Management Policy for Conflict of Interest (Outline) >Purpose >Scope of Shinsei Trust Bank                Group Companies >>Categories of Transactions                Which May Involve Conflict of                Interest, Examples and How to                Manage Transactions >Management System for Conflict                of Interest	Management System for Conflict of Interest (1) Establishment of a Division Responsible for the Management of Conflict of Interest 1) Trust Surveillance and Compliance Division, Shinsei Trust shall be the division responsible for the management of conflict of interest. 2) The division responsible for the management of conflict of interest will operate independently, and shall not receive direction from managers of other divisions regarding the specific details of its operations. 3) The division responsible for the management of conflict of interest shall be responsible for the company-wide management system to identify and control transactions that may involve conflict of interest. (2) Responsibilities of the Division Responsible for the Management of Conflict of Interest The division responsible for the management of conflict of interest shall discharge the following responsibilities independently of the Marketing Division responsible for businesses at Shinsei Trust 1) Identifying transactions that may involve a conflict of interest and giving appropriate directions to the Marketing Division on how to manage these transactions. 2) Periodic evaluation of the validity of relevant transactions and the management of conflict of interest in order to maintain appropriate control. 3) Instructing the Marketing Division as necessary regarding appropriate management of conflict of interest for transactions in which customers' interests may be unfairly compromised, and reviewing such transactions. 4) Providing training, on a regular basis, to statutory executive officers and employees of Shinsei Trust on the management of conflict of interest on the basis of this Policy and other related internal rules and procedures; ensuring that all employees share an appropriate understanding about the management of transactions which may involve conflict of interest. (3) Preparation/Storage of Management Records of Conflict of Interest Actions taken to appropriately ensure identification of relevant transactions, and measures to manage such transactions and protect customers shall be recorded, and such records shall be maintained for 5 years from the date of preparation.
c 2008 Shinsei Trust & Banking Co., Ltd.  | e-mail: | sitemap