According to the current laws and regulations in force, Mizuho Trust & Banking (Luxembourg) S.A.  (“MHTBL” or the “Bank”) has established a conflicts of interest policy (the “policy”) for the prevention and management of such conflicts. This policy identifies the circumstances which constitute or may rise to a conflict of interest, and defines the set up measures to adopt in order to prevent and manage those conflicts. 

Companies subject to the Conflicts of Interest Policy 

MHTBL has reviewed its activities with a view to detecting the situations likely to produce a conflict of interest. As the company is member of the Mizuho Financial Group (the “Group”), the policy has also taken into account any circumstances which may give rise to a conflict of interest resulting from the structure and business activities of other members of the Group, and if necessary, appropriate procedures have been set up. The following relationships have especially been considered:  

·         Mizuho Trust & Banking (Luxembourg) S.A.

·         Japan Fund Management (Luxembourg) S.A.

·         Mizuho Trust & Banking, Co., Ltd.

·         Other entities within the Group. 

Activities subject to the Conflicts of Interest Policy 

MHTBL is involved in activities related to Fund Administration, Custody (including treasury activities) and Securities Agency services. In relation to these services, the Bank discloses that the following situations potentially could generate one or several conflicts of interest: 

·         When acting or dealing for a client as depositary and central administration while the Bank is also the shareholder of the relevant Management Company;

·         If the Bank decides to deal with a client it may do so by dealing against its own books (i.e. dealing on own account);

·         Where the Bank acts for a client it may also be acting for other clients in the same sector or industry. 

Situations likely to produce a conflict of interest are recorded and kept at the registered office of MHTBL (The “register”). The Chief Compliance Officer of MHTBL is in charge of keeping such register up-to-date. 

Managing and Monitoring Conflicts of Interest 

MHTBL has put in place some preventive measures such as the submission to rules of conduct by all employees, directors and certain delegates, the adoption of security measures, in particular for information technology issues, preventing the circulation of information within the Group, the implementation of procedures regarding personal transactions, exchange of information, segregation of functions, and the treatment of inside information (where applicable). 

Disclosure of Conflicts of Interest 

In case MHTBL note that all risks of harming the interests of a client cannot be avoided with reasonable certainty, MHTBL shall work on resolving this conflict and shall inform the relevant party in writing of the general nature of the conflict of interest and/or its source. In order to obtain more details on this policy, please contact your account representative or send an email to clientservices@mizuho.lu.