Correspondence Chart Regarding Customer-Oriented Business Conduct (BNP Paribas, Tokyo Branch)
Date of posting or updating: June 19, 2025
| FSA – List of correspondence with COBC Policy | |
| Name | BNP Paribas, Tokyo Branch |
| ■URL for Policy： | https://www.bnpparibas.jp/en/important-notices/policy-on-cobc-tokyo-branch/ |
| ■URL for KPI： | https://www.bnpparibas.jp/en/important-notices/cobc-disclosure-tokyo-branch/ |
| Principle | Conduct/Not Conduct | Relevant Policy on Web | Relevant KPI on Web | ||
| Principle 2 | 【Pursuit of the Customers’ Best Interests】 Financial Business Operators should act in the best interests of their customers through carrying out business towards customers in a faithful and fair manner, maintaining a high level of sophistication and professional ethics. Financial Business Operators should endeavor to solidify such business conduct as part of the corporate culture. |
Conducted | Policy on Customer-Oriented Business Conduct 1. Pursuit of the Customers’ Best Interests (Correspondent with Principle 2) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 1. Pursuit of the Customer’s Best Interest” (Correspondent with Principle 2) |
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| Note | Financial Business Operators should aim to maintain a stable customer base and revenue raising via providing good quality service based on the efforts to carry out Customer Oriented Business and pursuing the customers’ best interests when transacting with customers. | Conducted | Policy on Customer-Oriented Business Conduct 1. Pursuit of the Customers’ Best Interests (Correspondent with Principle 2) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 1. Pursuit of the Customer’s Best Interest” (Correspondent with Principle 2) |
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| Principle 3 | 【Appropriate Management of Conflicts of Interests】 Financial Business Operators should correctly understand potential conflict of interests when transacting with customers, and when a conflict of interests potentially exists, to manage such conflict appropriately. Financial Business Operators should have in place detailed policies regarding this topic. |
Conducted | Policy on Customer-Oriented Business Conduct 2. Appropriate Management of Conflicts of Interests (Correspondent with Principle 3) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 2. Appropriate Management of Conflicts of Interests” (Correspondent with Principle 3) |
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| Note | Financial Business Operators should also take into consideration points such as the impact the following items may have on transactions or businesses, when determining the possibility of a conflict of interest:
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Conducted | Policy on Customer-Oriented Business Conduct 2. Appropriate Management of Conflicts of Interests (Correspondent with Principle 3) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 2. Appropriate Management of Conflicts of Interests (Correspondent with Principle 3) |
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| Principle 4 | 【Disclosure of Commissions, Fees and Other Costs】 Financial Business Operators should provide their customers with detailed information of commissions or other fees charged to the customer, including for what service such commissions or fees are for, in a way the customer can understand. |
Conducted | Policy on Customer-Oriented Business Conduct 3. Disclosure of Commissions, Fees and Other Costs (Correspondent with Principle 4) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 3.“Disclosure of commissions and other costs (Correspondent with Principle 4) |
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| Principle 5 | 【Provide Important Information in a Clear Way】 Financial Business Operators should provide their customer with important information regarding the sale or solicitation etc. of financial products or/and services in addition to what is stated under Principle 4 above, in a way the customer can easily understand, considering the asymmetry in the amount and quality of information that can be obtained between the customer and the Financial Business Operator. |
Conducted | Policy on Customer-Oriented Business Conduct 4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand (Correspondent with Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 4. Provide important information about financial products/services in a way which Customers can easily understand (Correspondent with Principle 5) |
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| Note 1 | Important information should include:
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Conducted | Policy on Customer-Oriented Business Conduct 4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand (Correspondent with Principle 5) 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) Information Disclosure 4. Provide important information about financial products/services in a way which Customers can easily understand (Correspondent with Principle 5) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 2 | When selling or soliciting multiple financial products or services as a package, Financial Business Operators should not only provide information on whether it is possible to purchase individual products separately, but also important information regarding both the packaged and the unpackaged versions so that the customer is able to compare ((Note 2) – (Note 5) applies when providing information regarding commission fees, etc. | Not conducted | Policy on Customer-Oriented Business Conduct 4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand (Correspondent with Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 4. Provide important information about financial products/services in a way which Customers can easily understand (Correspondent with Principle 5) |
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| Note 3 | Financial Business Operators should provide information in a clear and easy to understand manner with faithful contents which would is not misleading, taking into account the customers’ transaction record and financial knowledge. | Conducted | Policy on Customer-Oriented Business Conduct 4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand (Correspondent with Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 4. Provide important information about financial products/services in a way which Customers can easily understand (Correspondent with Principle 5) |
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| Note 4 | Financial Business Operators should provide information in a manner easy to understand, corresponding to the complexity of the financial product / service being offered to customers. While Financial Business Operators may conduct simple information provision when selling or soliciting simple and low-risk products, Financial Business Operators, when selling or soliciting complex or high-risk products must endeavor to ensure that a more clear and thorough information provision is conducted, including the basic structure such as the risk vs return, and by using materials arranged to make it easier for customers to compare the product to similar products. | Not conducted | Policy on Customer-Oriented Business Conduct 4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand (Correspondent with Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 4. Provide important information about financial products/services in a way which Customers can easily understand (Correspondent with Principle 5) |
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| Note 5 | When providing information to customers, Financial Business Operators should distinguish the information by level of importance, and regarding the more important information, to, for instance, emphasize it especially to draw customers’ attention to it. | Conducted | Policy on Customer-Oriented Business Conduct 4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand. (Correspondent with Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 4. Provide important information about financial products/services in a way which Customers can easily understand (Correspondent with Principle 5) |
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| Principle 6 | 【Provide Suitable Financial Products/Services to Customers】 Financial Business Operators should structure / sell / solicit financial products / services that are suitable for the particular customer, by understanding the customer’s status of assets, transaction record, knowledge level, purpose of transaction and needs. |
Conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) Products and Services Suitable for our Customers 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 1 | Financial Business Operators should be mindful of the following points then propose specific financial products and services based on this.
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Partially conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 2 | When selling or soliciting multiple financial products / services as a package, Financial Business Operators should consider whether the overall package is suitable for the specific customer. | Conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 3 | When manufacturing a financial product, the manufacturer should specify and disclose the customer attributes deemed necessary to be a target of sales for that product, based upon the characteristics of the product, etc. A distributor of financial products should fully understand such attributes, determine the suitability of customers, and sell financial products under its own responsibility. | Partially conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 4 | Financial Business Operators should, especially when selling / soliciting complex or high-risk financial products , as well as when selling / soliciting products to customers belonging to investor-types that are more likely to incur damage from financial transactions, carry out careful due diligence on whether it is appropriate or not to be selling / soliciting the particular product, in accordance with the product or the customer’s investor-type. | Conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 5 | Financial Business Operators should endeavor to deepen the understanding by their employees regarding the structure, etc., of the financial products they handle, and simultaneously, to proactively provide basic information on financial transactions to customers, based on their investor type. | Conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers. (Correspondent with Principle 6) 7. Appropriate Incentives Provided to Employees (Correspondent with Principle 7) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) 7. Appropriate Incentives Provided to Employees (Correspondent with Principle 7) |
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| Note 6 | Distributors of financial products should cooperate with the manufacturers of those products by providing them with information on the attributes of customers who actually purchased the financial products as well as information on customers’ responses and sales conditions for the financial products, in order for both manufacturers and distributors to achieve the best interests of customers. | Conducted | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Note 7 | Depending on the characteristics of financial products such as their complexity, risk, etc., distributors of financial products should endeavor to understand the measures taken by those products’ manufacturers to ensure effective product governance, and, if necessary, should use such information in the selection of manufacturers. | Not applicable | Policy on Customer-Oriented Business Conduct 5. Provide Suitable Financial Products/ Services to Customers (Correspondent with Principle 6) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 5. Provide suitable financial products/services to Customers (Correspondent with Principle 6) |
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| Principle 7 | 【Appropriate Framework Etc. to Incentivize Employees】 Financial Business Operators should establish a compensation / performance evaluation processes, training framework, and other framework which appropriately incentivizes employees, as well as an effective corporate governance framework designed to promote the pursuit of customers’ best interests, fair treatment of customers and effective management of conflicts of interests. |
Conducted | Policy on Customer-Oriented Business Conduct 7. Appropriate Incentives Provided to Employees (Correspondent with Principle 7) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 7. Appropriate incentives provided to employees (Correspondent with Principle 7) |
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| Note | Financial Business Operators should notify the employees who are involved in these measures about the content implemented in accordance with these principles (including the notes attached thereto), as well as the content of alternative measures to be taken in instead if not implemented, and establish a system to support and validate the business operations of the employees. | Conducted | Policy on Customer-Oriented Business Conduct 7. Appropriate Incentives Provided to Employees (Correspondent with Principle 7) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 7: “Appropriate incentives provided to employees” (Correspondent with Principle 7) |
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| Supplementary Principle 1 | 【Basic Philosophy】 In order to add value to its customers while ensuring the sustainable provision and management of financial products and services, a manufacturer of financial products should define a philosophy for providing better financial products to customers, and implement a governance structure consistent with that philosophy, under the leadership of a person sufficiently qualified for that role. |
Conducted | Policy on Customer-Oriented Business Conduct 8. Basic Philosophy (Correspondent with Supplementary Principle 1) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduc 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 8. Basic Philosophy (Correspondent with Supplementary Principle 1) |
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| Supplementary Principle 2 | 【Structure development】 A manufacturer of financial products should ensure effective product governance over the entire lifecycle of its products, based on the philosophy described above. On this basis, a manufacturer should conduct appropriate quality control in each stage of the manufacture, provision and administration of its financial products, and establish a system to ensure the effectiveness of these processes. |
Conducted | Policy on Customer-Oriented Business Conduct 9. Structure Development (Correspondent with Supplementary Principle 2) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 9. Structure Development (Correspondent with Supplementary Principle 2) |
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| Note 1 | A manufacturer of financial products should develop a framework for verification by its control divisions, to ensure effective product governance throughout the entire life cycle of financial products from manufacture to redemption and the effective quality control in each process of manufacture, provision and administration. Depending on the size of its business and the characteristics of the financial products offered, the financial service provider should also consider a mechanism to incorporate opinions from external directors, outside experts and third-party institutions that evaluate investment funds, if necessary. | Conducted | Policy on Customer-Oriented Business Conduct 9. Structure Development (Correspondent with Supplementary Principle 2) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 9. Structure Development (Correspondent with Supplementary Principle 2) |
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| Note 2 | A manufacturer of financial products should establish a PDCA cycle by, for example, reviewing the effectiveness of its product governance at regular intervals. | Conducted | Policy on Customer-Oriented Business Conduct 9. Structure Development (Correspondent with Supplementary Principle 2) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 9. Structure Development (Correspondent with Supplementary Principle 2) |
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| Supplementary Principle 3 | 【Handling of financial products at the time of manufacturing】 A manufacturer of financial products should examine the sustainability and relevance of its products, taking into consideration whether they meet the real needs of customers, after assessing such needs. In addition, customer attributes should be defined to identify the appropriate targets of sales depending on the characteristics of individual financial products such as their complexity, risk, etc. Information sharing should also take place with the distributors of these products so that sufficient understanding of these matters is disseminated among them. |
Partially conducted | Policy on Customer-Oriented Business Conduct 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
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| Note 1 | A manufacturer of financial products should verify whether the financial products that it produces are sustainable over the medium to long term and should also verify the reasonableness of risk-return-cost at appropriate intervals. | Conducted | Policy on Customer-Oriented Business Conduct 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
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| Note 2 | When identifying the attributes of prospective customers, a manufacturer of financial products should assess a customer’s asset situation, trading experience, knowledge, trading objectives and needs, etc. in relation with the products’ characteristics such as their complexity, risk, etc., and should also take into account the sales methods to be assumed. In doing so, customers who should not purchase certain products should also be identified (e.g. financial products that may affect the principal for customers who aim to secure principal). Additionally, for complex financial products or financial products with special investment and allocation methods, the type of needs the product is designed to meet and whether these needs are appropriately reflected in said product ought to be defined, and more detailed customer attributes should also be carefully established. | Not applicable | Policy on Customer-Oriented Business Conduct 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
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| Note 3 | When defining customer needs and identifying prospective customers’ attributes with a view to provide such customers with optimal products, a financial products manufacturer should cooperate with the distributors of such products and, if necessary, conduct surveys to understand the actual situation, considering the characteristics of the financial products such as their complexity, risk, etc. In addition, prior arrangements regarding the coordination of information sharing should be made between manufacturers and distributors to enhance the post-manufacture verification of the products. | Not applicable | Policy on Customer-Oriented Business Conduct 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 10. Handling of financial products at the time of manufacturing (Correspondent with Supplementary Principle 3) |
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| Supplementary Principle 4 | 【Post-Origination of financial products】 A manufacturer of financial products should continuously verify whether the merchantability of financial products as initially envisaged remains valid and use the results of such verification to review and improve its products. It should also review its overall product governance structure including the process of manufacture, provision and administration, as necessary. In addition, for manufacturers and distributors to realize the best interests of customers, a manufacturer of financial products should verify whether the customers who actually purchased its financial products correspond to the intended profile of prospective customers through information sharing with the distributors of those products, and, if necessary, use such information to improve investment and product provision, and subsequent product manufacturing. |
Partially conducted | Policy on Customer-Oriented Business Conduct 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
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| Note 1 | In verifying the merchantability of financial products, a manufacturer of financial products should verify at appropriate intervals whether the balance of risk, return and cost is appropriate. If a financial product fails to provide the added value that it is intended to provide, the financial service provider should consider improving the financial product, combining it with other financial products or offering early redemption. It should also use this information to review the product governance system, including the processes of product manufacturing, provision and administration, as necessary. | Conducted | Policy on Customer-Oriented Business Conduct 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
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| Note 2 | A manufacturer of financial products should receive from the distributors of such financial products the information necessary for verification after the products are sold, considering characteristics as the products’ complexity, risk, etc. The information to be shared should be practical and aimed at providing better financial products for customers. It may include, for example, customer complaints and sales conditions in addition to information related to the profile of customers who actually purchased the products. If a manufacturer does not or cannot receive such information from a distributor, it should review the method of financial products sales, if necessary. In addition, a manufacturer should share with distributors its own assessment derived from the information obtained from the distributors. | Not applicable | Policy on Customer-Oriented Business Conduct 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
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| Note 3 | When a manufacturer of financial products outsources its investment function to a third party, it should monitor the investment activities of the outsourced party. Based on the results of this verification, the financial service provider should improve or review its financial products as necessary. If relevant, the information shared between a manufacturer and a distributor of financial products should also be coordinated with the outsourced party. | Not applicable | Policy on Customer-Oriented Business Conduct 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 11. Post-Origination of financial products (Correspondent with Supplementary Principle 4) |
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| Supplementary Principle 5 | 【Provision of easy-to-understand information to customers】 A manufacturer of financial products should provide customers with easy-to-understand information about its investment system and product governance regime so that customers can choose better financial products. |
Conducted | Policy on Customer-Oriented Business Conduct 12. Provision of easy-to-understand information to customers (Correspondent with Supplementary Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 12. Provision of easy-to-understand information to customers (Correspondent with Supplementary Principle 5) |
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| Note 1 | A manufacturer of financial products should provide customers with information about its investment system or provide details about the way investments in individual financial products are made. For example, for financial products for which the judgement of a person/ team who invests is important, the financial service provider should, with the consent of the person/ team, provide information on the name, business performance, investment philosophy, etc., of the person responsible for investments or the composition of the investment team and its business performance. | Not applicable | Policy on Customer-Oriented Business Conduct 12. Provision of easy-to-understand information to customers (Correspondent with Supplementary Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 12. Provision of easy-to-understand information to customers (Correspondent with Supplementary Principle 5) |
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| Note 2 | A manufacturer should also provide a distributor with easy-to-understand information on the merchantability of financial products | Not applicable | Policy on Customer-Oriented Business Conduct 12. Provision of easy-to-understand information to customers (Correspondent with Supplementary Principle 5) |
Action Plan and Progress Report Regarding Customer-Oriented Business Conduct 2. Principles and Actions 2. Our Action Plan and Status (As of June, 2025) 12. Provision of easy-to-understand information to customers (Correspondent with Supplementary Principle 5) |
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| Contact Information | |
| Department | Business Management |
| Contact details | dl.jp.ginko.cobc@asia.bnpparibas.com |