Tokyo Capital Management has accepted all seven principles of the “Basic Principles on Client-Oriented Business Conduct” announced by the Financial Services Agency on March 30th, 2017 and established Policy on Client-Oriented Business Conduct.
1. Establishment and Announcement of Policy on Client-Oriented Business Conduct
We have established a policy to realize client-oriented business conduct announced the policy. We will review the state of activities related to the policy as well as periodically review the policy itself.
2. Pursuit of Clients’ Best Interest
We will comply with the Financial Instruments and Exchange Act and related laws and offer sincere and fair services as experts with professional ethics, and pursue best interest for the client.
3. Proper Obtainment of Personal Information
We will obtain personal information of clients through proper methods in compliance with the law.
4. Proper Management of Conflict of Interest
We have stipulated internal rules concerning conflict of interests that clarify scope of interested party and procedures with said parties (acquisition and sale of assets, operations consignment, etc.). When a transaction may have conflict of interests, the compliance committee which includes an outside expert will carefully deliberate the advisability of the transaction, including the possibility of conflict of interest. If there is conflict of interest, said transaction may be canceled to properly manage said conflict of interest.
5. Clarification of Pricing
We will communicate with each client in compliance with related laws as well as categories, characteristics, content of business, and market trading practices to set service fees or calculation method for the fee that clients can agree, and clearly indicate them on the contract, etc.
6. Provision of Important Information in an Understandable Manner
We will offer important information with proper content in an easy to understand manner, with consideration to the clients’ experience and financial knowledge in order to avoid misunderstanding. Such information includes transaction structures, returns, risks, condition of transaction, and performances of financial instruments and services we provide.
7. Provision of Services Appropriate for the Client
As a general rule, we limit our clients to Professional Investors. We recognize clients’ financial status, experience, knowledge and purpose of translation, and needs to offer appropriate service for each client.
8. Appropriate Framework to Incentivize Employees
We conduct compliance training for our employees to incentivize them to pursue best outcome for the clients, treat each client fairly, and to offer services without conflict of interest.