Code of Ethics
This “Mitsubishi HC Capital Group Code of Ethics” clarifies fundamental values and ethics to beshared across the Group as the basic guidelines for all the officers and employees, including all
persons working in the Group (hereinafter the same shall apply). Every officer and employee ofthe Group must follow this Code of Ethics.
1. Establishing Trust
Fully recognizing the weight of our social responsibility and public mission, we aim toestablish the unshaken trust of society through complete information management and soundand 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 andsupport.
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 theglobal 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 ofcivil 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.

Code of Conduct
All the officers and employees of the Group are expected to recognize corporate and own
responsibilities for the society to fulfill, respectively. We should adhere to the Code of Conduct
below with our strict sense of ethics and consciousness for compliance and perform all day-today activities with integrity.
[Management's commitment]
Every officer of the Group makes commitments as follows:
To take initiatives to observe the Code of Conduct,
To undertake business management based on corporate ethics and legal compliance,
To build a corporate structure deserving society and people’s trust and expectations tocontribute to the development of a healthy economy and society, andTo prevent the occurrence of any event or situation violating the Code of Conduct. If such anevent or situation occurs, the officers take immediate corrective measures, prevent areoccurrence, and have all the Group employees completely follow the Code of Conduct.
1. Establishing Trust(1) Performance of tasks with integrity based on the high ethical value
To facilitate fair and highly transparent corporate activities, all the employees perform theirtasks assigned based on high ethical value. No one distorts or hides facts, such as by falsereporting.
(2) Strict confidentiality and information management
No one discloses to a third party any customer information learned at work without a goodreason or consent from the customer who is the subject of the information in question. Each
employee controls and handles the company’s information assets, including customer
information, with great care, strictly adhering to the relevant internal rules.
(3) Appropriate accounting treatment and information disclosure
No one conducts an inaccurate accounting treatment or makes false or misleading bookentries. We disclose company information based on facts with integrity.
2. Customer-Oriented Approach(1) Sincere and respectful approach to customers
Each employee communicates with customers in a kind, respectful, and sincere mannerand keeps a customer-oriented approach not to impair the customer's interests.
(2) Thorough compliance with the principle of suitability and accountability
We offer products and services considered appropriate to the needs and experience ofcustomers. Each employee gives the customer a sufficient explanation of the merits,demerits, and risks before making a deal based on the customer’s consent.

(3) Thorough confirmation of customer's intent
When executing a contract with a customer, each employee must affirm that the customer
thoroughly understands the contract's content and it is based upon the customer’s intent.
(4) Responsible response to stakeholders
We provide information with the highest degree of fairness and transparency to customers
and diverse stakeholders and responsibly respond to them through various forms ofcommunication, such as dialogue with them.
3. Strict Compliance with Laws and Regulations(1) Compliance with laws and regulations
We perform fair and sincere corporate activities with strict compliance with laws and rules
at the local and international levels as a corporate group operating globally. All employees
aim to maintain and enhance high ethical standards and a corporate culture that respects
laws and rules.
(2) Prohibition of unfair transactions① No employee solicits transactions that use a position of superiority over customers. Also,no one engages in actions that harm any customer's benefits for the sake of the businessinterests of its own company or Group companies.
② No employee engages in activities to generate own profits based on information learned
at work. In particular, no one can trade stocks or securities nor make similar transactions
based on non-public material facts that could influence the stock price of any Group
company or business partner. When you possess information falling under the categoryof material facts, you should handle such information with the utmost caution.
③ No employee engages in activities that undermine the interests of another Group
company for the sake of its own company's gains. Each employee pays utmost care not
to engage in prohibited activities when handling customers' non-public information or
conducting transactions with the parent company or another Group company.
④ To maintain fair and unfettered competition, every employee must follow fundamental
rules for business transactions, including competition laws both at home and in othercountries, and undertake activities strictly adhering to laws and sound corporate ethics.
⑤ No employee permits nor engages in any bribery or corrupt practices. Also, no one offers
or accepts a gift or entertainment beyond the bounds of socially accepted limits, and that
becomes a hotbed of corruption. Further, we build healthy relationships withgovernmental and administrative agencies, politicians, and officials to maintaintransparency.
(3) National security
For maintaining international peace and security, we are required to block the flow ofmoney to countries, terrorists, and other suspicious persons who may engage in activities
of concern that threaten the safety and security of our home country and internationalsociety. Also, we must prevent the above persons from acquiring weapons, goods, andtechnologies that can be diverted for use in military applications. For that purpose, wecooperate with the international society to control the export and other transactions, andnone of us gets involved in such parties.
(4) Respect for intellectual property rights
We appropriately protect the rights in intellectual properties created by the company(patents, trademarks, copyrights, and other similar rights) and respect the intellectual
property rights held by third parties. In addition, each employee recognizes the brand as an
essential corporate resource and strives to maintain and increase the value of the Groupbrand.
(5) Prohibition of mixing business with private affairs
Every employee makes value judgments from the standpoint of fairness and equity at alltimes, regardless of the interests involved. Each employee must draw a line between
business and private matters and never makes private use of company assets.
4. Respect for Human Rights and the Environment(1) Respect for human rights
Consistent with the fundamental spirit of respect for humanity, no employee engages inany discriminatory action or human rights violation on the ground of gender, sexualorientation, age, nationality, race, ethnicity, political opinion, beliefs, religion, social status,lineage, illness, or disability.
(2) Fostering a comfortable work environment
We aim to realize flexible working styles, respect diversity in values, and develop a work
environment and systems that encourage employees to exercise their most entire abilities.
In this regard, every employee keeps in mind that sexual, power, or any other harassment
hurt people's dignity as human beings. Such an action must be eliminated from theworkplace.
(3) Understanding global human rights issues and action to take
Given international standards on human rights, every employee works to respect and not
infringe the rights of all persons involved in business activities and create relationships of
mutual understanding.
(4) Consideration for the environment
Attaching importance to the conservation of the global environment, every employee
pursues harmony with society.

5. Exclusion of Anti-Social Elements/Money-Laundering Prevention(1) Exclusion of anti-social elements
Every employee must resolutely address any anti-social element, such as organized crimegroups (boryokudan)and corporate racketeers (sokaiya).
(2) Money-laundering prevention
Every employee pays heed to the possibility that funds transacted through financial
institutions are used in various types of crime and terrorism. To prevent money laundering,each must follow, and never skip, the required step to verify a customer's identification; if
you find any suspicious transaction that may fall into crime, you should not condone andappropriately address it.
Establishment: April 1, 2021