Tokai Tokyo Financial Group's Ethical Code of Conduct

We, the employees and officers of Tokai Tokyo Financial Group* (hereinafter referred to as “the company”), shall behave in observing the ethical code of conduct of the company that is set below in accordance with the Basic Compliance Policy of the same.

1. Observance of laws, regulations and rules

We shall correctly understand and observe all the applicable laws, regulations and rules and perform our duties honestly based on social common sense.

2. Performance of duties with integrity and fairness

We shall remain conscious of the social mission that we are expected to fulfill and we shall honestly achieve duties as the business group that assumes the role as its core operation in financial and capital markets.

3. Establishment of trust

We shall offer the products, services and information that fit to the need and profile of our customers, and establish solid relationship of trust with customers.

4. Control of confidential information

We shall strictly control all the confidential information and business secrets of customers that become known to us in the course of business. We shall not use such information and secrets except for the purposes established in laws or our policies regarding the protection of customer information and shall prevent the leakage of them to the third parties.

5. Active and appropriate information disclosure

We shall exert ourselves to promote communication widely with society while disclosing our management policy and corporate data actively and suitably.

6. Prohibition on mixing up work and private matters, and on causing conflict of interest

We shall act with integrity not to cause conflict of interest between anyone of us as private person and either the company or customer, between the company and customer, or between any particular customer and the rest of the customers, while bearing clearly in our minds the distinction between business matter and personal one.

7. Prevention and strict administration of foul or illegal act

We shall respect the culture of discipline and shall not commit any foul or illegal act. Should any such act be noticed, we shall take swift and strict action for solution without overlooking or hiding it.

8. Respect for human rights

We shall respect human rights and shall not commit discrimination or harassment of any kind.

9. Environmental protection and social contribution

We shall take seriously the need to protect global environment and strive to make social contribution as good citizen.

10. Confronting anti-social group

We shall always resolutely confront any anti-social group that threatens the order and safety of civil society.

11. Prevention of Corruption and Bribery

We will not get involved in any form of corruption violating generally accepted social norms such as bribery to public officials and other third parties including such acts as entertaining, giving and receiving gifts, collusion, embezzlement, and breach of trust.