Outline of Conflict of Interest Management Policy
The Japan Bank for International Cooperation ("JBIC") and its subsidiary financial institutions, etc. (collectively, the "JBIC Group"), in accordance with the Financial Instruments and Exchange Act, have established the Conflict of Interest Management Policy (the "Policy") and will appropriately manage the transactions that may cause conflicts of interest in order to prevent the interests of our clients from being unjustly impaired. The summary of the Policy is hereby published as provided below.
1. Identification of Transactions That May Cause Conflicts of Interest
(1) Subject Transactions
"Transactions that may cause conflicts of interest", which are subject to the Policy, mean such transactions conducted by the JBIC Group that may unjustly impair the interests of its clients ("Subject Transactions") in the following situations: i) when the JBIC Group's interests conflict or compete with the interests of its clients or ii) when the interests of multiple clients of the JBIC Group conflict or compete with each other.
(2) Scope of the Subject Clients
"Clients" who are subject to this Policy mean any client who is utilizing, had previously been utilizing, or may enter into business relations in relation to, the services provided by the JBIC Group in its "Financial Instruments Related Business".
The "Financial Instruments Related Business" refers to the business specified in Article 70-3 of the Cabinet Office Order on Financial Instruments Business, etc.
2. Companies Requiring Conflict of Interest Management
As stated in 1 (1) above, the Subject Transactions are transactions conducted by the JBIC Group (i.e. JBIC and its subsidiary financial institutions, etc.). JBIC's "subsidiary financial institutions, etc." mean a subsidiary or affiliated company of JBIC which meets the definition of the term "Subsidiary Financial Institution, etc." specified in Article 36, Paragraph 5 of the Financial Instruments and Exchange Act.
As of March 31, 2023, the companies listed below are the subsidiary financial institutions, etc. of JBIC.
IFC Capitalization (Equity) Fund, L.P.
National Industrial Corridor Development Corporation Limited
JBIC IG Partners
RJIF GP2 Limited
Russian-Japan Investment Fund, L.P.
JB Nordic General Partner S.à.r.l.
JB Nordic Ventures Oy
JB Nordic Fund I SCSp
NordicNinja Fund II General Partner S.à.r.l.
NordicNinja VC Limited
3. Method of Managing Transactions That May Cause Conflicts of Interest
If the JBIC Group identifies any situations where conflicts of interest may arise in connection with transactions with its clients, the JBIC Group will take measures in accordance with the relevant situation, including, for example, the following methods:
- The method of separating the department conducting the Subject Transaction, from the department conducting the transaction with such client;
- The method of amending the conditions or method of the Subject Transaction or the transaction with such client;
- The method of discontinuing the Subject Transaction or the transaction with such client;
- The method of properly disclosing to such client the possibility that the interests of the client may be unjustly impaired in connection with the Subject Transaction; and/or
- Any other methods to properly manage the Subject Transaction.
4. Conflict of Interest Management System
The JBIC Group will centrally manage the group's overall conflict of interest by establishing a department which will manage and control conflicts of interest. The JBIC Group will continue to establish and maintain proper internal systems and comply with laws and regulations and other rules concerning the management of conflicts of interest.