Introduction

Message from thePresident & CEO

Value Creation Story Business Strategies

Financial Strategy

Strategy to EnhanceNon-financial Capital

Governance

Data Section

ComplianceTo ensure that our common values and ethics regarding compliance are recognized and shared among
all Group employees, the Mitsubishi HC Capital Group has established the Mitsubishi HC CapitalGroup Code of Ethics and Code of Conduct as basic guidelines for all Group employees. To ensurecompliance with this Code of Ethics and Code of Conduct, we have made our Compliance Manual
available on the Company intranet so that all Group employees can review it at any time.

Compliance Management Structure and System
At Mitsubishi HC Capital, the Chief Compliance Officer (CCO) supervises a company-wide compliance management
structure and system. Under the leadership of the CCO, the Legal & Compliance Department plans and manages
internal structures and systems and provides guidance and supervision to each division and Group company, as well asguidance on the correction of compliance violations.
Please refer to our website for details.
Code of Ethics
https://www.mitsubishi-hc-capital.com/english/sustainability/governance/compliance.html

Board of DirectorsExecutive Committee
President & CEO

Audit &Supervisory
Committee

Compliance Committees
President & CEO, Deputy Presidents, Head of Risk
Management Division, Head of Human Resources and General
Affairs Division, Head of Credit Division, Head of IT &Operations Division, Directors in charge of auditing

Chair of Committee

Relateddepartmentsand offices

Chief Compliance Officer

Legal & Compliance Department(Compliance officer)

Support, guidance and education

Whistleblowing System

Principles for Money-Laundering Prevention

The Mitsubishi HC Capital Group has set up a compliance hotline system as a whistleblowing system forofficers and employees to report and consult about
misconduct and related issues, including corruption (anyreal or suspected violations of laws, regulations, internalrules, or the Code of Ethics by officers, employees, etc.).
The compliance hotline system comprises (1) aLegal & Compliance Department contact and (2) a
Full-time Audit & Supervisory Committee Member contact as internal points of contact, and (3) an outside
attorney and (4) an external consultation desk as external points of contact. These all serve as contact points
for officers and employees(including those alreadyretired) to be able to report or consult without hesitation.
The external consultation desk also accepts anonymous
reports and consultations.
In the event that a compliance violation is brought tolight through a hotline or other means, our basic
response policy is for the Legal & ComplianceDepartment to ensure prompt reporting to management,
the fulfillment of corporate social responsibility, and theprevention of further harm and recurrences. Dependingon the nature of the compliance violation, a third-party
organization may be involved in the investigation. We
strive to investigate the cause of such incidents, formulate and implement measures to prevent recurrences,and further educate employees to raise awareness ofcompliance.

The Mitsubishi HC Capital Group (“Group”) is striving toenhance our structure and system to prevent money-laundering and terrorist financing (collectively,“Money-Laundering”) and eliminate any trade relationship with persons (individuals and entities) subject tosanctions, which violates economic sanctions of theUnited Nations, international organizations, andindividual countries.
1. We shall comply with all applicable laws and regulations for preventing Money-Laundering in and outsidethe country.
2. Recognizing Money-Laundering prevention as one of
our critical challenges, the top management of eachcompany of the Group shall proactively and aggressively tackle this issue.
3. With regard to persons subject to sanctions identified
under the UN Security Councilʼs resolution and by
OFAC or other regulatory authorities, we shall checkand screen every contemplated transaction appropriately according to applicable laws and regulations.
4. Taking the risk-based approach, we shall appropriately manage customers and transactions to address
the risks in the Money-Laundering.
5. We shall monitor all transactions continuingly, and if
any of them is suspected of being involved in
Money-Laundering, we shall report it to relevant
authorities as required.
6. We shall provide training programs continuously tomaintain and improve awareness about
Money-Laundering prevention of the officers andemployees of the Group and their capability to deal
with those transactions.
7. We shall ensure the appropriate business operation for
Money-Laundering prevention by conducting regularinternal audits and other processes.

Reporting on compliance

What can be consulted or reported
Compliance promotion managers(Heads of departments and offices)

Compliance promotion officers

Internal
Audit
Department

Group companies inJapan and overseas

Any acts engaged in by officers and employees in violation or suspected of being in violation of laws, regulations, internal rules, or the Code of Ethics can beconsulted or reported.
●

Acts affecting the protection of customer interests●

Acts impacting the protection of the environment●

Acts affecting fair competition, such as violations ofantitrust laws●

Acts related to provision of bribes or other illegal
benefits to government officials and the like both inJapan and overseas

Other inappropriate acts in violation of laws, regulations, rules, or social justice
Officers and employees who report or consult shallreceive no disadvantageous treatment whatsoever due
to such reporting or consulting.

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MITSUBISHI HC CAPITAL INTEGRATED REPORT 2023

MITSUBISHI HC CAPITAL INTEGRATED REPORT 2023

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