Code of Ethics and Conduct

The mission of the Aozora Bank 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 its own officers and employees.

• The Group contributes to the development of society through the creation of new value-added financial services (Aozora Mission).
• The Group adapts to a rapidly changing world while remaining a trusted, valued and specialized financial service provider (Aozora Vision).

Aozora Group’s management principle

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

The Aozora Bank Group provides products and services that meet the true needs of its customers while always taking a customer-oriented perspective, and performs its duties with fairness and integrity.

• The Aozora Bank Group establishes a corporate culture in which all of its officers and employees share an awareness of and practice Customer-Oriented Business Conduct.
• The Group strives to research, develop and select highly satisfactory products and services that meet the true needs of its customers, and aims to achieve best practices.
• When providing products/services to or performing transactions with customers, the Group offers clear and appropriate explanations not only on the benefits for customers but also on the risks and fees for customers.
• The Group appropriately manages transactions that may result in conflict of interest so as not to unduly harm the interests of its customers.
• The Group provides customers with necessary and appropriate information, including financial market trends and product information, and offers high-quality advice and ongoing follow-up support.
• The Group uses “Customer's Voice” to improve its services, provide appropriate products, and enhance its business operations.

3. 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 uses and shares customer information to the extent appropriate for business needs and purposes. In addition, it 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 such information
• The Group maintains appropriate business relationships with customers and appropriate relationships with civil services. 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 its 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 establishes 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 ensures that human rights are respected through 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 sense of unity among its officers and employees in order to develop a workplace where employees support the growth of their colleagues while respecting the 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 for corporate customers.
• 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 Relationships with Anti-social Elements, Anti-money Laundering, Combating the Financing of Terrorism, Countering Proliferation Financing, and Compliance with Economic Sanctions

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 anti-money laundering including the prevention of crimes involving the misuse of deposit accounts, combating the financing of terrorism, and countering proliferation financing (“anti-money laundering”), as well as compliance with economic sanctions.

• The Group 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 properly verifies the identity of customers when opening accounts and conducting other transactions, and continuously checks customer information thereafter. In addition, the Group monitors account activity to prevent financial crimes such as deposit account-related fraud.
• The Group responds appropriately to economic sanctions by properly fulfilling its confirmation obligations under the Foreign Exchange and Foreign Trade Act.
• The Group strives to improve its level of security, including in its 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.