Compliance System

The Group bases its actions on the social norms and corporate ethics upheld by the AEON Group, ensuring sound judgment and proper conduct at all times. In addition, the AFS (AEON Financial Service) Group Basic Policy for Compliance serves as a shared set of values and the behavioral standards that all officers and employees are expected to follow.

The Company has established the Compliance Regulations and the Compliance Manual to clearly define the laws and regulations to be observed, key points requiring attention, and procedures for responding to any identified violations. Furthermore, regular and ad-hoc training is provided to all officers and employees on compliance, harassment prevention, anti-corruption—including bribery prevention—and other forms of unethical conduct.

The Legal and Compliance Department has been designated as the supervisory division for compliance, responsible for monitoring the compliance status of each Group company and providing necessary guidance and advice.

The Internal Control Committee conducts Group-wide monitoring of compliance, reviews basic policies and regulations, and addresses individual cases as they arise.

The Board of Directors has established a framework for receiving reports and recommendations from the Internal Control Committee and making decisions on key compliance-related matters.

Within the Group, each company has established a whistleblowing contact point accessible to all officers and employees. In addition, the AEON Compliance Hotline and an external reporting hotline are available and widely communicated. Upon receiving a report, the Company investigates alleged illegal acts, violations, corruption including bribery, human rights infringements, discrimination, harassment, and other unethical behavior, and implements corrective measures. The Company also places strong emphasis on protecting whistleblowers, allowing anonymous reporting and prohibiting any disadvantageous treatment stemming from whistleblowing. A dedicated hotline for business partners is also available.

Regarding countermeasures against anti-social forces, the Company has established the Basic Policy for Handling Anti-Social Forces, clearly expressing its commitment to severing and excluding any such relationships. The Company and all Group companies are required to collect and analyze internal and external information related to anti-social forces and report their management status to the Company. The Company monitors these management efforts and provides guidance when necessary.

In view of the growing importance of anti–money laundering (AML) and counter-terrorist financing (CFT) measures in recent years, the Group considers these matters to be critical management priorities. The Group has established the AFS Group Basic Policy for AML/CFT and promotes the development and proper operation of AML/CFT control frameworks at each Group company.

The Company also strengthens its risk assessment and early detection mechanisms for insider trading, bribery, and other corrupt practices to prevent their occurrence. In principle, the provision of entertainment or gifts is prohibited; however, if such activities are unavoidable for legitimate business purposes, they may be exceptionally permitted in accordance with relevant laws and regulations, sound business practices, and social norms, and only after completing prescribed internal approval procedures. Any form of bribery (including facilitation payments) involving public officials or related parties is strictly prohibited without exception.

AFS Group Basic Policy for Compliance

  • 1. Earning Trust

    We are well aware that we have an important social responsibility and public mission as a comprehensive financial group, and we strive to earn unwavering trust from society by acting in good faith and ensuring sound business operations.

  • 2. Respecting Human Rights

    Our officers and employees all treat each other as partners in the workplace, showing mutual respect for one another’s personal characteristics and individuality.

  • 3. Complying Fully with Laws and Regulations

    We shall rigorously adhere to all laws and regulations and our corporate activities shall be fair, honest and aligned with social norms. We shall also be highly ethical and shall sustain and enhance a corporate culture of compliance with laws and regulations.

  • 4. Managing Information

    We shall handle customer data and other critical information with the utmost care, and manage it rigorously to avoid improper use.

    5. Ensuring a Customer-Oriented Approach

    We shall always put customers first and offer reliable, high-quality financial services suited to each customer’s needs. Furthermore, we shall ensure that our actions never harm our customers’ interests in order to benefit the AEON Financial Service Group, and shall refrain from using our dominant position to persuade customers to enter into transactions.

  • 6. Confronting Anti-Social Forces

    We are committed to maintaining a resolute stance against anti-social forces that pose a threat to civil society, and cut off any relations with anti-social forces.

  • 7. The effort for preventing AML/CFT

    We shall establish a management framework to prevent breaches of AML/CFT related laws and regulation,and handle suspicious transactions, when detected, in a timely and proper manner without overlooking.

  • 8. Anti-bribery and anti-corruption

    We shall comply with anti-bribery and anti-corruption laws and regulations applicable in each country, including Japan,and will not directly or indirectly conduct bribery and corruption.

 

Basic Policy for Handling Anti-Social Forces

We have established the following basic policy for precluding damage from anti-social forces in light of our social responsibility and public mission as a comprehensive financial group to eliminate anti-social forces from society, and the absolute necessity of this responsibility and mission in protecting our corporate interests.

The Group has promulgated the following basic policy to prevent damage by anti-social forces, which are groups or individuals that seek economic benefit from the use of violence, blackmail and fraud.

  • 1.  The Group shall have no relationship with antisocial forces.
  • 2.  The Group shall prevent damage from anti-social forces by cooperating with external specialized organizations such as police, the National Center for the Removal of Criminal Organizations, and attorneys in an organized and appropriate manner.
  • 3.  The Group shall not accede to any unfair demands by anti-social forces, and shall address them firmly and resolutely.
  • 4.  The Group shall not provide funds to or engage in secretive transactions with antisocial forces.
  • 5.  The Group shall ensure the safety of executives and employees who address to unfair demands from antisocial forces.

 

 

AFS Group Basic Policy for Prevention of Money Laundering and Terrorist Financing

  • 1. Management commitment

    AEON Financial Service Co., Ltd. (hereinafter referred to as “AFS”) and AFS’s consolidated subsidiary (hereinafter collectively referred to as “AFS Group ”), taking into account its social responsibility as a financial institution, company and corporate group, considers the prevention of money laundering and terrorist financing to be one of its most important management issues.

  • 2. Group commitment

    AFS Group respects and complies with the laws and regulations applicable to each group company in Japan and other countries and regions concerning the prevention of money laundering and terrorist financing.

  • 3.Officers and employees

    All officers and employees in AFS Group shall not engage in money laundering or terrorist financing, nor shall they provide any assistance, including involvement, support or inaction, to those who engage in such activities.

  • 4.Commitment to establish organizational control

    Based on applicable laws and regulations, AFS Group shall develop an organizational structure to prevent money laundering and terrorist financing under the leadership of management.

  • 5.Intra-group and mutual cooperation

    AFS Group shall work together to prevent money laundering and terrorist financing, and shall engage in necessary intra-group and mutual cooperation.

  • 6.Validation and Enhancement

    In accordance with applicable laws and regulations, AFS Group shall endeavor to continuously validate and enhance measures to prevent money laundering and terrorist financing, and establish an effective risk management framework.

  • 7.Training

    In order to prevent money laundering and terrorist financing appropriately, when implementing the program, AFS Group shall foster awareness among officers and employees, ensure necessary knowledge is delivered, and conduct training.