Customer Protection Management

Basic Policy

The Bank has taken actions for customer protection, improved customer-friendliness and developed and established a proper customer protection management so that customers can feel secure when transacting with us.

Customer Protection Management

The Bank has developed its master policy “Customer Protection” on customer explanation management, customer support management, customer information management, outsourcing management and conflict of interest management, as well as the internal rules determining specific countermeasures, etc.

The Director responsible for customer protection management, who is appointed by the Board of Directors, supervises customer protection management generally. The Head of Compliance and Governance supervises customer explanation management, customer information management, outsourcing management and conflict of interest management, and the Head of Operations Group supervises customer support management as the supervisor.

The Customer Protection Committee discusses issues on customer explanation management, customer support management, customer information management, outsourcing management and conflict of interest management, and semiannually reports the results to the Management Committee, the Audit and Compliance Committee and the Board of Directors.

Validation of New Products and Services at Introduction and Customer Explanation Management

When introducing new financial products and services, the Bank validates whether they are suitable for our customers (validation of suitability of rational basis) so that we can provide appropriate products. In addition, to appropriately and sufficiently explain the structures and risks of the products for the understanding of customers, the Bank fully complies with the customer suitability principle and fulfills accountability by developing sales standards and guidelines and internal rules concerning customer explanation and enhancing of training. The Bank has developed its Solicitation Policy for Financial Products on matters employees should comply with during solicitation and disclosed it at its sales branches and on its website.

As to sale of investment trust, the products managed under the Financial Instruments Intermediary Service, insurance products and over-the-counter derivatives in particular, the business division and the Compliance Management Division monitor whether explanation to customers is appropriate, and provide instructions and training to sales representatives and revise solicitation rules as necessary.

Customer Support Management

The Bank has determined the procedure for taking complaints from customers, preparing records and managing the report and response status in the internal rule for customer support management, and it responds to such complaints promptly and properly and reports to management surely.

As to the inquiries, contacts for advice, requests and complaints from customers that officers and employees or the Customer Service Office receive from all sales branches in the country, the call center, etc., the Bank makes efforts to find a solution that gains the understanding and satisfaction of customers, and the Operations Planning Division as the Supervising Division fully recognizes the reasons of occurrence and analyzes the contents, and reports the results to the Customer Protection Committee monthly, the Management Committee quarterly, and the Audit and Compliance Committee and the Board of Directors semiannually.

The Bank conducts “Research on Customer Satisfaction” every year for better customer satisfaction (CS) and uses the results to improve products and services and to enhance customer protection.

To swiftly respond to customers’ complaints and solve disputes with customers, the Bank offers information on ADR institutions, such as the Japanese Bankers Association (JBA) , Trust Companies Association of Japan and the Financial Instruments Mediation Assistance Center (FINMAC), to customers.


The Bank has concluded a contract with the following ADR institution:

Institution: Japanese Bankers Association
Address: Otemachi 2-6-1, Chiyoda-ku, Tokyo
Contact: JBA Consultation Desk
(Tel: 0570-017109 or 03-5252-3772)
Institution: Trust Companies Association of Japan
Address: Marunouchi 2-2-1, Chiyoda-ku, Tokyo
Contact: Trust Counseling Center
(Tel: 0120-817-335 or 03-6206-3988)

Protection of Customer Accounts and Compensation for Damages

The Bank conducts strict confirmation before a transaction on applicants for account opening to prevent illegal use of bank accounts and to protect transactions with customers and their accounts. When a customer suffers a loss due to fraud, the Bank asks the victim for details of the incident and compensates the victim in accordance with the Depositor Protection Act, and internal rules such as the Rule of Aozora Cash Card Plus and the Rule of Aozora Internet Banking.

Outsourcing Management

To outsource a task to a third party that has the ability to perform it appropriately, fairly and efficiently, the Bank carefully selects a vender by fully validating whether (1) the vender can provide adequate service, (2) it has financial and management strength to provide the service and bear any damage in accordance with an outsourcing agreement and (3) it is not related to anti-social elements, in terms of operational risk management.

In addition, the division responsible for the outsourced task (the outsourcing division) appropriately supervises the vender, by monitoring the progress status of the vender as needed and, in case the task is outsourced to the same vender repeatedly, by checking the operation system of the vender more than once a year. In the Bank, the Compliance Management Division, as the Supervising Division, reports the outsourcing management status to the Customer Protection Committee, the Management Committee, the Audit and Compliance Committee and Board of Directors semiannually.

Conflict of Interest Management

The Bank properly manages conflict of interest not to unreasonably damage customers’ interest for the interests of the Bank and third parties. To be specific, the Customer Protection Committee, which is delegated by the Board of Directors and the Management Committee, checks and approves the rules concerning conflict of interest management and material transactions. The Board of Directors appoints the Head of Compliance and Governance, which is independent of business divisions, as the supervisor for conflict of interest management, and makes the Compliance Management Division, which is independent of business divisions, the Supervising Division for Conflict of Interest Management. Under the direction and supervision of the supervisor for conflict of interest management, the system for conflict of interest management including development of internal rules and training shall be established and operated. The Supervising Division for Conflict of Interest Management validates the possibility of conflict of interest for inquiries and/or consultation by business divisions on a transaction that may contain conflict of interest, and provides instructions and advice on management measures. It also reports the status of conflict of interest management to the Customer Protection Committee, the Management Committee, the Audit and Compliance Committee and the Board of Directors semiannually.

Customer Information Management

The Bank believes it is an important business task to appropriately manage customer information and to stably operate the information system to provide reliable financial services to customers, and has developed “Protection of Information Assets (Security Policy),” which determines the basic policy for protection of all information assets held by the Bank, the organizational structure to properly manage the customer information, etc. To be specific, the Head of Compliance and Governance supervises information asset management in the Bank as the supervisor for information asset management, and the duty, responsibility and authority for the information systems out of the information assets are delegated to the Chief Technology Officer.

To prevent unauthorized access, misuse, leakage, falsification and so on of customer information, the Bank has developed a rule restricting access to customer information to the necessary extent, implemented security management measures such as system adjustment and monitored their proper implementation.

The Compliance Management Division, as the division supervising customer information, reports the status of customer information management to the Customer Protection Committee, the Management Committee, the Audit and Compliance Committee and the Board of Directors semiannually.

For thorough understanding of the importance of customer information management, customer information management is picked up as a theme for the annual training for Compliance Leaders and e-learning for all officers and employees, and the “Annual Acknowledgment of Code of Conduct and Ethics,” signed by all officers and employees every year, also contains an item stating that officers and employees shall properly manage customer information they know by performing their duties and have a confidentiality obligation.

As an entity handling personal information, the Bank has developed “Aozora Bank’s Policy on Personal Information Protection (Privacy Policy)” and “Basic Policy on Proper Handling of Specific Personal Information,” which determine the basic concept and policy to safely manage personal information and data of the Bank and prevent unauthorized access to, damage, falsification and leakage of customer information, and has disclosed them at sales branches and on the website. In addition, when jointly using the customer information in the Aozora Bank Group, the Bank takes proper actions in line with laws concerning personal information protection, the guidelines for personal information protection in the financial industry and other related laws and regulations.

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