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

To promote compliance across the Group, we regularly conduct training programs for all employees, including part-time employees, temporary agency workers, and contract employees.
Under the Compliance Program, the Group regularly conducts a range of initiatives, including compliance meetings, knowledge tests, level-specific training, and the dissemination of information through the Group’s intranet. These initiatives cover a broad range of topics, including respect for human rights and the prevention of harassment and corruption. Through these efforts, we seek to reinforce compliance-related knowledge and awareness and encourage behavioral change.
The implementation status of the program is regularly reported to the Group Compliance Committee and the Board of Directors. The Board of Directors oversees its implementation.

Anti-Corruption Initiatives

Under its Anti-Corruption Policy, the Group prohibits officers and employees from engaging in any form of corruption. We are committed to maintaining and enhancing sound business operations by conducting our business with integrity and fairness.
Corrupt practices include bribery, embezzlement, breach of trust, coercion to provide benefits, and the offering or acceptance of entertainment, gifts, or other benefits beyond socially accepted norms. We do not engage in such practices, whether directly or indirectly, in Japan or overseas, in our dealings with public officials or any other stakeholders involved in the Group’s business.
The Group communicates its Anti-Corruption Policy to all officers and employees, including part-time employees, temporary agency workers, and contract employees, through internal communications and promotes compliance with the Policy.

To ensure the effectiveness of the Anti-Corruption Policy and related regulations, we raise awareness and promote understanding among officers and employees through compliance meetings and various training programs. We have also established a whistleblowing system to enable the reporting of actual or suspected corrupt practices and take thorough measures to protect whistleblowers from any adverse treatment.
If a violation of applicable laws or the Anti-Corruption Policy is identified, we investigate the relevant facts and take strict action in accordance with the Group’s internal regulations, work rules, and other applicable rules.
In FY2025, there were no cases involving disciplinary action or disciplinary dismissal arising from corrupt practices (0 cases).

Whistleblowing System and Response to Whistleblowing

Whistleblowing System

The Group has established the “Compliance Hotline”*1,2, a whistleblowing channel available to all Group officers and employees, including part-time employees, temporary agency workers, and contract employees, as well as former employees. The hotline is designed to facilitate the early detection and remediation of a wide range of compliance issues, including violations of laws and regulations, corrupt practices*3, and harassment.

  1. Designed to be easily accessible through the portal on the Group’s intranet.
  2. Both internal and external whistleblowing channels are available, with a choice of a male or female attorney for the external channel.
  3. Abuse of authority to obtain improper benefits through acts such as bribery, embezzlement, breach of trust, coercion to provide benefits, and the offering or acceptance of entertainment, gifts, or other benefits beyond socially accepted norms.

The Group has also established the “Any Compliance Issue Help Desk” to receive inquiries and provide advice on a wide range of compliance-related concerns and issues, including conduct that may lead to violations of internal rules or generally accepted social norms, as well as harassment. The service is available to all Group officers and employees, including part-time employees, temporary agency workers, and contract employees.

The Group maintains strict confidentiality regarding the information provided in reports and consultations received through these channels and has safeguards in place to protect the privacy of whistleblowers and individuals seeking advice. Anyone who makes a report, seeks advice, or cooperates with a fact-finding investigation or otherwise takes appropriate action in connection with a whistleblowing matter is protected from dismissal and any other adverse treatment.

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

As part of our efforts to strengthen the Group’s framework for preventing and addressing harassment, we provide level-specific training for managers and other employees. Training for managers promotes a proper understanding of harassment and provides guidance on appropriate initial responses when concerns or reports are raised, as well as the proper handling of the information received.