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Compliance Code of Conduct and Privacy Policy

T&D United Capital Compliance Code of Conduct

With the T&D Insurance Group's "Try & Discover" motto for creating value, T&D United Capital aims to contribute to all people and society. Guided by this corporate philosophy, T&D United Capital has established the T&D United Capital Compliance Code of Conduct to conduct fair and appropriate business activities with integrity and sincerity for all stakeholders, including customers.
In the course of conducting business activities, the Company's corporate officers and employees must conduct business fairly in accordance with the Compliance Code of Conduct by correctly understanding laws, regulations and other rules pertaining to business activities and ensuring strict compliance with them.
Moreover, the Company will endeavor to foster a corporate culture that respects the purpose and spirit of this code of conduct.

1. Rigorously Enforcing Compliance

(1) Ensuring Compliance

We shall adhere to not only the laws and regulations of countries around the world, but also international rules, social norms and internal rules. Moreover, we shall seek to understand the underlying spirit of those rules, and act accordingly with integrity.

(2) Maintaining and Promoting Fair and Free Competition

We shall not engage in any unfair competitive practices, including conduct that would put our customers at a disadvantage through cartels or other forms of collusion with competitors in connection with the products and services we provide, and conduct that would put our business counterparts at a disadvantage using our bargaining power.

(3) Prevention of Conflicts of Interests

We shall always consider separating our professional and private lives in the course of conducting our duties. We shall not engage in conduct that promotes our own self-interest or the interests of third parties at the expense of the Company's interests.

(4) Prohibition of Insider Trading

As members of a publicly listed corporate group, we shall not use the non-public material information of the Company, or such information obtained in the course of performing our duties, for asset management purposes for the Company or privately, nor shall we use such information for private economic gain.

(5) Protection of Intellectual Property Rights

We shall respect the copyrights, patents and other intellectual property rights of third parties, and shall not infringe upon those rights in the course of our business activities.

2. Addressing Society

(1) Responding to Antisocial Powers

We shall reject and stringently respond to any antisocial powers that threaten the order and safety of civil society.

(2) Prevention of Corruption through Restrictions on Business Entertainment and Other Activities

We shall work to prevent corruption in our relationships with business counterparts, civil servants and other parties by refraining from providing or receiving any business entertainment within reasonable bounds under normal social conventions, as well as refraining from giving or receiving gifts, in connection with our business activities worldwide.

(3) Political Activities and Funding

We shall comply with laws and regulations and maintain an impartial stance when conducting political activities.

3. Appropriateness and Transparency in Management

(1) Appropriate Disclosure and Explanation of Information

We shall accurately disclose and explain the details of the products and services we provide and the Group's management information to stakeholders, including customers and shareholders and other investors.

(2) Appropriate Information Management

We shall handle the information we obtain from customers, including personal information, appropriately in accordance with laws, regulations and other rules. Moreover, we shall appropriately manage information that the Group has not published. Corporate officers and employees shall not disclose this information to others even after they retire from the Company.

4. Respect for Human Rights and Consideration for the Environment

(1) Respect for Human Rights

We shall support the protection of internationally declared human rights and show respect for those human rights. Moreover, we shall endeavor to maintain a sound workplace environment that is free of discrimination and harassment by protecting workers by upholding legal and regulatory compliance.

(2) Consideration for the Environment

We shall consider the global environment in the course of conducting business activities.

<Duties of Managers>
Recognizing their duty to implement the spirit of the Compliance Code of Conduct, T&D United Capital's managers shall endeavor to set a good example through their own conduct, and strive to make the code of conduct known throughout the Company and provide guidance to ensure company-wide compliance.

T&D United Capital Privacy Policy

T&D United Capital Co., Ltd. ("T&D United Capital") complies with all applicable laws and regulations, including the Act on the Protection of Personal Information and the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure ("the Number Act"). T&D United Capital establishes the Privacy Policy for Personal Information Protection and ensures that all possible efforts are made to protect personal information including specific personal information etc. such as individual numbers and specific personal information in accordance with the principles set forth in this policy (hereinafter, personal information includes specific personal information, etc.)

1. Collection of Personal Information and Notification of Purpose of Use

T&D United Capital collects personal information in a lawful and proper manner. When T&D United Capital collects personal information, the purpose of use will be promptly notified to each individual, or published on T&D United Capital's website, etc., except when the purpose of use has been announced in advance. This does not, however, apply when notification or announcement is not required by laws or regulations.

2. Use of Personal Information

(1) Purpose of Use

T&D United Capital uses personal information in a lawful and proper manner to the extent

  1. i. Investment business
  2. ii. Management of portfolio companies
  3. iii. Other operations associated with or related to the operations listed in the preceding items

* Notwithstanding the above, T&D United Capital collects and uses the specific personal information etc. of its customers in accordance with laws and regulations to the extent necessary to fill out legal documents which require individual numbers.

(2) Restriction on Purpose of Use

T&D United Capital does not use personal information beyond the extent necessary to fulfill the intended purpose without obtaining the prior consent of each individual, except in the following circumstances:

  • a. In instances when required by laws or regulations;
  • b. In instances when necessary to protect human life, body or property, and the consent of each individual can not be readily obtained;
  • c. In instances when specifically necessary for the improvement of public health or for the sound and healthy growth of children, and the consent of each individual can not be readily obtained; or
  • d. In instances when necessary to cooperate with government agency, etc. in providing services, as stipulated by laws and regulations, and if obtaining the consent of each individual may pose obstacles to the implementation of such works.

* Notwithstanding the above, T&D United Capital does not use the specific personal information etc. of its customers beyond the scope of the purpose of use, even if there is consent of the customer, with the exception that the Number Act regards the case as an exception.

(3) Proper Supervision over Third Parties

In case of T&D United Capital considering the handling of personal information to a third party, T&D United Capital conducts a strict investigation on that third party and provides proper supervision over the third party to maintain confidentiality.

3. Provision of Personal Information
(1)

T&D United Capital never provides personal information to a third party without the consent of each individual, except in circumstances as described in a. or d. of the preceding 2 (2).

* Notwithstanding the above, T&D United Capital does not provide the specific personal information etc. to a third party, even if there is consent of the customer, with the exception of the case described in the Number Act.

(2)

In instances when T&D United Capital uses personal information jointly with a third party, T&D United Capital notifies or announces in advance, as required by laws or regulations, the fact of joint use, the purpose of use, used items, etc.

* Notwithstanding the above, T&D United Capital does not use the specific personal information etc. jointly with a third party, even if there is consent of the customer.

4. Management of Personal Information
(1)

T&D United Capital manages personal information safely and accurately, and manages it safely at each stage of collection, use, custody, disposal, etc.

(2)

T&D United Capital implements appropriate security measures against unauthorized access, computer viruses, etc., to prevent leakage, loss, corruption or damage of personal information.

(3)

T&D United Capital never leaks personal information by taking it out or sending it outside.

5. Disclosure, Amendment, Suspension of Use of Personal Information

When each individual asks to have the information disclosed or amended, or its use suspended, T&D United Capital responds to such requests promptly after identifying the person unless there are special circumstances.
T&D United Capital also deals with requests regarding personal information in an appropriate manner.

* About procedures for disclosure, amendment (including addition or removal) or suspension of use (including deletion) of personal information, as well as for other requests related to personal information, please contact the address at the end of this Privacy Policy.

6. Organization
(1)

T&D United Capital designates the person responsible for the appropriate management of personal information.

(2)

T&D United Capital provides all directors, executive officers and employees with training program on protection and appropriate management of personal information to ensure proper handling on a daily business.

Please contact the address below if you have any requests, opinions, questions or proposals regarding the handling of personal information by T&D United Capital:

2-7-1, Nihonbashi, Chuo-ku,
Tokyo 103-6031, Japan
T&D United Capital Co., Ltd.
TEL: +81-(0)3-3272-6864
FAX: +81-(0)3-3272-6552

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