Mercuria Holdings
Basic Policy on Conflict of Interest Management
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Basic Policy on Conflict of Interest Management
Mercuria Investment Co., Ltd. (hereinafter referred to as the "Company") provides financial services, including financial instruments business. In order to prevent undue harm to the interests of the clients of the Company and to appropriately manage transactions that may cause conflicts of interest, we have established the following Basic Policy on Conflict of Interest Management.
1. Companies and Transactions Subject to Conflict of Interest Management
Subject transactions shall mean any transactions conducted by the Company in which the interests of a customer may be unduly impaired due to a conflict of interest between (1) the customer and the Company, and (2) the customer and another customer of the Company.
2. Classification and Identification of Conflicts of Interest
The Company categorizes conflicts of interest as follows, and if a conflict of interest is deemed to possibly fall under the relevant criteria, the general managers of the Company will identify the conflict of interest.
- (a) When there is a possibility that the Company will gain an economic benefit or avoid economic loss at the expense of a customer
- (b) When we obtain, or will obtain in the future, an inducement in the form of money, goods, or services other than the usual fees and expenses in a transaction with a person other than our customer
- (c) When conducting a transaction with a customer of the Mercuria Investment Group
- (d) When conducting a transaction on the part of the counterparty of a customer of the Mercuria Investment Group
- (e) When conducting a transaction with the counterparty of a customer of the Mercuria Investment Group that competes with another customer
- (f) When conducting a transaction to benefit oneself through the use of non-public information about customers of Mercuria Investment Group
- (g) When a transaction is impossible under the same conditions as a normal transaction due to the involvement of the Mercuria Investment Group in multiple capacities in that same transaction
3. Methods of Conflict of Interest Management
- (a) Changes to the content, method, conditions, etc. of a transaction with a conflict of interest
- (b) Termination of a transaction with a conflict of interest止
- (c) Disclosure of any conflict of interest to the customer
- (d) Other methods appropriate to the transaction
4. System for Conflict of Interest Management
The Company has designated the Compliance Department as the department responsible for the management of transactions with conflicts of interest, and the Cheif Compliance Officer as the person in overall charge. Information on transactions with conflicts of interest is gathered and centrally managed by the Compliance Department.
The Company has installed a system for appropriately managing conflicts of interest in each Mercuria Investment Group company, whereby if an officer or employee of the Mercuria Investment Group becomes aware of any actual or potential conflict of interest, they shall immediately report information about the conflict to the General Manager of the Compliance Department in accordance with the internal rules of each Mercuria Investment Group company, and the Chief Compliance Officer shall take action after considering the most appropriate way to deal with the conflict.
※This policy is subject to change or publication without notice.