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Basic Ideas

At the SBI Group, compliance activities are promoted based on the understanding that incomplete compliance has a potential to pose threats on the management foundation, therefore, it places the implementation of thorough compliance for all executives and employees as the basic principles of management.

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

"SBI Group Compliance Code of Conduct"

Code of Conduct

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 this, 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.

The SBI Group's Code of Conduct (Extract)

1. Code of conduct to earn trust from customers

- We will adhere to the "Customer-centric Principle" and provide customers with highly reliable goods and services that comply with laws and social norms and beneficial to the 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 will only be used within the scope of the purpose of use for which notification, publication, or consent has been obtained.

- We will 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.

- We will maintain appropriate relationships with customers.

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

2. Code of conduct for ensuring trust from shareholders

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

- We will 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 so 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.

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

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

- We will 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.

- We will 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.

- We will maintain sound, normal and transparent relationships with politics and administration.

- We will take a firm stand against anti-social forces.

- We will 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.

Structure of Promoting Compliance

<Compliance System>

At the SBI Group, the compliance management division of SBI Holdings is in charge of the overall compliance planning, implementation of specific measures, and overall management, while taking into consideration each industry and business category of the Group. In addition, we present a unified compliance policy towards the 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.

Practicing Compliance Measures

Measures towards the prevention of corruption

The SBI Group has steadfastly adhered to and practiced the management philosophy of "Sound Ethical Values" and is also taking preventative measures towards corruption such as clearly declaring "prohibition of insider trading," to "maintain a sound, normal, and transparent relation with politics and administration," to "eliminate of antisocial forces" and "prevention of money laundering" in the Compliance Code of Conduct.
Moreover, an "Rules on Interaction with External Parties " is establishes for Group executives and employees, to ensure that they are fully aware of these regulations in order to comply with laws and regulations that regulate bribery, etc. and to promote appropriate external exchange in accordance with social norms.

Measures taken towards customer protection and information security

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.
The 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.

Measures taken towards anti-social forces

In order to secure the appropriateness of its businesses as a financial conglomerate, the SBI Group implements the "Basic Policy Against Anti-Social Organizations" and promotes the development of systems to eliminate antisocial forces.

Measures taken towards anti-money laundering and countering the financing of terrorism (AML/CFT)

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 , the SBI Group implements the "Anti-Money Laundering and Countering the Financing of Terrorism Policy" and promotes the development of systems to ensure the soundness and appropriateness of operations throughout the Group.

Whistle-blowing System

<Reporting Route Diagram>

The SBI Group has established a whistle-blowing system enabling reporting by Group company employees (including non-regular employees) whenever they discover actions, whether organizational or individual, that violate laws or regulations. Moreover, to ensure the ease of use for whistle-blowers, a secondary point of contact has been established at SBI Holding's Board of Statutory Auditors, and we take ample care in ensuring the confidentiality of whistle-blowers and in the handling of the information. In order to ensure that the whistle-blower is protected after making a report, the Group investigates as appropriate to determine whether they have received any unfavorable treatments.