Sharing non-public information with companies within our group company
This notification is addressed to our clients who trade products associated with interest rates, credit, fx and or repo, and who have received a letter from UBSSJ on sharing non-public information with companies within our group company.
On June 1, 2009, amendments to the so-called firewalls regulations came into force. The amendments allow non-public information about a customer to be exchanged and shared among group companies when the customer has been appropriately granted opportunities to request for the discontinuance of the sharing of information among group companies. In this context, UBS Securities Japan Co., Ltd, (“UBSSJ”) would like to provide and share non-public information about your company among our group companies (“our group company”) in accordance with Article 153.2 of the Cabinet Office Ordinance regarding Financial Instruments Business (“Business Ordinance”). If your company wishes to discontinue the provision of non-public information to our group company, please contact the help desk indicated at the end of this notice.
1. Scope of non-public information provided to our group company
1. Scope of non-public information provided to our group company
Non-public information about your company that has come to our knowledge in the course of your business associated with interest rates, credit, fx and or repo ("relevant products") with UBSSJ until now (indicating “non-public information” as prescribed in Article 1.4(xii) of the Business Ordinance on past transactions, the transaction schedule, and the timing of transactions, etc.; hereinafter “Non-public information”) and Non-public information about your company that could come to our knowledge in the future.
2. Scope of our group company to which Non-public information is provided
2. Scope of our group company to which Non-public information is provided
- UBS AG (Head office and branches including UBS AG Tokyo Branch)
3. Methods of providing Non-public information
3. Methods of providing Non-public information
The provision of Non-public information with a group company may be made verbally, in writing, by email, or by some other method that gives access to or shares databases.
4. Methods by which the recipient manages Non-public information
4. Methods by which the recipient manages Non-public information
Our group company, which is the recipient of Non-public information about your company, has taken the necessary steps in the management of Non-public information to ensure that Non-public information is not wrongly accessed or misused, by setting restrictions on access, etc.
5. Purposes of the use of Non-public information by the recipient
5. Purposes of the use of Non-public information by the recipient
Our group company, which is the recipient of Non-public information about your company, may use Non-public information about your company for the purpose of managing business relationships with your company and/or proposing or providing financial products or services to your company.
6. Method of managing Non-public information when the provision of the Non-public information concerned to our group company is discontinued
6. Method of managing Non-public information when the provision of the Non-public information concerned to our group company is discontinued
Regarding the Non-public information about your company that UBSSJ obtain after your company makes a request to discontinue the provision of Non-public information about your company to our group company, UBSSJ shall treat such information as non-public information other than Non-public information that can be shared among our group company (“Unshared information”) and shall not provide Unshared information about your company for the purpose of business. In addition, UBSSJ shall decide in advance which companies’ Unshared information can be accessed by double-hatted personnel of the sales division and other divisions that use non-public information in UBSSJ and our group company and shall take necessary measures to prevent them to access to other companies’ Unshared information. However, please note that, with respect to the Non-public information about your company that our group company has already received from UBSSJ, our group company, which is the information recipient, shall continue to possess such information with appropriate management and shall in future solicit transactions, etc. using the Non-public information concerned.
7. Request to stop provision of Non-public information about your company
7. Request to stop provision of Non-public information about your company
If your company would like us to stop the provision and sharing of Non-public information about your company among our group company, please contact Compliance Department by using the Opt-out Notice.
Contact Information
UBS Securities Japan Co., Ltd., Compliance Department
Location: Otemachi One Tower, 2-1, Otemachi 1-chome, Chiyoda-ku, Tokyo 100-0004
Telephone number: 03-5208-6077 (Hours: Monday to Friday, 9 a.m. to 5 p.m. except for public holidays)
E-mail address: OL-Opt-Out@ubs.com