Basic Stance

DBJ believes compliance is at the heart of our corporate management and also, together with our business model and strategy, form two sides of the same coin. In addition, compliance risk must be properly managed in our organization’s overall governance and control structure in implementing our corporate philosophy based upon societal demand and expectation. We feel that compliance is achieved when each and every employee and executive actively engages in their work with compliance foremost on their minds.

Business Conduct and Compliance

The DBJ Group is a unique financial group which provides financing, investment, consulting and advisory services, asset management, and other various financial services. While reinforcing collaboration within the Group, DBJ creates proactive and advanced business and core strategies.

As a financial institution, DBJ’s first duty is to address the legitimate and logical expectations of its customers. Even in its initiatives in Crisis Response Operations and Special Investment Operations, DBJ carries out customer-oriented business conduct. DBJ conducts operations in compliance with all laws and regulations through appropriate function of the Three Lines of Defense to mitigate conduct risk. To achieve our corporate philosophy, all employees and executives engage in work while pursuing both economic and social value in accordance with our Action Guidelines, the basis for decisions and behavior by Group employees and executives.

Compliance Framework

The DBJ Group has determined basic policies and rules for compliance, creates and distributes compliance manuals for employees and executives to follow, and conducts training and explanatory sessions to spread awareness of compliance. Each fiscal year, all DBJ Group companies design compliance programs and evaluate and implement concrete compliance action plans tailored to their particular business characteristics.

DBJ has established relevant departments that report on the status of compliance with laws and regulations to the Executive Committee and Board of Directors. Compliance officers have been assigned to each department to ensure compliance by employees and executives at each department.

Compliance officers are in charge of internal management as internal managers and function as contact points for reporting compliance matters while centralizing such matters within their departments. Through compliance officers, relevant departments in charge of compliance provide advice and guidance to each department when necessary, with the aim of ensuring compliance. In order to quickly discover and resolve any compliance matters, DBJ has set up an internal reporting channel to relevant departments and Audit & Supervisory Board members, which circumvents the normal reporting channels in organizational structures. DBJ has also created an external reporting channel through a law office.

Internal Reporting System

Internal Reporting System Internal Reporting System

Compliance Practices

The DBJ Group believes compliance with laws and regulations is essential for maintaining the customer’s trust and ensuring the soundness and fitness of its business operations. We recognize compliance as one of our most important management priorities. Employees and executives are keenly aware of DBJ’s public mission and social responsibilities, as well as initiatives to mitigate conduct risk. We fairly engage in our business in good faith and in compliance with not only all laws, regulations and rules but also social norms, for supplying risk capital or pioneering initiatives.

Measures to Prevent Insider Trading

In the provision of various financial services including investments and loans, the DBJ Group believes that complying with insider trading regulations is essential to maintaining trust. For example, we have created rules for employees and executives to follow when trading in securities. Moreover, DBJ has established systems for preventing insider trading, as demonstrated by our formulation of strict procedures for confirming and executing transactions in our investment operations. In research operations, we manage and handle corporate information carefully.

Elimination of Anti-social Forces

The DBJ Group has a basic policy of not having any relationships with anti-social forces, and resolutely coping with them in cooperation with the police and other external institutions. Our rules and training programs have thus been carefully crafted to prevent relationships with anti-social forces. DBJ thoroughly assesses and manages this risk for each project and takes appropriate measures when necessary while communicating with special external institutions.

Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Measures

As it develops business worldwide, the DBJ Group understands the importance of taking measures to prevent international money laundering and the financing of terrorism. In addition to adhering to laws and regulations, DBJ takes extra measures to prevent global financial crimes based on the risks involved. DBJ has systems in place to ensure that proper procedures are taken, periodically conducts risk management operations, and thoroughly trains its employees and executives. We also strive to continuously improve this structure by evaluating a variety of measures.

Customer Protection Management

The DBJ Group has identified “the customer’s perspective” as a key element of its Action Guidelines. By taking the customer’s perspective, we endeavor to improve customer protections and convenience. Furthermore, we have created basic policies for customer protections from the standpoint of ensuring the soundness and fitness of our operations. Accordingly, we have taken a management posture for ensuring customer protections. Employees and executives provide support to customers by explaining and providing appropriate and adequate information to them.

Management of Conflicts of Interest

When providing customers with financing, investment, consulting and advisory service, asset management, and other financial services, the DBJ Group applies systems for identifying and managing transactions in order to prevent conflicts of interest and act fully in the interests of customers, based on the transaction type and degree of risk. When obtaining consent from customers for a transaction, we provide them accurate and appropriate information.

Management of Customer Information

In addition to following legal requirements and rules about sharing customer information among Group companies, preventing insider trading, and managing conflicts of interest, the DBJ Group has created management structures and systems for handling customer information, with particular attention paid to minutiae in order to maintain the customer’s trust.

DBJ has created and disclosed the Declaration on Personal Information Protection for protecting personal information.

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