All Nomura employees must ensure that conflicts of interest are identified and escalated appropriately. This is critical for the management of regulatory, legal and reputational risks and to ensure the fair treatment of clients. The primary structural measures implemented to manage potential or actual conflicts of interest include Chinese Walls; separate supervision of employees; removal of direct links between the remuneration of business areas or persons principally engaged in one activity and the remuneration of, or revenues generated by, employees principally engaged in another activity where a conflict of interest may arise in relation to those activities; segregation of decision-making and duties to ensure that employees are not exposed to conflicts of interest from being concurrently or sequentially involved in regulated or administrative activities on behalf of clients or Nomura; and measures to be taken to prevent an employee from exercising inappropriate influence over the way in which another employee carries out services or activities.
Additional measures are implemented including conflict clearance procedures, additional policies and procedures, regional transactional committees; training and awareness; and monitoring and surveillance of activities.
Please refer to policy summary:http://www.nomuranow.com/naim/resources/pdf/NAIM_Conflicts_of_Interest_Policy_summary_-_January_2018.pdf