Code of Ethics and Conduct

The mission of the Aozora Bank Group (the “Group”) is to “contribute to the development of society through the creation of new value-added financial services” as finance professionals through its vision to “adapt to a rapidly changing world while remaining a trusted, valued and specialized financial service provider”. The Group seeks to achieve sustainable growth and the creation of mid- to long-term corporate value through contributions to the well-being of all of its stakeholders, including customers, shareholders, society-at-large, as well as our own officers and employees.

Aozora Group’s management principle

2. Providing High-Quality Services that Meet Customers’ Needs

The Aozora Bank Group strives to contribute to the sustainable development of all of its customers by further enhancing its expertise while always taking a customer-oriented perspective on developing and providing products and services with high customer-satisfaction and convenience that meet their needs and interests (Customer-Oriented Business Management).

• As an intermediary in the financial market, the Aozora Bank Group always prioritizes the needs and interests of its customers while properly understanding their financial knowledge, experience, property, purpose, etc. The Group takes a customer-oriented perspective on protecting customer rights and performs its duties with fairness and integrity.
• The Group strives to improve customer convenience through the ongoing development and provision of highly-specialized financial services in response to changes in social and economic conditions as well as the diversification of customer needs. The Group also provides support for initiatives focused on the sustainable growth of society as well as resolving environmental and social issues from a financial perspective.
• When providing financial services to and performing transactions with customers, the Group strives to provide the appropriate level of information to customers according to their financial knowledge, experience and proficiency not only regarding benefits but also from a customer-risk and cost perspective.
• The Group handles customer consultations, opinions, requests, and complaints seriously and responds to them in good faith.
• The Group strives to ensure fair and impartial business management by appropriately managing transactions that may result in conflict of interest so as not to unduly harm the interests of our customers.

3. Legal Compliance

The Aozora Bank Group complies with all applicable laws and regulations in its business operations, conducts sensible corporate activities in conformity with social norms and common sense, and strives to completely eliminate unlawful activities such as bribery, illegal political or other donations, the provision of illicit benefits, etc.

• In order to ensure fairness and protect its investors, the Group correctly interprets and strictly complies with relevant laws and regulations, as well as the rules regarding financial instrument transactions. In addition, the Group conducts its operations in accordance with general social norms and ethics with respect to matters not covered by laws and regulations.
• The Group strictly manages insider information obtained by its officers and employees in the course of their duties in order to prevent insider trading.
• The Group has established and complies with a set of internal rules based on applicable laws and regulations and also performs security measures, including systems upgrades, in order to safely manage and prevent the unauthorized access, unauthorized use, leakage, falsification, etc. of private customer information.
• The Group maintains appropriate business relationships with customers and appropriate relationships with civil servants. The Group performs operations so as not to violate laws such as the National Public Service Ethics Act in order to avoid accusations of bribery or breach of trust.
• The Group strives to eliminate any abuse of its superior position as a lender, such as the signing of an unfair tie-in contract in the context of its existing business relationship with a customer, forcing the purchase of goods or services, or the binding of deposits that have not been officially acquired as collateral.

4. Communication with Society

The Aozora Bank Group strives to proactively, effectively, and fairly disclose management and other information and ensures proper understanding and trust of its operations through constructive dialogue with its wide-range of stakeholders.

• The Group strives towards the appropriate and timely disclosure of information and operates in order to maintain and improve the soundness, reliability, and transparency of the capital markets with full awareness of our social mission.

5. Respect for Human Rights

The Aozora Bank Group understands and respects the dignity and human rights of all people, including its customers, officers, and employees, while striving to eliminate discrimination.

• The Group has developed a corporate culture that respects human rights in the workplace, partially by conducting in-house training on human rights issues for all officers and employees.
• The Group aims to respect human rights in its communications with customers, suppliers, outsourcees, etc., and takes appropriate actions to make improvements as necessary.

6. Improving the Working Environment for Officers and Employees

The Aozora Bank Group supports the sustainable growth and respects the diversity of its officers and employees, and strives to create a comfortable working environment free from unfair treatment and discrimination that prioritizes the health and safety of its employees. The Group also maintains fair hiring practices and treatment so that employees have the opportunity to fully demonstrate their abilities through their work.

• The Group strives to create a greater common sense of purpose among its officers and employees in order to develop a workplace where employees support the growth of their colleagues while respecting their diverse life-styles, ways of thinking, and working styles.
• The Group expects its officers and employees to respect one another's gender, personalities, individuality, privacy, and differing values while working to create a workplace free of all types of harassment, including sexual and power harassment.
• The Group values the work-life balance of its officers and employees and strives to support those involved in childbirth, childcare, and nursing care, and work to create an efficient and comfortable workplace where every officer and employee can find motivation in their lives and careers.
• The Group works to maintain and improve the physical and mental health of all its officers and employees as well as their families.

7. Responding to Environmental Problems

The Aozora Bank Group is actively committed to developing initiatives to tackle environmental problems. In addition to reducing the environmental impact of its business activities through the efficient use of resources and waste reduction, etc., the Group also supports its customers' efforts to address environmental issues, including climate change, through the provision of financial services.

• The Group strives to reduce its greenhouse gas emissions and power consumption as a business operator while reducing waste through recycling.
• The Group supports its customers’ promotion of the transition to a low-carbon/decarbonized society through project finance for renewable energy businesses, such as solar power and wind power generation, and sustainable finance, such as sustainability linked loans.
• The Group established an investment and lending policy that takes environmental and societal issues into consideration. Based on this policy, the Group strives to make improvements through dialogue with customers whose businesses may have a negative impact on the environment and work to reduce environmental and social risks by restricting or prohibiting credit when no improvement can be made.

8. Contribution to Society

The Aozora Bank Group participates in Japanese society as a "good corporate citizen" and proactively engages in activities that contribute to its development.

• The Group aims to develop an environment committed to providing opportunities for volunteer activities and other kinds of social participation as well as introducing a social participation support system, all while respecting the self-motivation of its individual officers and employees.

9. Preventing Financial Crimes and Relationships with Anti-Social Elements,

The Aozora Bank Group strives to confront anti-social elements that pose a threat to public order and safety while ensuring that the Group categorically blocks any relationship with such elements. In addition, the Group is committed to preventing deposit account-related crimes and improving its countermeasures against money laundering and the financing of terrorism.

• The Group strives to combat money laundering and the financing of terrorism when establishing an ongoing business relationship or performing a large cash transaction by conducting a thorough verification of identifying personal information, such as name and address, as well as specific items required for customer management, such as occupation and purpose of transaction.
• The Group is resolutely committed to the elimination of organizations and groups engaged in anti-social activities, and strives to prevent any and all relationships with them, including transactions. The Group thoroughly rejects any violent or unreasonable demands made by anti-social elements and refuses to perform any action that may serve to provide them with income or funding, such as monetary contributions, membership fees, and subscriptions to informational magazines.
• The Group cooperates with the relevant authorities in order to be prepared for preventing financial crimes such as deposit account-related fraud. In addition, we strive to improve our level of security, including in our Internet banking services, in order to ensure the safety of deposits and other transactions which forms the basis of trust in the banking and financial systems.