Basic Policy on Customer-Oriented Business Conduct
As a “Type II Financial Instruments Business Operator,” Mitsubishi HC Capital Inc. (the“Company”) shall thoroughly practice customer-oriented business conduct in the courseof implementing Type II Financial Instruments Business, to this end adhering to its Codeof Ethics and Code of Conduct.
1. Customer-Oriented Business Conduct
 Each employee shall communicate with customers in a kind, respectful and sincere
manner and keep a customer-oriented approach not to impair the customers’ interests.
 All the officers and employees shall remain fully aware of the significance of theirsocial responsibilities, and shall maintain fairness, impartiality and integrity while
acting upon the highest professional ethics, thereby practicing customer-oriented
business conduct in a thoroughgoing manner.
 Through employee training and other means, we shall ensure that the Code of Ethics,
Code of Conduct and the Basic Policy on Customer-Oriented Business Conduct are
thoroughly embraced by our officers and employees to serve as guidelines for their
judgment and action.
2. Customer-Oriented Approach to the Provision of Services
 We shall offer products and services considered appropriate to the needs andexperience of customers.
3. Customer-Oriented Approach to the Provision of Information(1) Customer-Oriented Provision of Information
 We shall provide customers with an easy-to-understand, meticulous and sufficient
explanation with regard to benefits, disadvantages, opportunities and risks arisingfrom their transactional choices. By doing so, we shall ensure that no deal would besigned without the consent of customers who are fully informed about these factors.
(2) Meticulous Provision of Information to Ensure Customers’ Understanding ofProducts In the course of product proposals, we shall provide customers with sufficient
information by using easy-to-understand expressions to explain features of products,
risks associated with them, service fees required and other essential factors.
(3) Enhancement of Transparency regarding Service Fees, etc. to Help Customers Make
Optimal Investment Decisions

 We shall keep our service fee systems transparent to our customers, to this end

offering a meticulous explanation of such fees to help them make well-informed
investment decisions.
(4) Appropriate Incentivization for Employees We shall develop education systems to properly train employees in charge of sales toensure our sales activities serve the interests of our customers and fulfill their needs
in a comprehensive manner.
 Having positioned compliance as an important management matter, we shall develop
a structure to ensure appropriate employee incentives, as well as a proper governancestructure, to pursue the customer’s best interests.
4. Appropriate Management of Conflicts of Interest in the Course of Engagement in
Type II Financial Instruments BusinessWe shall accurately assess potential conflicts of interest that may arise fromtransactions with our customers. In cases where this possibility exists, we shallprovide the customer involved with prior notification and otherwise manage theconflict of interest accompanying transactions in an appropriate manner.

Established: April 1, 2021