Code of Conduct / Code of Ethics

WealthNavi has set forth the Code of Conduct in our compliance manual. It outlines basic principles to guide employees and directors conduct in relation to our business on the following.

1. Code of Conduct with our customers
2. Code of Conduct with business partners, regulatory agencies and other counterparties
3. Code of Conduct with investors and shareholders
4. Code of Conduct with society
5. Code of Conduct to build better corporate culture
6. Code of Conduct as a member of WealthNavi
In addition, we have set the Code of Ethics as a basic principle to do business and we declare to comply with it.

Code of Ethics

Compliance management

We have adopted the following Compliance Management structure to run the business with top priority on compliance.

Chart of compliance management

Compliance programs

As a financial institution, WealthNavi recognizes that each and every employee should have a high level of compliance awareness.

To raise awareness, we conduct training based on the Compliance Manual as part of our onboarding for new employees. This training includes sessions on the laws and regulations that are necessary in our business.

In addition, we hold training on privacy, AML/CTF, information security, and other topical issues that need to follow. We also conduct quizzes to confirm employees’ level of understanding.

We disseminate compliance information and provide training on a continuous basis to ensure that all employees maintain a high level of compliance awareness and to foster a culture of compliance awareness.

Whistleblower Hotline

WealthNavi has set forth our “Whistleblowing Rules” to ensure early detection and implementation of remedial action against fraud or misconduct and to maintain highest compliance standards. We have set up a Whistleblowing Hotline so that employees can raise any kind of concerns about possible organizational or individual violations of laws, regulations, or Company rules. The Whistleblower Hotline has an internal reporting channel and an external reporting channel, and whistleblowers may use either of these. The Whistleblowing Rules clearly stipulate that “whistleblowers shall not be subject to disadvantageous treatment for consulting or making a report” and that “due consideration shall be given to ensure whistleblower confidentiality.”
In addition to the whistleblower channel, we have set up a separate consultation desk for such matters as workplace relationships, mental and physical health counseling, and harassment.

Employees are provided with information on these services during their compliance training at the time of onboarding.

Flowchart of Whistleblower Hotline

Segregation of customer assets

WealthNavi has established an appropriate segregation system to keep our customers’ assets separate from our own assets in accordance with the relevant laws and regulations.
In addition, we have assigned KPMG AZSA LLC to conduct audits on our compliance with relevant laws and regulations regarding the segregated management of customer assets, in accordance with Assurance Practical Guideline 3802 of the Industry Committee of the Japanese Institute of Certified Public Accountants. As of December 31, 2023, we have received a written assurance from the auditor that the Company is managing assets on a segregated basis in compliance with the relevant laws and regulations in all material respects.

Audit on segregation of
customer assets

In addition, we have disclosed WealthNavi's Measures for Customer Safety and Security to our customers that explains how we protect our customers’ assets by segregating their assets.

WealthNavi's Measures for
Customer Safety and Security

Anti-Money Laundering and Counter-Terrorism Financing (AMT/CFT)

WealthNavi recognizes the importance of measures to combat money laundering and terrorist financing (hereinafter referred to as “money laundering or similar activities”). We have established and disclosed a Basic Policy on Anti-Money Laundering and Counter-Terrorism Financing.

Basic Policy on Anti-Money Laundering and Counter-Terrorism Financing

In addition, we provide an annual training on money laundering or similar activities to our employees to ensure that they are aware of the importance of AMT/CFT and to keep them up to date on recent cases and trends.

AMT/CFT controls is an important management issue, and we are working to build strong and effective prevention regimes based on a risk-based approach to ensure that the Company is not used for or engaged in money laundering or similar activities.

Anti-social forces exclusion

WealthNavi has established and announced the Basic Policy Against Anti-Social Forces to exclude any transactions that involve organized crime or anti-social forces. The Company has a clearly defined stance in terms of its refusal to engage with any demands from anti-social forces.

Basic Policy Against Anti-Social Forces

Anti-bribery and corruption

WealthNavi is committed to prevent bribery and corruption, and our Compliance Manual stipulates that employees must be “fair” and “transparent” in our relationships with the organizations and individuals with whom they come into contact in the course of their business activities.

Specifically, employees are prohibited from accepting gifts or business hospitality that exceed common social norms, nor may they ask for such gifts or business hospitality. In addition, the giving of gifts or provision of business hospitality is strictly prohibited with respect to public officials or other persons who are in a position of influence in relation to our business activities.

Furthermore, we provide training programs to employees to prevent bribery and corruption on a regular basis in order to ensure that these rules are thoroughly understood within the Company.

Avoiding insider trading

WealthNavi has established a structure to manage insider information and has stipulated a code of conduct for employees’ stock trading in order to prevent insider trading and to be socially responsible as a financial institution. We are committed to ensuring compliance with the relevant laws and regulations at all times.

In addition to our rules on insider trading, we have also established a structure to manage sensitive corporate information obtained by employees in the course of their work, and we are committed to preventing illegal transactions that are based on such information.

Managing conflicts of interest

WealthNavi’s fee is linked exclusively to customers’ AuM in order to ensure that our interests are always aligned with those of our customers.

Additionally, we have established a Policy on Managing Conflicts of Interest to ensure that the interests of our customers are protected and unharmed, and we have disclosed a summary of this policy.

Policy on Managing Conflicts of Interest

Specifically, the Compliance Department is designated as the department to manage conflicts of interest by overseeing transactions where there is a risk of conflicts of interest, and taking preventive measures to deal with any potential conflicts of interest that may arise. In addition, the Company ensures that its employees are fully aware of its policy on managing conflicts of interest and has established the structure that is necessary to manage them.