Action Plan and Progress Report Regarding Customer-Oriented Business Conduct (BNP Paribas, Tokyo Branch)
1. Executive Summary
BNP Paribas, Tokyo Branch has established a Policy based on the Customer-Oriented Business Conduct principles as they were established by FSA in April 2017.
In order to promote and ensure that we make progress in light of this policy, BNP Paribas, Tokyo Branch has been, and is taking the actions described hereunder.
2. Principles and Actions
1. Common KPIs
Please note that BNP Paribas, Tokyo Branch does not carries out any selling of investment trusts within the scope of common KPIs.
2. Our Action Plan and Status (As of June, 2025)
1 : “Pursuit of the Customer’s Best Interest” (Correspondent with Principle 2)
| Actions | Status |
| With the purpose of striving to meet the needs of our Clients, we established and are periodically updating a suitability framework for the relevant Business areas. | Framework in place. Periodic reviews carried out on an on-going basis. |
| We have a global policy specifically addressing the protection of interest of Clients. | Framework in Place. Periodic Reviews carried out on an on-going basis. |
| We make sure that our Clients’ feedback (including complaints) is properly taken into consideration and that actions (including remediation) are taken when needed. Also, we monitor any issue impacting the level of service to our clients and take appropriate remedial action in a timely manner. | Carried out on an on-going basis. 100% of client complaints handled within the timeframe set out by internal policies. Training on client complaints handling assigned and completed by 100% of relevant staff. |
2 : “Appropriate Management of Conflicts of Interests” (Correspondent with Principle 3
| Actions | Status |
| We established a specific framework for the handling of conflicts of Interest. | Framework in place and Policy publicized. Reviews carried out as appropriate, and 100% of conflicts confirmed non-present or cleared prior to engagement. Conflict of Interest Policy: BNP Paribas, Tokyo Branch Training on Conflict of Interests assigned and completed by 100% of relevant staff. |
| In addition to the general framework around the control of Conflicts of Interests, we have specific frameworks and controls around Personal Account Dealing, Gifts & Invitations and Outside Business Activities, aiming at preventing potential conflicts of interests from occurring through our activities and our employees’ activities. | Framework in place. Reviews carried out as appropriate. Controls carried out on an on-going basis. |
3 : “Disclosure of commissions and other costs” (Correspondent with Principle 4)
| Actions | Status |
| We have established a framework around transacting with appropriate commission, fees and other costs for our Clients taking into account potential end-investors. This framework shall be reviewed and amended as necessary to be in line with the market environment. Commissions, fees and other costs incurred by our counterparties are disclosed where necessary. | Framework is in place, and the process is carried out as set out in our internal procedures. |
4 : “Provide important information about financial products/services in a way which Customers can easily understand” (Correspondent with Principle 5)
| Actions | Status |
| We provide our Clients with product specifications which we believe to be easy to understand and have systematic reviews of any written materials used for marketing to ensure continued quality of their content. | Framework in place and carried out on an on-going basis. |
Note) As stated within our Policy on Customer-Oriented Business Conduct, under “4. Provide Important Information About Financial Products/Services in a Way Which Customers Can Easily Understand”, we do not transact with individual clients, and therefore we do not create nor provide the Important Information Sheet. Reflecting this point, we have indicated “Not conducted” with regard to Principle 5, Notes (2) and (4) in our Correspondence Chart.
5 : “Provide suitable financial products/services to Customers” (Correspondent with Principle 6)
| Actions | Status |
| In order to ensure proper suitability of our products to our Clients, we carry out a thorough and detailed KYC process to understand the needs and status of our Clients. | Framework in place, and carried out for new Clients as well as existing Clients, as set out in our internal policies. |
| In the case of distribution business, we have procedures in place to conduct due diligence on our distributor clients (KYD, Know Your Distributor) to check their process for suitability analysis and selling framework. This process involves both the 1st and 2nd lines of defense, as well as the senior management of the entity. Additionally, we also periodically check the business situation and selling framework etc. of the distributor clients with whom we have continuous business relationships. | Framework in place and carried out as set out in our internal procedures. In 2023, we have enhanced our existing KYD framework and product governance framework for distribution business. We endeavor to continuously enhance this framework with the spirit of the Customer-Oriented Business Conduct. |
| We have policies and procedures which we follow, including our product governance process established locally and globally, in ensuring the suitability of the product to our Clients, as well as detailed reviews of new transactions, products or activities, involving scrutiny and approval from all control functions (Legal, Risk, Compliance, etc.) as well as from senior management. | Framework in place, and carried out for new products/activities, as set out in our internal policies. In the past 12 months (April ’24 – March ‘25) 100% of the new transactions, products or activities were reviewed in accordance with the relevant framework or policies. Compliance Training: 100% of all staff In 2023, we have enhanced our existing KYD framework and product governance framework for distribution business. We endeavor to continuously enhance this framework with the spirit of the Customer-Oriented Business Conduct. |
| For cases where we are in the capacity of structuring financial products to be sold through distributors to end investors, in response to the latest “Principles on Customer-Oriented Business Conduct” issued by FSA, and following the latest JSDA Guideline on Reasonable Basis Suitability issued in July 2023, we provide the required information of target clients’ investor type to whom the product is expected to be sold. | Framework is in place, and we conduct the required information provision. In 2023, we have enhanced our existing KYD framework and product governance framework for distribution business. We endeavor to continuously enhance this framework with the spirit of the Customer-Oriented Business Conduct. |
| We proactively provide information on the basics around financial transactions to clients, based on their investor type. | Conduct Dilemma Session: 100% of all clients facing staff who are deemed required to participate. |
Note) As stated within our Policy on Customer-Oriented Business Conduct, under “5. Provide Suitable Financial Products/ Services to Customers”, we carry out business with corporate and institutional customers, and the way we deal with our customers reflects their nature and their level of sophistication, and we provide products or services as well as required information etc. in relation to such products or services, considering factors such as the client’s investment purpose, experience, knowledge, expertise and financial status etc. Additionally, we do not transact with individual clients, and therefore we do not propose financial products or services based on customers’ life plan. (Where we have indicated “Partially conducted” with regard to Principle 6, Notes (1) and (3) in the Correspondence Chart below, it means that we will take the necessary action, as and when required, as set out in the Note, as per explained in the previous sentences.) . As We do not envisage a case which we, as a distributor, sell financial products manufactured by other companies. However, we as a manufacturer provide our Assumed Client Attributes to the distributors, and we will request them to provide information on the distribution status to the end investors and on any complaints that may be raised. This is for the sake of ensuring a communication between the manufacturer / distributor, in order to achieve the best interest of customers.
As described above, since we consider that there is no case in which we will be selecting manufacturers, we have indicated “Not applicable” with regard to Principle 6, Note (7) in our Correspondence Chart.
6 : “Protecting Customers’ confidentiality”
| Actions | Status |
| We have a framework to ensure confidentiality and take appropriate measures where necessary. This includes strict respect for information barriers within the BNP Paribas group. | Framework in place and carried out on an on-going basis. |
7 : “Appropriate incentives provided to employees” (Correspondent with Principle 7)
| Actions | Status |
| We raise continuous initiatives in order to further strengthen conduct and ethical values among employees in general, with a focus on Client facing employees. We give to our staff the relevant training multiple times a year to achieve this goal. We have established a framework on the evaluation of staff performance that requires all employees to act, behave appropriately and comply with the general ethical standards expected by BNP Paribas Group and relevant regulatory authorities (“Conduct Rating”). The Conduct Rating is taken into account to the compensation process under the supervision of senior management. | Framework in place and carried out on an on-going basis. During the past 12 months (April ’24 – March ’25), the following, amongst others, have been carried out: Training on Protection of Interest of Clients: 100% of relevant staff Training on the Code of Conduct. 100% to all staff Performance review and evaluation conducted based on the Code of Conduct: 100% of all staff Conduct Dilemma Session: 100% of all client facing staff who are deemed required to participate. |
8: “Basic Philosophy” (Correspondent with Supplementary Principle 1)
| Actions | Status |
| ‘We have a global policy and concept specifically addressing the protection of interest of Clients, and have established a governance framework in line with our philosophy. | Framework in place. Periodic reviews carried out on an on-going basis. |
9: “Structure Development” (Correspondent with Supplementary Principle 2)
| Actions | Status |
| By holding “Product Lifecycle Management Committee” meetings regularly and reviewing all products we handle on a risk-based basis, we manage the quality of each of the processes in the value chain appropriately and efficiently and ensure effectiveness. | Framework in place and SOP to be publicized; Product Lifecycle Management Committee has been held on June 11, 2025. We endeavor to continuously enhance the framework with the spirit of the Customer-Oriented Business Conduct, by feeding the result of the committee into the product governance framework. |
10: “Handling of financial products at the time of manufacturing” (Correspondent with Supplementary Principle 3)
| Actions | Status |
| We have policies and procedures in place, including our product governance process established locally and globally, in ensuring the suitability of the product to our clients. We also have a governance framework around cost, which ensures the pricing will be made in a fair manner. For cases where we are in the manufacturer role of financial products to be sold through distributors to end investors, we provide the required information of target clients’ investor type to whom the product is expected to be sold. We carry out periodical reviews of our information disclosure requirements and stand ready to adapt to new requirements, including the ones specified by JSDA, to ensure all information exchanged remains relevant. | Framework in place. In the past 12 months (April ’24 – March ‘25) 100% of the new transactions, products or activities were reviewed in accordance with the relevant framework or policies. Compliance Training: 100% of all staff Framework in place, and carried out as set out in our internal procedures. We provide clients with necessary information, including the Assumed Client Attributes. |
| In the role as manufacturer of distribution business, we have procedures in place to conduct due diligence on our distributor clients (KYD, Know Your Distributor) to check their process for suitability analysis and their distribution framework. Additionally, we periodically check the business situation and the distribution framework etc. of the distributor clients with whom we have continuous business relationships. | Framework in place. In 2023, as part of our ongoing efforts, we have enhanced our existing KYD framework and product governance framework for distribution business. In the past 12 months (April ’24 – March ‘25) 100% of transactions were conducted with approved distributors in line with their tiering. We endeavor to continuously enhance this framework with the spirit of the Customer-Oriented Business Conduct. |
Note) As stated within our Policy on Customer-Oriented Business Conduct, under “10. Handling of financial products at the time of manufacturing”, since we do not provide financial product through distributors, the latter part of the Supplementary Principle 3 does not apply and hence our reply is “Partially conducted” in our Correspondence Chart. For the same reason, both Footnote (2) and (3) are classified as “Not applicable”.
11: “Post-Origination of financial products” (Correspondent with Supplementary Principle 4)
| Actions | Status |
| As part of post origination assessment, we assess whether the product features expected at the point of product launch are still valid by monitoring the balance of risk and return on a risk-based approach. We have a framework around transacting with appropriate commission, fees and other costs for our clients taking into account potential end-investors. | Framework in place and Policy publicized. Product Lifecycle Management Committee has been held on June 11, 2025. In 2023, we have enhanced our existing KYD framework and product governance framework for our distribution business. Under the governance, we are periodically reviewing our products. We follow our internal policy on Commissions to ensure appropriate level of fees and commissions |
| We make sure that our clients’ feedback (including complaints) is properly taken into consideration and that necessary actions (including remediation) are taken when needed. Also, we monitor any issue impacting on the level of service on our clients and take appropriate remedial action in a timely manner. As part of the mutual exchange of information with distributors, we are expecting to receive information from the distributors on any mismatch in the status of the end investors vs the assumed client attributes that we have provided, as well as the status of client complaints, as stated in the guideline issued by JSDA. | Framework in place: We are in mutual communication with the distributors, and we provide information to the distributors, including the Assumed Client Attributes. We expect to receive relevant information (such as client complaints and any mismatch in the status of the end investors vs our assumed client attributes) from the distributors as stated in the guideline issued by JSDA |
Note) As stated within our Policy on Customer-Oriented Business Conduct, under “11. Post-Origination of financial products”, since we do not provide financial product through distributors, the latter part of the Supplementary Principle 4 does not apply and hence our reply is “Partially conducted” in our Correspondence Chart. For the same reason, both Footnote (2) and (3) are classified as “Not applicable”.
12: “Provision of easy-to-understand information to customers” (Correspondent with Supplementary Principle 5)
| Actions | Status |
| We endeavor to provide our clients with product specifications which we believe to be easy to understand, and have systematic reviews of any written materials used for marketing to ensure continued quality of their content. We also provide distributors with detailed information about the reference assets that form an important part of the product and information about risks as necessary. | Framework in place, and carried out on an on-going basis. |
Note) As stated within our Policy on Customer-Oriented Business Conduct, under “12. Easy-to-understand information to customers”, as we do not manufacture funds such as Invest Trusts, we have indicated “Not applicable” with regard to Supplementary Principle 5, Notes (1) in our Correspondence Chart, and since we do not provide financial product through distributors, we have indicated “Not applicable” with regard to Supplementary Principle5 , Note (2) and (3) in our Correspondence Chart.
* Training refers to both periodical training and ad-hoc training.
3. Continuous Review and Improvement
At BNP Paribas, Tokyo Branch, we consider Conduct as a journey for which we need to continuously move forward and improve our setup, actions, policies and mind set.
This is why we will continue not only to review our actions and our staff’s actions, but also to take further initiative. Communication will be made in due course on such initiatives as well as to update on our progress.