15 July 2022
The Hongkong and Shanghai Banking Corporation Limited, Tokyo Branch
HSBC Securities (Japan) Co., Ltd.
HSBC Asset Management (Japan) Limited

Sharing of Customer Non-Public Information within HSBC Group Based on the New Opt-OutRegime
We hereby notify you that in order to more effectively serve our customers’ needs, The
Hongkong and Shanghai Banking Corporation Limited, Tokyo Branch (including any otherbranches, etc. in Japan (same below)), HSBC Securities (Japan) Co., Ltd. and HSBC AssetManagement (Japan) Limited (collectively hereinafter, “HSBC Entities in Japan”) will exchange
and share your Non-Public Information within our Group for the following in-scope customers
pursuant to the Cabinet Office Order on Financial Instruments Business (hereinafter, the“Cabinet Office Order”), article 153, paragraph 1, items (vii) and (viii) (the New Opt-Out Regime1).

1.

In-scope customers whose information will be shared under the New Opt-Out Regime

Customers subject to information sharing under the New Opt-Out Regime are the following
customers defined as Listed Companies, etc. as per the Cabinet Office Order, article 123,
paragraph 1, item xviii (g).
(1) A listed company, etc., prescribed in the Financial Instruments and Exchange Act(hereinafter, "FIEA"), article 163, paragraph 1, and its subsidiary companies, etc.
(2) A stock company which intends to list its shares on a Financial Instruments Exchange(limited to a stock company which has concluded a contract for receiving the advice
necessary for conforming to the listing standards or a contract to be audited by a certified
public accountant or an auditing firm in accordance with the provisions of FIEA, article 1931 Under the New Opt-Out Regime we will place a notice on our website, etc. (an easily accessiblelocation) in advance stating that we will mutually exchange in-scope customers’ Non-PublicInformation within our Group with no requirement to notify the customer or obtain thecustomer’s consent. A customer may request (opt-out) that we cease the mutual exchange of
its Non-Public Information. However, we may mutually exchange such customer’s Non-PublicInformation until the customer makes such request.
12), and its subsidiary companies, etc.
(3) A juridical person who has submitted a securities report as prescribed in FIEA, article 24,paragraph 1 (including cases which apply mutatis mutandis pursuant to the same article,
paragraph 5 (including cases which apply mutatis mutandis to FIEA, article 27) and FIEA,
article 27), and its subsidiary companies, etc.
(4) A Qualified Institutional Investor (excluding those listed in article 10, paragraph 1, item xxiii(limited to the part pertaining to (a)) and item xxiv of the Cabinet Office Ordinance on
Definitions under Article 2 of the Financial Instruments and Exchange Act), and its subsidiarycompanies, etc.
2.

Definition of Non-Public InformationNon-Public Information means non-public information as defined in the Cabinet Office
Ordinance, article 1, paragraph 4, item 12.
3.

Scope of our Group entities your Non-Public Information can be shared with

(Including the HSBS Entities in Japan) their parent companies, etc. (as defined under Order forEnforcement of the Financial Instruments and Exchange Act, article 15-16, paragraph 1) andsubsidiary companies, etc. (as defined under the same Enforcement Order, article 15-16,paragraph 2) (collectively hereinafter, “relevant Group companies”).
4.

Scope of Non-Public Information to be shared

Non-public Information regarding you that HSBC Entities in Japan have already obtained or may
obtain in the future.
5.

Methods of sharing Non-Public Information

Non-public Information will be shared orally, by email, in writing, through access to a shared
database, or through any other means, with due attention to prevent information leaks.
6.

Procedures for managing Non-Public Information

Non-Public Information received by HSBC Entities in Japan and relevant Group companies will
be managed by the relevant business department in each entity, and will be kept separate fromother lines of business through strict information barriers and controls that are designed toprevent the improper access, use or dissemination of your information unless there is alegitimate business or control reason or other need to know basis as described in this notice.

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7.

Purposes of sharing Non-public Information(i)

To offer you various financial services that better meet your financial needs.

(ii) To better manage our Group’s businesses and functions from a governance as well asa strategic perspective.
(iii) To achieve other purposes that are related to the foregoing.
In any event, your Non-Public Information will be shared only on a need to know basis in line
with, and in strict compliance with, the requirements of applicable laws and regulations.
8.

Procedures for managing Non-public Information of Customers who opt-out

In the event that you choose to opt out and request us not to share your Non-public Information
with other entities in our Group, we will not share your Non-Public Information which we may
obtain after our receipt of your opt-out request except to the extent that it is permitted underapplicable laws and regulations, regulatory guidance, etc. However, with respect to any NonPublic Information that has already been shared within our Group and is stored in shared
databases and other information repositories with proper control, we will continue to use theinformation as far as such use is consistent with all applicable laws and regulations. For theavoidance of doubt, the opt-out does not restrict each of the HSBC Entities in Japan from sharing
Non-Public Information received directly from you within the same entity. In addition, if werecognize that your company no longer falls under the definition of Listed Companies, etc., wewill cease to share your information pursuant to the New Opt-Out Regime.

However, each

entity in our Group may continue to retain the Non-Public Information that was shared prior tosuch recognition.
9.

Customers who have submitted an information sharing agreement, etc.

Where we have already received an information sharing agreement to share your Non-PublicInformation, etc., we will share your Non-Public Information that is covered by such agreementin accordance with the existing information sharing agreement, even if you are an eligible
customer under the New Opt-Out Regime. For the avoidance of doubt, in accordance with theNew Opt-Out Regime, we may share your Non-Public Information that is not covered by theexisting information sharing agreement or notices made under the previous opt-out regime.
However, depending on your original intent, we may reconfirm your intention.
Where we have entered into a separate confidentiality agreement with a customer, with respect
to the information subject to such confidentiality agreement, we will comply with the terms andconditions of that agreement notwithstanding the contents of this notice.
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10. Method for requesting suspension of information sharing under the New Opt-Out Regime
If you do not agree to the sharing of your information under the New Opt-Out Regime, please
inform your HSBC sales representative that you are requesting the suspension of the sharing ofyour Non-Public Information, describing your company name (formal name), the name of theperson with authority to make the request as well as the name, department, and job title of yourcontact person.

Also, please kindly inform us if you are the parent company of a group ofcompanies and you are requesting a complete cessation of information sharing on behalf of allthe companies in your group.
Please note that if you have no objection to the sharing of your Non-Public Information, there isno need to contact us.
11. Miscellaneous
Please contact your HSBC sales representative if you have any specific questions or comments
regarding the sharing of your information.

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