Customer Information Management

Compliance system
Compliance 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 their deliberations.

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 working
to raise awareness of the whistleblowing system among officers
and employees throughout the Group, while engaging in efforts
to enhance the system.
In line with revisions to the Whistleblower Protection Act,
we are also developing internal regulations to make it easier for
officers and employees to use the internal reporting system.

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. TheJuroku Bank and Juroku TT Securities have planned and announced a “Customer-oriented Business Operation Policy,” andare working to further improve the quality of their products andservices from a customer-oriented perspective.
The “Customer Protection Management Policy” is aimed atprotecting customers and improving convenience through thefollowing measures.

(1) Giving appropriate explanations and providing information
on products and services to customers(2) Appropriately handling customer requests, consultations,inquiries, complaints, etc.
(3) Appropriately managing customer information(4) Appropriately managing outsourced business(5) Appropriately managing conflicts of interest in order toprevent unduly infringement on the interests of customers

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 loss of
information to external parties with regard to customer information acquired by each group company. As such, we have established the “Information Security Management Rules” to ensure
proper handling of customer information, and also disclose a“Personal Information Protection Policy” (Privacy Policy).
Based on these regulations, we have appointed a Chief
Information Officer as the general manager of the protection of
information assets, and designated responsible divisions according to the type of information assets, as efforts to protect information assets more effectively.

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 stronger international demand for financial institutions to prevent money laundering andfinancing of terrorism.
■ Risk management system
We have positioned the prevention of money laundering andfinancing of terrorism as a top management issue, and we havebuilt an effective risk management system and are working tofurther enhance it.
■ Risk assessment documents
We identify and assess risks we are facing associated with money
laundering and financing of terrorism, and plan “documents
prepared by specified companies (risk assessment documents),”in order to implement mitigation measures commensurate withthe risks.

■ Training for officers and employees
We continuously implement training for officers and employees, so that they can gain deeper knowledge and understanding
regarding measures against money laundering and financing ofterrorism, and improve their 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 a basic agreement for the execution of procedures with the following designated dispute resolution organization. By involving a neutral and fair third-party

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organization, we are appropriately responding to the financial
ADR system, which are procedures intended for simple andswift dispute resolution without resorting to litigation.

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