Group Human Rights Policy

The Shinsei Bank Group (the "Group") places sustainability management at the heart of its business activities and aims to both increase the sustainability of the Group's value and to realize a sustainable society.
For sustainable improvement of Group value, through the awareness of the chain of values resulting from the Group's business activities ("Value Chain"), the Group will aim to sustainably improve the value generated by the Value Chain.
For realization of a sustainable society, the Group believes that the human rights of all people involved in the Group's business activities including customers, business partners (meaning suppliers, purchasers, service providers, business partners, and other related people in the Group's business activities), employees, and people in the local community is a critical foundation.
In addition, the Group recognizes the importance to continue constructive engagement with its customers, business partners, employees, people in the local community with connections to the Group's business activities, shareholders, investors, and all other stakeholders.

The Human Rights Policy (this "Policy") highlights the Group's commitment to fulfill its responsibility to respect the human rights of all stakeholders. Further, in conformity with the SBI Group Compliance Code of Conduct, the Charter of Shinsei Bank Group Corporate Behavior, and the Group Sustainability Management Policy, this Policy outlines the Group?? basic policy concerning respect for human rights and necessary actions for fulfilling its responsibility to respect human rights.

The Group will use this Policy as the guidelines concerning the respect for human rights with the highest priority as it promotes its initiatives for the respect for human rights.

This Policy is founded in accordance with the Universal Declaration of Human Rights, the International Covenants on Human Rights, the Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the Children's Rights and Business Principles.

1. Purpose

This policy is designed to outline that the Group's responsibility to respect all the human rights of all people to both internal external stakeholders.

2. Scope

This Policy applies to all employees of the Group, including officers, employees, and temporary employees.
Further, the Group expects that its customers and business partners to support and share the content of this Policy.

3. Our Commitment to Respect for Human Rights

ⅰ. Basic policy

The Group's responsibility to respect all the human rights of all people with following commitments.

  • The Group will avoid having any Group business activities that infringe on human rights and will address any adverse human rights impacts involving the Group.
  • The Group will avoid causing or contributing to adverse human rights impacts through the Group's business activities and will address such impacts when they occur.
  • The Group will promote respect for human rights throughout the Value Chain and will do its best to prevent or mitigate any adverse human rights impacts.
  • The Group will do its best to prevent serious or irremediable adverse human rights impacts.
  • The Group will implement human rights due diligence to identify, prevent and mitigate adverse human rights impacts.
  • If the Group causes or contributes to adverse human rights impacts, the Group will work in good faith to seek relief for the victims.
  • The Group will comply with the laws and regulations of the countries and regions where the Group engages in business activities. If there is any conflict with the internationally recognized standards, the Group will respect the internationally recognized standards while taking into consideration of the laws and regulations where the Group engages in business.

ⅱ. Respect for the Human Rights of Customers

  • The Group respects the human rights of all customers, ensures a safe environment where customers have access to finance without unfair discrimination and provides fair and responsible financial products and services.
  • The Group asks customers themselves to also respect human rights in accordance with the internationally recognized standards.
  • If any adverse human rights impact by a customer are confirmed, the Group will engage in dialogue to remedy such adverse impacts. If it is found that the customer has no intent to remedy the adverse impacts, or such remedy is infeasible, the Group may choose not to engage in, or to terminate transactions with such customer.

ⅲ. Resect for the Human Rights of Business Partners

  • The Group asks business partners to also respect human rights in accordance with the internationally recognized standards.
  • If any indications of adverse human rights impact by a business partner are confirmed, the Group will engage in dialogue to resolve the confirmed issue. If it is found that the business partner has no intent to resolve the adverse impacts, or such resolution is infeasible, the Group may choose not to engage in, or to terminate transactions with such business partner.

ⅳ. Respect for the Human Rights of Employees

  • The Group will protect the dignity of each individual employee and respect the human rights of all employees.
  • The Group will provide an environment where employees are able to maintain their physical mental and social health while working with enthusiasm and apply their abilities to the maximum extent.
  • The Group will foster a culture where open and candid communication is actively encouraged, diversity is respected, and through such inclusivity, sustainable value can be created.

ⅴ. Respect for the Human Rights of Local Communities

  • The Group will contribute to the social and economic development of the local community with the consideration of the human rights of people related to the Group's business activities in the local community.

4. Approach to Human Rights Issues

The Group recognizes the matters listed below to be major human rights issues. Through the process of human rights due diligence, the Group will identify salient human rights issues among numerous human rights issues.

ⅰ. Forced labor and child labor

Forced labor, bonded labor, slave labor, and labor through human trafficking, where workers work against their will, as well as child labor below the minimum age for employment, are all prohibited.

ⅱ. Overwork and excessive working hours

Excessive working hours that exceed the number of hours agreed by labor and employer are prohibited. Overwork due to excessive demands or pressure is prohibited. Further, measures to minimize overtime work will continue by enhancing flexibility regarding places and hours of work and by encouraging a heightened awareness of the importance of productivity.

ⅲ. Ensuring mental and physical health and safety

A work environment is provided where the mental and physical health and safety of employees are protected through appropriate safety and hygiene management.

ⅳ. Freedom of association and right to collective bargaining

Freedom of association and the right to collective bargaining are assured, and the trust relationship between labor and management will be strengthened more.

ⅴ. Decent wage and equal pay for equal work

Wages no less than the minimum wages specified in laws and regulations are assured, and work for unfair wages is prohibited. Further, it is recognized that wage is an essential consideration factor when leveraging job offers , and a policy of equal pay for equal work is thoroughly implemented.

ⅵ. Discrimination

Fair and equal opportunities are offered regardless of age, gender, birthplace, nationality, race, ethnicity, color of skin, religion, belief, social status, disability, illness, physical characteristics, sexual orientation, gender identity or other attributes, and any discrimination on account of any such attributes is prohibited.

ⅶ. Harassment

Sexual harassment, power harassment, harassment related to pregnancy, birth and childcare leave, and any other conduct that can cause discomfort or disadvantages to, or that will impair the dignity of, another person, are prohibited.

ⅷ. Privacy rights

Comply with laws and regulations etc. relating to personal information, and properly obtain and handle all personal information thoroughly.

5. Human Rights Due Diligence

ⅰ. Human rights due diligence

The Group will conduct human rights due diligence to identify, prevent and mitigate important human rights issues within the Group.

The Group recognizes that because risks to human rights may alter due to changes of internal or external environment, the human rights due diligence process must be implemented continuously.

ⅱ. Implementation Structure

For the human rights due diligence, a structure will be built through discussion within the Group Sustainability Committee and careful deliberations to be made by the Group Executive Committee to ensure the proper and effective implementation.

6. Grievance Mechanism (Consultation Helplines)

The Group provides internal consultation services for victims of adverse human rights impacts seeking relief. Further, to provide an environment where employees can consult with ease. There are two separate consultation helplines run by different entities.
The consultation helplines will maintain anonymity and confidentiality and provide Group employees with safe and accessible service.

Main consultation helpline:
Harassment/human rights consultation helpline
Compliance hotline

7. Stakeholder Engagement

The Group will do its best to engage in constructive dialogue regarding human rights issues relating to business activities with customers, business partners, employees, people in local communities with connections to the Group's business activities, shareholders, investors, and other stakeholders.

8. Raising awareness and Training

ⅰ. Raising awareness

To raise awareness of this Policy, the Group will provide appropriate training to the Group's employees and communicate this Policy to customers and business partners.

ⅱ. Training

To cultivate a better understanding of human rights and enhance awareness of human rights issues by the Group's employees, the Group will conduct human rights awareness training periodically.

ⅲ. Implementation Structure

The Group Human Rights Promotion Committee will facilitate dissemination, education, and other human rights awareness activities for the Group.

9. Disclosure

The Group will monitor the particulars of adverse human rights impacts identified through human rights due diligence. The Group will take measures to prevent and mitigate the negative impact on human rights, and will disclose the details of such measures.

10. Governance

Regarding those salient human rights issues of the Group, the Group Sustainability Committee will discuss and examine how to address those issues. The Group Executive Committee will make the final decision, and the Board of Directors will monitor how such issues are addressed.

11. Periodic Review

In order to strengthen measures for the respect for human rights in light of changes in internal and external environment, the Group will periodically review this Policy.

This Policy has been approved by the Group Executive Committee of Shinsei Bank,

Enactment date: November 1, 2018
Amendment date: August 1, 2021
Amendment date: November 1, 2021