Fundamental Principles

Employees of the JA Mitsui Lease Group share the corporate ethics and values set forth in the 'Group Management Philosophy' and the 'Behavioral Principles' as the foundation of their conduct. Employees exercise self-discipline with a constant commitment to fairness and conduct business activities in accordance with this Code of Conduct.

• 1. Compliance with Laws and Regulations

  Employees recognize their responsibilities as members of society, deepen their understanding of history, culture, and customs, and comply with applicable laws, regulations, and social norms, acting in a fair and transparent manner.

• 2. Respect for Human Rights and Improvement of the Workplace Environment

  Employees respect human rights, embrace diversity, and do not engage in discrimination, harassment, or any other conduct that infringes upon the dignity of others.

  Employees foster an open and positive workplace environment where individuals respect one another and can fully demonstrate their abilities and individuality.

• 3. Acting with integrity and a clear distinction between professional and personal matters

  Employees practice high ethical standards and do not engage in conduct that, even if not in violation of laws or regulations, could harm the interests of customers or society or be deemed inappropriate. When in doubt, employees make decisions proactively based on accountability to customers and society and whether they contribute to long-term trust.

  Employees comply with all applicable anti-bribery laws, regulations, and social norms, and do not engage in bribery, corruption, misconduct.

  Employees appropriately manage conflicts of interest and do not engage in conduct that is contrary to the interests of the JA Mitsui Lease Group for the benefit of themselves or any third party or conduct that could be perceived as such.

  Employees do not use company assets (tangible or intangible) for purposes other than legitimate business.

  Employees do not engage in other employment without prior approval from the Company.

• 4. Proper Management of Information

  Confidential and proprietary information, customer data, and personal information are managed appropriately, and disclosure to third parties or non-business use is prohibited.

  Employees use only authorized means and devices for business activities.

  Employees recognize that their words and actions can affect the Company's reputation and credibility and, when using social media or other communication channels, act responsibly.

  Employees maintain records and reports, including accounting and financial reports, accurately and in a timely manner and do not make false or misleading entries.

• 5. Contribution to Society

  Employees proactively address social issues and engage in business and social contribution activities based on mutual trust with society as a good corporate citizen.

• 6. Environmental Responsibility

  Employees recognize that environmental initiatives are essential to the sustainable development of the Company, comply with environmental laws and regulations, and act in accordance with the JA Mitsui Lease Group Environmental Policy to achieve both sound business activities and environmental conservation.

• 7. Response to Anti-Social Forces

  Employees have no relationships with anti-social forces, their affiliates, criminal organizations, organizations involved in money laundering, or terrorist organizations and take a firm stand against inappropriate or illegal demands.

• 8. Reporting and Consultation

  Employees promptly report, seek guidance on, or raise concerns through the designated reporting channel or whistleblowing channels if they become aware of actual, suspected, or potential violations of laws, regulations, this Code of Conduct, or other internal rules and policies.

  Employees do not obstruct good-faith reporting, consultation, or whistleblowing.
  Employees do not engage in retaliation, adverse treatment, harassment, or any similar conduct against any person who makes a report or whistleblowing disclosure, or who cooperates in an investigation.

  Where an investigation is conducted to determine whether a violation of laws, regulations, this Code of Conduct, or other internal rules and policies has occurred, employees cooperate fully and in good faith with the investigation.