Compliance Related Policies

Compliance Policy

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.
ORIX Group has adopted its Group-wide Compliance Policy, which sets out Group compliance requirements and compliance risk management systems. ORIX Group has also adopted a Compliance Manual which explains the Group’s Compliance Policy and Code of Conduct in an easy -to -understand manner and aims to deepen employee awareness of compliance matters and improve compliance readiness.

Policy on 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 a Group-wide 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.

Policy on 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 our 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.

Policy on Prevention of Money-laundering

ORIX Group endeavors to detect and appropriately manage money laundering risks. In the ORIX Group Anti-Money Laundering Policy, ORIX Group prescribes that in all business transactions of the Group, it will not participate in transactions related to revenue arising from an unlawful act, transactions that provide funds to terrorists, or transactions that do not adhere to sanctions or money laundering regulations of relevant jurisdictions. In addition, each Group company that is involved in business subject to the Japanese Act on Prevention of Transfer of Criminal Proceeds verifies the identity of the other parties to a transaction at the beginning of such transaction and notifies the relevant authorities of any suspicious transactions, as prescribed by the act.

Policy on Prevention of Harm by Antisocial Forces

In ORIX Group’s Policy to Prevent Money Laundering, rules on policies for the prevention of money laundering, terrorism funding, and other related rules prescribe Group-wide rules for the prevention of harm by antisocial forces, including adherence to laws and regulations relating to freezing the assets of international terrorists and to 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.

Policy on Prevention of Conflicts of Interest

The ORIX Group Conflicts 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.

Policy on Prevention of Insider Trading

To prevent insider trading and other unfair business transactions, the ORIX Group Insider Trading Policy sets forth both the basic policy surrounding and non-disclosure of insider information obtained by officers and employees of the Group over the course of their business, the regulation of the trading of shares, as well as other matters.

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.