Morgan Stanley Capital K.K. (hereinafter referred to as “Morgan Stanley”) has established policies for client-oriented business conduct as set out below.
We will provide periodic disclosures regarding the status of our compliance with such policies. Also, we will review the policies on a periodic basis and make a constant effort to provide our services in a client-oriented manner.
1. Our Policy on Putting Clients First
At Morgan Stanley, we are committed to fostering and maintaining a culture based on our five core values: Put Clients First, Lead with Exceptional Ideas, Do the Right Thing, Commit to Diversity & Inclusion, and Give Back. Living these values means, above all, conducting ourselves and our business activities in accordance with the letter and spirit of applicable laws and regulations and our policies, and acting with integrity to deliver first-class business in a first-class way. As directors, officers and employees, we have a shared responsibility to maintain the highest standards of ethical behavior in our dealings with our clients and communities.
- Do the Right Thing
- Act with integrity
- Think like an owner to create long-term shareholder value
- Value and reward honesty and character
- Put Clients First
- Keep the client’s interests first
- Work with colleagues to deliver the best of the Firm to every client
- Listen to what the client is saying and needs
- Lead with Exceptional Ideas
- Win by breaking new ground
- Leverage different perspectives to gain new insight
- Drive innovation
- Be vigilant about what we can do better
- Commit to Diversity & Inclusion
- Value individual and cultural differences as a defining strength
- Champion an environment where all employees feel a sense of belonging-are heard, seen and respected
- Expect everyone to challenge behavior counter to our culture of inclusion
- Attract, develop and retain talent reflecting the full diversity of society
- Give Back
- Serve our communities generously with our expertise, time and money
- Build a better Firm for the future by contributing to our culture
- Develop our talent through mentoring and sponsorship
Please refer to Morgan Stanley’s Code of Conduct for greater detail.
2. Our Policy on Proper Management of Conflict of Interest
Our core value of Putting Clients First requires us to place our clients’ interests first and manage conflicts appropriately between their interest and ours. Therefore, as set forth in our global policy, officers and employees must be sensitive to whether the actions they take could create an actual or potential conflict of interest, or even the appearance of a conflict of interest.
Conflicts of interest can arise in a number of circumstances, including between Morgan Stanley and one or more clients or between two or more clients. If we become aware of an actual or potential conflict of interest, we must act in accordance with regulatory requirements and our policies and procedures. Under our policies and procedures, we are required to identify, and where appropriate, address, disclose and/or restrict, business conduct and practices that may pose an actual or potential conflict involving the interests of Morgan Stanley, its clients and/or its officers and employees.
Please refer to our Code of Conduct available on Morgan Stanley website for greater detail.
3. Our Policy on Clarification of Fees, Applicable Commissions, etc., for the Financial Instruments Transaction Contracts and Services
We will seek to determine the terms and conditions of financial instruments transaction contracts and services that we provide for our clients in compliance with applicable laws and regulations.
When we provide information regarding financial instruments transaction contracts or services to our clients, we will provide an appropriate explanation of commissions for the financial instruments transaction contracts or services in compliance with applicable laws and regulations.
4. Our Policy on Providing Important Information in an Understandable Manner
When we provide important information regarding financial instruments transaction contracts or services to our clients, we will endeavor to provide such information in a manner easily understandable by our clients.
5. Our Policy on Providing Suitable Service for Clients
We will strive to offer financial instruments transaction contracts and services suitable to our clients in an appropriate manner.
Please refer to our Solicitation Policy (Japanese only) available on Morgan Stanley website for greater detail.
6. Our Policy on Proper Training and Incentives for Employees
We strive to adhere to the highest standards of ethical conduct. Our commitment to ethical conduct means that we abide by the letter and the spirit of applicable laws and regulations. These principles are hallmarks of Morgan Stanley’s company culture and reflect our pledge to Do the Right Thing and Put Clients First.
In order to promote the compliance with our policies and procedures, we deliver mandatory training to all the employees on a regular basis to raise their awareness and remind them to act in the best interest of the clients.
A breach of Morgan Stanley’s five core values and above mentioned policies including the Code of Conduct may result in disciplinary action. Also, we regularly review our incentive compensation programs. We have implemented an employee performance evaluation and compensation determination processes designed to ensure that each employee’s compliance with the five core values and the policies will be reviewed and considered during those processes.