Chapter 1. Basic Principles

1. Compliance with Laws and Regulations

Compliance with laws and regulations represents the most basic attitude throughout the business area and activities of Company. Employees should not cause any situations to arise, which constitute the breach of laws and regulations, and should consider that their decisions or conduct may contravene laws, regulations, and by-laws before making ethical judgment on their decisions or conduct.

1. 1.1 Compliance with overall regulations: Employees should, in good faith and earnest, comply with related laws, regulations and any and all by-laws which credit finance businesses are required to observe in the course of performance of works, and should not request or order their colleagues or subordinates to handle any works contravening such laws, regulations and by-laws.
2. 1.2 Compliance with the requirements under the real-name financial transaction system: Employees should be engaged in financial transactions under real name, and should not leak, disclose or demand any financial transaction information of customer unduly
3. 1.3 Prevention of money laundering: Employees should abide by related laws and regulations related to prevention of money laundering, such as the Act on Reporting and Using Specific Financial Transaction, and should not involve in any transaction which raises suspicion of or is suspected of money laundering.

2. Respect for Customers

Employees should take the protection of customers’ fair profits and properties as utmost priority for creation of customer value in the course of performance of their works.

1. 2.1 Delivery of products and services for customers: Employees should provide the products and services most suited for customers from their standpoint to ensure that their real demands expectations can be met, and should provide explanations to customers, using the easy-to-understand words to ensure that customers fully grasp important details.
2. 2.2 Customer Data Protection: Employees should not use any customer information for personal purpose nor disclose any customer information to any third party, and should comply with related laws, regulations, and by-laws for protection of customer information. In addition, employees should manage customer information with adequate care to prevent abuse, misuse, leakage, etc., if customer information has to be handled unavoidably by any third party in cases such as rollout of new products, launch of new business.
3. 2.3 Respect for Customer Opinion & Fulfillment of Promises: Employees should gather the inputs from customers attentively, such as customer opinions and proposals, and make efforts to incorporate such inputs into the process of works, and furthermore, should keep the promises to customers with duty of care.

3. Win-win co-growth with subcontractors

Employees should understand that the growth of subcontractors for customer value creation creates foundation for further growth of the Company, and should provide as much support as possible to help improve products and services of subcontractors. Subcontractors should also make efforts to ensure that the performance of each contract or works is made in line with business philosophy and policies of the company.

4. Responsibility for Reputation of the company

Each employee should understand that his/her decisions and behaviors under the circumstances involving ethical issues will shape or affect the reputation of the company and that good ethical reputation of the company, resulting from desirable decision-making and behaviors befitting the ethical value, will be the key asset of the company. Based on such understanding, employees shall comply with the followings.

1. 4.1 Employees shall take pride as a member of the company and observe the Code of Ethics to ensure that the company can maintain and further improve its reputation.
2. 4.2 Each employee shall carefully consider the effect of his/her decision or behavior on the society and environment even under the circumstances not related to works
3. 4.3 Each employee should avoid causing any misleading belief that his/her political, religious, or ideological opinions represent those of the company.

Chapter 2. Integrity & Honesty

Integrity and honesty are the essential virtues vital for ethical organization culture. Ethical organization culture, conducive to strengthening customers’ trust, represents indispensable asset for sustainable growth of the company. To build ethical organization culture that reinforces customers’ trust, employees should comply with the followings:

1. Desirable Mode of Life Commensurate with Financial Status

1. 1.1 Restrictions on excessive investment or incurrence of excessive liability: Employees should refrain from excessive investment that goes beyond their financial ability and should maintain proper scale of liability in light of their ability to repay.

2. 1.2 Maintenance of decency: Employees should basically have ethical consciousness and law-abiding attitude as a member of the society, and should not be involved in any of the following behaviors that contravene such principles:

   • Any spending or consumption that goes beyond his/her financial ability or extravagant spending beyond his/her means
   • Speculative gambling that goes beyond the limit of one-time entertainment; or any act of gambling in gambling places
   • Excessive drinking that causes others feel inconvenience or aversion; or, habitual visit to harmful businesses, which may evoke criticism in the society
   • Drunk driving
   • Spending the budget or expenses of Company, such as travel expenses or business execution expenses, unduly for any purpose other than performing the works.
   • Other behaviors corresponding to any of aforesaid behaviors

2. Performance of Works with Honesty and Transparency

1. 2.1 Employees should be clearly aware of their authority and responsibilities. Employees, not eligible or without authorization, should not provide any products and services to customers and should communicate honestly in the course of performance of works.
2. 2.2 Employees should not be involved in any behaviors that cause disruption to healthy market order by engaging in transactions under alias or with any account opened under false name or by attempting to accomplish excessive performance using expedient methods which are convenient but improper.
3. 2.3 The materials, which are submitted to supervisory authorities or external auditors or disclosed or published externally through exchanges or internet, etc., should be prepared and managed in accordance with laws, regulations and by-laws in timely, accurate, transparent and fair manners.
4. 2.4 Employees should not be involved in any business activities through unfair methods that exploit the weakness in the laws and should be engaged in righteous business activities to help establish fair transaction order and healthy financial climate,
5. 2.5 Employees should not be involved in any unfair transactions, such as use of undisclosed information or manipulation of market value, by using internal information obtained in the course of performance of works.
6. 2.6 Employees should use the best efforts to protect the rights and benefits of consumers in all business activities based on trust.

Chapter 3. Prohibition of Bribery & Prevention of Corruption

Employees should keep in mind that bribery and corruption go against the underlying principles of honesty and undermines fairness of works, and should not provide to, or receive from, any customer or stakeholder any gift or entertainment. Furthermore, no employee should demand, or be offered the promise of, any gift or entertainment for the benefit of himself/herself or any third party by taking advantage of his/her status or position within the company.

1. Prohibition from Acceptance of Gift and Entertainment

Employees should not accept any gift or entertainment from customers or stakeholders. In particular, gift or entertainment is prohibited under any circumstances which may cause any third party to believe that such gift or entertainment might have affected the judgment and decision of employees in connection with works. That is not applicable to the cases where such gift or entertainment is not deemed to go beyond social norms and is unlikely to cause any conflict of interest.

• Meals, etc., which are provided within the boundary of normal practices in the course of performance of works
• Goods and other giveaways which are provided by organizers of work-related official events to all participants
• Souvenirs or promotional Goods to be handed out to unspecific many people
• Others corresponding to any of aforesaid cases

2. Prohibition from Providing or Offering Gifts and Entertainment

Provision or offering of gifts and entertainment to any customer or stakeholder should be prohibited if such gifts or entertainment can be considered as bribes or solicitation to any third party in return for favors related to works.
However, that is not applicable to the cases where such gift or entertainment does not exceed the boundary of social norms, and even in such cases, by-laws or ethical standards of the counterparty should not be breached.
The provision or offering of gifts and entertainment between employees, albeit prohibited in principle, is not prohibited; provided, however that such gifts and entertainment aim to raise condolence or congratulation money as part of mutual assistance or to simply promote friendship and not go beyond the limits.

3. Handling of Prohibited Gift

1. 3.1 Any employee, who received gift in breach of the 『Code of Conduct』, should return the provider of the gift the excess (the portion going beyond limits) or any prohibited gift to without delay.
2. 3.2 When the gift referred to in the foregoing Clause 1 is likely to be lost, corrupt, or deteriorated, the provider of the gift should report such concern to the Compliance Officer.
3. 3.3 Audit Team Head or Compliance Officer may handle the gifts, reported to them pursuant to this Chapter 3.2, as specified below:
   • Disposal in cases where the gift has lost its economic value due to corruption, deterioration or other reasons
   • Donation to social welfare facilities or public interest groups, etc. forthwith when there is any concern about degradation of economic value due to corruption, deterioration or other reasons
   • Donation to social welfare facilities or public interest groups, etc. in other cases, unless otherwise specified in other regulations

Chapter 4. Obligation of Faithfulness to Works & Prevention of Conflict of Interests

Conflict of interest refers to any and all situations in which the benefits of individual employee may take precedence over those of Company in the course of performance of works, and at this time, each employee should not put his/her benefits above the benefits of the company.

1. Obligation to Perform Works in Earnest & Works Unrelated to Works

Employees should carry out works faithfully and earnestly in the performance of works and should not be engaged in ‘non-work related activities’ (like excessively using the internet for personal purpose, engaging in stock trading, holding double or multiple positions for the purpose of profit during the working hours) which may cause distraction or affect faithful and earnest performance of works. However, that is not applicable to the ‘non-work related activities’ which are rarely likely to cause a conflict of interests and are conducted to the extent that no disruption is caused to the performance of works (for example, external lecture or meeting); provided that such ‘non-work related activities’ were reported or approved in advance.

2. Protection of Company’s Business Opportunities and Assets

1. 2.1 No employee is allowed to use the business opportunity of Company, obtained by using his/her position or internet information in the course of performance of works, for the benefits of himself/herself or any third party.
2. 2.2 Assets of Company should be used for work-related purposes, and should not be used for personal benefits of employees.
3. 2.3 Important information of Company, which needs to be kept confidential externally (for instance, unique information related to works of Company, R&D information of Company), should be strictly protected and managed pursuant to related laws, regulations, and by-laws, and should not be used for personal purpose nor leaked or disclosed externally.
4. 2.4 Employees should not embezzle or, use for illegal purpose, any assets of the company.

Chapter 5. Mutual Respect Among Employees

1. Observance of Workplace Etiquettes

1. 1.1 Employees should keep basic etiquettes mutually in workplace, listen attentively to the opinions of others, and should not use or display any acts or words humiliating, offensive or violent to others.
2. 1.2 Employees should perform their works with a sense of responsibility and in good faith and earnest, and should not make other employees handle their works unfairly.

2. Prohibition of Workplace Sexual Harassment

Employees should not perpetrate or acquiesce sexual harassment in workplace and should not take any action that puts any person raising issues at a disadvantage.

3. Prohibition from Discrimination

Employees should not be involved in any act of unfair discrimination based on kinship, school relations, regionalism, age, gender, race, religion, marital status, disability, and political inclination.

4. Prohibition from Lending and Borrowing Among Employees

Employees should not be involved in any act of lending and borrowing the money to and from each other nor provide security collateral, regardless of whether any payment of money, such as interests, etc. is made in return.

5. Prohibition from Solicitation and Graft

Employees should not make personnel solicitation related to recruitment, promotion, assignment to positions, etc., nor make any arrangement that undermines impartiality in the performance of works.

Chapter 6. Creation of Healthy Working Environment

1. Self-development

Each employee should respond flexibly to the challenges in the changing payment and clearance market, and should make efforts to improve work-related competency and develop himself/herself to further sharpen their competitiveness.

2. Work-Life Balance

Employees should allocate optimal time and resources for their families, health, leisure, and hobby activities, so that they can lead a balanced life.

Chapter 7. Contribution of Community

1. Contribution to Community

Employees should recognize that community forms the basis for sustainable growth of the company and should actively participate in the contributory activities that heighten the value of both community and its members to fulfill their duties as members of the company and the community.

Chapter 8. Environmental Protection

1. Environmental Protection

Employees should recognize that the Earth environment is the valuable asset which needs to be shared with future generations and creates the life foundation vital for basic survival and welfare of the human beings. Furthermore, employees should minimize risks to the environment across whole areas of their activities, comply with related laws and regulations, and actively be involved in the activities aiming to protect the environment both at home and abroad.

Chapter 9. Supplementary Provisions

1. Inquiries and Reports

Employees may ask questions to the person in charge below when they cannot make judgment on their own under specific circumstances involving ethical issues or when they have inquiries or questions pertaining to application and interpretation of the 『Code of Conduct』. Each employee should immediately notify the person in charge without delay if there is any legitimate ground for suspecting certain behavior as breach of Code of Conduct or upon becoming aware of any breach thereof.

• Compliance Officer
• Person in charge at the Compliance Monitoring Team or at the Audit Team
• In-house attorneys
• Other qualified persons

2. Effects from Breach

Employees who violated the 『Code of Conduct』 may be subject to investigation pursuant to internal regulations and may be put to an disadvantage, depending on the results of the investigation.