

(Former Retail sector)

Retail Services center, DBS Operations Address: 11-1, Nihonbashi 3-chome Chuo-ku, Tokyo Japan Telephone (Japan): 0120-777-369(9 am to 5 pm Monday to Friday (excluding holidays), toll-free) Telephone (overseas): +81-3-5204-5001(9 am to 5 pm Monday to Friday (excluding holidays), not toll free)

The Bank is a member of the following Authorized Personal Information Protection Organization. If you have any complaints or inquiries regarding the handling of Personal Information, you may contact these organizations as below:

  • All Banks Personal Data Protection Council (http://www.abpdpc.gr.jp/) JBA Customer Relations Center or Bank Business Consultation offices Tel: 03-5222-1700 or at any of the Bank Business Consultation offices
  • Personal Information Consulting Centre (http://www.jsda.or.jp) Japan Securities Dealers Association Tel: 03-3667-8427
  • Personal Information Complaints/Consultations Centre (http://www.ffaj.or.jp/) Financial Futures Association of Japan Tel: 03-5280-0881

10. Changes to this Policy

The contents of this policy may by changed without notice and without informing customers individually in accordance with relevant laws and regulations due to legislative amendments and others reasons. In such case, the changes shall be published on the Bank’s website.

End

The Hongkong and Shanghai Banking Corporation Limited, Japan Branch 11-1, Nihonbashi 3-chome Chuo-ku, Tokyo Japan Edward Weeks President and Chief Executive Officer in Japan

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

  • 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.
  • 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.
  • 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.
  • The Bank shall not solicit neither at places nor during hours inappropriate to the customers.
  • 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.
  • The Bank shall make efforts to improve knowledge and skills on our financial products in order to conduct solicitation in an appropriate manner.
  • 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.

Our Policy for Handling Complaints and Disputes

In relation to the handling of complaints and disputes, taking into consideration the financial Alternative Dispute Resolution system, the relevant departments of The Hongkong & Shanghai Banking Corporation Limited, Tokyo Branch, in coordination with one another, shall clarify the cause and responsibility of a complaint or dispute, respect the client’s situation, and make efforts to resolve the matter promptly, sincerely and fairly.

  • • Complaints and disputes raised by clients shall be treated sincerely, the relevant information shall be shared and used in order to improve our firm’s business operations.
  • • Personal information received from clients shall be managed appropriately.
  • • Complaints by anti-social forces and unjustified involvements disguised as disputes shall be handled with a robust attitude, and managed appropriately in cooperation with the police or other relevant organizations as necessary.
  • • Resolution with the understanding and consent of the client shall be pursued to the extent possible, such as by explaining appropriately to the client the process in handling the complaint or dispute.
  • • In cases where it is evident that the complaint or dispute will not able to be resolved internally or in other cases that are deemed appropriate, an external dispute resolution organization below shall be introduced to the client in order to resolve the complaint or dispute.

Contact Point for Making a Complaint or Dispute

If you wish to make a complaint or dispute, please contact your sales representative or the Compliance Department (the designated responsible department).

The Hongkong & Shanghai Banking Corporation Limited, Tokyo Branch Compliance Department

Phone: 03-5203-3000

Alternative Dispute Resolution Framework

Disclosure pursuant to the Banking Act Article 12-3

The Hongkong and Shanghai Banking Corporation Limited, Tokyo Branch has 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 November 2022 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)
14 specified related companies*

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

The information can be found on the website of Moody’s Japan K.K. and Moody’s SF Japan K.K. (https://ratings.moodys.com/japan/ratings news), under the tab “Regulatory Affairs” (「規制関連」), then by clicking on “Disclosures” (「開示」) and in the “Matters Related to the Explanation of Unregistered Ratings” (「無登録格付説明関連」) section. *Specified related companies are published on the website under (「金融庁長官より指定を受けた特定関係法人一覧」).

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 November 2022 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 (https://www.fitchratings.com/site/japan).

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 November 2022 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 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.

For customers who have been reclassified as a Professional Investor, reclassification continues to be effective on and from the date of acceptance for reclassification by The Hongkong & Shanghai Banking Corporation Limited, Tokyo Branch (hereinafter, “HSBC”) to and including the immediately succeeding September 30 (the last day of the effective period hereinafter referred to as the “Expiry Date”). If a customer desires to remain reclassified as a Professional Investor beyond the Expiry Date, the customer is required to make a renewal request for reclassification prior to the Expiry Date. If a customer who has been reclassified as a Professional Investor wishes to be treated as a General Investor, the customer may make the request at any time to HSBC.

For a customer who has been reclassified as a General Investor, the customer will continue to be treated as a General Investor until the earlier of (i) the day on which HSBC accepts, pursuant to the provisions of the Financial Instruments and Exchange Act, a request from such customer to be treated as a Professional Investor, or (ii) the day immediately preceding the day on which such customer becomes a qualified institutional investor.

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) Co., Ltd. and HSBC Asset Management (Japan) Limited

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) Co., Ltd., HSBC Asset Management (Japan) Limited and all other HSBC Group companies worldwide which engage in financial business. Please be advised that HSBC Asset Management (Japan) Limited.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.