Governance

Ensuring Compliance

To ensure that all officers and employees, including those of Group companies, are aware of and share in our common values and our ethics regarding basic compliance, the Board of Directors has established the Mitsubishi HC Capital Group Code of Ethics and Code of Conduct. Furthermore, the Executive Committee has established the Principles for the Prevention of Bribery and Corruption, Principles for Compliance with Competition Laws, Basic Policy on Anti-social Elements, Policy on the Prevention of Money-Laundering, etc., Privacy Policy, and Security Export Control Policy, and has set rules and regulations linked to each policy. We have prepared a Compliance Manual to inform all officers and employees about these policies, rules and regulations, and have made it available on the Company intranet so that it can be easily reviewed at any time.
The Group Code of Ethics establishes fundamental values and ethics to be embraced throughout the Group, and serves as a set of fundamental guiding principles for all officers and employees. All officers and employees of the Group adhere to the Code of Ethics.

Code of Ethics

1. Establishing Trust
   Fully recognizing the weight of our social responsibility and public mission, we aim to establish the unshaken trust of society through complete information management and sound and proper business activities, including the timely and appropriate disclosure of company information.
2. Customer-Oriented Approach
   Consistently taking a customer-oriented approach and having good communication, we offer products and services that best meet customers' needs to obtain customers' satisfaction and support.
3. Strict Compliance with Laws and Regulations
   We strictly adhere to all applicable laws and rules (including social, industry, and company rules) and undertake appropriate and sincere corporate activities in line with social norms. We also respect internationally accepted standards as a corporate group operating globally.
4. Respect for Human Rights and the Environment
   Respecting the personality and character of each other and emphasizing conservation of the global environment that is the shared asset of humankind, we pursue harmony with society.
5. Exclusion of Anti-Social Elements/Money-Laundering Prevention
   We take a resolute stance against anti-social elements that threaten the order and safety of civil society. In compliance with all applicable laws and regulations related to preventing money laundering, we take every possible measure to block money laundering and terrorist financing.

Compliance management structure and system

Mitsubishi HC Capital's compliance management structure and system is supervised by the Chief Compliance Officer (CCO), who is responsible for building and operating a Company-wide compliance management structure and system. Under the leadership of the CCO, the Legal & Compliance Department plans and manages internal structures and systems and provides guidance and supervision to divisions and Group companies, as well as guidance on the correction of compliance violations.
In the event that a compliance violation is brought to light through a hotline or other means, our basic response policy is for the Legal & Compliance Department to ensure prompt reporting to management, the fulfillment of corporate social responsibility, and the prevention of further harm and recurrences. Depending on the nature of the compliance violation, a third-party organization may be involved in investigations. We strive to investigate the cause of such incidents, formulate and implement measures to prevent recurrences, and further educate employees to raise compliance awareness.

Compliance awareness and training

We provide training to employees on various laws under which the Group has been registered or licensed, including the Money Lending Business Act, the Installment Sales Act, and the Financial Instruments and Exchange Act, and test their comprehension following training. We provide annual training on the Group Code of Ethics and Code of Conduct as well as various other anti-corruption laws, including understanding of bribery prevention, competition law compliance, fraud prevention, insider trading prevention, prevention of transactions with anti-social elements, prevention of money laundering, privacy protection, the Whistleblower Protection Act, security and trade control, and harassment prevention. In addition to the training, we conduct periodic monitoring using separate self-checks, to measure the employees' level of understanding and confirm whether understanding has spread throughout the Group.

Whistleblowing System

The Mitsubishi HC Capital Group has set up a compliance hotline system as a whistleblowing system for officers and employees to report and consult about misconduct and related issues, including corruption (any real or suspected violations of laws, regulations, internal rules, or the Code of Ethics by officers, employees, etc.).
The compliance hotline system comprises (1) a Legal & Compliance Department contact and (2) a Full-time Audit & Supervisory Committee Member contact as internal points of contact, and (3) an outside attorney and (4) an external consultation desk as external points of contact. These all serve as contact points for officers and employees (including those already retired) to be able to report or consult without hesitation. The external consultation desk also accepts anonymous reports and consultations.
In the event that a compliance violation is brought to light through a hotline or other means, our basic response policy is for the Legal & Compliance Department to ensure prompt reporting to management, the fulfillment of corporate social responsibility, and the prevention of further harm and recurrences.
Depending on the nature of the compliance violation, a third-party organization may be involved in the investigation. We strive to investigate the cause of such incidents, formulate and implement measures to prevent recurrences, and further educate employees to raise awareness of compliance.

(What can be consulted or reported)
Any acts engaged in by officers and employees in violation or suspected of being in violation of laws, regulations, internal rules, or the Code of Ethics can be consulted or reported.

• Acts affecting the protection of customer interests
• Acts impacting the protection of the environment
• Acts affecting fair competition, such as violations of antitrust laws
• Acts related to provision of bribes or other illegal benefits to government officials and the like both in Japan and overseas
• Other inappropriate acts in violation of laws, regulations, rules, or social justice

Officers and employees who report or consult shall receive no disadvantageous treatment whatsoever due to such reporting or consulting.

Number of internal reports and consultations

Principles for Money-Laundering Prevention

The Mitsubishi HC Capital Group ("Group") is striving to enhance our structure and system to prevent money-laundering and terrorist financing (collectively, "Money-Laundering") and eliminate any trade relationship with persons (individuals and entities) subject to sanctions, which violates economic sanctions of the United Nations, international organizations, and individual countries.

1. We shall comply with all applicable laws and regulations for preventing Money-Laundering in and outside the country.
2. Recognizing Money-Laundering prevention as one of our critical challenges, the top management of each company of the Group shall proactively and aggressively tackle this issue.
3. With regard to persons subject to sanctions identified under the UN Security Council's resolution and by OFAC or other regulatory authorities, we shall check and screen every contemplated transaction appropriately according to applicable laws and regulations.
4. Taking the risk-based approach, we shall appropriately manage customers and transactions to address the risks in the Money-Laundering.
5. We shall monitor all transactions continuingly, and if any of them is suspected of being involved in Money-Laundering, we shall report it to relevant authorities as required.
6. We shall provide training programs continuously to maintain and improve awareness about Money-Laundering prevention of the officers and employees of the Group and their capability to deal with those transactions.
7. We shall ensure the appropriate business operation for Money-Laundering prevention by conducting regular internal audits and other processes.

Prevention of Fraud and Corruption

The Group complies with laws and regulations relating to prohibition of fraud, corruption, bribery, etc. applicable to countries and areas where the Group operates, and prohibits acts of fraud, entertainment and gifts, giving or receiving bribes, etc. that may invite suspicion or distrust from society.
In addition, all officers and employees of the Group will observe the following:

1. Do not conduct any form of corruption such as money laundering, embezzlement and obstruction of justice.
2. Fully understand laws and regulations, and not provide entertainment or gifts that may invite suspicion or distrust from society, or offer any money or other benefits for the purpose of gaining any unfair advantage to Japanese or foreign public officials or any other persons equivalent thereto.
3. Maintain a firm stance against antisocial forces that threaten the order and safety of the civil society and do not have any relationship whatsoever with them, including business relationships.
4. Do not conduct any act that may violate insider trading regulations.
5. Do not give or receive gifts to or from business partners that deviate from social norms or sound business practices.
6. Do not take advantage of position and authority in the Company to make a demand to business partners, etc. for private profit.

Number of violations related to anti-corruption regulations

There were no violations of anti-corruption regulations that may significantly affect the management of the Group.

Fines for corruption

No payments related to corruption were made, such as payments of fines and other costs related to penalties or compensation.