1. Executive Summary
BNP Paribas, Tokyo Branch and BNP Paribas Securities (Japan) Limited (hereinafter, “BNPP Japan”), have 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, BNPP Japan has been, and is taking below actions.
2. Principles and Actions
1. Our Action Plan and Status (As of 28th February, 2019)
Customer’s Best Interest
Principle 1 : “Pursuit of the Customer’s Best Interest”
|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.||Carried out on an on-going basis.|
Conflicts of Interest
Principle 2 : “Appropriate Management of Conflicts of Interests”
|We established a specific framework for the handling of conflicts of Interest.||Framework in place and Policy publicized.
Reviews carried out as appropriate.
Conflict of Interest Policy:
BNP Paribas, Tokyo Branch
BNP Paribas (Securities) Japan Ltd
|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 activities of our firms and our firms’ employees.||Framework in place. Reviews carried out as appropriate.
Controls carried out on an on-going basis.
Commissions, Fees and Other costs
Principle 3 : “Disclosure of commissions and other costs”
|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.
Adherence to such framework is being properly checked and monitored.
|Framework in place. Reviews carried out as appropriate.
Controls carried out on an ongoing basis.
Principle 4 : “Provide important information about financial products/services in a way which Customers can easily understand”
|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.|
Products and Services Suitable for our Customers
Principle 5 : “Provide suitable financial products/services to Customers”
|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.|
|We have policies and procedures which we follow 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 firm management||Framework in place , and carried out for new products/activities, as set out in our internal policies.|
Principle 6 : “Protecting Customers’ confidentiality”
|We have a framework to ensure confidentiality and take appropriate measures where necessary. This includes strict respect of information barriers within the BNP Paribas group.||Framework in place , and carried out on an on-going basis.|
Appropriate Incentives to our Employees
Principle 7 : “Appropriate incentives provided to employees”
|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 takes into account conduct matters.
|Framework in place and carried out on an on-going basis|
2. Continuous Review and Improvement
At BNPP, 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 firms’ and our staff’s actions, but also to take further initiatives. Communication will be made in due course on such initiatives as well as to update on our progress.