Basic Concepts of Compliance

The Group has established the “Compliance Regulations” and has set out the following basic policy regarding compliance. 
The Group shares a common understanding of its responsibilities to fulfill its public mission and corporate social responsibilities as a financial group. Accordingly, we accord topmost management priority to thorough compliance, take the seriousness of effective compliance and consider earning the trust of a broad-based society as the basic policy.

Compliance System

To ensure appropriate compliance, the Group has established the compliance administration department, and conducts the development of compliance-related system and training for officers and employees. The Compliance Administration Dept. liaises with the compliance administration department of each group company, and centrally manages compliance matters throughout the Group.

 

In addition, the Group has established the Group Compliance Committee as a deliberative body, and important matters deliberated and reported at the Committee are submitted and reported to the Board of Directors via the Group Executive Management Meeting, which exercises oversight.

Compliance System

Compliance Program

To maintain and improve the compliance system, strengthen ongoing initiatives, thoroughly prevent illegal activities, integrally manage management plans and compliance, and implement measures based on risk, formulate the “Compliance Program” as a concrete action plan every fiscal year. This program has been approved by the Board of Directors via the Group Compliance Committee and the Group Executive Management Meeting. In addition, the progress status of this program is regularly reported to the Board of Directors, and improvements are made as appropriate according to the progress.

 

For the fiscal year ending March 31, 2026, we have established an approach that emphasizes the awareness and actions of officers and employees, focusing on up-to-date compliance and human rights awareness, judgment and conduct based on integrity, risk-based thinking, and acting as one’s own responsibility, while continuing to instill basic knowledge of laws and regulations.

Promoting the Compliance Program

The Compliance Program conducts multiple regular activities, including compliance meetings, knowledge tests, level-specific training, and information dissemination through the internal intranet. These activities cover a broad range, from respect for human rights to prevention of harassment and corruption, to instill knowledge and awareness and to encourage action.

The implementation status of the program is regularly reported to the Group Compliance Committee and the Board of Directors, which exercises oversight.

Whistleblowing System and Response to Whistleblowing

Whistleblowing System

In order to prevent scandals caused by compliance violations and harassment, etc., to detect risks at an early stage, and to strengthen the company’s self-cleaning function, a Group-wide whistleblowing help desk, the “Compliance Hotline,” has been established. The Compliance Hotline has been established an internal hotline and an external hotline. Callers can choose between consulting with a male or female attorney when calling the external hotline.

 

In addition, for cases of compliance-related concerns and issues including acts that may be connected to a violation of internal rules and social rules, harassment, etc., we have established the “Any Compliance Issue Help Desk,” which receives a broad range of consultations and questions, and have developed a system to receive reports and consultations broadly.

 

This information is designed to be immediately accessible from the Compliance Hotline, which can be accessed directly via the Company’s intranet.

Response to Whistleblowing

In the event of a whistleblowing report, we respond according to the following procedures, in principle.
(1) Investigation and determination of facts

  • The Compliance Administration Department immediately investigates the facts
  • Consult with legal counsel on the investigation results to determine the facts

(2) Reporting and deliberation of investigation results

  • Report the results to management while protecting the whistleblower’s identity
  • Deliberate significant matters at the Group Compliance Committee

(3) Notification to the whistleblower and implementation of corrective measures

  • Notify whistleblower of investigation results
  • Implement corrective measures and recurrence-prevention measures for violations