The company's compliance officer and compliance support team are the final officers in charge of enacting, revising, and checking the implementation status of the Stewardship Code, and they shall strive to systematically prevent conflicts of interest and ensure the legality and fairness of business performance. They perform their duties under the order of the board of directors and the CEO, can refer directly to the CEO and auditor, and maintain an independent position without order from other departments. In addition, there are no personnel disadvantages for reasons related to job performance.
The following are examples of conflict of interest situations that the company may encounter.
- <Examples of conflict of interest>
- Relationship between the company and employees
- Relationship between the company and investors
- Relationship between the company's affiliates, etc. and investors
- Relationship between employees and investors
- Relationship between specific investors and other investors
In the process of fulfilling the company's responsibilities, the company shall establish internal control standards to effectively resolve issues of actual or potential conflicts of interest between major stakeholders. In accordance with the principle of prioritizing client interests, the company shall take measures to prevent problems such as protecting client interests by actively responding to each situation.
- <Principles of prioritizing clients' interests>
- The interests of clients take precedence over the interests of the company and its shareholders and employees
- The company's interests take precedence over the employee's interests
- All clients' interests are treated equally
The company has established a system to regularly independently monitor and audit the adequacy and efficiency of work performance for all tasks performed by employees through internal control standards and internal control checklist. The company establishes, manages, and supervises matters related to system construction and operation in order to properly prevent and manage situations such as violations of related laws and regulations and other operational and legal risks such as controlling all documents sent to the outside.
The employees of the company shall strive to ensure that no actual or potential conflict of interest arises in relation to all trading of financial investment products, and that the entire process is fair and transparent without using a superior position in business.
The compliance officer must take measures to prevent problems in protecting clients, etc. if there is a conflict of interest between the company and clients or between clients and clients, or when there is a concern regarding conflict of interest. In other words, for transactions that may cause a conflict of interest, proactive measures must be taken so that the interests of clients are not infringed upon, and if such measures are deemed difficult, follow-up measures shall be taken according to the procedure. In addition, they shall endeavor to prevent conflicts of interest by listing and managing items and company names that are concerned with the occurrence of a conflict of interest with the company as a list of trade restrictions or traders.
Finally, the compliance officer shall check the compliance with related laws and regulations, internal control standards, and information protection, and take necessary measures such as sanctions against illegal acts and improvement of the internal control system. In addition, actions taken in response to a conflict of interest shall be recorded and kept for 5 years from the date of creation.