Basic Policy on Internal Control Systems

The Company recognizes that enhancing corporate governance and establishing internal control systems are essential to increasing corporate value and fulfilling its social responsibilities, and regards them as important management priorities.

Development Status of Internal Control Systems

1. Framework for Ensuring that Directors and Employees of the Company and its Group Companies Perform Their Duties in Compliance with Laws and the Articles of Incorporation
   
   The Company has established a Compliance Committee as part of its compliance framework and has defined measures to prevent violations of laws and regulations within the Company and its Group Companies, as well as procedures for responding to and remedying such violations. The General Administration Division, which serves as the secretariat of the Committee, is responsible for developing and operating the compliance framework and strives to enhance compliance knowledge and awareness among officers and employees through training programs and the preparation and distribution of manuals. In addition, the Company and its Group Companies have established a whistleblowing system that enables their officers and employees to report directly to their compliance departments, external attorneys, or the Company’s Audit and Supervisory Board Members.


2. Framework for Managing Risks of Losses of the Company and its Group Companies
   
   The Company has established a Crisis Management Emergency Response Headquarters, headed by the President and CEO, to respond to unforeseen threats to business operations, such as wars, terrorism, and major natural disasters in Japan and overseas. When a crisis is deemed to have occurred within the Group, the Company promptly establishes an appropriate response framework. For risks that may arise in the ordinary course of business operations, the Company has established various risk management committees by purpose and function, including committees relating to internal control, product and technical information, management information, and safety, such as the Legal Affairs Committee, the Confidential Information Management Committee, the Credit Management Committee, and the Disaster Management Committee. Through these committees, the Company strives to enhance its internal control systems by ensuring compliance with applicable laws, the Company’s Articles of Incorporation, and internal regulations, while strengthening its risk management framework.


3. Framework for Retaining and Managing Information Related to the Performance of Duties by Directors
   
   In accordance with applicable laws and internal regulations, the Company records and retains information related to the performance of duties by directors in written or electronic form and ensures that directors and Audit and Supervisory Board Members may access such records at any time.


4. Framework for Ensuring the Proper Conduct of Business within the Company and its Group Companies
   
   The Company implements its compliance framework across the entire Group and, through the establishment of Regulations for the Management of Affiliated Companies and the dispatch of officers and other personnel, strives to strengthen and ensure the proper conduct of business operations of its Group Companies.

Internal Control System