Policy on Conflicts of Interest (Summary)
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 thatcompanies or businesses within the HSBC Group may from time to time potentially haveinterests which conflict, or potentially conflict, with its customers・interests or with theduties 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 acustomer.
For example, HSBC Group may trade proprietary positions in a security when at the sametime another business or entity within HSBC Group may have information about futuretransactions 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 businessactivities 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 businessdepartments, is the responsible department for Conflict of Interest Management. TheCompliance Department identifies potential conflicts of interest by monitoring thenecessary business information and where applicable taking appropriate measures tomanage and control conflicts of interest when they arise. These control procedures

include organisational measures and administrative arrangements to safeguard theinterests 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 andShanghai Banking Corporation Limited, HSBC Securities (Japan) Co., Ltd., HSBC AssetManagement (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 Groupcompanies.
Any customer requiring more details of our Conflict of Interest Management proceduresshould contact their Relationship Manager or other contacts at any of HSBC's offices inJapan.