Basic Policy
The Accordia Group has established the charter of corporate behavior and a code of conduct in the compliance policy which the Group applies to itself. In addition to compliance with laws, the Group realizes it is its social responsibility to conduct corporate activities in accordance with values and ethics required for a member of the society.

Compliance Efforts

1.Functions of the Compliance Committee

As a standing committee under the direct control of the President of the Company, the Compliance Committee deliberates on and approves the compliance organizations and systems of the Accordia Group and makes plans for education and enlightenment aimed at fostering better understanding of compliance among all Group employees.

In addition, the Compliance Committee reports the operating status of the compliance systems to the Board of Directors at least once every three months. The Compliance Committee also cooperates with Audit & Supervisory Board members and the Internal Auditing Department as needed.

The Company has built the system through which approximately 30 compliance advocates assigned to play the role of promoting compliance in their respective divisions.

2.Improvement of the whistle-blowing system (the hotline system) Reporting obligation

Officers and employees share the obligation to report problems involving the compliance policy and all acts that may cause such problems.

They may report such problems and acts to their supervisor, the Compliance Committee or legal advisors the Company designated.

Protection of whistle-blowers

The Compliance Committee investigates matters raised in reports or consultations, takes appropriate measures based on the results of its investigations, and informs whistleblowers on the actions taken.

The Company guarantees that whistleblowers, and officers and employees who cooperated in investigations, experience no disadvantage.

3.Promotion of compliance

The Compliance Committee observes only laws, the Articles of Incorporation of the Company and regulations set by the Company, to prevent the diffusion of judgment criteria.
The Compliance Committee also makes comprehensive efforts to maintain the compliance systems, make officers and employees aware of the need for compliance and require them to observe rules. In addition, the Compliance Committee investigates compliance-related problems it discovered independently or through the whistleblowing system, and takes the measures necessary for addressing those problems.
The Company is publishing the Compliance Handbook, offering training sessions at Head Office and other places of business, and undertaking activities for raising awareness as the occasion demands.