As part of our commitment to strict compliance and to earning strong recognition from stakeholders and the trust of society, the SBI Group hereby establishes its basic policy on the prevention of bribery and corrupt practices.

This policy shall be managed and implemented by the Group’s Compliance Control Division under the supervision of the Board of Directors

1. Prohibition of Bribery and Corrupt Practices

SBI Group strictly prohibits all forms of bribery and corrupt practices by its employees, whether directly or indirectly. In addition, any involvement in such activities is likewise strictly forbidden.
*Bribery and corrupt practices refer to: ① Offering, promising, agreeing to provide, or authorizing the provision of tangible or intangible benefits—either directly or indirectly—to public officials or any third parties, including those in the private sector, with the intent to gain unfair business or operational advantages. This also includes similar acts such as donations and gifts. ② Soliciting or accepting, either directly or indirectly, any tangible or intangible benefits from public officials or any third parties, including private individuals, in exchange for providing unfair business or operational advantages. ③ Any other actions that violate laws, regulations, or societal norms and ethics. Furthermore, any entertainment or gift-giving involving clients or business partners by Group officers or employees must be conducted in accordance with internal guidelines and subject to appropriate approval processes. The Group is committed to ensuring proper management and oversight in these matters.

2. Compliance with Laws and Regulations

SBI Group complies with all applicable laws and regulations, both domestic and international, concerning the prevention of bribery and corrupt practices, as well as rules governing entertainment, gifts, and related activities.

3. Establishment of a Governance Framework

SBI Group established and maintains internal rules and procedures in accordance with applicable laws and regulations to prevent bribery and corrupt practices. The Group also implemented a framework to monitor compliance by the employees and to take appropriate corrective actions as necessary. Furthermore, the effectiveness of this framework is reviewed on a regular basis.

4. Initiatives to Ensure Effectiveness

SBI Group is committed to ensuring the effectiveness of its anti-bribery and anti-corruption framework through the following key initiatives:

4-1. Management Involvement
The management teams of the SBI Group companies recognize the prevention of bribery and corruption as a critical management issue. They bear responsibility for this effort and actively and proactively promote related measures.
4-2. Internal Training
To raise awareness of compliance among the employees, ensure understanding of relevant laws, regulations, and internal policies, and maintain and enhance professional standards, the SBI Group conducts regular internal training sessions on anti-bribery and anti-corruption practices.
4-3. Record Keeping
SBI Group maintains accurate and appropriate records and documents —such as those related to entertainment and gifts—in accordance with applicable laws, regulations, and internal policies, as part of its anti-bribery and anti-corruption efforts.
4-4. Risk Assessment
SBI Group conducts annual risk assessments on bribery and corruption across its group companies, and implements appropriate risk management measures based on the results of these evaluations.

5. Reporting and Whistleblowing

SBI Group maintains a framework that enables the employees to promptly report or whistleblow any actual or potential violations of laws, regulations, or internal policies related to the prevention of bribery and corrupt practices. The Group is also committed to ensuring the protection of whistleblowers by preventing any disadvantage or retaliation against those who make such reports in good faith.

6. Investigation and Disciplinary Action

If a serious violation—or potential violation—of anti-bribery and anti-corruption rules is discovered, the SBI Group will promptly conduct an investigation led by the relevant division or responsible executive of the respective company. Should a violation be confirmed, the Group will take strict disciplinary action in accordance with applicable laws, regulations, and internal policies.