Aozora Group's Basic Policy on Customer-Oriented Business Conduct

July １,2025

1. Basic idea

Aozora Group has its own mission of contributing to the social development by creating new financial added values as a financial professional, flexibly addresses changes of the times and aims to remain a highly specialized financial group that is always trusted by and familiar to many people.
For that purpose, Aozora Group intends to take the customer's point of view, provide products and services that meet the customers' true needs and carry out its work in an honest and fair manner.

2. Positioning of Basic Policy on Customer-Oriented Business Conduct

"Aozora Group's Basic Policy on Customer-Oriented Business Conduct " is consistent with Aozora Group's operating principle, and is defined to promote Aozora Group-wide customer-oriented business conduct under Code of Ethics and Conduct which all the officers and employees belonging to Aozora Group are required to comply with.
We try to continuously monitor how the customer-oriented business conduct is implemented and make an improvement led by the senior management.

3. Aozora Group's Basic Policy on Customer-Oriented Business Conduct

1) Customer support

We make an effort to propose and provide the most appropriate products and services to the customers based on their future life and business planning.
When we understand that our products and services cannot be the best ones to customers, we may not to propose or provide them in some cases.
Ｗhen we provide each product or service, or make a transaction、We explain not only advantages for the customer but also risks and fees in an easy-to-understand and appropriate manner At the same time, we share information to improve the customers' financial literacy.
We appropriately manage transactions that may cause a conflict of interest not to unfairly impair the interests of consumers.
We provide the customers with necessary and appropriate information including a financial market trend and product information, and give good advice and continuous backup follow.
We make use of "comments from our customers" to improve the services, provide the appropriate products and improve our work.

2) Products

We make an effort to study, develop and select highly satisfactory products and services that meet the customers' true needs, and aim at best practice.
We adequately cooperate with divisions and companies that originate the products and implement products and services under the commitment by the senior management. After implementation we continuously monitor and improve the quality of the products and services based on actual sales results or "comments from our customers". We have in place a product governance system to review or eliminate the products and services as necessary.

3) Human resources

Aozora Group intends to establish a corporate culture in which all the officers and employees share awareness of the customer-oriented business conduct and actually conduct such business.
We try to train highly professional human resources through an improvement in training sessions and support for their acquisition of qualification.
We build an appropriate performance evaluation system that contributes to promoting the customer-oriented business conduct.

Customer-Oriented Business Conduct Policy

July １,2025

1. Formulation and Disclosure of Customer-Oriented Business Conduct Policy

The "Aozora Group's Basic Policy on Customer-Oriented Business Conduct" is in line with the management philosophy of the Aozora Group and is established for the purpose of promoting customer-oriented business conduct across the Group under the "Code of Ethics and Conduct" that all officers and employees of the Group are required to comply with. In order to appropriately meet the needs of retail customers, Aozora formulated the "Customer-Oriented Business Conduct Policy" based on that basic policy.
As a financial professional, the Bank's mission is to contribute to the development of society by creating new value-added financial services, and we aim to remain a trusted, valued and specialized financial institution while adopting to a rapidly changing world.
The Bank and its officers and employees are committed to carrying out our business in a fair and sincere manner, while maintaining the customer-oriented business conduct recognizing the importance of "helping our customers through specialized services in pursuit of the best interests of the customers".
Recognizing the importance of instilling and establishing its customer-oriented business conduct further, the Bank will report and hold discussions on the status of activities according to this policy in the Customer Committee, which is responsible for deliberation on the development of a framework and various measures for the promotion of customer-oriented approach and the customer protection management, and we will strengthen its efforts to practice the policy and disclose the status of those efforts every six months.
In addition, the Bank will review the policy on a regular basis for better business management.

2. For the pursuit of the best interests of customers

The Bank believes that meeting the diverse needs of our customers, such as those who want to increase their accumulated assets or protect and pass them on to the next generation, is in their best interest and will also lead to our growth. We will appropriately provide advanced financial and non-financial services and expertise tailored to the characteristics and needs of our customers in collaboration within the Group as well as with external partners. If the Bank determines that a product or service, we offer is not the best product or service for a customer, we may not propose or offer it to the customer.
To pursue the best interests of our customers, all officers and employees are obliged to submit an "Annual Written Confirmation of Compliance on the Aozora Group Code of Ethics and Conduct", and we strive to instill the "corporate culture" that aims for the best interests of the customers by periodically conducting training and similar activities.
The Bank has established and is committed to a product governance framework in which its management team is involved in the origination, selection, sale and management of financial products that will contribute to the best interests of the customers.
When providing consultations for customers on asset management, the Bank will make diversified investment proposals after accurately recognizing the customers' needs and fully understanding the customers' financial knowledge, investment experience, transaction purpose, asset status, risk tolerance, life plan, etc. We support our customers' mid- to long-term and stable asset building, and will not make proposals that do not match the customers' wishes, or propose a review of financial products in a short period of time that will not suit the interests of the customers. The positioning of the main financial products is as follows.
<Investment Trusts>
The Bank will propose investment trusts as the core product of diversified investment, based on fund diversification and time diversification. For instance, for customers who are just starting their asset building, we offer products that allow "investment trust accumulation" at a fixed amount on a fixed date each month, and for customers who wish to invest a large amount of funds, we offer those that include a time diversification mechanism.
In addition, we will increase the number of products corresponding to the new NISA system so that many customers can take advantage of the new NISA system that started in January 2024.
In addition to asset management consultation, for customers who want to "leave a legacy" or "prepare for the future", the Bank also provides a wide range of consulting services that meet the needs of its customers, such as proposals of insurance products, support on wealth transfer and business succession, etc., in order to help protect and pass on their accumulated assets to the next generation.
The Bank will constantly verify and evaluate the results and progress of the above activities, and will announce some of the results in the "Status of Initiatives".

3. Appropriate management system for conflict of interest

The Bank strives to accurately understand and identify the possibility of conflict of interest with customers in transactions and the possibility of conflict of interest when developing and introducing products, and determine whether interests of customers are unreasonably harmed by transactions that may cause conflict of interest, in a bid to pursue appropriate management to prevent conflict of interest.
When proposing financial products and services, the Bank will not select products by considering fees paid by the company that provides the product or will not prioritize products of our Group companies, but always will make proposals from the customer's point of view.
An overview of the Bank's conflict of interest management system is published in the "Policy to Manage Conflict of Interest".

4. Fees to be borne by customers

The Bank will consider fees to be borne by customers as one of the important information to make their decision on transactions. We will thus strive to ensure transparency as well as provide easy-to-understand explanations, including presenting comparisons with similar products and alternative products. In addition, we will post the information on the Bank's website and BANK app for easy confirmation.
Regarding the details of fees and other costs, when proposing financial products and services, the Bank will ask customers to check with the Important Information Sheet, the documents delivered prior to the conclusion of the contract, or the prospectus, and after the transaction, we will ask them to check with the reports and others.

5. Providing important information in an easy-to-understand manner

The Bank will explain important information in an easy-to-understand manner using the Important Information Sheet, sales materials, legal documents, and materials presenting easy comparison for each product, in order to propose financial products and services suitable for customers. In addition, we will also post the information on the Bank's website and BANK app for easy confirmation. The major "important information" is as follows.
・ Risks, returns, and transaction conditions of the financial products and services
・ Attributes of potential customers for sale of the products
・ Reasons for selecting the financial products and services
・ Fees received as compensation for services to customers as well as fees received from third parties (Even in the same products, if the fee varies depending on the quantity, currency, course, etc., such information will be included.)
・ Packaged or not
"Important Information Sheet (Financial Business Operator)" (Japanese Only)

6. Providing services suitable for customers

<Maintenance of branches and infrastructure>

The Bank will provide "BANK™" services for customers who do not have a branch nearby. We offer "Bank The Debit" and "Bank The Savings" as services for "Spending" and "Saving", and "BANK The Teiki (time deposit)" as a service for "Increasing", as well as financial products such as investment trusts.

<Efforts to enhance financial literacy>

The Bank will help enhance its customers' financial literacy by expanding services such as "BANK The Partner", which supports many customers in achieving their life plans from a neutral perspective through seminars and e-mail delivery services, etc.

<Providing financial products>

After accurately recognizing the customers' needs and fully understanding the customers' financial knowledge, investment experience, transaction purpose, asset status, risk tolerance, life plan, etc., the Bank will carefully consider the target asset amount and study appropriate asset ratio using "Aozora Model Portfolios". Then we select and propose the financial products suitable for each and every customer from the diverse product line-up, while also giving due consideration to the complexity of the product, the potential risks, whether it is packaged or not, and other characteristics of the product. In addition, we will also post the information including product line-up on the Bank's website and BANK app for easy confirmation.
The Bank will coordinate with a wide range of domestic and international asset management companies and insurance companies, and based on the attributes of the target potential customers, we will improve our product line-up that will contribute to our customers' mid-to long-term asset management needs by introducing financial products and services and reviewing their handling. In addition, in order to understand customers' diverse needs, we will conduct regular surveys to customers, and make good use of the results to improve our product line-up.
When introducing new financial products and services, the Bank will strive to evaluate the product governance framework of the product origination company, etc. And including financial products originated by the Bank, the product group conducts verification, which includes research and analysis as well as confirmation of management framework, in terms of various issues and problems with clarification of target customers, risk/return/cost of products, and sales solicitation framework for customers. Then the product group consults with the compliance divisions, and when necessary, these issues are discussed at the Integrated Risk Committee, the Customer Committee, etc.
Even after the Bank starts handling financial products and services, we will check the results of the verification of products, etc. conducted at the time of introduction, and review or discontinue the products, etc. as necessary. In addition, in order to provide better financial products, we share customer feedback regarding financial products with product origination companies, etc., and such information on financial products originated by the Bank is also shared between the sales divisions and the origination divisions.
In preparation for introducing complicated or high-risk financial products to customers or providing information for those with limited investment experience, the Bank will take a more cautious approach by establishing solicitation rules such as suitability judgments and solicitation start criteria. In addition, we will monitor whether confirmation of the customer's intension and explanation to the customer were properly performed, and will provide instructions and training to sales personnel in order to improve and enhance the explanation to customers.

＊Regarding the Supplementary Principle 4 (Note 3) of the "Principles for Customer-Oriented Business Conduct" published by the FSA (Financial Services Agency), as the Bank does not outsource the investment management, we do not conduct verification of the management, etc. of outsourced companies as guided in the Principle.
＊Regarding the Supplementary Principle 5 (Note 1) of the "Principles for Customer-Oriented Business Conduct" published by the FSA, as the Bank does not originate financial products for which the judgment of the person who manages the investment is important, we do not provide information about its management system in accordance with the characteristics of individual financial products as guided in the Principle.

Principles for Customer-Oriented Business Conduct (FSA's website)

<Detailed follow-up services>

The Bank will make proposals while giving due consideration to the customer's life plan, and after the sale of financial products and services as well, we will regularly provide information such as the status of customer's owned products and market trends, and in addition, we will provide information from a long-term perspective in response to changes in the customer's life stage. Through those efforts, we will contribute to the asset formation of our customers for a long time.

<Responding to Customers' Voice>

The Bank will take seriously the customers' feedback received in the branches and call center as well as from customer satisfaction surveys, interviews, etc. and make good use of them for our service improvement, product design, etc.
The Bank will constantly verify and evaluate the results and progress of the above activities, and will announce the results in the "Status of Initiatives".

7. Consultant training policy and appropriate motivational framework

In order to promote the customer-oriented business conduct, we evaluate our performance based on items that are useful to our customers. The items include contribution in supporting customers' mid- to long-term asset formation and increase, courteous consulting services tailored to asset formation needs, and contribution to the realization and satisfaction of customers' needs for life plan through solution proposals.
To instill the customer-oriented business conduct, we developed the "Specialized Retail Training Program" that fully considers enhancement of consulting skills and improvement of compliance awareness, and for realizing highly specialized consulting services, all sales personnel are required to obtain financial planner qualifications.
Regarding the framework for consultant training and appropriate motivation, such as training implementation and its understanding level, performance evaluation system, the Bank will regularly check, verify and evaluate the results and progress status.