Compliance and Code of Conduct

At the SBI Group, compliance activities are promoted based on the understanding that incomplete compliance riskily poses threats to the management foundation; therefore, it places the implementation of thorough compliance for all executives and employees as the basic principle of management.

Going forward, SBI Group will continuously strive to achieve a high reputation from stakeholders and to establish trust from society through appropriate corporate activities that comply with laws, regulations, social norms, corporate ethics, in Japan and other countries.

In the "Five Corporate Missions" that the SBI Group has steadfastly adhered to and practiced since its founding, there is a principle related to the way a company that adheres to the spirit of compliance and social norms should be. Specifically, it is the two philosophies of "Sound Ethical Values" and "Fulfill Social Responsibility," and based on these, we have established the "SBI Group Compliance Code of Conduct" as a code of conduct for respecting compliance that should be observed and widely practiced by all executives and employees.

1. Code of conduct to earn trust from customers

- Adhere to the "Customer-centric Principle" and provide customers with highly reliable goods and services that comply with laws and social norms are beneficial to society.

- Information acquired from transactions and any other activities with customers will be strictly managed, and will not be disclosed to any third parties for no justifiable reason.

- Personal information will be obtained in an appropriate manner and be used within the scope of the purpose of use for which notification, publication, or consent has been obtained.

- Ensure an appropriate quality is maintained in order to live up to the trust of our customers in the execution of our business.

- In our business activities, we will choose to act with an awareness of our public responsibility and influence on society as a company engaged in the financial industry.

- Maintain appropriate relationships with customers.

- Listen honestly to the voices of our customers and respond sincerely and promptly to any complaints we receive.

2. Code of conduct to ensure trust from shareholders

- Establish a sound management system that complies with laws and regulations such as the Companies Act and the Financial Instruments and Exchange Act.

- Secure financial soundness and distribute profits appropriately in line with business performance.

- Management will be executed with a focus on shareholders, customers and society, and information will be disclosed in a proactive and fair manner.

- We will not provide any payoffs provided without consideration to shareholders, etc.

3. Code of conduct towards society

- When we conduct our business, we will base our decisions on whether it is right to do in light of social justice.

- Each company in the SBI Group will understand the nature of its role as a constituent of society and contribute to the maintenance and development of society while responding to the requests of various stakeholders.

- Comply with the scope of business as stipulated by the laws and regulations related to each business of the SBI Group.

- Fulfill our obligations under the laws and regulations related to each business of the SBI Group.

- Promote fair, transparent and free competition in accordance with the gist of the Anti-Monopoly Act.

- As a good corporate citizen, we will contribute to the sustainable growth of society.

- Act voluntarily and proactively, understanding that addressing environmental issues is an essential requirement for corporate existence and activities.

- We will not use undisclosed information (insider information) obtained in the course of performing our business operations to benefit ourselves or a third party.

- Maintain sound, normal and transparent relationships with politics and administration.

- Take a firm stand against anti-social forces.

- Comply with laws and regulations regarding identity verification and cooperate towards preventing the financing of terrorism and money laundering by reporting suspicious transactions in a timely and appropriate manner.

4. Code of conduct to build a better corporate culture

- Respect human rights without conducting any act of discrimination

- Arrange and keep a pleasant and open working environment

- Properly treat and assign employees based on appropriate evaluation

5. Code of conduct as a member of an organization

- Make internal decisions in a transparent and fair manner

- Fulfill duties by acting for the benefit of the Company

- Make a sharp distinction between public and private and maintain the integrity

- Drictly manage information and protect the reputation of the Company

- Keep fair and highly transparent relationship with group companies in order to ensure sound management

- Make immediately reports and hold consultations when finding any violation of compliance without neglecting it

6. Code of conduct of top management

- Recognize that they are responsible for realization of the spirit of this Code of Conduct and take the lead in keeping relevant persons fully informed of it

- Grasp views within and outside the Company all the time, arrange effective internal scheme, and try to establish corporate ethics and realize thoroughgoing implementation of compliance, the denotation of corporate ethics.

- Declare that top management themselves will try to solve problems inside and outside the Company upon occurrence of violation of this Code of Conduct and make efforts to find out the cause and prevent recurrence thereof

- Disclose quickly and adequately disclose information and fulfill accountability to the public, clarify where the authority and responsibility lie, and severely punish officers and employees including top management themselves

To grasp the issues on compliance and the code of conduct, Chief Ethics Officer（CEO）and a compliance officer is appointed by resolution of the Board of Directors, and the Group Governance & Compliance Department is established as the compliance control division directly under the officer. SBI group strengthens and thoroughly implements its compliance promotion system through the following initiatives.

・SBI Holdings has appointed a Chief Ethics Officer to promote and oversee the code of conduct and compliance framework across the entire Group.

・ The compliance control division of SBI Holdings, while taking into consideration each industry and business category of the Group, is in charge of the overall planning and drafting, implementation of specific measures, and overall management related to compliance.

・ The Company establishes the "SBI Group Compliance Code of Conduct" and other guidelines to ensure that all executives and employees comply with and widely practice compliance.

・ The Company presents a unified compliance policy towards Group companies through the divisions in charge of compliance at each company, and provide support, follow-ups and guidance for the implementation of the policy. The officer in charge of compliance and the compliance control division, together with the those in charge within each SBI Group company, hold regular meetings to share information across the whole Group.

・ Every year, the Company conducts compliance training sessions using e-learning and other means to improve knowledge related to compliance and raise awareness of employees including non-regular employees.

・ We are actively working with overseas bases and creating a strong global compliance structure such as by implementing effective monitoring depending on characteristics of businesses at each bases.

SBI Group places “SOUND ETHICAL VALUES - We shall undertake judgments on actions based not only on whether they conform to the law or profit the company, but also whether they are socially equitable-.” at the forefront of its corporate mission. Those engaged in the financial industry are required to uphold exceptionally high ethical value compared to other sectors. A sound ethical value is a fundamental prerequisite for business operations, and at the SBI Group, this value is intended to be deeply embedded in our corporate culture and environment, ensuring it is consistently upheld across a diverse workforce.

At the SBI Group, the corporate mission of “SOUND ETHICAL VALUES” is upheld, with corporate judgements on actions based on only on whether they conform the law or profit the company, but also whether they are socially equitable. Bribery and corruption are recognized as unacceptable acts, and efforts to prevent such misconduct across the entire Group are considered essential for promoting fair business practices, gaining strong stakeholder recognition, and building trust with society. In line with this approach, “SBI Group Anti-Bribery and Anti-Corruption Policy” has been established.

Moreover, the SBI Group has established restrictions and approval procedures for the entertainment of, and gifts of money and goods to and from, customers and business partners of its officers and employees, in order to prevent conflicts of interest and violations of laws and regulations.

In addition, the SBI Group has established regulations on corporate ethics, guidelines on practices such as entertainment and gift-giving and rules towards interactions with business partners and civil servants for all officers and employees of the Group, including the prohibition in principle of providing entertainment or gifts of money or goods to officers and employees of government and municipal offices.

Aside from that, the Group is committed to ensuring appropriate external interactions in accordance with social norms and laws regulating bribery and other corrupt practices by raising awareness of prevention of bribery and corruption through compliance training and other means.

Based on the fundamental view of the "Customer-centric Principle" the SBI Group is thoroughly implementing measures to ensure the appropriate management and protection of customer information and assets related to its business.
In order to continuously maintain and improve the standards of information security within the group, the Company has stipulated the outline of activities and organizational structure of information security management in the “policy of information security.”

SBI Group has also established a group-wide framework for ensuring information security to protect the information, assets, etc. of customers and the Group from cyber security threats whose seriousness has been increasing in recent years. In order to protect not only the Company’s own information assets but also those of customers, partners, and other stakeholders, the Company has established the comprehensive "SBI Group Security Guidelines" as a guide for information security measures at each Group company.

In addition, training is conducted periodically to improve the awareness and knowledge of information security of officers and employees.

Cybersecurity

In order to secure the appropriateness of its businesses as a financial conglomerate, SBI Group implements the "Basic Policy Against Anti-Social Organizations" and establishes the group-wide systems to eliminate antisocial forces.
For new external contractors, a check is conducted prior to the commencement of any transaction to ensure they are not affiliated with anti-social forces. In addition, contracts include clauses for the execution of such groups, and contractors are required to submit a written pledge, thereby reinforcing strict compliance requirements for all counterparties.

Based on the understanding that strengthening anti-money laundering measures and measures countering the financing of terrorist organizations is an important duty of an enterprise operating a financial business , SBI Group implements the "Anti-Money Laundering and Countering the Financing of Terrorism Policy" and establishes a group-wide system to ensure compliance with relevant laws and regulations, to continue to further strengthen measures to prevent money laundering and the financing of terrorism.

In order to foster an awareness of respect for compliance among officers and employees, the compliance control division of SBI Holdings systematically conducts compliance-related training and other programs for all executives and employees.

Training themes (examples)
Company policy/ power harassment / sexual harassment / security policy/ Rules on Interaction with External Parties / compliance policy/ compliance manual/ Business Ethics/ Consumer Contract Act, Regulation related to campaign, regulation related to mail-order, Act on Regulation of Transmission of Specified Electronic Mail, Money Lending Business Act, Interest Rate Restriction Act, Act against Unjustifiable Premiums and Misleading Representations, Unfair Competition Prevention Act, Ordinance for Enforcement of the Act on Prevention of Transfer of Criminal Proceeds, Laws and regulation on insider trading/ Rules for Management of Insider Trading

At the SBI Group, in order to identify and understand potential risks related to compliance and corporate ethics – and to evaluate them autonomously – compliance self-assessments are conducted twice a year. These assessments not only cover common items across all Group companies but also include company–specific evaluation items tailored to the characteristics and scale of each business, ensuring effective compliance risk management. If the self-assessment identifies areas requiring improvement, a corrective action plan is developed under the leadership of the compliance department, which also monitors and manages the status of the implementation.
In addition, the compliance self-assessment includes not only the evaluation of internal business operation but also regular assessment of external contractors. Beyond self-assessment, periodic checks are conducted through employee compliance awareness surveys and internal reviews related to compliance and ethical values are thoroughly upheld throughout the Group.

At the SBI Group, such initiatives are part of ongoing efforts to build and strengthen a framework in which all executives and employees are encouraged to proactively recognize and comply not only with laws and regulations, but also with social norms, internal policies, and rules. In addition, a Group-wide whistleblowing system has been established, allowing employees ---including temporary staff and those within one year of resignation--- as well as executives, to report organizational and individual violations of laws and regulations.