Code of Conduct

Article 1. Objective

This Code of Conduct (the "Code") shall be for the objective of setting forth codes of conduct with which officers and employees of IG Markets Securities Limited (the "Company") shall comply on a day-to-day basis.

Article 2. General Provisions

The officers and employees of the Company will comply with law, order and regulation, internationally established rules, and internal regulations of the Company, maintain a high ethical standard and responsibly behave in accordance with social morals. Not only the text of the laws and regulations but also the spirit thereof shall be followed.

Article 3. Relationship with Society

  1. Our business and transactions shall comply with law and regulation, etc., and be conducted in the principle of fairness, in accordance with the following:
    1. The laws in the industry that pertain to the products and services that we provide shall be obeyed, and care shall be taken that there is no procedural omission in, inter alia, acquiring permits or making notifications.
    2. We will not, in concert with a competitor or with any industry association, refuse to transact or terminate a transaction with a specific party or any new entrant to the industry.
  2. Gift-giving and entertainment, etc., shall not be done in violation of law and regulation, and shall be conducted in a socially accepted and appropriate manner, as set forth below: 
    1. We will not provide unlawful gifts of money or goods, favors, or economic benefit to government officials and the like in Japan or abroad.
    2. Gift-giving to and entertainment of our business counterparts and their officers and employees, etc. shall not be excessive and shall be conducted within socially-accepted limits.
    3. We will not accept excessive entertainment, nor gifts that exceed the bounds of social etiquette and protocol.
  3. We will take an unyielding policy in accordance with the following basic principles, cutting off and eliminating any relationship with antisocial forces.
    1. We shall not have any relationship including a transaction relationship.
    2. We shall firmly refuse any inappropriate demand.
    3. We will take legal action both civil and criminal, against any inappropriate demand.
    4. We shall respond as an entire organization against an inappropriate demand and will protect the safety of officers and employees who respond to an inappropriate demand.
    5. We shall create a close working relationship with, inter alia, police, attorneys, and Centers for the Elimination of Boryokudan, on a daily basis.
    6. We shall not for any reason engage in illicit transactions or provide funds

In order for us not to have any relationship with any antisocial group, we will at all times exercise the care that is normally thought to be necessary in connection with whether the other party to a transaction is an antisocial group and if we have any type of relationship without knowing that the other party is an antisocial group, we shall promptly terminate the relationship at such time as it is determined that the other party to the transaction is an antisocial group or suspicion occurs that the other party to the transaction is an antisocial group.

Article 4  Relationship with Employees

We will respect human rights and there shall be no discrimination or harassment, as follows:

  1. Irrespective of reason, will not discriminate on the basis of race, skin color, belief, religion, gender, nationality, age, physical or mental disability, or illness, etc.
  2. There will be no sexual harassment.
  3. There will be no power harassment.
  4. Human rights issues such as the dowa (discriminated communities) shall be correctly understood and recognized, and discrimination shall not occur.
  5. We will respect culture (local and foreign), customs and languages. We will make efforts to maintain harmony in the local community and in international society.

Article 5  Respect for the Environment

We will obey treaties, law and regulation, etc. pertaining to the environment, and we will carry out our business while paying heed to the global environment.

  1. We will obey treaties, law and regulation, etc. pertaining to the environment, and our decisions will made in a spirit of preserving the environment.
  2. Resources and energy are to be used efficiently, and efforts are to be made to reduce trash in the office as well as in effective use of resources and recycling.

Article 6  Relationship with the Company

Not only must Company be managed in an appropriate manner, but also information obtained from sources outside the Company and intellectual property rights belonging to third parties will be appropriately handled.

  1. Confidential information of the Company will be strictly managed. It must not be leaked or used other than for business purposes.
  2. If it is necessary to disclose confidential information of the Company to someone outside the Company, steps shall be taken to prevent disclosure of confidential information, including, inter alia, the execution of a confidentiality agreement in advance.
  3. Confidential information shall not be used or leaked by personnel after their retirement (from the Company).
  4. Trade secrets from another company or person shall not be brought into the Company without permission.
  5. Trade secrets of the Company shall not be illegitimately acquired, used or disclosed.
  6. Acts of violating the intellectual property rights of another company or another person shall not be permitted, including unauthorized copying of computer software.
  7. Personal information and databases and the like containing personal information will not be copied without authorization, nor taken out of the Company, divulged without authorization or used other than for their intended purpose.
  8. There shall be no involvement in activities that would create a conflict of interest with the Company.  

Article 7 Relationship with Shareholders and Investors

  1. Appropriate information about the Company’s management including its financial status and business activities shall be disclosed, and the Company’s management philosophy and management policies shall be accurately communicated to the shareholders and investors; and any opinions and criticism received by the Company concerning such information will be dealt with earnestly. 
  2. No Insider Trading
    1. There will be no trading in shares, etc. using material, non-public information such as that which would have an impact on investment decisions, prior to the time such information is publicly disclosed.    

Article 8 Duty of Good Faith

In conducting the business, officers and employees must treat customers, etc. fairly and in good faith.

Article 9 Prohibited Acts

  1. In no circumstances shall officers and employees (of the Company) engage in any of the following:
    1. give false information to a customer in connection with concluding or soliciting to conclude an OTC derivatives contract (meaning a contract for OTC derivatives transactions with the customer as a counterparty, hereinafter the same);
    2. solicit the customer to conclude an OTC derivatives contract, offering a decisive judgment as to uncertain matters, or misleading the customer into believing them to be certain;
    3. visiting or telephoning a customer who has not requested soliciting to enter into an OTC derivatives contract (meaning a contract in which an act of trading in OTC derivatives will be made with the customer as the other party, hereinafter the same), and soliciting the customer to enter into an OTC derivatives contract (excluding the soliciting of a customer who is not applied to the prohibition on conducting uninvited solicitation  , provided by the Financial Instruments and Exchange Law, Article Commodity Futures Law and other relevant rules and regulations;
    4. solicit a customer to conclude an OTC derivatives contract without confirming with the customer prior to the solicitation whether he/she wishes to receive such solicitation;
    5. solicit a customer to conclude an OTC derivatives contract, even though he/she has expressed his/her intention not to conclude an OTC derivatives contract (including his/her intention not to wish to continue to receive such solicitation; hereinafter the same) or continue to solicit the customer to conclude an OTC derivatives contract;
    6. solicit a customer to conclude or cancel an OTC derivatives contract by visit or call during hours that would cause the customer to be inconvenienced;
    7. offer or promise, or cause a third party to offer or promise a customer or a third party designated by the customer that if the customer incurs a loss or does not earn a predetermined profit in connection with an OTC derivatives transaction, FXONLINE or any third party will provide economic benefits to the customer or the third party so designated, in order to cover all or a part of loss or make up all or part of deficit in predetermined profit; 
    8. offer or promise, or cause a third party to offer or promise that FXONLINE or any third party will provide economic benefits to the customer or a third party designated by the customer in order to cover all or a part of the losses incurred by the customer or to supplement the profit of the customer in relation to an OTC derivatives transaction;
    9. provide, or cause a third party to provide, economic benefits to the customer or the third party, in order to compensate all or a part of loss incurred by the customer or provide economic benefits additional to the profit of the customer, in relation to an OTC derivatives transaction;
    10. enter into an OTC derivatives contract without giving a prior explanation to the customer in connection with the delivery of the pre-contract document and the document on amendment of contract, in a manner and to such extent that is necessary in view of the customer’s knowledge, experience, financial circumstances, and objectives of entering into the OTC derivatives contract, in order for the customer to understand the matters set forth in Article 37-3(1)(i) through (vii) of the Financial Instruments and Exchange Law and Article 217-1(1) through (4) of Commodity Futures Law;
    11. make a false representation or a representation that would cause a misunderstanding concerning a material matter in connection with entering into an OTC derivatives contract or soliciting of the same;
    12. promise to provide special benefits to a customer or a person designed by the customer, or provide special benefits to a customer or third party, in connection with an OTC derivatives contract (including an act of having a third party promise to provide special benefits, or having a third party provide the same);
    13. employ artifice, battery or coercion to enter into or cancel an OTC derivatives contract;
    14. decline or unduly delay an OTC derivatives transaction under an OTC derivatives contract or other performance of all or part of its obligations under an OTC derivatives contract;
    15. usurp the money, securities and any other assets or margin and other surety deposits held by FXONLINE for the account of the customer under an OTC derivatives contract by using a false market price or any other fraudulent means;
    16. gather customers without specifying in advance that there is an objective of soliciting the conclusion of an OTC derivatives contract, and engaging in soliciting to enter into an OTC derivatives contract;
    17. enter into an OTC derivatives transaction for the account of a customer without obtaining consent from the customer in advance;
    18. conduct on the part of a director, statutory auditor or employee of a OTC derivatives dealer of using his or her status in his or her duties to enter into a Sale and Purchase or Other Transaction of Securities or Derivatives transaction, based on special information obtained in the course of business, such as customer’s order trends in connection with OTC derivatives transactions of customers, or primarily in pursuit of speculative profits;
    19. conclude a contract, other than in writing, which provides that out of total customer’s funds, upon consent of such customer, the type of trading, composition of currency pairs, number or volume of trading, and contract price (each of which remains undetermined by the customer) shall be determined by an electronic computer upon occurrence of certain events or other predetermined method, and financial instruments dealer will execute transactions accordingly (excluding concluding through electronic information processing system or other information and telecommunication technology); and
    20. make a solicitation or engage in any similar act concerning an offsetting trade against the sale or purchase of an OTC derivatives transaction or any similar transaction entered into by the customer (meaning a transaction to reduce loss arising from such transactions).

Supplementary Provisions

This Code shall become effective on September 1, 2007

Supplementary Provisions (Partial revision made on September 27, 2007)
This Code shall take effect from October 1, 2007.
(Note) Revised clause: Prohibited Acts were amended as Article 9.

Supplementary Provisions (Partial revision made on February 24, 2009)
This revision shall take effect from March 18, 2009
(Note) Revised clauses are Article 3.3 and Article 9.

Supplementary Provisions (Partial revision made on March 7, 2011)
This revision shall take effect from March 8, 2011.
(Note) Revised clauses are Article 1 and Article 9.