To whom it may concern

May 16, 2017

Sumitomo Mitsui Trust Holdings, Inc.

Notice regarding Revisions to the Management Policy Concerning Conflicts of Interest (Summary)

- Enhancements to the Framework of the Trust Bank Group -

Sumitomo Mitsui Trust Holdings, Inc. (President: Tetsuo Ohkubo) ("SuMi TRUST Holdings") hereby announces revisions to our group-wide Management Policy Concerning Conflicts of Interest. (For a summary of these revisions, please refer to the annex hereto.)

The Sumitomo Mitsui Trust Group operates with sound business management based on a high degree of self-discipline with the background of trustee spirit, and provides our client with not only banking services, trust services and registered financial institution services, but also a wider range of financial services through fully utilizing its significant expertise and comprehensive capabilities.

Along with the various products and services provided by the companies in our Group and its officers and employees, in order to protect the interests of our clients from undue harm, as from before, we have made public a summary of the Management Policy Concerning Conflicts of Interest. Based on this Policy, we shall appropriately manage transactions that have possible conflicts of interest and carry out business operations.

At our Group, we will, in addition to these initiatives, revise the Management Policy Concerning Conflicts of Interest, and seek to enhance the framework described below.

We will, based on the revised Policy, advance the enhancement and consolidation of the conflict of interest management framework of our Group and, under a framework of best practice, we will proceed to provide our clients with high value-added "total solutions", as a trust banking group that is the "best partner to our clients", able to foster even greater comfort and confidence than before.

Details

Summary of Enhancements to the Conflict of Interest Management Framework of the Sumitomo Mitsui Trust Group
  1. Improvement of the Supervisory Structure of the Entire Group (establishment of the Conflicts of Interest Committee)

    We will establish at SuMi TRUST Holdings the "Conflicts of Interest Committee", which is not a statutorily required committee, as an advisory body of the Board of Directors (scheduled for July 2017), and strengthen supervisory functions. Moreover, on the operational side of SuMi TRUST Holdings and at Sumitomo Mitsui Trust Bank, we have also established the "Committee for Enhancement of Conflict of Interest Management".

    The Conflicts of Interest Committee will be majority comprised of external experts and external officers and, as well as examining the adequacy and effectiveness of the group's conflict of interest management framework, it will publish summaries of these deliberations, and implement a

    highly-transparent operational framework.

  2. Introduction of Separation of Authority, etc. in the Major Departments and Businesses of Sumitomo Mitsui Trust Bank

  3. Conflict of Interest Management Framework related to Asset Management Operations

    We have established and publicly announced the "Policy for the Conflict of Interest Management Framework relating to Asset Management Operations", as a pillar for the development, etc. of a new framework, based on the "Stewardship Activities Advisory Committee", which includes participation of external experts (January 31, 2017).

    http://smth.jp/en/news/2017/E170131.pdf

  4. Separation of Authority etc. of Wholesale Total Solutions Services Business and Wholesale Asset Management Business.

    As between the "wholesale total solution services business" (centered on banking transactions with clients such as business corporations) and the "wholesale asset management business" (centered on providing managed products and services, such as trusts, to institutional investors, etc., such as regional financial institutions), we are proceeding with enhancement of a management structure that involves separation of authority, etc. within the company based on the characteristics of the business.

  5. Highly-Effective Management System (Sumitomo Mitsui Trust Bank)

  6. Strengthening the Product Review Process when Introducing New Products and New Services Regarding reviews for the introduction of new products and new services, we are proceeding to strengthen our product review structures, including further enhancements to the substantive adequacy of reviews from the perspective of conflict of interest management.

    Together with this, we will examine the adequacy and effectiveness of conflict of interest management with respect to our existing main products and services, and proceed with improvements, etc. to management methods as necessary.

  7. Deployment of a "Conflict of Interest Management Officer"

  8. From the perspective of improving the effectiveness of conflict of interest management, in addition to a Conflict of Interest Management General Manager at the company-wide level, we will deploy "Conflict of Interest Management Officers" to the business supervising departments etc. of our business divisions, and will seek to implement management of conflicts of interest that is further suited to individual products and transactions.

    (Annex)

    Summary of the Management Policy of the Sumitomo Mitsui Trust Group Concerning Conflicts of Interest

    The Sumitomo Mitsui Trust Group operates with sound business management based on a high degree of self-discipline with the background of trustee spirit, and provides our clients with not only banking services, trust services, and registered financial institutional services, but also a wider range of financial services through fully utilizing its significant expertise and comprehensive capabilities.

    Along with the various products and services provided by the companies in our Group and its officers and employees, in order to protect the interests of our clients from undue harm, as from before, we have made public a summary of the Management Policy Concerning Conflicts of Interest. Based on this Policy, we shall appropriately manage transactions that have possible conflicts of interest and carry out business operations.

    Further, we will conduct client-oriented business operations, including the provision of important information on products and services in an easy-to-understand manner.

    1. The Conflict of Interest Management Process

    Our Group will, in principle, conduct conflict of interest management by the following process.

    1. Regarding "transactions, etc. that have possible conflicts of interest", together with definition as per Section 2 below, the "transactions, etc. that have possible conflicts of interest" that may arise in the operations conducted by each of our Group companies will be identified in advance, measures will be prescribed to prevent harm from conflicts of interest when conducting said transactions, etc. ("Covered Transactions") (methods for conflict of interest management).

    2. When conducting Covered Transactions, we will seek to prevent harm from conflicts of interest, by methods of conflict of interest management prescribed in advance.

      Further, if it is more effective to provide for the prevention of harm by establishing an operations execution system, then regardless of whether or not the Covered Transaction is carried out, we will take measures to prevent harm, by establishing the appropriate operations execution system in advance.

    3. In the event that a new "transaction, etc. that have possible conflicts of interest" is envisioned, it will be identified in advance as a Covered Transaction, and a method of conflict of interest management will be prescribed in advance, so as to prevent harm from conflicts of interest.

    4. Further, in order to smoothly and promptly identify the new "transactions, etc. that have possible conflicts of interest" and to select appropriate methods of conflict of interest management, together with the classification of the Covered Transactions as set forth in Section 3 below, we have clarified

    Sumitomo Mitsui Trust Holdings Inc. published this content on 16 May 2017 and is solely responsible for the information contained herein.
    Distributed by Public, unedited and unaltered, on 16 May 2017 11:02:17 UTC.

    Original documenthttp://www.smth.jp/en/news/2017/E170516.pdf

    Public permalinkhttp://www.publicnow.com/view/7A1370BAE13F2B228B41E250405099D8D15B328B