June 1, 2009
SBI Holdings, Inc.

1. Purpose
 With the diversification of services provided by financial institutions and accompanying the development of global financial conglomerates, multiple competing and confrontational interests have arisen within financial institutions and groups, resulting in an increased chance of developing conflicts of interest..
Given this environment, the SBI Group (the “Group”) is required to manage transactions at risk of causing conflicts of interest so that our Customers’ interests will not be harmed.  SBI Holdings, Inc. (the “Company”), as the management company of an industry conglomerate that provides various services, centering on financial services, has established a Management Policy for Conflicts of Interest as published here, in order to ensure an appropriate management system for conflicts of interest.
2. Financial Institutions within the SBI Group Required by Law to Maintain a System to Manage Conflicts of Interest
 SBI promotes the Financial Institutions within the SBI Group to provide for a system to manage conflicts of interest. The Group’s financial institutions which are legally required to provide for a system to manage conflicts of interest (“Financial Institutions with Conflict of Interest Management”) are shown in Exhibit 1.
3. Method of Identifying a Transaction at risk of causing a Conflict of Interest
 “Conflicts of Interest” as used herein are situations where the interests of :

(1) a customer and the Group; or
(2) a customer and another customer of the Group

Are in conflict. A “transaction which threatens to cause a conflict of interest” at a Financial Institution with Conflict of Interest Management (hereinafter “Subject Transaction”) is a transaction at a company referred to in Article 5 below which may threaten a customer’s interest. A Financial Institution with Conflict of Interest Management must establish an integrated Conflict of Interest Department independent from its business departments, to make appropriately identify Subject Transactions.
4. Type
Whether or not a transaction meets the definition of a Subject Transaction shall be determined using individual concrete factors. For example, the following transactions may to Subject Transactions.
  1. A Group Customer and the Group 2. A Group Customer and Another Customer of the Group
Interest Conflict Type Transaction in which there is a conflict of interest between the Company and a Customer Transaction in which there is a conflict of interest between the Customer and another Customer of the Group.
Competitive Transaction Type Transaction in which there is a conflict of competition between the Company and a Customer Transaction in which there is a competition between the Company’s customer and another Customer of the Group
Information Use Type Transaction in which the Group benefits itself by utilizing non-public information that the Group gathered from the customer based on that relationship Transaction in which the Customer benefit itself by utilizing non-public information which the Group gathered from another customer of the Group, based on that relationship
5. Scope of Companies under Conflict of Interest Management
 Within the Group, Subject Transactions shall be transactions of each company with a business regulated pursuant to the law of the corresponding Financial Institution with Conflict of Interest Management. Major companies are shown in Exhibit 2. Considering the character of the Group’s businesses, transactions which are not regulated by law shall also be considered.
6. Method of Managing Transactions which May Involve Conflict of Interest
 If a transaction is determined to be a Subject Transaction, the Financial Institution which Conflicts of Interest Management shall try to protect Customers appropriately through a selection or combination of methods below and other methods (The following methods are only examples, which may or may not be implemented)

i) Separation of the division responsible for the Subject Transaction and the division responsible for the applicable Customer’s deal
ii) Change in conditions or ways of the Subject Transaction or the applicable Customer’s deal
iii) Cancellation of the Subject Transaction or the applicable Customer’s deal
iv) Appropriate disclosure of information on possible risks that the applicable Customer’s interests may be unfairly impaired incidental to the Subject Transaction (provided, however, that such disclosure does not infringe the confidential duties of the Group)
7. Management System for Conflicts of Interest
 The Company shall establishes a Unified Conflict of Interest Department independent from the business departments and shall collaborates with each Unified Conflict of Interest Department in each Financial Institution with Conflict of Interest Management, and commits to maintain the Group’s System of Conflict of Interest Management..

Exhibit 1 (Last update date: May 1, 2015)
(1)SBI Japannext Co., Ltd.
(2)SBI SECURITIES Co., Ltd.
(3)SBI Insurance Co., Ltd.
(4)SBI Sumishin Net Bank, Ltd.
(5)SBI Life Insurance Co., Ltd.


Exhibit 2  (Last update date: Nov 1, 2016)
(1)SBI Asset Management Co., Ltd.
(2)SBI IKIIKI SSI Inc.
(3)SBI Investment Co., Ltd.
(4)SBI Estate Management Co., Ltd.
(5)SBI FXTRADE Co.,Ltd.
(6)SBI Card., Ltd.
(7)SBI Japannext Co., Ltd.
(8)SBI Resta SSI Co., Ltd.
(9)SBI SECURITIES Co., Ltd.
(10)SBI Insurance Co., Ltd.
(11)SBI Fund Management Company S.A.
(12)SBI Holdings, Inc.
(13)SBI MONEYPLAZA Co.,Ltd.
(14)SBI Sumishin Net Bank, Ltd.
(15)SBI Estate Finance Co., Ltd.
(16)SBI Life Insurance Co., Ltd.
(17)Morningstar Asset Management Co., Ltd.
(18)Book Field Capital Co., Ltd.
(19)SBI Bond Investment Management Co., Ltd.
(20)Nihon Small amount & Short term Insurance Co., Ltd.