Conflicts of Interest Management Basic Policy (Summary)

Sony Bank ("The Company") shall establish a basic policy for the management of conflicts of interest with respect to transactions that may cause conflicts of interest and manage so as not to unreasonably harm the interests of the Customer (*1) in the relation between the Customer and The Company, between the Customer and Group companies (*2), between the Customer and The Company agents, between the Customer and other Customer or between the Customer and Group companies' client (excluding the Customer) conducting financial transactions.

• "the Customer" shall mean the following Customer.
  • The Customer pertaining to the banking business, the business of Registered Financial Institutions, and all other business conducted as a bank by The Company
  • The Customer related to the bank agency business conducted by The Company agent to which The Company belongs through the entrustment of The Company
• "Group companies" shall mean the following companies.
  • Sony Life Insurance Co., Ltd.
  • Sony Assurance Inc.

Managed transactions specified

The Company shall identify and manage transactions that may unreasonably harm the Customer's interest among transactions that may result in conflicts of interest according to the following categories (“Managed transactions").

Types of Managed transactions

Types of Managed transactions are as follows.

• Transactions that capture profits or avoid losses at the expense of the Customer's profits
• Transactions in which the Customer may benefit differently from the Customer's interests as a result of such transactions
• Transactions that give preference to the interests of another Customer over the interests of the Customer
• Transactions, which received a fee other than the standard normal fee for the service from a third party other than the Customer (or pay the fee, etc.) rendered to the service provided to Customer
• Transactions that benefit from the use of the Customer non-public information
• Transactions in which the Customer has reasonable expectations that its interests will be prioritized through advice or suggestion
• Any transaction similar to any of the preceding items or any other transaction that may unreasonably harm the interests of the Customer

Practices for Management of Conflicts of Interest

Depending on the characteristics of the Managed transactions, the following controls are selected or combined to ensure that the interest of the Customer is not to unreasonably harm the interest of the Customer.

• Separate departments that may cause Conflicts of interest
• Change the trade terms or methods of one or both transactions in which there is the threat of Conflicts of interest
• Suspend one of the transactions concerned (that may pose a Conflicts of interest’s risk)
• Disclose to the Customer that there is a risk of Conflicts of interest
• Take any other action deemed appropriate by The Company

Structure for Management of Conflicts of Interest (5. Control System)

The Conflicts of interest shall be centrally managed by a department independent of the Sales Department.