Basic Policy

Social norms and the expectations of financial institutions are constantly evolving due to the impact of the COVID-19 pandemic and the expansion of digitalization. The Aozora Group complies with all the laws and regulations applicable to all business operations, conducts sensible corporate activities based on social norms and common sense, and strives to further improve its compliance/risk management framework to respond to these changing business conditions. By adhering to these principles, we will ensure that Aozora's business operations and transactions do not violate any laws and rules, are not regarded as actions that go against social norms, business practices, market conventions, etc., and are not deemed as corporate activities lacking common sense, including from our customers' perspectives, so as not to damage Aozora's corporate value.
In addition, Aozora has established a "Code of Conduct and Ethics" that every officer and employee must comply with. Aozora's officers and employees, including group companies, all pledge that they understand and comply with the Code of Conduct and Ethics every year.

Compliance Structure

Aozora's Compliance Management Division is responsible for supervising compliance and develops internal rules regarding compliance while providing a range of training sessions and conducting educational activities. As a specific action plan to realize our compliance framework, the Compliance Management Division annually develops compliance programs that are designed to enhance compliance awareness among the Aozora Group's officers and employees. The progress and achievement status is reported to the Audit and Compliance Committee and the Board of Directors on a semi-annual basis.

Compliance Awareness

The Compliance Management Division works to maintain and raise compliance awareness among Aozora's officers and employees through a wide range of training and educational activities. For example, all officers and employees are periodically provided with e-learning opportunities. In addition, the division's staff hold workshops for business divisions/branches to answer compliance-related questions that arise in the normal course of business.

Customer Protection Management

Aozora Bank continuously reviews and improves its operations in order to protect customers' interests while respecting their intentions, including assets and information held at the Bank, and to offer more convenient services.
The Director in charge of customer protection management, who is appointed by the Board of Directors, supervises customer protection management in general. The Head of Compliance and Governance supervises customer explanation management, customer information management, outsourcing management and conflict of interest management, and the Head of the Operations Group supervises customer support management as Supervisor.
The Customer Protection Committee discusses these management issues and semiannually reports the results to the Management Committee, the Audit and Compliance Committee and the Board of Directors.

Customer Information Management

The Aozora Group believes it is an important business responsibility to appropriately manage customer information and to responsibly operate the information systems designed to provide reliable financial services to our customers. In light of these responsibilities, we have developed internal rules (Security Policy), which determine the basic policy and organizational structure regarding the protection of all information assets held by the Group.
In addition, Aozora has developed its Privacy Policy and Basic Policy, which determines the basic concept and policy to safely manage personal information and data acquired and held by Aozora and prevent unauthorized access to damage, falsification and leakage of customer information, and has disclosed them at sales branches and on the website.

Elimination of Anti-Social Elements

The Aozora Group clearly states in "Aozora Bank Group Basic Policy on the Elimination of Anti-Social Elements" that the Group steadfastly confronts any anti-social elements that pose a threat to public order and safety while ensuring that it categorically blocks any relationship with such elements.
Aozora always strives to establish and maintain close cooperative relationships with external specialist organizations, including law enforcement agencies, the Tokyo Center for Removal of Criminal Organizations, and attorneys. In addition, we refuse to perform any action that may serve to provide income/ funding for anti-social elements, including but not limited to backdoor transactions, monetary contributions/membership fees, and subscribing to informational magazines.

Anti-Money Laundering Policy

The Aozora Group is aware that "Anti-Money Laundering and Combating the Financing of Terrorism" is one of the most important issues facing the global financial system. We have established a framework to comply with domestic and international laws, regulations and rules, while also making an on-going effort to further strengthen our preventive measures against money laundering and the financing of terrorism ("Anti-Money Laundering").
For example, Aozora has developed internal regulations and an organizational structure, which includes the establishment of a department handling anti-money laundering issues, while conducting a review as needed to ensure their effectiveness. We also provide training for officers and employees regarding the prevention of financial crimes. In addition, we ensure that we verify the identity of customers and their transaction purpose at the time of account opening, which is followed by the continued monitoring of our transactions with customers.
Furthermore, we have developed an internal structure that allows for immediate reporting to the relevant authorities regarding any suspicious transactions detected by our daily monitoring processes.

Efforts to Prevent Bribery

The Aozora Group has announced the "Basic Policy on Anti-bribery", which prohibits all of Aozora's officers and employees from giving, offering or promising improper corporate hospitality, gifts and other benefits to public officials, etc. in any country as well as from giving or receiving excessive corporate hospitality, gifts or other benefits beyond socially-acceptable limits. In addition, we continue to provide opportunities for all officers and employees to learn more about our anti-bribery policy.

Whistle-Blowing Program

The Aozora Group has in place a whistle-blowing program that enables officers and employees to directly report to in-house and outside (a law firm) channels if they find any conduct that violates or may violate laws and regulations. When using the program, the officer or employee is not subject to any recrimination including disciplinary actions because of making a report and the identity of a whistle-blower is kept strictly confidential.

Tax Compliance

The Aozora Group recognizes that complying with tax laws and properly paying tax liabilities in all countries where it conducts business are part of our social responsibilities as a business entity. As such, we have developed the "Aozora Bank Group Tax Compliance Policy" based on the "Code of Ethics and Conduct", which incorporates Aozora's management philosophy, as a way to raise awareness of tax compliance among the Group's officers and employees.