HC asset management
JP

Fiduciary Declaration

HC Asset Management Co., Ltd. has adopted all 7 principles of the “Principles for customer first business practices” dated March 30, 2017.
We revised the “Fiduciary Declaration” that is the norm in fulfilling the customer first business practice as follows that same day.

Fiduciary Declaration

HC Asset Management Co., Ltd.
Noriyuki Morimoto, Chief Executive Officer

Based on the belief that there is no asset management without fiduciary duty, we hereby declare that the following norms shall be observed so that HC and HC’s executives and employees can fulfill our fiduciary duty of working “for the exclusive benefit of clients”.
When observing the norms, this shall not merely be in form, and we shall abide by the fiduciary duty doctrine and put it into practice as a “living norm”.

1.Complete customer first business practices

1-1
We provide the best service from the perspective of the clients’ interest based on rational objectives traced back to the underlying reason for such demand.
1-2
We provide clients with symmetry of information and information that generates common benefit with clients.
1-3
We deploy customer first business practices through operational functions taking the client as the starting point combined with the subordination of our Company’s standards so that there is no loss from the perspective of the clients’ interest.
1-4
We cultivate investment professionals with strict work ethics that work “exclusively for the benefit of the clients”
1-5
We appropriately evaluate and promote executives and employees on the basis of initiatives that incorporate proactive best practice that keep the clients’ interest at the forefront.

2.Prohibition of conflicts of interest

2-1
We do not exert improper influence through our company or persons with a vested interest when entering into new contracts.
2-2
We do not transact with stakeholders when investing and managing client assets so that we do not put ourselves in a position that could arouse concerns about conflicts of interest.
2-3
We appoint external investment management companies in each specialist field when undertaking investment management. Our selection and dismissal of such investment management companies is based exclusively on evaluation of their investment management capabilities. We do not have any special relationship with an investment management company irrespective of any business tie-up or investment in an investment management company or other pretext.

3.Rationality of remuneration

3-1
We adopt a reasonable remuneration rate reflecting differences such as the size of the clients assets and investment management details and accomplish fairness between clients by charging the same rate of remuneration for the same service.
3-2
We determine the rate of remuneration based on appropriate management expenses that are reasonably required to provide the stable and long lasting quality of our service. We strictly manage appropriate management expenses based on proper treatment as investment professionals, appropriate general management expenses and an appropriate rate of return on capital.

4.Compliance structure

4-1
To consolidate fiduciary duty as a corporate culture, we have established a Fiduciary Liaison Committee, evaluate the practice in relation to business management and share this between executives and employees.
4-2
To ensure that compliance of norms becomes a matter of course, any behavior that could be construed as being in conflict with the norms is implemented after prior confirmation by the Management Committee or other prescribed body.
4-3
The internal audit function is to regularly report to the Board of Directors following review of the state of compliance with the norms.
4-4
The Board of Directors comprises directors who are investment professionals and independent outside directors, who monitor and supervise the state of compliance with the norms.

Established August 21, 2015
Revised March 30, 2017

Reviewing that state of compliance (in Japanese)

Change in declaration (in Japanese)