Compliance Framework

Compliance Basic Policy

ORIX Group has positioned compliance as one of our most important management issues, striving to build an effective compliance structure alongside a corporate culture that values high ethical standards, and good faith, fairness and transparency in all corporate activities.

Compliance Structure

ORIX Group reports important compliance matters to the Executive Committee and the Audit Committee of the Board of Directors. The compliance department, under the oversight of the Executive Officer responsible for compliance, coordinates with the compliance officers appointed at subsidiaries and business units and promotes compliance activities across the Group.

Annual Compliance Plan

In order to prevent and mitigate compliance risks, ORIX Group establishes annual Group-wide compliance initiatives each fiscal year.
Each Group subsidiary and business unit conducts risk assessments pursuant to these compliance initiatives, and formulates an annual compliance plan for its own business in accordance with such risk assessments. The compliance department reviews the appropriateness and effectiveness of the individual annual compliance plans. Following such review, each annual compliance plan is then put into practice at each respective subsidiary or business unit.
At the end of the relevant period, a status report is filed and the content of this report is reviewed by the compliance department.

Compliance Training and Awareness Activities

At ORIX Group, members of the senior management, including the CEO and the Executive Officer responsible for compliance, distribute messages to the officers and employees of ORIX Group with the objective of enhancing and reinforcing compliance awareness. The compliance department conducts compliance training and awareness activities, including on-site and off-site training sessions, the sharing of compliance violation cases, and the dissemination of alerts and reminders.

Compliance Training

In order to promote the understanding of the importance of compliance to the officers and employees of ORIX Group and translate that awareness into their day-to-day practices, compliance training is conducted annually by way of e-learning, group training and on-site courses. Additionally, we also provide training programs tailored to the officers’ or employees’ years of service and job functions. Training for managers incorporates specific examples of harassment and ways in which to address such situations.
The e-learning program offered to the officers and employees of ORIX and its domestic and overseas group companies is structured around the Core Compliance Values and Guiding Principles defined in the ORIX Group Code of Conduct. The content focuses on high-risk areas and key regulations, including anti-bribery and anti-corruption, conflict of interest prevention, anti-money laundering, sanctions compliance, insider trading prevention, respect for human rights, and personal data protection. The training curriculum is updated annually based on actual compliance violation cases and incident analyses. In the fiscal year ended March 2025, approximately 37,000 employees across Japan and overseas completed the e-learning program.

Compliance Awareness Activities

For the officers and employees of domestic group companies, we conduct compliance awareness surveys and workplace environment interviews. We have also published a Harassment Prevention Handbook to equip the officers and employees with the knowledge to prevent harassment and encourage appropriate behavior. In addition, we promote awareness using a Casebook of Gray-area Harassment Cases, which is based on actual consultations received via the compliance hotline and feedback from workplace interviews. To ensure awareness of the internal whistleblower system, new employees receive a card with the compliance hotline contact information during onboarding training.
For overseas group companies, we deliver awareness messages, tailored to current topics and circumstances, through each company’s compliance officer or equivalent. These messages include information on internal whistleblower system and aim to foster awareness and behavioral change among the officers and employees both in Japan and abroad.

Strengthening the Compliance Promotion Framework

In Japan, we regularly hold liaison meetings with compliance promotion officers appointed at each group company and headquarters division, and also conduct individual meetings as needed. Overseas group companies submit quarterly compliance reports, which are analyzed by the compliance department. In addition, we take various actions including online meetings with compliance officers at the overseas group companies to promote the understanding of ongoing compliance measures and improve overall knowledge regarding compliance.
In addition, officers at the compliance department continuously endeavor to build a library of the latest market practices and information related to compliance and acquire skills for implementing compliance by liaising with external organizations and undergoing external training courses.

Surveys and Monitoring

The compliance department conducts employee surveys on workplace environment and compliance awareness, and reflects the results of such surveys in compliance measures.
In addition, in the event of a potential compliance violation, the compliance department conducts an investigation, provides instructions on corrective actions, and provides recommendations to the Human Resources Department on disciplinary action to take against violators, as appropriate.

Internal Whistleblower System / External Whistleblower System

The ORIX Group has established an internal whistleblower system and an external whistleblower system.