Compliance Related Policies

ORIX Group has established group-wide regulations on compliance and has prescribed and promoted rules and codes of conduct designed to keep officers and employees of ORIX Group in strict adherence to legal requirements, internal rules, and generally accepted standards of business conduct.
We adopted the ORIX Group Compliance Governance Framework Policy, which sets out Group compliance requirements and compliance risk management systems.
We aim to deepen employee understanding and awareness of compliance matters by establishing and promoting various compliance-related internal rules and regulations. These regulations are established in accordance with our Code of Conduct, which outlines all of the basic guidelines that all ORIX Group employees must follow.

Prevention of Corruption

ORIX Group maintains the highest ethical standards, adheres to all applicable laws, and endeavors to ensure that its officers, employees, representatives and agents do not perform any acts over the course of business that are or may appear to be inappropriate. ORIX Group has adopted the ORIX Group Global Anti-Corruption Policy, which prohibits any inappropriate transfer of money regardless of circumstances or whether the other party to the transaction is a government employee, employee of a private company, or any other individual.

Giving and Receiving of Entertainment and Gifts

ORIX Group prescribes rules governing entertainment and gifts (whether given or received) in relation to government officials or the Group’s business partners in the ORIX Group Global Anti-Corruption Policy. ORIX Group prohibits the provision of entertainment or gifts as a means to obtain any unfair gain, and endeavors to conduct all transactions with government officials or business partners in a fair and transparent manner.

Prevention of Money Laundering

ORIX Group has positioned anti-money laundering, countering the financing of terrorism, counter-proliferation financing (AML/CFT/CPF), and sanctions compliance as key management priorities. It is the policy of ORIX Group to refrain from engaging in any of the following transactions:

  • Financial transactions involving proceeds derived from unlawful activities;
  • Transactions that finance terrorist activities or the proliferation of weapons of mass destruction; and
  • Transactions with individuals, corporations, or other entities that have been designated as prohibited counterparties by the governments or other regulatory authorities of any country or region in which ORIX Group conducts business, as well as transactions with persons residing in or located within any countries or regions that are designated as a prohibited jurisdiction.

ORIX Group adopts a risk-based AML/CFT/CPF and Sanctions Compliance Program that is designed to adhere to applicable legal and regulatory requirements and align with differing risks across the jurisdictions and sectors in which we operate. Our program consists of, among other things:

  • A clear and ongoing commitment from senior management, with reporting to the Board of Directors on matters of significant importance;
  • The assessment of relevant AML/CFT/CPF and sanctions risks, and the development of appropriate risk-based mitigation measures;
  • The implementation of customer due diligence (CDD) procedures, including verification of beneficial ownership where applicable or required by law;
  • Enhanced due diligence for high-risk jurisdictions, industries, and transactions;
  • Due diligence on politically exposed persons (PEPs) where appropriate;
  • Risk-based ongoing customer due diligence and transaction monitoring;
  • The maintenance of accurate records as required by law (in Japan, records are generally retained for seven years);
  • An independent audit function that assesses compliance with the AML/CFT/CPF and Sanctions Program;
  • AML/CFT/CPF and sanctions compliance training for appropriate personnel; and
  • Investigations and reporting of suspicious transactions in accordance with applicable laws and regulations.

Prevention of Harm by Antisocial Forces

The ORIX Group Global Anti-Money Laundering Policy and related rules prescribe Group-wide rules for the prevention of harm caused by antisocial forces, including adherence to laws and regulations relating to the freezing of assets of international terrorists, and the prevention of money laundering. The ORIX Group rules related to antisocial forces aim to minimize any damage or loss caused to the Group business in addition to fulfilling our basic responsibility to society to minimize the influence of antisocial forces.

Protecting Personal Information

The ORIX Group Rule Regarding the Handling of Personal Information outlines the rules and management procedures for the collection, storage, use, and sharing of personal information, as well as training for officers and employees and monitoring of handling practices. We stringently follow the personal information protection laws of each country, and work to secure appropriate handling of personal information.

In accordance with the above Rule and our Information Security Management Rules, ORIX Group is committed to the proper management of information assets, including personal information, and to maintaining information security (for details, please refer to Information Security). In addition, to ensure the appropriate handling of information assets, we conduct self-inspections within each department and audits by our Internal Audit Department. Furthermore, when any inappropriate handling of information assets occurs, including information leakage, loss, damage, or unauthorized use, the matter is promptly reported to the relevant departments in accordance with our Incident Response Rules, and corrective actions are taken, including measures to minimize damage and prevent recurrence (for details, please refer to Incident Management System).

Prevention of Unfair Transactions

ORIX Group endeavors to always engage in fair and free competition. The ORIX Group Compliance Rules Relating to the Prevention of Unfair Transactions are designed to prevent ORIX Group from conducting business transactions involving any unfair business practices.

Prevention of Insider Trading

To prevent insider trading, the ORIX Group Global Insider Trading Policy sets forth both our basic policy on management of material non-public information obtained by officers and employees of the Group over the course of their business and the regulation and restrictions on the trading of any listed securities.

Prevention of Conflicts of Interest

The ORIX Group Global Conflict of Interest Policy prescribes the Group standards for avoiding conflicts of interest and sets out appropriate management of an actual or potential conflict of interest for an officer or employee of the Group.