Customer Information Management

Compliance SystemCompliance Structure
The Company has designated the Group Risk Management
Division to oversee compliance and manage the status of compliance for the entire Group.
Every fiscal year, the division formulates a Group Compliance Program, a concrete action plan for compliance, andconducts appropriate compliance risk management for the entireGroup.

In addition, the Group Risk Compliance Meeting and theGroup Risk Compliance Committee hold meetings regularlyand as needed, to confirm that the Group is properly practicing
compliance, and to deliberate and give instructions regarding
the compliance system. The Group Risk Compliance Committee reports to the Board of Directors on the content of theirdeliberations.

Internal Reporting System
The Company has established a whistleblowing system for theentire Group. In order to detect and correct compliance violations early on, the Company and other group companies haveeach set up whistleblowing contact points.
In addition to internal contact points, we are working toenhance and improve our whistleblowing system via designatedexternal lawyers as contact points for reporting and consultation.

We have appointed a Chief Whistleblowing Officer as thegeneral manager of the whistleblowing system, and are workingto raise awareness of the whistleblowing system among officers
and employees throughout the Group, while engaging in efforts
to enhance the system.

The Company recognizes the secure management of customer
information as one of its most important issues.
We are fully aware of various risks such as leakage and lossof information to external parties with regard to customer
information acquired by each group company. As such, we haveestablished the “Information Security Management Rules” toensure proper handling of customer information, and also

Initiatives to Prevent Money Laundering, etc.
There is a growing threat of international terrorism, and fund transfers by criminal organizations and terrorists are spreading andbecoming international. As such, there is a stronger international demand for financial institutions to prevent money laundering,financing of terrorism, and proliferation financing (hereinafter “money laundering, etc.”).
The Company’s Group Risk Management Division oversees the Group’s overall anti-money laundering, etc. measures, and eachgroup company appoints a person responsible for anti-money laundering, etc. measures from among its officers.
■ Risk management system
We have positioned the prevention of money laundering, etc. asa top management issue, and we have built an effective risk
management system and are working to further enhance it.
■ Risk assessment documents
We identify and assess risks we are facing associated with money
laundering, etc., and plan “documents prepared by specified
companies (risk assessment documents),” in order to implement
mitigation measures commensurate with the risks.

Customer Protection
The Company has established a Group-wide “Customer Protection Management Policy,” and is striving to protect customers
and improve convenience for the whole Group. The Juroku
Bank and Juroku TT Securities have planned and announced a“Customer-oriented Business Operation Policy,” and are working to further improve the quality of their products and services
from a customer-oriented perspective.
The “Customer Protection Management Policy” is aimed at
protecting customers and improving convenience through thefollowing measures.

Giving appropriate explanations and providing information onproducts and services to customers
Appropriately handling customer requests, consultations,inquiries, complaints, etc.
Appropriately managing customer information
Appropriately managing outsourced businessAppropriately managing conflicts of interest in order to prevent
unduly infringement on the interests of customers

disclose a “Personal Information Protection Policy” (PrivacyPolicy).
Based on these regulations, we have appointed a Chief
Information Officer as the general manager of the protection ofinformation assets, and designated responsible divisions according to the type of information assets, as efforts to protect information assets more effectively.

■ Training for officers and employees
We continuously implement training for officers and employees,
so that they can gain deeper knowledge and understandingregarding measures against money laundering, etc., and improvetheir expertise and adaptability according to the roles of various
divisions.
■ Audits on compliance status
The Audit Division conducts internal audits from an independent perspective on a regular basis and as necessary. Based on theresults of these audits, we strive to further improve our systems.

Stakeholder Engagement
The Group emphasizes engagement with all stakeholders. We have progressed from taking action “for” our stakeholders to acting “with”
them.
In our “Group management philosophy,” we set the “Engagement Cycle” as our Code of Conduct, with the aim of taking on thechallenges faced by our customers and local communities, and resolving them together.

Designated dispute resolution organization
The Juroku Bank has concluded an agreement with the following designated dispute resolution organizations. By involving aneutral and fair third-party organization, we are appropriately
Contact for consultations, inquiries, opinions
and complaints about the Bank
Designated dispute resolution organizations
with which The Juroku Bank has anagreement32

responding to the financial ADR system, which are procedures
intended for simple and swift dispute resolution without resorting to litigation.

[Hours of operation]
Monday through Friday, 9:00 a.m. to 5:00 p.m.
(excluding national holidays and bank holidays)
Japanese Bankers Association (Contact: JBA Customer Relations Center)

Telephone: +81-3-5252-3772
Trust Companies Association of Japan (Contact: Trust Consultation Center)

Telephone: +81-3-6206-3988

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