Various Policies

Mitsubishi HC Capital Malaysia Sdn Bhd will continuously contribute to solving social issues through social contribution activities based on its basic business policies, with a focus on “Environment”, “Human Cultivation”, “Welfare and Health”, “Safety and Security”, and “Regional Contribution”.

This “Mitsubishi HC Capital Group Code of Ethics” clarifies fundamental values and ethics to be shared across the Group as the basic guidelines for all the officers and employees, including all persons working in the Group (hereinafter the same shall apply). Every officer and employee of the Group must follow this Code of Ethics.

1. Establishing Trust Fully recognizing the weight of our social responsibility and public mission, we aim to establish the unshaken trust of society through complete information management and sound and proper business activities, including the timely and appropriate disclosure of company information.
2. Customer-Oriented Approach Consistently taking a customer-oriented approach and having good communication, we offer products and services that best meet customers’ needs to obtain customers’ satisfaction and support.
3. Strict Compliance with Laws and Regulations We strictly adhere to all applicable laws and rules (including social, industry, and company rules) and undertake appropriate and sincere corporate activities in line with social norms. We also respect internationally accepted standards as a corporate group operating globally.
4. Respect for Human Rights and the Environment Respecting the personality and character of each other and emphasizing conservation of the global environment that is the shared asset of humankind, we pursue harmony with society.
5. Exclusion of Anti-Social Elements/Money-Laundering Prevention We take a resolute stance against anti-social elements that threaten the order and safety of civil society. In compliance with all applicable laws and regulations related to preventing money laundering, we take every possible measure to block money laundering and terrorist financing.

All the officers and employees of the Group are expected to recognize corporate and own responsibilities for the society to fulfill, respectively. We should adhere to the Code of Conduct below with our strict sense of ethics and consciousness for compliance and perform all day-today activities with integrity.

[Management’s commitment]

Every officer of the Group makes commitments as follows: To take initiatives to observe the Code of Conduct, To undertake business management based on corporate ethics and legal compliance, To build a corporate structure deserving society and people’s trust and expectations to contribute to the development of a healthy economy and society, and To prevent the occurrence of any event or situation violating the Code of Conduct. If such an event or situation occurs, the officers take immediate corrective measures, prevent a reoccurrence, and have all the Group employees completely follow the Code of Conduct.

1. Establishing Trust

(1) Performance of tasks with integrity based on the high ethical value To facilitate fair and highly transparent corporate activities, all the employees perform their tasks assigned based on high ethical value. No one distorts or hides facts, such as by false reporting.

(2) Strict confidentiality and information management No one discloses to a third party any customer information learned at work without a good reason or consent from the customer who is the subject of the information in question. Each employee controls and handles the company’s information assets, including customer information, with great care, strictly adhering to the relevant internal rules.

(3) Appropriate accounting treatment and information disclosure No one conducts an inaccurate accounting treatment or makes false or misleading book entries. We disclose company information based on facts with integrity.

2. Customer-Oriented Approach

(1) Sincere and respectful approach to customers Each employee communicates with customers in a kind, respectful, and sincere manner and keeps a customer-oriented approach not to impair the customer’s interests.

(2) Thorough compliance with the principle of suitability and accountability We offer products and services considered appropriate to the needs and experience of customers. Each employee gives the customer a sufficient explanation of the merits, demerits, and risks before making a deal based on the customer’s consent.

(3) Thorough confirmation of customer’s intent When executing a contract with a customer, each employee must affirm that the customer thoroughly understands the contract’s content and it is based upon the customer’s intent.

(4) Responsible response to stakeholders We provide information with the highest degree of fairness and transparency to customers and diverse stakeholders and responsibly respond to them through various forms of communication, such as dialogue with them.

3. Strict Compliance with Laws and Regulations

(1) Compliance with laws and regulations We perform fair and sincere corporate activities with strict compliance with laws and rules at the local and international levels as a corporate group operating globally. All employees aim to maintain and enhance high ethical standards and a corporate culture that respects laws and rules.

(2) Prohibition of unfair transactions

① No employee solicits transactions that use a position of superiority over customers. Also, no one engages in actions that harm any customer’s benefits for the sake of the business interests of its own company or Group companies.

② No employee engages in activities to generate own profits based on information learned at work. In particular, no one can trade stocks or securities nor make similar transactions based on non-public material facts that could influence the stock price of any Group company or business partner. When you possess information falling under the category of material facts, you should handle such information with the utmost caution.

③ No employee engages in activities that undermine the interests of another Group company for the sake of its own company’s gains. Each employee pays utmost care not to engage in prohibited activities when handling customers’ non-public information or conducting transactions with the parent company or another Group company.

④ To maintain fair and unfettered competition, every employee must follow fundamental rules for business transactions, including competition laws both at home and in other countries, and undertake activities strictly adhering to laws and sound corporate ethics.

⑤ No employee permits nor engages in any bribery or corrupt practices. Also, no one offers or accepts a gift or entertainment beyond the bounds of socially accepted limits, and that becomes a hotbed of corruption. Further, we build healthy relationships with governmental and administrative agencies, politicians, and officials to maintain transparency.

(3) National security

For maintaining international peace and security, we are required to block the flow of money to countries, terrorists, and other suspicious persons who may engage in activities of concern that threaten the safety and security of our home country and international society. Also, we must prevent the above persons from acquiring weapons, goods, and technologies that can be diverted for use in military applications. For that purpose, we cooperate with the international society to control the export and other transactions, and none of us gets involved in such parties.

(4) Respect for intellectual property rights

We appropriately protect the rights in intellectual properties created by the company (patents, trademarks, copyrights, and other similar rights) and respect the intellectual property rights held by third parties. In addition, each employee recognizes the brand as an essential corporate resource and strives to maintain and increase the value of the Group brand.

(5) Prohibition of mixing business with private affairs

Every employee makes value judgments from the standpoint of fairness and equity at all times, regardless of the interests involved. Each employee must draw a line between business and private matters and never makes private use of company assets.

4. Respect for Human Rights and the Environment

(1) Respect for human rights

Consistent with the fundamental spirit of respect for humanity, no employee engages in any discriminatory action or human rights violation on the ground of gender, sexual orientation, age, nationality, race, ethnicity, political opinion, beliefs, religion, social status, lineage, illness, or disability.

(2) Fostering a comfortable work environment

We aim to realize flexible working styles, respect diversity in values, and develop a work environment and systems that encourage employees to exercise their most entire abilities. In this regard, every employee keeps in mind that sexual, power, or any other harassment hurt people’s dignity as human beings. Such an action must be eliminated from the workplace.

(3) Understanding global human rights issues and action to take

Given international standards on human rights, every employee works to respect and not infringe the rights of all persons involved in business activities and create relationships of mutual understanding.

(4) Consideration for the environment

Attaching importance to the conservation of the global environment, every employee pursues harmony with society.

5. Exclusion of Anti-Social Elements/Money-Laundering Prevention

(1) Exclusion of anti-social elements

Every employee must resolutely address any anti-social element, such as organized crime groups (boryokudan)and corporate racketeers (sokaiya).

(2) Money-laundering prevention

Every employee pays heed to the possibility that funds transacted through financial institutions are used in various types of crime and terrorism. To prevent money laundering, each must follow, and never skip, the required step to verify a customer’s identification; if you find any suspicious transaction that may fall into crime, you should not condone and appropriately address it.

In performing their respective duties, all officers and employees of the Mitsubishi HC Capital Group (“Group”) shall comply with competition laws and related laws and regulations in Japan and other related countries and regions (“Competition Laws”) according to the principles below. In compliance with the Competition Laws and through fair and free competition, the Group shall contribute to boosting the world economy and its sound development.

1. In commercial transactions, whether inside or outside the country, no one shall conduct any acts impeding fair and free competition in the market. Those acts include private monopoly, cartel, bid-rigging, and other practices which restrain competition. Each officer and employee shall strictly refrain from conducting activities that may raise those suspicions.
2. No one shall exchange information or agree with competitors on trading conditions, client lists, and other matters that may affect competition. Each officer and employee shall limit contacts with competitors to the cases imperative. When contacting competitors, the officer or employee shall properly make and preserve the record of the background and communications made.
3. Each company of the Group (“Company”) shall establish the necessary internal structure to comply with Competition Laws by setting auditing process, providing training, and stipulating relevant rules and procedures.

In addition, to comply with the Competition Laws and ensure fair and free competition in the Group’s businesses, the Company shall ask the cooperation from its suppliers and business partners involved in the Group’s businesses to comply with Competition Laws and understand the Group’s principles.

In performing our respective duties, all officers and employees of the Mitsubishi HC Capital Group (“Group”) shall comply with laws and regulations for preventing bribery and corruption, applicable in countries and regions where the Group performs businesses (“Anti-Corruption Laws”) according to the principles below. The Anti-Corruption Laws include the Penal Code, the National Public Service Ethics Act, and the Unfair Competition Prevention Act (all in Japan), the Foreign Corrupt Practices Act (the U.S.), the Bribery Act (the U.K.), and the Bribery & Corruption Laws and Regulations (China). The Group prohibits all officers and employees from offering and receiving any bribe because those acts cause suspicions or distrust from society.

1. No one shall conduct corrupt practices in any form, including embezzlement and obstruction of justice.
2. Each officer and employee shall fully understand the laws and regulations related to public officials or equivalent persons in Japan and foreign countries. No one shall offer any entertainment or gift that may cause suspicions and distrust from society, nor any money or other benefits to profit illegally.
3. Whether inside or outside the country, no one shall receive any entertainment or gift beyond common sense and sound commercial custom from a supplier or business partner.
4. No one shall demand any supplier or business partner to offer private profit by exploiting its position or abusing its authority in the company.
5. Each company of the Group (“Company”) shall establish the necessary internal structure to comply with Anti-Corruption Laws inside and outside the country by setting auditing process, providing training, and stipulating relevant rules and procedures. In addition, to eliminate any bribery and corrupt practices and ensure fair execution in the Group’s businesses, the Company shall ask the cooperation from its suppliers and business partners involved in the Group’s businesses to comply with Anti-Corruption Laws and understand the Group’s principles.

The Mitsubishi HC Capital Group (“Group”) is striving to enhance our structure and system to prevent money-laundering and terrorist financing (collectively, “MoneyLaundering”) and eliminate any trade relationship with persons (individuals and entities) subject to sanctions, which violates economic sanctions of the United Nations, international organizations, and individual countries.

1. We shall comply with all applicable laws and regulations for preventing MoneyLaundering in and outside the country.
2. Recognizing Money-Laundering prevention as one of our critical challenges, the top management of each company of the Group shall proactively and aggressively tackle this issue.
3. With regard to persons subject to sanctions identified under the UN Security Council’s resolution and by OFAC or other regulatory authorities, we shall check and screen every contemplated transaction appropriately according to applicable laws and regulations.
4. Taking the risk-based approach, we shall appropriately manage customers and transactions to address the risks in the Money-Laundering.
5. We shall monitor all transactions continuingly, and if any of them is suspected of being involved in Money-Laundering, we shall report it to relevant authorities as required.
6. We shall provide training programs continuously to maintain and improve awareness about Money-Laundering prevention of the officers and employees of the Group and their capability to deal with those transactions.
7. We shall ensure the appropriate business operation for Money-Laundering prevention by conducting regular internal audits and other processes.

Mitsubishi HC Capital Malaysia Sdn Bhd positions information security and cyber security as management issues of the utmost importance.

As such, we are aware of our societal duty to protect the information assets in our possession, including those of our clients, from various security threats, and through the compliance of our officers and employees with the following Information Security Policy we have established, we make every effort to maintain and enhance the confidentiality, integrity, and availability of our information assets.

1. All individuals engaged in our business have an obligation to uphold security measures regarding information assets, and shall without respite undertake information security practices which conform with security control measures organizationally, individually, physically and technically.
2. We shall apply information security measures continuously and proactively, so as to realize “the quantitative expansion, sharpened accuracy, and further enhancement of added value” to the information assets in our possession, to work for the strategical utilization of information assets, and to offer and return useful information to our clients.
3. Together with instituting preventative measures against serious information security incidents that we expect, in the event such an incident does actually occur, we shall disclose that fact in a timely and appropriate manner, and move to bring the situation quickly under control using our companywide response framework. Furthermore, we shall investigate the causes of the incident and takes steps to prevent its reoccurrence.
4. Together with working to enhance the information-security awareness of all individuals engaged in our business, we shall install educational and training programs regarding information security.
5. As with other laws and ordinance, all individuals engaged in our business shall comply with laws, ordinances, guidelines, standards, etc. regarding information security

Human Rights Policy

We at the Mitsubishi HC Capital Group recognize that conducting business with the utmost respect of human rights is a major challenge, and we will fulfill our responsibilities in this matter across all our business activities.

Through dialogue and collaboration with relevant stakeholders, we will exclude exploitative labor practices such as modern slavery, forced labor, human trafficking, and child labor, from the businesses and supply chains of the Mitsubishi HC Capital Group.

We will address human rights risk relevant to our businesses earnestly and appropriately to fulfill our obligations to respect human rights in a manner expected of global companies, aiming to realize a society that respects human rights.

We will realize a flexible working style and respect a diversity of values, and strive to create a comfortable working environment in which each and every individual can demonstrate their maximum potential.

1.Global Standards to be Respected and Upheld
We respect the human rights described in the Universal Declaration of Human Rights, the International Bill of Human Rights (International Covenant on Civil and Political Rights and the International Covenant on Economic Social and Cultural Rights), and the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work which stipulates core labor standards.

Furthermore, based on the Guiding Principles on Business and Human Rights, as a corporate group that operates its businesses globally, we will uphold and respect internationally recognized standards relating to human rights, and concurrently comply with associated laws and regulations. Where there is a contradiction between internationally recognized standards, or the like, and the laws and regulations of a country or region in which we operate, we will seek methods to maintain respect for the international standards.

2.Role
This human rights policy complements the Mitsubishi HC Capital Group Code of Ethics and Code of Conduct. The policy clarifies our commitment to conduct business activities while fulfilling our responsibilities to respect human rights. As such, the policy has been approved by the Executive Committee and reported to the Board of Directors.

3.Scope of Application
This human rights policy will apply to all persons engaged in duties at any Mitsubishi HC Capital Group company. Additionally, we will actively require customers, partners, and suppliers to uphold and practice this human rights policy. Furthermore, if the measures we take to ensure this are deemed insufficient or inappropriate, and they are confirmed to contribute to violating human rights, we will take the appropriate action to rectify these measures.

3.Human Rights Due Diligence
We will abide by the Guiding Principles on Business and Human Rights and create a human rights due diligence framework and continue to make efforts to evaluate and identify human rights risks in our business activities and supply chains, and to prevent and mitigate such risks.

4.Relief Measures, etc.
In addition to not violating human rights ourselves in our business activities and services we provide, we will take action to ensure our stakeholders, including customers, partners and suppliers do not violate human rights. Furthermore, if it is determined that we have caused a human rights violation, or have engaged in or contributed to such a violation, we will act to provide relief for and rectify the situation.

Specifically, based on the internal reporting system, we will make efforts to prevent improper actions on a global basis. Furthermore, we will make clear that we will not tolerate such practices as forced labor or child labor, and make efforts to create relief and rectification mechanisms in anticipation of risks of incidents present at our company and across the supply chain.

6.Communication, Dissemination, Education and Awareness-Raising
We will communicate, disseminate, and provide appropriate education, awareness-raising and talent development so that this human rights policy is incorporated in all business activities.

7.Dialogue with and Information Disclosure to Stakeholders
We will hold dialogue and discussions with relevant external stakeholders on measures for potential and real impacts on human rights. Furthermore, we will disclose our efforts that are based on this human rights policy in our corporate website, etc., and work to obtain the understanding of stakeholders.

8.Governance and Administration Framework
Determination of the necessity of revisions, etc. to this human rights policy will be subject to approval by the Executive Committee and then reported to the Board of Directors.