The governing language of this Policy shall be Japanese. This English translation is made only for reference purpose and shall have no effect.

1. Preamble

In order to conduct the foreign exchange transaction business by complying with the "FX Global Code", SBI Shinsei Bank, Limited (hereinafter, "the Bank") has developed and hereby discloses the "Foreign Exchange Transaction Policy" for the Bank's roles and standard transaction practices of foreign exchange transactions with its customers.
This Policy does not override the laws and regulations that apply to foreign exchange transactions and individual agreement with the Bank's customers.

2. The Bank's roles in foreign exchange transactions with its customers

The Bank undertakes foreign exchange transactions with its customers as principal for its own account. This means that, as a party to the transaction, the Bank assumes credit risk and market risk at various levels that are embedded in the orders or related transactions made by the Bank's customers. Without a separate individual agreement, the Bank does not act as an agent, trustee, financial advisor for its customers or any other roles.

3.Transaction requests from customers

Two types of transaction requests can be made from the Bank's customers:


I. Price quotation requests: Customers request the Bank to quote a price

II. Order: Customers request the Bank to execute a transaction at the Bank's own discretion. Customers can add certain conditions to each order (such as "At Best" and "Stop Loss").

4. Order handling

(1) The Bank does not guarantee executing customer orders under a particular method or executing all or any part of the orders.


(2) Without separate individual agreement, the Bank has discretion to decide which order, how, and when to execute (in an electronic method or manually, etc.).


(3) Execution of orders depends on financial conditions and the Bank's foreign exchange position. The Bank may decline to execute orders that have excessive risk or may distort market functions anytime in its own judgement and has no obligation to disclose why the Bank did not execute the orders.


(4) The Bank may also conduct cover transactions ("pre-hedging") before accepting or executing customer orders for securing customer profit and controlling the Bank's foreign exchange position.


(5) Risk management transactions of the Bank may be executed at a level close to the trigger level of the Stop Loss orders received from customers. The transactions may therefore affect the reference prices of customer orders which may trigger Stop Loss orders.


(6) Customer orders may be executed together with transactions aimed at the Bank's risk management, transactions for adjusting or terminating the Bank's position or transactions with other customers.

5.Execution price

As long as there is no separate agreement, the final price at which the Bank contracts with its customers ("execution price") is the total of a price including the bid-offer spread, the Bank's costs related to executing the transaction, and factors such as the risks assumed by the Bank and consideration, etc. of the services provided by the Bank to the customer ("mark-up"). Execution prices depend on the financial conditions at the time of execution, the Bank's foreign exchange position, the customer credit standing and transaction status, and other factors. Accordingly, the prices may differ by customer even for the same or similar transactions.
Furthermore, prices quoted by the Bank to the customer before execution are reference prices at the time of the quote, and therefore guarantee neither the execution at that price nor the execution itself.

6. Handling of customer information

The Bank has introduced policies, procedures and management methods to manage and protect the confidential information of its customers adequately. However, the Bank may disclose the confidential information of its customers externally as necessary in certain circumstances such as it is required to be disclosed under relevant laws or regulations, or requested by relevant regulatory authorities, etc. When information of a foreign exchange transaction is of a confidential nature, the information is shared internally under an appropriate information management structure and within the scope needed for business.

7. Market color

After aggregating, anonymizing and generalizing it, the Bank may share internally or disclose to third parties information related to its customer orders and transactions executed, as "market color".

8. Information provided by the Bank

Reports or information on market trends and the market outlook provided by the Bank are solely for the purpose of information provision and are not aimed at solicitation for any particular transaction. The Bank provides the information based on publicly available information and data but does not guarantee the accuracy or certainty of the information. When considering any financial product transaction, customers are advised to sufficiently understand the product and execute the transaction at their own risk and responsibility.


The Bank has released a Statement of Commitment to "the FX Global Code". The Bank operates the foreign exchange transaction business based on the "Code" for the Statement.

As a liquidity provider, the Bank has established a "Disclosure Cover Sheet" related to the "FX Global Code" for the Sheet.