**
**Exhibit 11.1**

[Translation] 

**Compliance Rules**

Article 1 (General Provision) 

These Rulesestablish the Compliance rules of the Company. 

Article 2 (Definitions) 

For the purposes of these Rules, “**Compliance**” means complying with laws, regulations, company rules, and corporate ethics(“**Laws**”). 

Article 3 (Management Policy) 

In accordance with the terms of the Ethics Charter in the separately-established Compliance Handbook, the Company’s basic managementpolicy shall be Compliance that is primarily composed of each of the items listed below, and the Company shall comply with said policy: 

 
 (1)
Compliance with Laws (including the Payment Services Act and other relevant laws and regulations, and theself-regulatory rules established by Japan Payment Service Association) 

 
 (2)
Social responsibility 

 
 (3)
Respect for human rights and ban on discrimination and sexual harassment 

 
 (4)
Fair transactions 

 
 (5)
Ensuring the reliability of financial reporting 

 
 (6)
Disclosure of corporate information 

 
 (7)
Creation of work environment 

 
 (8)
Separation of business and personal affairs 

 
 (9)
Information management 

 
 (10)
Devotion to personal development 

 
 (11)
Dealing with antisocial forces 

Article 4 (Implementation of Compliance System) 

 
 1.
The department responsible for Compliance shall be the General Affairs Department. 

 
 2.
The internal audit manager shall conduct an internal audit in accordance with the Internal Audit Rules todetermine whether or not the Company is complying with the management policy provided for in the preceding Article. 

Article 5(Employee’s Responsibilities) 

An employee shall faithfully comply with Laws based on the basic policy set forth in the precedingArticle and shall carry out his or her work with the good sense and responsibility of a businessperson as well as a member of society. 

Article 6(Prohibited Employee Conduct) 

An employee shall not commit any of the following acts: 

 
 (1)
An act that violates any Laws 

 
 (2)
Instructing or instigating another employee to commit an act that violates any Laws 

 
 (3)
Turning a blind eye to an act committed by another employee that violates any Laws 

 
 (4)
Accepting business entertainment or favors from a business partner 
**

Article 7 (Reporting Obligation) 

If an employee becomes aware that another employee is committing an act that violates the preceding Article, the employee shall promptly reportto the Company. 

Article 8 (Disciplinary Action, Etc.) 

The Company may take disciplinary action or the like in accordance with the Work Rules against an employee who has violated Article 5. 

Article 9 (Limitation of Exclusion of Liability) 

An employee shall not be exempt from liability with regard to acts that violate any Laws and were committed by the employee for the followingreasons: 

 
 (1)
The employee lacked correct knowledge regarding the Laws 

 
 (2)
The employee lacked the intent to violate the Laws 

 
 (3)
The employee committed the act at the instruction or instigation of another employee 

 
 (4)
The employee committed the act in pursuit of the Company’s interests 

Article 10 (Prior Consultation) 

If an employeeis uncertain whether or not his or her own action or decision violates any Laws, the employee shall consult in advance with the General Affairs Department, which is in charge of Compliance. 

Article 11 (Compliance Training) 

The Companyshall hold training workshops as necessary for the following purposes: 

 
 (1)
To increase awareness regarding Compliance 

 
 (2)
To provide the correct knowledge regarding Compliance 

Supplementary Provisions 

These Rules shall go into effect onJanuary 1, 2008. First edition 

Revised on December 12, 2013 

Revised on February 25, 2015