Group Anti-corruption Policy

We at Concordia Financial Group maintain fair and sound relationships with all stakeholders and never engage in corruption^(*).

The Group adheres to applicable laws, regulations, and rules in countries and regions where it conducts business and undertakes honest and fair corporate activities that do not violate social norms.

The Group does not engage in bribery or any other corruption that targets public officials or any stakeholder related to the Group's business whether in Japan or overseas, directly, or indirectly.

The Group provides appropriate training for executives and employees to ensure that this policy is adhered to.

The Group strengthens its internal control system and works to prevent corruption by establishing rules, properly accounting for items, undertaking appropriate management, and implementing other measures.

The Group maintains a system so that executives and employees can report and make internal notifications regarding corruption and corruption (including potential corruption) to their superiors, the department that manages and provides guidance related to compliance, and other parties. In addition, the Group thoroughly protects whistleblowers so that executives and employees who report or make internal notifications are not subject to unfavorable treatment.
The Group promptly investigates and takes steps such as imposing disciplinary measures on executives and employees who are found to have caused the violation if an act that violates or may violate laws, regulations, this policy, or other items is discovered. In addition, the management regularly receives reports on the status of efforts to prevent corruption.